In order to operate, Oxford Studio Orchestra needs to gather, store and use certain forms of information about individuals.
These can include members, prospective members, deputy players, contractors, suppliers, volunteers, audience members and potential audience members, 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 Oxford Studio Orchestra data protection standards and comply with the General Data Protection Regulations (GDPR) as from 25th May 2018.
Why is this policy important?
This policy ensures that Oxford Studio 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 Oxford Studio Orchestra e.g.:
- Other committee members.
It applies to all data that Oxford Studio Orchestra holds relating to individuals, including:
- e-mail addresses
- postal addresses
- phone numbers
- Gift Aid declarations and records of payments
- records of attendance.
Roles and responsibilities
Oxford Studio Orchestra is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Oxford Studio Orchestra is Bill Manville. He, together with the Committee, is responsible for the secure, fair and transparent collection and use of data by Oxford Studio Orchestra. 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 Oxford Studio Orchestra has a responsibility to ensure that they adhere to this policy.
Data protection principles
a) We fairly and lawfully process personal data in a transparent way
Oxford Studio Orchestra will only collect data where lawful and where it is necessary for the legitimate purposes of the group.
- A member’s name, contact details and what instruments they play 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’ and their attendance at rehearsals and other group activities.
Lawful basis for processing this data: contract (the collection and use of data is fair and reasonable in relation to Oxford Studio Orchestra completing tasks expected as part of the individual’s membership).
- A prospective member’s or deputy player’s name, contact details and what instruments they play will be collected when they first apply to join the group or are asked to deputise. The information will be used to contact that person regarding opportunities to join the group or act as a deputy player. Other data may also subsequently be collected in relation to their participation in group activities.
- The name and contact details of volunteers and contractors will be collected when they take up a role, and will be used to contact them regarding group administration related to their role.Further information, including personal financial information may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person).
Lawful basis for processing this data: contract (the collection and use of data is fair and reasonable in relation to Oxford Studio Orchestra completing tasks expected as part of working with the individuals).
- 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 Oxford Studio 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’).
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, Oxford Studio 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
Oxford Studio Orchestra will not collect or store more data than the minimum information required for its intended purpose.
For example, 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
Oxford Studio Orchestra will ask people whose data are held to check and update their data on a triennial basis. Any individual will be able to update their data at any point by contacting the Secretary or the Treasurer.
e) We ensure data is not kept longer than necessary
Oxford Studio 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 Oxford Studio 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
Oxford Studio 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.
- Physically held data (e.g. Gift Aid declarations) will be stored in a secure place.
- 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 Data Protection Officer 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
Oxford Studio 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.
When Oxford Studio Orchestra collects, holds and uses an individual’s personal data that individual has the following rights over that data. Oxford Studio 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.
What are these rights?
- Right to be informed: Whenever Oxford Studio 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 Oxford Studio Orchestra 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.
- Right to rectification: Individuals can request that their data be updated where it is inaccurate or incomplete. Oxford Studio Orchestra will request that people whose data are held check and update their data on a triennial 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. Oxford Studio 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. Oxford Studio 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, Oxford Studio Orchestra will restrict the data while it is verified).
Though unlikely to apply to the data processed by Oxford Studio Orchestra, 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 Oxford Studio Orchestra encourages communication between members.
To facilitate this:
- Members can request the personal contact data of other members in writing via the Data Protection Officer or Membership Secretary. These details will be given, as long as they are for the purposes of contacting the subject (e.g. an e-mail 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
Oxford Studio 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:
- 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. ‘Tick this box if you would like Oxford Studio Orchestra to send you email updates with details about our forthcoming events, fundraising activities and opportunities to get involved’)
Data collected will only ever be used in the way described and consented to (e.g. we will not use e-mail data in order to market third-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 e-mail). Opt-out requests such as this will be processed within 14 days.
Regular data review
A regular review of all data will take place to establish if Oxford Studio Orchestra 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 three years and no more than 40 calendar months after the last review. The first review took place in May 2018.
Data to be reviewed
- Data stored in digital documents (e.g. spreadsheets) stored on personal devices held by committee members
- Data stored on third party online services (SQL Server on Microsoft Azure)
- Physical data stored at the homes of committee members.
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
- Physical data will be destroyed safely and securely, by 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.
The following criteria will be used to make a decision about what data to keep and what to delete.[table to be inserted]
Data stored by Oxford Studio Orchestra may be retained based on 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 records
Other data retention procedures
- When a member leaves Oxford Studio Orchestra and all administrative tasks relating to their membership have been completed any potentially sensitive data held on them will be deleted.
- 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 three-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 three-year review.
Contractor and supplier data
- When a contractor or supplier stops working with Oxford Studio 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
- 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 three-year review.
Policy availability and review
This policy will be made available to all the Orchestra’s members and reviewed from time to time by the Committee.
This is version 1 of this policy, approved on 14/5/2018 and confirmed 2/6/2021