Data Protection policy
- Policy prepared by: Simon White
- Approved by Management Committee on: September 2024
- Last reviewed on: September 2024
Introduction
In order to operate, Oxford Proud Voices needs to gather, store and use certain forms of information about individuals.
These can include singing 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 Oxford Proud Voices data protection standards and comply with the General Data Protection Regulations (GDPR).
Why is this policy important?
This policy ensures that Oxford Proud Voices:
- 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
This applies to all those handling data on behalf of Oxford Proud Voices including:
- Management team
- Contracted employees and volunteers
- Members
- Contractors/3rd-party suppliers
It applies to all data that Oxford Proud Voices holds relating to individuals, including:
- Names
- Email addresses
- Postal addresses
- Phone numbers
- Access requirements
- Any other personal information held (e.g. financial)
Roles and responsibilities
Oxford Proud Voices is the Data Controller and will determine what data is collected and how it is used. They, together with the management team, are responsible for the secure, fair and transparent collection and use of data by Oxford Proud Voices.
Any questions relating to the collection or use of data should be directed to the Co-Chairs, at chair@oxfordproudvoices.org. Everyone who has access to data as part of Oxford Proud Voices has a responsibility to ensure that they adhere to this policy.
Oxford Proud Voices may use certain third party Data Processors (e.g. Mail Chimp, Google, WordPress) to process data on its behalf. Oxford Proud Voices will ensure all Data Processors are compliant with GDPR.
Data Protection Principles
1. We fairly and lawfully process personal data in a transparent way
Oxford Proud Voices 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 subscription payments, medical and access information for organised domestic and international travel, dates of birth for Gift Aid applications and salary and other financial information for subsidy applications. Where possible Oxford Proud Voices will anonymise this data.
Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Oxford Proud Voices 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 Oxford Proud Voices 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 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, subscribing to the newsletter or at an event), with their consent, in order 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 Oxford Proud Voices website’ below.
Lawful basis for processing this data: Consent (see ‘How we get consent’)
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, Oxford Proud Voices 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. We ensure any data collected is relevant and not excessive
Oxford Proud Voices 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, gender identity or sexuality will not be collected, since it is unnecessary and excessive for the purposes of group administration.
We may need to collect limited medical information as necessary in the interest of health and safety when an individual chooses to take part in an organised domestic or international trip with Oxford Proud Voices.
4. We ensure data is accurate and up-to-date
Oxford Proud Voices will ask members, volunteers 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 Co-Chairs.
5. We ensure data is not kept longer than necessary
Oxford Proud Voices 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 Oxford Proud Voices 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.
6. We keep personal data secure
Oxford Proud Voices 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. sign-up sheets, membership forms) will be converted to electronic versions and stored within a password-protected and secure environment as soon as feasibly possible. Physical copies will be securely disposed of as soon as possible.
Access to data will only be given to relevant contractors and people on the management team where it is clearly necessary for the running of the group.
6.1 Transfer to countries outside the EEA
Oxford Proud Voices 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.
6.2 Individual Rights
When Oxford Proud Voices collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Oxford Proud Voices 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.
- Right to be informed: whenever Oxford Proud Voices 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 Oxford Proud Voices holds on them and confirmation of how it is being used. Requests should be made in writing to the Secretary 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. Oxford Proud Voices 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. Oxford Proud Voices 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. Oxford Proud Voices 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, Oxford Proud Voices will restrict the data while it is verified).
Though unlikely to apply to the data processed by Oxford Proud Voices , we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
6.3 Member-to-member contact
We only share members’ data with other members with the subject’s prior consent. As a membership organisation Oxford Proud Voices encourages communication between members. To facilitate this:
- Members can request the personal contact data of other members in writing via the Co-Chairs. 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.
6.4 How we get consent
Oxford Proud Voices may 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 Oxford Proud Voices 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 (e.g. we will not use email data in order to market 3rd-party products unless this has been explicitly 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.
6.5 Cookies on Oxford Proud Voices 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.
Oxford Proud Voices may use cookies on our website oxfordproudvoices.org 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 oxfordproudvoices.org 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
Introduction
This policy sets out how Oxford Proud Voices will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. It forms part of the overall Oxford Proud Voices Privacy Policy.
Roles and responsibilities
Oxford Proud Voices is the Data Controller and will determine what data is collected, retained and how it is used. They, together with the Management Committee are responsible for the secure and fair retention and use of data by Oxford Proud Voices.
Any questions relating to the collection or use of data should be directed to the Co-Chairs, at chair@oxfordproudvoices.org. Everyone who has access to data as part of Oxford Proud Voices has a responsibility to ensure that they adhere to this policy.
Regular Data Review
A regular review of all data will take place to establish if Oxford Proud Voices 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 in September 2025.
Data to be reviewed
- Oxford Proud Voices stores data on digital documents (e.g. spreadsheets) stored on Google Drive. Data should not generally be held on personal devices held by the management team.
- Data stored on third party online services (e.g. Google Drive, Mail Chimp, WordPress).
- Physical data stored at the homes of people who are or were part of the management team.
Who the review will be conducted by
The review will be conducted by the management team.
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 if “yes” | Action if “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 Oxford Proud Voices 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 and management team meeting minutes
- Contracts and agreements with suppliers/customers
- Insurance details
- Tax and employment records
Other data retention procedures
Member data
- When a member leaves Oxford Proud Voices 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.
- All other data will be stored safely and securely and reviewed as part of the next two year review.
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.
Volunteer and freelancer data
- When a volunteer or freelancer stops working with Oxford Proud Voices 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
- We may use a plugin on our website at oxfordproudvoices.org to display thumbnails of YouTube videos. This plugin accesses YouTube API Services. We are obliged by YouTube to link to the YouTube terms of service and also refer you to the Google privacy policy. Note that no data relating to either OUR YouTube account or YOUR YouTube account is stored by us.
- All other data will be included in a regular two year review.