Privacy Policy

Maidenhead Operatic Society Data Protection policy

Overview

Key details

  • Policy prepared by: Claire Sargent
  • Version 1.0
  • Approved by Board/committee on: 18/05/2018
  • Next review date: 22/05/2020
Introduction

In order to operate, Maidenhead Operatic Society (MOS) needs to gather, store and use certain forms of information about individuals.

These can include members, 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 our data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that MOS:

  • 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
Who and what does this policy apply to?

This applies to all those handling data on behalf of MOS:

  • Committee members
  • Production teams
  • Members
  • Audiences
  • Contractors/3rd-party suppliers

It applies to all data that MOS holds relating to individuals, including:

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

Full details are available in the data audit (Annex 1).

MOS is the Data Controller and will determine what data is collected and how it is used. Claire Sargent, is the committee member given responsibility for the secure, fair and transparent collection and use of data by MOS.  Any questions relating to the collection or use of data should be directed towards Claire.

Everyone who has access to data as part of MOS has a responsibility to ensure that they adhere to this policy.

MOS uses third party Data Processors (e.g. MailChimp, TicketSource and various costumiers) to process data on its behalf.  MOS will ensure all Data Processors are compliant with GDPR.

Data protection principles
a)    We fairly and lawfully process personal data in a transparent way

MOS 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 ‘subs’.

Lawful basis for processing this data: legitimate interest (GDPR Article 6 (1) (f).

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 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: performance of a contract (the collection and use of data is fair and reasonable in relation to MOS 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 MOS to communicate with them about and promote group activities. See ‘How we get consent’ below.

Lawful basis for processing this data: 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 MOS website’ below.

Lawful basis for processing this data: Consent

b) 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, MOS 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 excessive

MOS 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) We ensure data is accurate and up-to-date

MOS will ask members 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 committee members responsible for data protection.

e) We ensure data is not kept longer than necessary

MOS 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 MOS’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) We keep personal data secure

MOS 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 securely stored
  • 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 Committee 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

MOS 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 MOS collects, holds and uses an individual’s personal data that individual has the following the rights over that data. MOS 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 MOS 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 MOS 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. MOS will request that members check and update their data on an annual basis.
  • Right to object: individuals can object to their data being used for a particular purpose. MOS 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. MOS 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, MOS will restrict the data while it is verified).

Though unlikely to apply to the data processed by MOS, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.

 Member-to-member contact

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

 How we get consent

MOS 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

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 14 days.

 Cookies on the MOS 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.

The MOS website, which uses WordPress, collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. WordPress.org’s purpose in collecting non-personally identifying information is to better understand how WordPress.org’s visitors use its website. Further information is available from the WordPress privacy policy. browsers.

Data retention policy
Introduction
This policy sets out how MOS will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.
Roles and responsibilities

MOS is the Data Controller and will determine what data is collected and how it is used. Claire Sargent, is the committee member given responsibility for the secure, fair and transparent collection and use of data by MOS.  Any questions relating to the collection or use of data should be directed towards Claire.

A regular review of all data will take place to establish if MOS 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 took place in May 2018.

Data to be reviewed
  • MOS 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. Mail Chimp)]
  • Physical data stored at the homes of committee members
Who the review will be conducted by

The review will be conducted by the MOS Committee.

How data will be deleted
  • Physical data will be destroyed safely and securely, e.g. shredded.
  • All reasonable and practical efforts will be made to remove data stored digitally.

o   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.

o   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.

Criteria

The 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
Can the data be anonymised Anonymise data Continue to use
Statutory Requirements

Date stored by MOS 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)
  • Insurance details
Member and former member data
  • When a member leaves MOS 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
  • All other data will be stored safely and securely and reviewed as part of the next two year review

As membership depends on the Society’s choice of show, membership fluctuates with the same people joining and leaving regularly.  MOS therefore keeps names and contact details on file indefinitely.

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
Other data

All other data will be included in a regular two year review.