COCKERMOUTH HARMONIC SOCIETY

PRIVACY POLICY

Privacy & Data Protection

At Cockermouth Harmonic Society, we take great care to safeguard personal data provided by our supporters and to process this data fairly and lawfully in accordance with the Data Protection Act 1998.

When providing details about yourself you can be confident that:

• Any information you provide to us is confidential and secure
• We will always endeavour to keep accurate and up to date information on you
• We will not share or sell your details to other organisations for marketing or fundraising purposes.

We may share you details with third parties where absolutely necessary, such as for donation processing or data management purposes, such as with HMRC to process Gift Aid claims.

When will I need to provide my details?

Signing up to receive our publicity for concerts and fundraising event emails: If you wish to sign up to receive our email notification of events, you will need to provide us with your name and email.  These details are received and stored within our contacts database hosted by Yahoo.  Yahoo is based in the US, and therefore have certified to the U.S. Department of Commerce that it adheres to the new EU-U.S. Privacy Shield principle.

We adhere to an Opt-in system for our e-newsletter and you can remove yourself from the mailing list anytime via the link to unsubscribe at the bottom of every newsletter or by emailing cockemouthharmonics@yahoo.co.uk.

Making a donation: When donating, you will be asked to fill out your postal address and contact details for the purposes of reclaiming Gift Aid on your donation. Legally we are obliged to store donation data for Gift Aid and accounting purposes for a minimum of five years. These details are also stored in our paper filing system. If you have made a donation to us, we may contact you regarding the donation (eg. if there is a problem receiving the funds, or to acknowledge receipt of payment) but will only contact you with marketing communications if you have opted in to receiving our e-newsletter.

You have the right to request a copy of all data we hold on you, as well as the 'right to be forgotten' (request that all data we hold on you is deleted or anonymised). If you would like to exercise your right to request your data, or be forgotten, please email cockermouthharmonoics@yahoo.co.uk or call 07917 590769 to let us know and we will implement your request within the required 30 days.

Why do you need my details?

There are several reasons why we need, or would like, to keep your details on record.

If you signed up to our e-newsletter, we need your name and email address to keep you informed of news, activities, fundraising campaigns and events that may be of interest to you and opportunities to get involved. We will only do this if you issue consent for us to send you our newsletter via email. We do not add people to our mailing list unless they have explicitly given us permission to do so, either electronically, on paper, or verbally.

In accordance with the incoming GDPR regulations, we are obliged to retain documented evidence of individuals opting in to receive communications from us, either electronically, on paper or face to face. This data is filed in our paper filing system and options recorded in our mail account database.

If you have donated to us, and/or filled out a gift aid declaration, we are legally obliged to retain the details you provide on our secure supporter database for 5 years, in order to ensure that we have the information needed for accounting and tax purposes.  

We also like to have your details so that we can contact you to say thank you!

Cookies

We do not currently use cookies on our website.  However, we may provide links external websites that do use cookies.

Analytics – we may use tools to understand how our site is being used in order to improve it for our users by making it easier to use and more accessible. User data is all anonymous.

External web content

Sometimes we embed content from external sources on our website. The most common kind of content embedded on the site are videos from YouTube.  These services may collect statistics and information on your use of the embedded content, so please check their specific privacy policies.

COCKERMOUTH HARMONIC SOCIETY

Data Protection Policy

Key details

• Policy prepared by: Diana Tillman
• Approved by Board/committee on: 08/10/2019
• Next review date: 01/11/2020

Introduction

In order to operate, Cockermouth Harmonic 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 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 Cockermouth Harmonic Society data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that Cockermouth Harmonic Society:

• 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

Who and what does this policy apply to?

This applies to all those handling data on behalf of Cockermouth Harmonic Society e.g.:

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

It applies to all data that Cockermouth Harmonic Society holds relating to individuals, including:

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

Roles and responsibilities

The membership secretary is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Cockermouth Harmonic Society is the chairman. They, together with the committee, are responsible for the secure, fair and transparent collection and use of data by Cockermouth Harmonic 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 as part of Cockermouth Harmonic Society has a responsibility to ensure that they adhere to this policy.  Cockermouth Harmonic Society uses third party Data Processors (e.g. Yahoo Mail) to process data on its behalf. Cockermouth Harmonic Society will ensure all Data Processors are compliant with GDPR.

We fairly and lawfully process personal data in a transparent way

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

• A member of Cockermouth Harmonic Society 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 Cockermouth Harmonic Society will anonymise this data
• 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).
• An individual’s name and contact details may be collected when they make a booking for an event. Where this is collected 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 Cockermouth Harmonic Society to communicate with them about and promote group activities. See ‘How we get consent’ below.

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, Cockermouth Harmonic 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.

We ensure any data collected is relevant and not excessive

Cockermouth Harmonic Society 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.

We ensure data is accurate and up-to-date

Cockermouth Harmonic Society 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.

We ensure data is not kept longer than necessary

Cockermouth Harmonic 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 Cockermouth Harmonic Society 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.

Transfer to countries outside the EEA

Cockermouth Harmonic 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. When Cockermouth Harmonic Society collects, holds and uses an individual’s personal data that individual has the following rights over that data. Cockermouth Harmonic 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.

We keep personal data secure

Cockermouth Harmonic 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 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.
• 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  

Individual’s rights

• Right to be informed: whenever Cockermouth Harmonic 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 Cockermouth Harmonic 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. 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. Cockermouth Harmonic Society 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 Cockermouth Harmonic Society 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. Cockermouth Harmonic Society 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 Cockermouth Harmonic Society will restrict the data while it is verified).

Member-to-member contact

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

As a membership organisation Cockermouth Harmonic Society 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) and the subject has consented to their data being shared with other members in this way

How We Get Consent

Cockermouth Harmonic Society 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 Cockermouth Harmonic 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 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 30 days.

Cookies on the Cockermouth Harmonic Website

Cockermouth Harmonic Society does not use cookies on our website.

COCKERMOUTH HARMONIC SOCIETY

Data Retention Policy

Introduction

This policy sets out how Cockermouth Harmonic Society will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.

It forms part of Cockermouth Harmonic Society Data Protection Policy.

Roles and responsibilities

The membership secretary is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Cockermouth Harmonic Society is the chairman. They, together with the committee are responsible for the secure and fair retention and use of data by Cockermouth Harmonic Society. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.  A regular review of all data will take place to establish if Cockermouth Harmonic 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 2 years and no more than 27 calendar months after the last review. The first review will take place on 1 November 2021

Data to be reviewed

• Cockermouth Harmonic Society 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. Yahoo mail)]
• 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.
• 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.

Statutory Requirements

Data stored by Cockermouth Harmonic Society 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 Requirements

Member data
 

•  When a member leaves Cockermouth Harmonic 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 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 Cockermouth Harmonic 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 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

Criteria

 

The following criteria will be used to make a decision about what data to keep and what to delete

Question 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  

Can the data be anonymised?  

Anonymise data / Continue to use  

Last updated 27 October 2019