Cambridge Early Music is committed to protecting any personal information supplied to it in accordance with the General Data Protection Regulation, which came into effect on 25 May 2018. If you have any questions about our Policy, you should email us at firstname.lastname@example.org.
Last updated: 1 January 2020
“The Charity” means Cambridge Early Music, registered Charitable Incorporated Organisation No. 1127932
“GDPR” means the General Data Protection Regulation
“Data Controller” means the Administrator
“Senior Information Rights Owner” means the Company Secretary
“Register of Systems” means a register of all systems or contexts in which personal data is processed by the Charity
1. Data protection principles
The Charity is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by the Charity.
b. The Data Controller shall take responsibility for the Charity’s ongoing compliance with this policy. He/she shall work with the Senior Information Rights Owner in this.
c. This policy shall be reviewed at least triennially.
d. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least triennially.
c. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests.
b. The Charity shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems.
5. Data minimisation
a. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
a. The Charity shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process triennially.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
a. The Charity shall ensure that personal data is stored securely using modern software that is kept up to date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.
END OF POLICY
Last updated: 25 May 2020
General Data Protection Regulation (2018): Register of Systems
Ways in which CEM gathers data from an individual:
– Subscription to one of our email mailing lists (run via MailChimp)
– Friends Scheme joining form and renewal form
– Standing Order form
– Direct Debit form
– Gift Aid declaration form
– Online or in-person purchase of concert and event tickets
Online tools which store data gathered from individuals:
– MailChimp (for emailing newsletters to our email mailing list)
– Cameo (dedicated online membership base and ticket sales)
– Google Drive (for hosting some company documents)
– Doodle (for scheduling meetings)
– iZettle (for in-person purchase of concert and event tickets)
– Stripe (for online purchase of concert and event tickets)
In accordance with the General Data Protection Regulation which came into force on 25 May
2018, this document sets out the approach of Cambridge Early Music to the collection, use and
management of the personal data of its members under the following headings:
– The data we collect and in what way;
– How the data are stored and who has access to them;
– Sharing the data;
– Purpose for which the data are used;
– Data removal and archiving;
The data we collect and in what way
On becoming a member of Cambridge Early Music individuals are asked to complete an application form and to supply name and email address, a residential address and telephone number.
The data is stored electronically on Cameo, then updated either through the annual membership renewal process or as new data are made available throughout the year (e.g. change of email or residential address).
Names and email addresses are also entered by the Administrator on a MailChimp contact database in order to facilitate the dispatch/receipt of an online newsletter.
How the data are stored and who has access to them
Only the Administrator, the Chair of CEM, the Chair of the Friends of Cambridge Early Music, and the data officer for the Friends of Cambridge Early Music have access to the full set of personal data of members of Cambridge Early Music stored by Cameo.
Only the Administrator has access to the set of names and email addresses stored by MailChimp.
Paper application forms are passed to the Chair and data officer for the Friends of Cambridge Early Music once data have been entered on to Cameo and MailChimp contact database by the Administrator, and are stored alphabetically in year order.
Online application forms are stored electronically and password-protected.
Sharing the data
The complete data set is shared solely between the officers as described above.
The complete data set will not be shared with any third party unless legally obliged to do so.
From time to time it might be necessary to share the personal data of one member of Cambridge Early Music with another in order, for example, to arrange transport to a concert of one member by another. This will not, however, be done, without the agreement of the members concerned.
Purpose for which the data are used
The data are processed on the basis of legitimate interest.
The data are used primarily as a vehicle for disseminating information about Cambridge Early Music and its activities.
The membership application form and online ticket purchase website specifically ask members to opt in to receiving information from Cambridge Early Music.
Each electronic newsletter provides the option to unsubscribe.
Data removal and archiving
A member who fails to renew his/her membership is marked on the database as expired. Newsletters continue to be sent to lapsed members, with their permission. However, the data relating to former members will be deleted after 5 years from expiration of their membership, if we have had no contact with them. Anybody who requests to be removed is deleted.
ADOPTED 29 MAY 2020