Data Protection policy
In order to operate, Notorious 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 data protection standards and comply with the General Data Protection Regulations (GDPR).
This policy ensures that Notorious:
Who and what does this policy apply to?
This applies to all those handling data on behalf of Notorious e.g.:
It applies to all data that Notorious holds relating to individuals, including:
Notorious is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Notorious is Meurig Gallagher. They, together with the Trustees/Committee, are responsible for the secure, fair and transparent collection and use of data by Notorious.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 Notorious has a responsibility to ensure that they adhere to this policy.
Notorious uses third party Data Processors (e.g. YMLP) to process data on its behalf. Notorious will ensure all Data Processors are compliant with GDPR.
Notorious will only collect data where lawful and where it is necessary for the legitimate purposes of the group.
When collecting data, Notorious 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.
Notorious 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.
Notorious 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 at email@example.com.
Notorious 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 Notorious 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 upon request.
Notorious will ensure that data held by us is kept secure.
Notorious 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 Notorious collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Notorious 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 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, Notorious will restrict the data while it is verified).
Though unlikely to apply to the data processed by Notorious, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
We only share members’ data with other members with the subject’s prior consent. As a membership organisation Notorious encourages communication between members.
To facilitate this Notorious has a Facebook group that members can join in interact on directly. We do not give out members personal details without first gaining their consent/
How we get consent
Notorious 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:
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 notorious 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.
We will implement a pop-up box on www. notoriouschoir.org 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).
Data retention policy
This policy sets out how Notorious will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.
It forms part of Notorious’ Data Protection Policy.
Notorious is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Notorious is Meurig Gallagher. They, together with the Trustees/Committee are responsible for the secure and fair retention and use of data by Notorious. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.
Regular data review
A regular review of all data will take place to establish if Notorious 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 on Monday 14th May 2018.
The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.
The following criteria will be used to make a decision about what data to keep and what to delete.
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
Can the data be anonymised
Continue to use
Date stored by Notorious may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
Other data retention procedures