RTWCS Data Retention Policy

Royal Tunbridge Wells Choral Society (RTWCS) Data Protection policy

Overview

• Approved by Board/committee on: 24/05/2018
• Due for review:  November 2026

Introduction

• Protects the rights of its 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

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

It applies to all data that RTWCS holds relating to individuals, including:

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

Roles and responsibilities

Data protection principles

a) We fairly and lawfully process personal data in a transparent way RTWCS 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 RTWCS will anonymise this data
• Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to RTWCS 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 RTWCS 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 RTWCS 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 RTWCS 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, RTWCS 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. RTWCS will not collect or store more data than the minimum information required for its intended purpose.

d) We ensure data is accurate and up-to-date. RTWCS will ask members, staff and contractors 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 Controller.

e) We ensure data is not kept longer than necessary. RTWCS will keep records for no longer than is necessary in order to meet the intended use for which it was gathered (except where there is a legal requirement to keep records). The storage and intended use of data will be reviewed in line with RTWCS 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. RTWCS 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 reset 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 locked cupboard
• Physical data files will be collected by the Data Controller from an individual when they leave 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 Data Controller 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. RTWCS 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

• Right to be informed: whenever RTWCS 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 RTWCS holds on them and confirmation of how it is being used. Requests should be made in writing to the Data Controller 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. RTWCS 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. RTWCS 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 that all data held on them be deleted. RTWCS’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 OR 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, RTWCS will restrict the data while it is verified). Though unlikely to apply to the data processed by RTWCS, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.

Member-to-member contact

• 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 email address) and the subject has consented to their data being shared with other members in this way

How we get consent

• 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 RTWCS to send you email updates with details about our forthcoming events, fundraising activities and opportunities to get involved’)