Data Protection policy

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:

Roles and responsibilities

This applies to all those handling data on behalf of Oxford Proud Voices including:

It applies to all data that Oxford Proud Voices holds relating to individuals, including:

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 oxfordproudvoices@gmail.com. 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.

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.

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:

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:

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 oxfordproudvoices@gmail.com. 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

Who the review will be conducted by

The review will be conducted by the management team.

How data will be deleted

The following criteria will be used to make a decision about what data to keep and what to delete.

QuestionAction if “yes”Action if “no”
Is the data stored securely?No action necessaryUpdate storage protocol in line with Data Protection policy
Does the original reason for having the data still apply?Continue to useDelete or remove data
Is the data being used for its original intention?Continue to useEither delete/remove or record lawful basis for use and get consent if necessary
Is there a statutory requirement to keep the dataKeep the data at least until the statutory minimum no longer appliesDelete or remove the data unless we have reason to keep the data under other criteria
Is the data accurate?Continue to useAsk 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 useGet consent
Can the data be anonymised?Anonymise dataContinue 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:

Other data retention procedures

Member data

Mailing list data

Volunteer and freelancer data

Other data