Burgess Hill Choral Society Data Protection and Retention Policy, September 2018 Key details Approved by Committee on 16 October 2018 Review date: normally not more than 27 months after last review
Introduction In order to operate, Burgess Hill Choral Society needs to gather, store and use certain forms of information about individuals. Data can relate to members, contractors, suppliers, service providers, volunteers, audiences and potential audiences, sponsors and other people with whom the group has a relationship or whom the group regularly needs to contact. This policy explains how this data should be collected, stored and used in order to meet Burgess Hill Choral Society’s data protection standards and comply with the 2018 General Data Protection Regulation (GDPR).
Why is this policy important? This policy ensures that Burgess Hill Choral Society:
protects the rights of its members, volunteers and supporters
complies with data protection law and follows good practice
protects the group from the risks of a data breach.
Who and what does this policy apply to? This applies to all those handling data on behalf of Burgess Hill Choral Society; for example:
Committee members
volunteers
choir members
contractors/third-party suppliers
anyone else providing a service for the Society
It applies to all data that Burgess Hill Choral Society holds relating to individuals:
names
email addresses
postal addresses
telephone numbers
any other personal information held
Roles and responsibilities The Committee is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for the Society is normally the Secretary. The Data Protection Officer, together with the Committee, is responsible for the secure, fair and transparent collection and use of data by Burgess Hill Choral Society. Any questions relating to the collection or use of data should be directed to the Data Protection Officer. Everyone who has access to data has a responsibility to ensure that they adhere to this policy.
Data Protection Principles a) Data is fairly and lawfully processed in a transparent way Burgess Hill Choral Society 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 subscriptions. Where possible Burgess Hill Choral Society will anonymise this data.
The names and contact details of volunteers, service providers 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 (e.g. in order to process payment to the person, or in order to carry out a Disclosure and Barring Service check).
An individual’s name and contact details may 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.
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 Burgess Hill Choral Society to communicate with them about and promote group activities. See ‘How consent is obtained’ below.
Pseudonymous or anonymous data (including behavioural, technological and geographical/regional) on an individual may be collected via tracking ‘cookies’ when they access the BHCS website or interact with emails, in order for the Society to monitor and improve effectiveness. See ‘Cookies on the Burgess Hill Choral Society website’ below.
b) Personal data is collected and used for specific and legitimate purposes and will only be used for those specified purposes. When collecting data, Burgess Hill Choral Society 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) Any data collected is relevant and not excessive. Burgess Hill Choral Society will not collect or store more data than the minimum information required for its intended purpose. For example, telephone numbers need to be collected 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) Data is accurate and up-to-date. Burgess Hill Choral Society will ask members, volunteers and service providers to notify any changes to their data when necessary. Any individual will be able to update their data at any point by contacting the Data Protection Officer.
e) Data is not kept longer than necessary. Burgess Hill Choral Society 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 the Society’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) Personal data is kept secure. Burgess Hill Choral Society will ensure that data it holds is kept secure.
Electronically held data will be held within a 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 secure location.
Any 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 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 Burgess Hill Choral Society 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 Burgess Hill Choral Society collects, holds and uses an individual’s personal data, that individual has the following rights over that data. Burgess Hill Choral Society 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.
Right to be informed: Whenever Burgess Hill Choral Society 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 Burgess Hill Choral Society 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.
Right to rectification: Individuals can request that their data be updated if they believe it to be inaccurate or incomplete. Any requests for data to be updated will be processed within one month. Members, service providers and contractors will be asked to provide current data as necessary.
Right to object: Individuals can object to their data being used for a particular purpose. Burgess Hill Choral Society will always provide a way for an individual to withdraw consent in all marketing communications. When a request is made to stop to using data, the Society will comply unless there is a lawful reason to use the data for legitimate interests or a contractual obligation.
Right to erasure: Individuals can request all data held on them to be deleted. Burgess Hill Choral Society’s data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose for which was originally collected. If a request for deletion is made, this will be complied with unless:
there is a lawful reason to keep and use the data for legitimate interests or contractual obligations, or
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. (For example, if they have contested the accuracy of any of their data, Burgess Hill Choral Society will restrict the data while it is verified.)
Though unlikely to apply to the data processed by Burgess Hill Choral Society, rights related to portability and automated decision making (including profiling) will be complied with where appropriate.
Member-to-member contact Members’ data is only shared with other members with the subject’s prior consent.
How consent is obtained Burgess Hill Choral Society will 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.
Whenever data is collected for this purpose, a clear and specific explanation will be given of what the data will be used for (e.g. ‘Tick this box if you would like Burgess Hill Choral Society to send you email updates with details about forthcoming events, fundraising activities and opportunities to get involved’).
Data collected will only ever be used in the way described and consented to. For example, email data will not be used to market third-party products unless this has been explicitly consented to.
Marketing communications will contain a method by which a recipient can withdraw his/her consent (e.g. an ‘unsubscribe’ option in an email). Opt-out requests such as this will be processed within 14 days.
Cookies on the Burgess Hill Choral Society website A cookie is a small text file that is downloaded onto 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.
At the bottom of each webpage on www.burgesshillchoralsociety.org.uk there is a toolbar which appears when a new user visits the website. This allows users to click to consent to continuing with cookies enabled, or to ignore the message and continue browsing (i.e. give their implied consent). It includes a link to www.youronlinechoices.eu which offers guidance in turning off unwanted cookies.
Data Retention Policy Overview
Introduction This policy sets out how Burgess Hill Choral Society will approach data retention and establishes procedures to ensure that data is not held for longer than is necessary. It forms part of the Data Protection Policy.
Roles and responsibilities The Committee is the Data Controller and will determine what data is collected and retained, and how it is used. The Data Protection Officer for the Society is normally the Secretary. That person and the Committee are responsible for the secure and fair retention and use of data. 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 whether the Committee 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 two years and no more than 27 calendar months after the last review. The first review took place on 16 October 2018.
Data to be reviewed
Burgess Hill Choral Society data stored on digital documents (e.g. spreadsheets) on personal devices held by Committee members
data stored on third-party online services
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 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.
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.
Where deleting the data would mean deleting other data that there is a valid lawful reason to keep (e.g. in old emails emails) then the data may be retained safely and securely but not used.
Criteria: SEE THE TABLE BELOW
Statutory Requirements Data stored by the Committee may be retained based on statutory requirements for storing data other than data protection regulations. These might include but are not limited to:
Gift Aid declaration records
details of payments made and received (e.g. in bank statements and accounting records)
Committee meeting minutes
contracts and agreements with suppliers/customers
insurance details
tax and employment records
Other data retention procedures Member data
When a member leaves Burgess Hill Choral Society 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 to retain data 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 Burgess Hill Choral Society 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 to retain data has been given, data will be removed from all email mailing lists.
Other data All other data will be stored safely and securely and reviewed as part of the next two-year review.
