Notorious

Data Protection policy 

Overview

Key details

Introduction

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).

Why is this policy important?

This policy ensures that Notorious:

Roles and responsibilities

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:

Roles and responsibilities

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.

Data protection principles

  1. We fairly and lawfully process personal data in a transparent way

Notorious will only collect data where lawful and where it is necessary for the legitimate purposes of the group.

  1. 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, 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.

  1. We ensure any data collected is relevant and not excessive

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.

  1. We ensure data is accurate and up-to-date

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 secretary@notoriouschoir.org.

  1. We ensure data is not kept longer than necessary

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.  

  1. We keep personal data secure

Notorious will ensure that data held by us is kept secure.

  1. Transfer to countries outside the EEA

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.

Individual 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.

Individual’s 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.

Member-to-member contact

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.

Notorious uses cookies on our website www.notoriouschoir.org 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.

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).

It will also include a link to our Privacy Policy which outlines which specific cookies are used and how cookies can be disabled in the most common browsers.

 


Data retention policy

Overview

Introduction

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.  

Roles and responsibilities

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.

Data to be reviewed

Who the review will be conducted by

The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.

How data will be deleted

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 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

Member data

Mailing list data

Volunteer and freelancer data

Other data