Data Protection policy
Overview
This policy ensures that Northern Praeclassica
Roles and responsibilities
Who and what does this policy apply to?
This applies to all those handling data on behalf of Northern Praeclassica e.g.:
Northern Praeclassica is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Northern Praeclassica is Alice Brunton. They, together with the trustees, are responsible for the secure, fair and transparent collection and use of data by Northern Praeclassica .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 Northern Praeclassica has a responsibility to ensure that they adhere to this policy.
If / when Northern Praeclassica uses third party Data Processors (e.g. [Mail Chimp]) to process data on its behalf, Northern Praeclassica will ensure all Data Processors are compliant with GDPR.
Data protection principles
a) We fairly and lawfully process personal data in a transparent way
Northern Praeclassica will only collect data where lawful and where it is necessary for the legitimate purposes of the group.
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, Northern Praeclassica] 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
Northern Praeclassica 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
Northern Praeclassica 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.
e) We ensure data is not kept longer than necessary
Northern Praeclassica 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 Northern Praeclassica 's data retention policy.
f) We keep personal data secure
Northern Praeclassica will ensure that data held by us is kept secure.
Northern Praeclassica 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 Northern Praeclassica collects, holds and uses an individual’s personal data that individual has the following rights over that data. Northern Praeclassica 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
Though unlikely to apply to the data processed by Northern Praeclassica 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 Northern Praeclassica encourages communication between members.
To facilitate this:
How we get consent
Northern Praeclassica 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:
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 Northern Praeclassica 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.
Northern Praeclassica uses cookies on our website www.northernpraeclassica.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.
We will implement a pop-up box on www.northernpraeclassica.org.uk 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).
Overview
This policy ensures that Northern Praeclassica
- Protects the rights of our members, volunteers and supporters
- Complies with data protection law and follows good practice
- Protect 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 Northern Praeclassica e.g.:
- Committee members
- Employees and volunteers
- Members
- Contractors/3rd-party suppliers
- Names
- Email addresses
- Postal addresses
- Phone numbers
- Any other personal information held (e.g. financial)
Northern Praeclassica is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Northern Praeclassica is Alice Brunton. They, together with the trustees, are responsible for the secure, fair and transparent collection and use of data by Northern Praeclassica .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 Northern Praeclassica has a responsibility to ensure that they adhere to this policy.
If / when Northern Praeclassica uses third party Data Processors (e.g. [Mail Chimp]) to process data on its behalf, Northern Praeclassica will ensure all Data Processors are compliant with GDPR.
Data protection principles
a) We fairly and lawfully process personal data in a transparent way
Northern Praeclassica 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 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’. Where possible Northern Praeclassica will anonymise this data
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Northern Praeclassica completing tasks expected as part of the individual’s membership).
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Northern Praeclassica 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 Northern Praeclassica completing 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 Northern Praeclassica completing tasks expected as part of the booking),
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Northern Praeclassica 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 Northern Praeclassica 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 Northern Praeclassica 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, Northern Praeclassica] 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
Northern Praeclassica 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
Northern Praeclassica 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.
e) We ensure data is not kept longer than necessary
Northern Praeclassica 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 Northern Praeclassica 's data retention policy.
f) We keep personal data secure
Northern Praeclassica 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. membership forms or email sign-up sheets) will be stored in a safe 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
Northern Praeclassica 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 Northern Praeclassica collects, holds and uses an individual’s personal data that individual has the following rights over that data. Northern Praeclassica 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 Northern Praeclassica 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 Northern Praeclassica 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. 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. Northern Praeclassica will 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. Northern Praeclassica 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. Northern Praeclassica'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.
Though unlikely to apply to the data processed by Northern Praeclassica 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 Northern Praeclassica encourages communication between members.
To facilitate this:
- Emails will continue to show email addresses of members unless any of the members object
- Members can request the personal contact data eg phone number 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 member and the subject has consented to their data being shared with other members in this way
How we get consent
Northern Praeclassica 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 Northern Praeclassica to send you email updates with details about our forthcoming events, fundraising activities and opportunities to get involved’)
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 Northern Praeclassica 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.
Northern Praeclassica uses cookies on our website www.northernpraeclassica.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.
We will implement a pop-up box on www.northernpraeclassica.org.uk 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
Overview
Introduction
This policy sets out how Northern Praeclassica will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.
It forms part of Northern Praeclassica Data Protection Policy.
Roles and responsibilities
Northern Praeclassica is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Northern Praeclassica is Alice Brunton. They, together with the trustees are responsible for the secure and fair retention and use of data by Northern Praeclassica . 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 Northern Praeclassica 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. The first review will take place on or before 1 June 2020
Data to be reviewed
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
The following criteria will be used to make a decision about what to keep and what to delete.
Statutory Requirements
Data stored by Northern Praeclassica may be retained based on statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
Other data retention procedures
Member data
Other data
Policy approval date: 21 May 2018
Overview
Introduction
This policy sets out how Northern Praeclassica will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.
It forms part of Northern Praeclassica Data Protection Policy.
Roles and responsibilities
Northern Praeclassica is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Northern Praeclassica is Alice Brunton. They, together with the trustees are responsible for the secure and fair retention and use of data by Northern Praeclassica . 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 Northern Praeclassica 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. The first review will take place on or before 1 June 2020
Data to be reviewed
- Northern Praeclassica stores data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members.
- Data stored on third party online services (e.g. Google Drive, Mail Chimp)
- Physical data stored at the homes of committee members
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, 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.
The following criteria will be used to make a decision about what to keep and what to delete.
- Is the data stored securely?
- Yes - No action necessary
- No - Update storage protocol in line with Data Protection policy
- Does the original reason for having the data still apply?
- Yes - Continue to use
- No - Delete or remove data
- Is the data being used for its original intention?
- Yes - Continue to use
- No - Either delete/remove or record lawful basis for use and get consent if necessary
- Is there a statutory requirement to keep the data?
- Yes - Keep the data at least until the statutory minimum no longer applies
- No - Delete or remove the data unless we have reason to keep the data under other criteria.
- Is the data accurate?
- Yes - Continue to use
- No - 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
- Yes - Continue to use
- No - Get consent
- Can the data be anonymised
- Yes - Anonymise data
- No - Continue to use
Statutory Requirements
Data stored by Northern Praeclassica 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 and employment records
Other data retention procedures
Member data
- When a member leaves Northern Praeclassica 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 Northern Praeclassica 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
Other data
- All other data will be included in a regular two year review.
Policy approval date: 21 May 2018