Privacy policy

 

KINGSTON THIRD AGE ORCHESTRA

 

Data Protection policy

 

Overview

 

 

Key details

  • Policy prepared by: Michael Winterburn based on Guidance from Making Music
  • Approved by the committee on: 13/06/2018
  • Next review date: 12/06/2019

Introduction

In order to operate, Kingston Third Age Orchestra 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 Kingston Third Age Orchestradata protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that Kingston Third Age Orchestra:

  • Protects the rights of our members, volunteers and supporters
  • Complies with data protection law and follows good practice
  • Protects 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 Kingston Third Age Orchestra e.g.:

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

It applies to all data that Kingston Third Age Orchestraholds relating to individuals, including:

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

Roles and responsibilities

Kingston Third Age Orchestrais the Data Controller and will determine what data is collected and how it is used. The members responsible for data for Kingston Third Age Orchestra are the Secretary (for members) and the Web Administrator (for the supporters’ mailing list.They, together with the committee, are responsible for the secure, fair and transparent collection and use of data by Kingston Third Age Orchestra. Any questions relating to the collection or use of data should be directed to the Secretary.

Everyone who has access to data as part of Kingston Third Age Orchestra has a responsibility to ensure that they adhere to this policy.

Kingston Third Age Orchestra uses third party Data Processors (e.g. Mailchimp) to process data on its behalf. Kingston Third Age Orchestra will ensure all Data Processors are compliant with GDPR.

 

 

Data protection principles

 

 

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.

 

 

Individual rights

 

When Kingston Third Age Orchestra collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Kingston Third Age Orchestra 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.

Individual’s rights

  • Right to be informed: whenever Kingston Third Age Orchestra 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 Kingston Third Age Orchestra 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. Kingston Third Age Orchestrawill 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. Kingston Third Age Orchestra 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. Kingston Third Age Orchestra’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, Kingston Third Age Orchestra will restrict the data while it is verified).

Though unlikely to apply to the data processed by Kingston Third Age Orchestra, 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

As a membership organisation Kingston Third Age Orchestra encourages communication between members.

To facilitate this:

  • Members can request the personal contact data of other members in writing via the Secretary 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

 

How we get consent

 


Kingston Third Age Orchestra 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 (via Mailchimp):

  • 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. Kingston Third Age Orchestra will use the information you provide on this form to be in touch with you and to provide updates and marketing. Please let us know all the ways you would like to hear from us)

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 Kingston Third Age Orchestra Website

 

 A cookie is a small text file that is downloaded onto 'terminal equiment' (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.

 

Kingston Third Age Orchestra uses cookies on our website (www.kingstonthirdageorchestra.org.uk) in order to monitor and record their activity. This allows us to improve users’ experience of our website by, for example, allowing for a ‘logged in’ state, and by giving us useful insight into how users as a whole are engaging with the website. The website is hosted by Surrey Community. Information on its use of cookies can be found at https://www.surreycommunity.info/about/cookies.

 

 

 

 

 


Data retention policy

 

Overview

 

Introduction

This policy sets out how Kingston Third Age Orchestra will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.

It forms part of Kingston Third Age Orchestra Data Protection Policy.

Roles and responsibilities

Kingston Third Age Orchestra is the Data Controller and will determine what data is collected and how it is used. The members responsible for data for Kingston Third Age Orchestra are the Secretary (for members) and the Web Administrator (for the supporters’ mailing list. They, together with the committee, are responsible for the secure, fair and transparent collection and use of data by Kingston Third Age Orchestra. Any questions relating to the collection or use of data should be directed to the Secretary.

 

Regular Data Review

 

 

 

A regular review of all data will take place to establish if Kingston Third Age Orchestrastill 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 in June 2019.

Data to be reviewed

  • Kingston Third Age Orchestra stores data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members.
  • Data stored on third party online services (Mailchimp).
  • Physical data stored at the homes of committee members

Who the review will be conducted by

The review will be conducted by the Secretary 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.

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 Kingston Third Age Orchestramay 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 procedures

 

 

 

 

Member data

  • When a member leaves Kingston Third Age Orchestra 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
  • 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
  • When a volunteer or freelancer stops working with Kingston Third Age Orchestra 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
  • All other data will be included in a regular 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
  • When a volunteer or freelancer stops working with Kingston Third Age Orchestraand 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
  • All other data will be included in a regular two year review.

Volunteer and freelancer data

  • When a volunteer or freelancer stops working with Kingston Third Age Orchestraand 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.

 

 making music logo

 

 

 

  

Google+

 

©Kingston Third Age Orchestra - Reg. charity no. 1140445

Vacancies for strings

There are currently vacancies for violins and violas. 

If you are interested or know of someone else who might be interested please look at our Join us page.

Click here to read what one or our members wrote about her experience in a letter to a newspaper.

Next concert

Spring Concert

 

3 pm Sunday 24 March 2019
All Saints Parish Church
Kingston KT1 1JP