South Chiltern Choral Society Data Protection and Retention Policy

South Chiltern Choral Society
(SCCS) Data Protection policy

Overview

Key details

• Policy prepared by: David Cottam
• Data Protection Advisor: David Cottam

• Approved by Board/committee on: 21/06/18
• Next review date: 21/06/20

Introduction

In order to operate, SCCS needs to gather, store and use certain forms of information about
individuals.

These can include members, employees, contractors, suppliers, volunteers, audiences and
potential audiences, business contacts and other people the group has a relationship with or
regularly needs to contact.

This policy explains how this data should be collected, stored and used in order to meet
SCCS data protection standards and comply with the General Data Protection
Regulations (GDPR).

Why is this policy important?

This policy ensures that SCCS

• Protects the rights of our members, volunteers and supporters
• Complies with data protection law and follows good practice
• Protect the group from the risks of a data breach

Roles and responsibilities

Who and what does this policy apply to?

This applies to all those handling data on behalf of SCCS e.g.:

• Committee members
• Employees and volunteers
• Members
• Contractors/3rd-party suppliers

It applies to all data that SCCS holds relating to individuals, including:

• Names
• Email addresses
• Postal addresses
• Phone numbers
• Any other personal information held (e.g. financial)

Roles and responsibilities

SCCS is the Data Controller and will determine what data is collected and how it is
used. The Data Protection Officer for SCCS is Jackie Outram. She, together with the
trustees, are responsible for the secure, fair and transparent collection and use
of data by SCCS. Any questions relating to the collection or use of data should be
directed to the Data Protection Officer.

Everyone who has access to data as part of SCCS has a responsibility to ensure that
they adhere to this policy.

SCCS uses third party Data Processors to process data on its
behalf. SCCS will ensure all Data Processors are compliant with GDPR.

Data protection principles

a) We fairly and lawfully process personal data in a transparent way

SCCS will only collect data where lawful and where it is necessary for the legitimate
purposes of the group.

• A member’s name and contact details will be collected when they first join the
group, and will be used to contact the member regarding group membership
administration and activities. Other data may also subsequently be collected in
relation to their membership, including their payment history for ‘subs’. Where
possible SCCS will anonymise this data

o Lawful basis for processing this data: Contract (the collection and use of data
is fair and reasonable in relation to SCCS completing tasks expected
as part of the individual’s membership).

• The name and contact details of volunteers, employees and contractors will be
collected when they take up a position, and will be used to contact them regarding
group administration related to their role.

Further information, including personal financial information and criminal records
information may also be collected in specific circumstances where lawful and
necessary (in order to process payment to the person or in order to carry out a DBS
check).
o Lawful basis for processing this data: Contract (the collection and use of data
is fair and reasonable in relation to SCCS completing tasks expected
as part of working with the individuals),

• An individual’s name and contact details will be collected when they make a booking
for an event. This will be used to contact them about their booking and to allow them
entry to the event.
o Lawful basis for processing this data: Contract (the collection and use of data
is fair and reasonable in relation to SCCS completing tasks expected
as part of the booking),

• An individual’s name, contact details and other details may be collected at any time
(including when booking tickets or at an event), with their consent, in order for SCCS to communicate with them about and promote group activities. See ‘How we
get consent’ below.
o Lawful basis for processing this data: Consent (see ‘How we get consent’)

• Pseudonymous or anonymous data (including behavioural, technological and
geographical/regional) on an individual may be collected via tracking ‘cookies’ when
they access our website or interact with our emails, in order for us to monitor and
improve our effectiveness on these channels. See ‘Cookies on the SCCS
website’ below.
o Lawful basis for processing this data: Consent (see ‘How we get consent’)

b) We only collect and use personal data for specific, explicit and
legitimate purposes and will only use the data for those specified
purposes.

When collecting data, SCCS will always provide a clear and specific privacy
statement explaining to the subject why the data is required and what it will be used for.

c) We ensure any data collected is relevant and not excessive
SCCS will not collect or store more data than the minimum information required for
its intended purpose.

E.g. we need to collect telephone numbers from members in order to be able to contact
them about group administration, but data on their marital status or sexuality will not be
collected, since it is unnecessary and excessive for the purposes of group administration.

d) We ensure data is accurate and up-to-date

SCCS will ask members, volunteers and staff to check and update their data on an
annual basis. Any individual will be able to update their data at any point by contacting the
Data Protection Officer.

e) We ensure data is not kept longer than necessary

SCCS will keep records for no longer than is necessary in order to meet the
intended use for which it was gathered (unless there is a legal requirement to keep records).

The storage and intended use of data will be reviewed in line with SCCS’s data
retention policy. When the intended use is no longer applicable (e.g. contact details for a
member who has left the group), the data will be deleted within a reasonable period.

f) We keep personal data secure

SCCS will ensure that data held by us is kept secure.

• Electronically-held data will be held within a password-protected and secure
environment
• Passwords for electronic data files will be re-set each time an individual with data
access leaves their role/position
• Physically-held data (e.g. membership forms or email sign-up sheets) will be stored
in a locked cupboard
• Keys for locks securing physical data files should be collected by the Data Protection
Officer from any individual with access if they leave their role/position. The codes on
combination locks should be changed each time an individual with data access
leaves their role/position
• Access to data will only be given to relevant trustees/committee members/contractors
where it is clearly necessary for the running of the group. The Data Protection Officer
will decide in what situations this is applicable and will keep a master list of who has
access to data
g) Transfer to countries outside the EEA

SCCS will not transfer data to countries outside the European Economic Area (EEA),
unless the country has adequate protection for the individual’s data privacy rights.

Individual Rights

When SCCS collects, holds and uses an individual’s personal data that individual
has the following the rights over that data. SCCS will ensure its data processes
comply with those rights and will make all reasonable efforts to fulfil requests from an
individual in relation to those rights.

Individual’s rights

• Right to be informed: whenever SCCS collects data it will provide a clear and
specific privacy statement explaining why it is being collected and how it will be used.

• Right of access: individuals can request to see the data SCCS holds on them
and confirmation of how it is being used. Requests should be made in writing to the
Data Protection Officer and will be complied with free of charge and within one
month. Where requests are complex or numerous this may be extended to two
months

• Right to rectification: individuals can request that their data be updated where it is
inaccurate or incomplete. SCCS will request that members, staff and
contractors check and update their data on an annual basis. Any requests for data to
be updated will be processed within one month.

• Right to object: individuals can object to their data being used for a particular
purpose. SCCS will always provide a way for an individual to withdraw
consent in all marketing communications. Where we receive a request to stop using
data we will comply unless we have a lawful reason to use the data for legitimate
interests or contractual obligation.

• Right to erasure: individuals can request for all data held on them to be deleted.
SCCS data retention policy will ensure data is not held for longer than is
reasonably necessary in relation to the purpose it was originally collected. If a
request for deletion is made we will comply with the request unless:

• There is a lawful reason to keep and use the data for legitimate interests or
contractual obligation.

• There is a legal requirement to keep the data.

Right to restrict processing: individuals can request that their personal data be ‘restricted’ –
that is, retained and stored but not processed further (e.g. if they have contested the
accuracy of any of their data, SCCS will restrict the data while it is verified).

Though unlikely to apply to the data processed by SCCS, we will also ensure that
rights related to portability and automated decision making (including profiling) are complied
with where appropriate.

Member-to-member contact

We only share members’ data with other members with the subject’s prior consent

As a membership organisation SCCS encourages communication between
members.

To facilitate this:
• Members can request the personal contact data of other members in writing via the
Data Protection Officer or Membership Secretary. These details will be given, as long
as they are for the purposes of contacting the subject (e.g. an email address, not
financial or health data) and the subject has consented to their data being shared
with other members in this way

How we get consent

SCCS will regularly collect data from consenting supporters for marketing purposes.
This includes contacting them to promote performances, updating them about group news,
fundraising and other group activities.

Any time data is collected for this purpose, we will provide:

• A method for users to show their positive and active consent to receive these
communications (e.g. a ‘tick box’)
• A clear and specific explanation of what the data will be used for (e.g. ‘Tick this box if you would like SCCS to send you email updates with details about our
forthcoming events, fundraising activities and opportunities to get involved’)

Data collected will only ever be used in the way described and consented to (e.g. we will not
use email data in order to market 3rd-party products unless this has been explicitly
consented to).

Every marketing communication will contain a method through which a recipient can
withdraw their consent (e.g. an ‘unsubscribe’ link in an email). Opt-out requests such as this
will be processed within 14 days.

Cookies on the SCCS website

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (e.g. a computer or
smartphone) when the user accesses a website. It allows the website to recognise that
user’s device and store some information about the user’s preferences or past actions.

SCCS uses cookies on our website www.southchilternchoralsociety.org.uk in order to monitor and record their activity. This allows us to improve users’ experience of our website by, for example, allowing for a ‘logged in’ state, and by giving us useful insight into how users as a whole are engaging with the website.

We will implement a pop-up box on www.southchilternchoralsociety.org.uk that will activate each new time a user visits the website. This will allow them to click to consent (or not) to continuing with cookies enabled, or to ignore the message and continue browsing (i.e. give their implied consent).

It will also include a link to our Privacy Policy which outlines which specific cookies are used
and how cookies can be disabled in the most common browsers.

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Data retention policy

Overview

Introduction

This policy sets out how SCCS will approach data retention and establishes
processes to ensure we do not hold data for longer than is necessary.
It forms part of SCCS Data Protection Policy.

Roles and responsibilities

SCCS is the Data Controller and will determine what data is collected, retained and
how it is used. The Data Protection Officer for SCCS is Jackie Outram. She, together with
the trustees are responsible for the secure and fair retention and use of data by
SCCS. Any questions relating to data retention or use of data should be directed to
the Data Protection Officer.

Regular Data Review

A regular review of all data will take place to establish if SCCS still has good reason
to keep and use the data held at the time of the review.

As a general rule a data review will be held every 2 years and no more than 27 calendar
months after the last review. The first review took place on 21/06/2018]

Data to be reviewed

• SCCS stores data on digital documents (e.g. spreadsheets) stored on
personal devices held by committee members.
• Data stored on third party online services [(e.g. Google Drive, Mail Chimp)]
• Physical data stored at the homes of committee members

Who the review will be conducted by

The review will be conducted by the Data Protection Officer with other committee members
to be decided on at the time of the review.

How data will be deleted

• Physical data will be destroyed safely and securely, including shredding.
• All reasonable and practical efforts will be made to remove data stored digitally.
o Priority will be given to any instances where data is stored in active lists (e.g.
where it could be used) and to sensitive data.
o Where deleting the data would mean deleting other data that we have a valid
lawful reason to keep (e.g. on old emails) then the data may be retained
safely and securely but not used.

Criteria

The following criteria will be used to make a decision about what data to keep and what to
delete.
Question / Action
Yes / No

Is the data stored securely?

YES No action necessary NO Update storage protocol in line with Data Protection policy

Does the original reason for,having the data still apply?

YES Continue to use NO Delete or remove data

Is the data being used for its original intention?

YES Continue to use NO Either delete/remove or record lawful basis for use and get consent if necessary

Is there a statutory requirement to keep the data?

YES Keep the data at least until the statutory minimum no longer applies

NO Delete or remove the data unless we have reason to keep the data under other criteria.

Is the data accurate? YES Continue to use NO Ask the subject to confirm/update details

Where appropriate do we have consent to use the data. This consent could be implied by previous use and engagement by the individual
YES Continue to use NO Get consent

Can the data be anonymised YES Anonymise data NO Continue to use

Statutory Requirements

Date stored by SCCS may be retained based in statutory requirements for storing
data other than data protection regulations. This might include but is not limited to:
• Gift Aid declarations records
• Details of payments made and received (e.g. in bank statements and accounting
records)
• Trustee meeting minutes
• Contracts and agreements with suppliers/customers
• Insurance details
• Tax and employment records

Other data retention procedures

Member data
• When a member leaves SCCS and all administrative tasks relating to their
membership have been completed any potentially sensitive data held on them will be
deleted – this might include bank details or medical data
• Unless consent has been given data will be removed from all email mailing lists
• All other data will be stored safely and securely and reviewed as part of the next
two year review

Mailing list data

• If an individual opts out of a mailing list their data will be removed as soon as is
practically possible.
• All other data will be stored safely and securely and reviewed as part of the next two
year review

Volunteer and freelancer data

• When a volunteer or freelancer stops working with SCCS and all
administrative tasks relating to their work have been completed any potentially
sensitive data held on them will be deleted – this might include bank details or
medical data
• Unless consent has been given data will be removed from all email mailing lists
• All other data will be stored safely and securely and reviewed as part of the next
two year review
Other data
• All other data will be included in a regular two year review.

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