Privacy Policy

.1 IntroductionIn order to operate, Wirral Community Orchestra 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 Wirral Community Orchestra data protection standards and comply with the General Data Protection Regulations (GDPR).
1.2  Why is this policy important?This policy ensures that Wirral Community Orchestra:
  • 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
 
  1. Who and what does this policy apply to?
This applies to all those handling data on behalf of Wirral Community Orchestra e.g.:
  • Committee members
  • Employees and volunteers
  • Members
  • Contractors/3rd-party suppliers
It applies to all data that Wirral Community Orchestra holds relating to individuals, including:
  • Names
  • Email addresses
  • Postal addresses
  • Phone numbers
  • Any other personal information held (e.g. financial)
1.4  Roles and responsibilitiesWirral Community Orchestra is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Wirral Community Orchestra is [name]. They, together with the committee are responsible for the secure, fair and transparent collection and use of data by Wirral Community Orchestra .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 Wirral Community Orchestra has a responsibility to ensure that they adhere to this policy.
 
2.     Data Protection Principlesa)    We fairly and lawfully process personal data in a transparent wayWirral Community Orchestra 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 ‘weekly subscriptions.

    • Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Wirral Community Orchestra 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).

    • Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to  Wirral Community Orchestra 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.

    • Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Wirral Community Orchestra 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 Wirral Community Orchestra to communicate with them about and promote group activities.

    • Lawful basis for processing this data: Consent
 
  1. 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, Wirral Community Orchestra 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 excessiveWirral Community Orchestra 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.
  1. We ensure data is accurate and up-to-date
Wirral Community Orchestra 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.
  1. We ensure data is not kept longer than necessary
Wirral Community Orchestra 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 Wirral Community Orchestra 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.  
  1. We keep personal data secure
Wirral Community Orchestra 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 securely a locked box.

  • 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.

3. Individual Rights
When Wirral Community Orchestra collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Wirral Community Orchestra 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.
  1. Individual’s rights

  • Right to be informed: whenever Wirral Community Orchestra 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 Wirral Community Orchestra 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. Wirral Community Orchestra 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. Wirral Community Orchestra 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. Wirral Community 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, Wirral Community Orchestra will restrict the data while it is verified).
Though unlikely to apply to the data processed by Wirral Community Orchestra, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
  1. Member to Member
We only share members’ data with other members with the subject’s prior consent. To facilitate this:
  • Members can request the personal contact data of other members in writing via the Data Protection Officer or 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.

  1. Website Cookies

  • The Wirral Community Orchestra website is constructed using Weebly tools. All Weebly based website use cookies to collect anonymised data from website visitors.  Weebly will automatically display a cookie notification banner on published sites when visited from a European IP address. Until the site visitor consents to the use of cookies through this banner, cookie-setting functionality will not work on the published site.
4. Data Retention Policy
a)    IntroductionThis policy sets out how Wirral Community Orchestra will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. It forms part of Wirral Community Orchestra Data Protection Policy. 
b)    Roles and responsibilitiesWirral Community Orchestra is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Wirral Community Orchestra is HELEN TANKARD]. They, together with the committee are responsible for the secure and fair retention and use of data by Wirral Community Orchestra. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.
5. Regular Data Review
A regular review of all data will take place to establish if Wirral Community Orchestra 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 will take place in December 2019.
a)    Data to be reviewed
  • Wirral Community Orchestra stores data on digital documents (e.g. spreadsheets/word) stored on personal devices held by committee members.
  • Physical data stored at the homes of committee members.
b)    Who the review will be conducted byThe review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.
c)    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 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.
CriteriaThe 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?
No action necessary
Update storage protocol in line with Data Protection policy

Does the original reason for having the data still apply?
Continue to use
Delete or remove data

Is the data being used for its original intention?
Continue to use
Either delete/remove or record lawful basis for use and get consent if necessary

Is there a statutory requirement to keep the data?
Keep the data at least until the statutory minimum no longer applies
Delete or remove the data unless we have reason to keep the data under other criteria.

Is the data accurate?
Continue to use
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
Continue to use
Get consent

 
Statutory RequirementsData stored by Wirral Community Orchestra may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
  • 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
 
6. Other data retention proceduresa)    Member data
  • When a member leaves Wirral Community Orchestra 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
b)    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.
c)    Volunteer  data
  • When a volunteer stops working with Wirral Community Orchestra 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.
d)    Other data
  • All other data will be included in a regular two year review.
 
This policy was agreed by the AGM on February 7th 2019
 
Policy Review :