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Introduction
In order to operate, Avon Wind Band Association 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 Avon Wind Band Association data protection standards and comply with the General Data Protection Regulations (GDPR).
Why is this policy important?
This policy ensures that Avon Wind Band Association:
- 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
This applies to all those handling data on behalf of Avon Wind Band Association 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)
Avon Wind Band Association is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Avon Wind Band Association is Stephen Spooner. He, together with the
Everyone who has access to data as part of Avon Wind Band Association has a responsibility to ensure that they adhere to this policy.
Avon Wind Band Association does not use third party Data Processors to process data on its behalf.
Data protection principles
- We fairly and lawfully process personal data in a transparent way
- A member’s
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Avon Wind Band Association 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 Avon Wind Band Association completing tasks expected as part of the individual’s membership).
- The name and contact details of volunteers 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 Avon Wind Band Association 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 Avon Wind Band Association 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 Avon Wind Band Association 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 Avon Wind Band Association 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’)
- We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.
- We ensure any data collected is relevant and not excessive
E.g. we may 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.
- We ensure data is accurate and up-to-date
- We ensure data is not kept longer than necessary
The storage and intended use of data will be reviewed in line with Avon Wind Band Association’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.
- We keep personal data 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 by the Data Protection Officer in a secure location.
- Access to data will only be given to relevant trustees 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
- Transfer to countries outside the EEA
Individual Rights
When Avon Wind Band Association collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Avon Wind Band Association 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 Avon Wind Band Association 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 Avon Wind Band Association 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. Avon Wind Band Association 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. Avon Wind Band Association 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. Avon Wind Band Association’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, Avon Wind Band Association will restrict the data while it is verified).
Member-to-member contact
We only share members’ data with other members with the subject’s prior consent
As a membership organisation Avon Wind Band Association 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 email address, not financial or health data) and the subject has consented to their data being shared with other members in this way
Avon Wind Band Association will, from time to time, 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 Avon Wind Band Association 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. Opt-out requests such as this will be processed within 14 days.
Data breaches
Avon Wind Band Association takes any breach of data seriously. A data breach could be the deliberate or accidental:
- Loss of data – e.g. not knowing where physical or digital data is stored or how to access it, including devices being lost or stolen.
- Destruction of data – both physical and digital
- Corruption of data – e.g. changing data without permission or good reason or changing it with permission or good reason but incorrectly, either by Avon Wind Band Association staff, volunteers or third parties
- Unauthorised use of data e.g. sending an email that requires consent where consent has not been given.
- Unauthorised access to data – e.g. an (unauthorised) third party gains access to data stored by Avon Wind Band Association
- Unauthorised disclosure of data – e.g. Avon Wind Band Association passing data to a third party where we do not have a lawful basis to do so.
Avon Wind Band Association acknowledges that a data breach can occur through both action and inaction on the part of any trustee.
How we prevent Data breaches
Avon Wind Band Association has the following safeguards to ensure against possible data breaches:
- Data is stored on secure systems with access controlled by passwords
- Automatic, and manual, processes ensure passwords are updated on a regular basis, including as soon as an individual’s role within, or relationship to, Avon Wind Band Association changes.
- Automatic, and manual, processes ensure mass communications are only sent in line with mailing preferences.
If a Data breaches occurs
If anyone associated with Avon Wind Band Association thinks a data breach has occurred then it should be reported to the Data Protection officer/trustees immediately.
The Data protection officer/trustees will work with relevant individuals to investigate the potential breach. The response plan will include the following steps:
- Establish if a breach has occurred.
- Investigate if any measures can be taken to contain or minimise the breach.
- Establish the full extent and nature of that breach – including what the breach was, how many data subjects are affected and who they are.
- Establish if the data breach has, or is likely to, pose a significant risk to the data subjects rights and freedoms:
- If the breach does pose a significant risk to the data subjects rights and freedoms we will:
- Ensure all trustees are informed
- Report the breach to the ICO. This will be done in-line with their guidelines and as soon as possible, but no later than 72 hours after the breach occurred
- Report the breach to any other relevant regulators, including the Charity Commission and OSCR.
- Report the breach to the data subjects affected, informing them of what has happened, possible and likely impacts it might have on them and what we are doing to manage the breach and reduce risk of future occurrences
- If the breach does not pose a significant risk to the data subjects rights and freedoms we will:
- Document details of the breach and the decision making process involved in assessing the severity and risk of the breach.
- Ensure the breach is reported to the Trustees at the next planned meeting.
Cookies on the Avon Wind Band Association 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.
Avon Wind Band Association uses cookies on our website, avonwindbandassociation.com, 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 have implemented a pop-up box on the website that activates 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 also includes 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
Introduction
This policy sets out how
It forms part of
Roles and responsibilities
Avon Wind Band Association is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Avon Wind Band Association is Stephen Spooner. He, together with the
Regular Data Review
A regular review of all data will take place to establish if Avon Wind Band Association 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 will take place before the end of 2024
Data to be reviewed
- Avon Wind Band Association digital documents (e.g. spreadsheets) stored on personal devices held by committee members.
- Data stored on third party online services
- Physical data stored at the homes of committee members
The review will be conducted by the Data Protection Officer with other trustees 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 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
Data stored by Avon Wind Band Association may be retained based in 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 Avon Wind Band Association 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 Avon Wind Band Association 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
- All other data will be included in a regular two year review.
