Privacy Policy

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

Kingston Third Age 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 orchestra, and will be used to contact the member regarding orchestra membership administration and activities. Other data may also subsequently be collected in relation to their membership, including their payment history for ‘subs’. Where possible Kingston Third Age Orchestra will anonymise this data
  • Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Kingston Third Age 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 Kingston Third Age Orchestracompleting 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 Kingston Third Age 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 Kingston Third Age Orchestra 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 Kingston Third Age Orchestra website’ below.
  • Lawful basis for processing this data: Consent (see ‘How we get 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, Kingston Third Age 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 excessive

Kingston Third Age 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.

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

Kingston Third Age 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 Secretary.

e)  We ensure data is not kept longer than necessary

Kingston Third Age 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 Kingston Third Age Orchestra’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

Kingston Third Age 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
• 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 Secretary will decide in what situations this is applicable and will keep a master list of who has access to data.
• Mailing list data is kept only on Mailchimp and only the Web Administrator has access. Mailchimp has implemented appropriate technological means to protect against accidental loss, destruction, damage, alteration and disclosure. Mailchimp’s privacy policy can be seen at https://mailchimp.com/legal/privacy

g)  Transfer to countries outside the EEA

Kingston Third Age Orchestra 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.