The Summertown Choral Society (also referred to as the “choir”) and its Trustees are committed to protecting the personal information the choir holds and being transparent about that information.
In order to operate, Summertown Choral Society 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 choir 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 Summertown Choral Society’s data protection standards and comply with the General Data Protection Regulations (GDPR).
Further information about GDPR can be found on the website of the Information. Commissioner:
2. Why this policy is important
- Protects the rights of our members, volunteers and supporters
- Complies with data protection law and follows good practice
- Protects the choir from the risks of a data breach
3. Who we are
The Summertown Choral Society is a registered charity No: 900317, and is run by an elected committee of Trustees, all of whom are members of the choir.
4. Who and what this policy applies to
This policy applies to all those handling data on behalf of Summertown Choral Society e.g.:
- Committee members
- Contractors/third-party suppliers
It applies to all data that Summertown Choral Society holds relating to individuals, including:
- Email addresses
- Postal addresses
- Phone numbers
- Subscriptions and payments
- Any other personal information held (e.g. Voice part, Gift Aid)
Everyone who has access to data in the course of carrying out choir business has a responsibility to ensure that they adhere to this policy.
5. Data controller
Summertown Choral Society is the Data Controller for the purposes of the Data Protection Act 1998 and other relevant data protection law, and will determine what data is collected and retained and how it is used.
The choir is not required to have, and has not appointed, a Data Protection Officer.
The committee is responsible for the secure, fair and transparent collection and use of data by Summertown Choral Society. Any questions relating to the collection or use of data should be directed to the Secretary of the choir.
Whenever Summertown Choral Society uses third-party Data Processors (e.g. email automation companies) to process data on its behalf, Summertown Choral Society will ensure such Data Processors are compliant with GDPR.
6. Data protection principles
a) We fairly and lawfully process personal data.
Summertown Choral Society will only collect data where lawful and where it is necessary for the legitimate purposes of the choir.
- A member’s name and contact details will be collected when they first join the choir, and will be used to contact the member regarding choir membership administration and activities.
- 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 choir administration related to their role. Banking information may also be collected where necessary in order to process payments.
- An individual’s name and other details may be collected at any time with their consent, (including when booking tickets or at an event), for Summertown Choral Society to communicate with them about choir activities. See ‘How we get consent’ below.
b) We only collect and use personal data for specified and lawful purposes.
When collecting data, Summertown Choral Society will explain to the subject why the data is required and what it will be used for e.g.
“Please enter your email address in the form below. We need this so that we can send you email updates for group administration including about rehearsal and concert schedules, subs payments and other business.”
We will never use data for any purpose other than for that stated or for a purpose that can be reasonably considered to be related to it. For example: we will never pass on personal data to third parties without the explicit consent of the subject and we will never sell personal data to a third party.
c) We ensure any data collected is relevant and not excessive.
Summertown Choral Society will not collect or store more data than the minimum information required for its intended purpose.
d) We ensure that data is accurate and up-to-date.
The Summertown Choral Society will ask members, volunteers and staff to check for any changes and update their data on an annual basis.
Any individual will be able to update their data at any point by contacting the Secretary.
e) We ensure data is not kept longer than necessary.
Summertown Choral Society will keep records for no longer than is necessary in order to meet the intended use for which they were gathered (unless there is a legal requirement to keep records).
The storage and intended use of data will be reviewed in line with Summertown Choral Society’s data retention policy.
f) We keep personal data secure.
Summertown Choral Society 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 reset each time an individual with data access leaves their role/position.
- Physically held data (e.g. paper membership forms) will be kept secure.
- Access to data will only be given to relevant trustees/committee members/contractors where it is clearly necessary for the running of the choir. The Secretary will decide in what situations this is applicable and will keep a master list of who has access to data.
7. Individual rights
When Summertown Choral Society collects, holds and uses an individual’s personal data that individual has the following rights over that data and Summertown 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 Summertown 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 Summertown Choral Society holds on them and confirmation of how it is being used. Requests should be made in writing to the Secretary 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. 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. Summertown Choral Society will always provide a way for an individual to withdraw consent in all communications.
- Right to erasure: individuals can request for all data held on them to be deleted. Summertown 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 it was originally collected.
- Right to restrict processing: individuals can request that their personal data be ‘restricted’ – that is, retained and stored but used (e.g. if they have contested the accuracy of any of their personal data, Summertown Choral Society will not use the data while it is verified).
Where we receive a request to delete or to stop using data we will comply unless we have a legal or contractual obligation to keep and use the data
8. Member-to-member contact
We only share members’ data with other members with the subject’s prior consent.
As a membership organisation Summertown Choral Society encourages communication between members.
To facilitate this:
- Members can request the personal contact data of other members in writing via the Membership Secretary. These details may be given, as long as they are for the purposes of contacting the subject (e.g. an email address), and the subject has consented to their data being shared with other members in this way.
9. How we get consent
Summertown Choral Society will collect data from consenting supporters for marketing purposes. This includes promoting performances, providing updates of choir news, fundraising and other choir activities.
- When 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 Summertown Choral Society 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 third-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).
10. Data security policy
a) Data stored
- Digital documents (e.g. spreadsheets) may be stored on third-party online services (eg Dropbox) with password-protection.
- Data may be stored as digital documents on the personal devices of committee members who have been authorised to use and store data for specified purposes. Such devices shall be password-protected.
- Data may be stored as paper copies at the homes of committee members who have been authorised to use and store data for specified purposes. Such data shall be kept in locked storage.
- An inventory will be kept of which data each committee member should keep and update, and how this is stored.
- Each committee member at the end of their term of office will ensure that their successor has access to the necessary electronic files and hard copies of current data, and will undertake to then destroy and delete all choir data that they may hold.
- Personal details of Committee members who are Trustees of the choir are uploaded as required to the Charity Commission website and may be circulated by email to other committee members. These details shall be updated annually after the AGM.
- Emails relating to choir business will be received and stored by all committee members and others including contractors and employees. Committee members undertake to delete all such emails from personal devices at the end of their term of office.
b) Regular data review
A regular review will take place to establish if Summertown Choral Society 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.
When the intended use is no longer applicable (e.g. contact details of someone who has stopped singing with the choir but may be encouraged to return), the data will be deleted within a reasonable period, such as three years. Financial records will be retained for 6 years
The review will be conducted by the Secretary with such other Committee members to be decided at the time of the review.
The Membership Secretary shall keep a spreadsheet of members’ details for the current choir year with updated contact information. This information will be kept for three years.
Forms with member’s signatures confirming that Gift Aid may be claimed by the Choir may be kept for six years after a member leaves the choir
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 delete and remove digital data stored on personal devices.
- 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 be used.
11. Third party sites
12. How to contact us
Approved by Trustees of the Choir: 14 May 2023
Next review date: 14 May 2024