Data Protection Policy
In order to operate, Holymoorside Band 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 Holymoorside Band’s data protection standards and comply with the General Data Protection Regulations (GDPR).
This policy ensures that Holymoorside Band:
- 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
2.1 Who and What Does This Policy Apply To?
This applies to all those handling data on behalf of Holymoorside Band e.g.:
- Committee members
- Employees and volunteers
- Members Contractors/3rd-party suppliers
It applies to all data that Holymoorside Band holds relating to individuals, including:
- Email addresses
- Postal addresses
- Phone numbers
- Any other personal information held (e.g. financial)
2.2 Roles and Responsibilities
Holymoorside Band is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Holymoorside Band is Andy Booker. They, together with the band’s trustees and committee, are responsible for the secure, fair and transparent collection and use of data by Holymoorside Band. 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 Holymoorside Band has a responsibility to ensure that they adhere to this policy.
Where Holymoorside Band uses third party Data Processors (e.g. Mail Chimp) to process data on its behalf. Holymoorside Band will ensure all Data Processors are compliant with GDPR.
3. Data Protection Principles
Holymoorside Band is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a) processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);
Holymoorside Band 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 band and will be used to contact the member regarding band membership administration and activities. Other data may also subsequently be collected in relation to their membership, including their allocated instrument, mutes and uniform. Where possible Holymoorside Band will anonymise this data.
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Holymoorside Band 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 Holymoorside Band 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 Holymoorside Band 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 Holymoorside Band to communicate with them about and promote group activities. See “How we get consent” below.
- 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 Holymoorside Band website’ below.
- Lawful basis for processing this data: Consent (see “How we get consent”)
b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (“purpose limitation”);
When collecting data, Holymoorside Band 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) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”);
Holymoorside Band 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) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (“accuracy”);
Holymoorside Band 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) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”);
Holymoorside Band 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 Holymoorside Band’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) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
Holymoorside Band 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
Holymoorside Band 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.
4. Individual Rights
When Holymoorside Band collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Holymoorside Band will ensure its data processes comply with those rights and will make all reasonable efforts to fulfill requests from an individual in relation to those rights.
4.1 Individual’s Rights
- Right to be informed: whenever Holymoorside Band 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 Holymoorside Band 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. Holymoorside Band 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. Holymoorside Band 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. [Group name’s] 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, Holymoorside Band will restrict the data while it is verified).
- Though unlikely to apply to the data processed by Holymoorside Band, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
5. Member-to-Member Contact
We only share members’ data with other members with the subject’s prior consent. As a membership organisation Holymoorside Band 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.
6. How We Get Consent
Holymoorside Band 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 Holymoorside Band 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). Opt-out requests such as this will be processed within 14 days.
7. Cookies on the Holymoorside Band 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.
A pop-up box has been implemented on http://www.holymoorsideband.co.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).
8. Changes to this Data Protection Policy
We reserve the right to make changes to this Data Protection Policy at any time. Any changes will be posted in this Data Protection Policy and material changes will be prominently notified on the respective website or application this Data Protection Policy applies to or will be otherwise communicated to you prior to the change becoming effective. We encourage you to regularly review this Data Protection Policy to make sure you are aware of any changes and how your information may be used.
This Data Protection Policy was last updated on 12th May 2018.
9. Contacting Us
If you any questions or comments about this Data Protection Policy, please contact the data controller:
C/O Holymoorside United Reformed Church
Cotton Mill Hill
You can contact the Information Commissioners Office:
Information Commissioner’s Office
Telephone: 0303 123 1113