Last Updated: 4-Nov-2023

​1.​ Introduction

In order to operate, Oxford Harmony Club (hereafter “OH”) needs to gather, store and use certain forms of information about individuals. 

This policy explains how this data should be collected, stored and used in order to meet OH data protection standards and comply with the General Data Protection Regulations (GDPR) and ensures that OH:

• Protects the rights of our members and supporters
• Complies with data protection law and follows good practice
• Protects the group from the risks of a data breach

​2.​ Roles and responsibilities

This applies to all those handling data on behalf of OH and it applies to all data that OH holds relating to individuals, including:

• Names
• Email addresses
• Postal addresses
• Phone numbers

OH is the Data Controller and will determine what data is collected and how it is used. The name of the Data Protection Officer for OH is published on the OH website. They, together with the Trustees, are responsible for the secure, fair and transparent collection and use of data by OH. 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 OH has a responsibility to ensure that they adhere to this policy.

​3.​ Data protection principles

​3.1.​ We fairly and lawfully process personal data in a transparent way

The OH 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 OH will anonymise this data
• Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to OH completing tasks expected as part of the individual’s membership).
• Pseudonymous or anonymous data (including behavioral, technological and geographical/regional) on an individual may be collected via tracking ‘cookies’ when they access the OH website or interact with our emails, in order for us to monitor and improve our effectiveness on these channels. See ‘Cookies on the The Oxford Harmony  website, below.
• Lawful basis for processing this data: Consent (see ‘How we get consent’)

​3.2.​ 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, OH 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.

​3.3.​ We ensure any data collected is relevant and not excessive

OH will not collect or store more data than the minimum information required for its intended purpose. The information we collect is limited to basic contact details, voice part, Gift Aid declarations and related data.

​3.4.​ We ensure data is accurate and up to date

OH 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.

​3.5.​ We ensure data is not kept longer than necessary

OH 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 the OH 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. 

​3.6.​ We keep personal data securely

OH will ensure that data held by us is kept securely.

• Electronically held data will be held within a password-protected and secure environment
• Access to  electronic data will be removed each time an individual with data access leaves their role/position
• Physically-held data – membership or Gift Aid forms, for example – will be scanned and held electronically. The originals, if retained, will be held securely.
• Access to data will only be given to relevant persons 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.

​3.7.​ Transfer to countries outside the EEA

OH will not transfer data to countries outside the UK, unless the country has adequate protection for the individual’s data privacy rights. 

​4.​ Individual Rights

When OH collects, holds and uses an individual’s personal data that individual has rights over that data as listed below. OH will ensure its data processes comply with those rights and will make all reasonable efforts to fulfill requests from an individual in relation to those rights. 

• Right to be informed: whenever OH 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 OH 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 (unless vexatious) 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. OH 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. OH will always provide a way for an individual to withdraw consent in all marketing communications such as occasional newsletters. 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. OH 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, OH will restrict the data while it is verified). 

​5.​ How we get consent

OH may 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.

Whenever 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 OH 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.

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.

​6.​ Data Breaches

OH takes any breach of data seriously and acknowledges that a data breach can occur through both action and inaction on the part of the Data Controller or Processor.

A data breach could be the deliberate or accidental:

• Loss of data
• Destruction of data
• Corruption of data
• Unauthorized use of data
• Unauthorized access to data
• Unauthorized disclosure of data

​6.1.​ How we prevent Data breaches

OH has the following safeguards to ensure against possible data breaches: 

• Data is stored on secure systems
• Only those needing access to the data will have access
• As soon as an individual’s role within, or relationship to, OH changes their access will be updated
• Processes ensure mass communications are only sent in line with mailing preferences.

​6.2.​ If a Data breach occurs

If anyone associated with OH thinks a data breach has occurred then it should be reported to the Data Protection Officer or 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 minimize 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 posed, or is likely to pose a significant risk to the data subjects’ rights and freedoms and if it does we will:

• Ensure all trustees are informed
• Report the breach to the Information Commissioner’s Office. 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.
• 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 subject’s 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 Board of Trustees at the next planned full Trustees’ meeting.
• Conduct an internal investigation into how the breach happened and what measures need to be taken to minimize the risk of similar breaches occurring in the future.

​7.​ Cookies on the Oxford Harmony website

The OH website uses cookies to monitor and record users’ activity. The website will be able to display a Cookie Policy and a Privacy Policy.

Visitors to the website will be notified that cookies are in use and permission to store them will be requested. Links will be provided to the Cookie Policy and to the full Privacy Policy.

​8.​ Data retention

This sets out how OH will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. 

​8.1.​ Regular Data Review

A regular review of all data will be conducted by the Data Protection Officer with other Trustees to be decided on at the time of the review to establish if OH 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.

​8.1.1.​ Data to be reviewed:

• Data on digital documents (e.g. spreadsheets) stored on personal devices held by Trustees. 
• Data stored on third party online services 
• Physical data stored at the homes of Trustees.

​8.1.2.​ Deletion of data

• 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.

​8.1.3.​ Criteria – for taking action

Question	Action onYes	Action on 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

​8.1.4.​ Statutory Requirements

Data stored by OH 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 

​9.​ Other data retention procedures

​9.1.​ Member data

• When a member leaves OH 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 

​9.2.​ 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 two year review 

​9.3.​ Other data

• All other data will be included in a regular two-year review.