Privacy Policy

Introduction

In order to operate, Harrogate Theatre Choir needs to gather, store and use certain forms of information about individuals.

These can include members, supporters, 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 Harrogate Theatre Choir’s data protection standards and comply with the General Data Protection Regulations (GDPR).

This Policy ensures that Harrogate Theatre Choir:

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

Who are we?

Harrogate Theatre Choir is a mixed voice choir based in Harrogate. For more information on the choir see our website and constitution. Our website address is: https://www.harrogatetheatrechoir.co.uk

Who and what does this policy apply to?

This policy applies to all those handling data on behalf of Harrogate Theatre Choir eg:

• Committee members
• Volunteers
• Members
• Contractors/third party suppliers

It applies to all data that Harrogate Theatre Choir holds relating to individuals, including:

• Names
• Email addresses
• Postal addresses
• Phone numbers
• Digital images ie photos/video footage
• Emergency contacts
• Any other personal information held (eg financial)

Roles and responsibilities                

The Data Protection Officer for Harrogate Theatre Choir is the Membership Secretary.  He/She, together with the Committee, are responsible for the secure, fair and transparent collection and use of data by Harrogate Theatre Choir. Any questions relating to the collection or use of data should be directed to the Data Protection Officer. He/She can be contacted at htcsecretary17@gmail.com

Everyone who has access to data as part of Harrogate Theatre Choir has a responsibility to ensure that they adhere to this policy.

Harrogate Theatre Choir uses third party Data Processors (eg Mailpoet, Muzodu and Trybooking) to process data on its behalf. Harrogate Theatre Choir will ensure all Data Processors are compliant with GDPR.  The Data Processors that we use may disclose personal information to their third-party service providers (including IT service providers, data storage and handling facilities, payment systems operators and legal or financial advisers) to the extent necessary for them to assist us in providing services to you. However, we engage service providers who do not use or disclose your personal information for any purpose other than the services for which they are engaged to provide.

Data Protection Principles

a)    We fairly and lawfully process personal data in a transparent way

Harrogate Theatre Choir 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 subscriptions.
• The name and contact details of volunteers 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 may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person).

• An individual’s name, contact details and payment detailswill 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.
• 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 Harrogate Theatre Choir to communicate with them about and promote group activities.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, Harrogate Theatre Choir 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.

b)   We ensure any data collected is relevant and not excessive

Harrogate Theatre Choir will not collect or store more data than the minimum information required for its intended purpose.

c)  We ensure data is accurate and up-to-date

Harrogate Theatre Choir will ask members and volunteers 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.

d)  We ensure data is not kept longer than necessary

Harrogate Theatre Choir 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 Harrogate Theatre Choir’s data retention policy. When the intended use is no longer applicable (eg contact details for a member who has left the group), the data will be deleted as soon any administrative tasks have been completed and within a reasonable period.

e)  We keep personal data secure

Harrogate Theatre Choir 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 (eg membership forms or email sign-up sheets) will be stored in a locked cupboard

Access to data will only be given to relevant committee members/contractors where it is clearly necessary for the running of the group. The Data Protection Officer will decide in what situations this is applicable.

f)  Transfer to countries outside the EEA

Harrogate Theatre Choir 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.

Individual Rights

When Harrogate Theatre Choir collects, holds and uses an individual’s personal data that individual has the following rights over that data. Harrogate Theatre Choir 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 Harrogate Theatre Choir 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 Harrogate Theatre Choir 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. Harrogate Theatre Choir will request that members 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. Harrogate Theatre Choir 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. Harrogate Theatre Choir’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:

1. There is a lawful reason to keep and use the data for legitimate interests or contractual obligation.
2. There is a legal requirement to keep the data.

Member to member contact

With the exception of names and email addresses, we only share members’ data with other members with the subject’s prior consent.

However, as a membership organisation Harrogate Theatre Choir encourages communication between members.

To facilitate this:

• Members can request the personal contact data of other members in writing via the Membership Secretary. These details will be given, as long as they are for the purposes of contacting the subject (eg a mobile number or postal address, not financial or health data) and the subject has consented to their data being shared with other members in this way.

Some members may share other information between themselves, but this is not held centrally.

How we get consent

Harrogate Theatre Choir will 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 (eg a consent tick box)

• A clear and specific explanation of what the data will be used for

• Data collected will only ever be used in the way described and consented to (eg we will not use email data in order to market third party products)

• 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.

Data Breaches

Harrogate Theatre Choir takes any breach of data seriously. A data breach could be the deliberate or accidental:

• Loss of data – eg 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 – eg changing data without permission or good reason or changing it with permission or good reason but incorrectly, either by Harrogate Theatre Choir committee members, volunteers or third parties
• Unauthorised use of data eg sending an email that requires consent where consent has not been given.
• Unauthorised access to data – eg an (unauthorised) third party gains access to data stored by Harrogate Theatre Choir
• Unauthorised disclosure of data – eg Harrogate Theatre Choir passing data to a third party where we do not have a lawful basis to do so.

How we prevent Data breaches

Harrogate Theatre Choir 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, Harrogate Theatre Choir, 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 Harrogate Theatre Choir thinks a data breach has occurred then it should be reported to the Data Protection officer or a member of the committee immediately.

The Data Protection Officer/committee members 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 relevant parties 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 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 Management Committee at the next planned full board meeting. 

Conduct an internal investigation into how the breach happened and what measures need to be taken to minimise the risk of similar breaches occurring in the future.

Cookies on our Website

A cookie is a small text file that is downloaded onto ‘terminal equipment’ (eg 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.

HTC uses cookies on our website www.harrogatetheatrechoir.co.uk in order to monitor and record their activity. This allows us to improve users’ experience of our website and provides us with useful insight into how users as a whole are engaging with the website.

We will implement a pop-up box on www.harrogatetheatrechoir.co.uk 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 (ie give their implied consent).

How can you contact us?

Please contact the Membership Secretary at htcsecretary17@gmail.com or approach any member of HTC committee.

How long will we hold your data?

Harrogate Theatre Choir will review all data held on individuals at least every two years, and remove data where we no longer have a legitimate reason to keep it.

What if you have a complaint?

You have a right to complain to the Information Commissioner’s Officer (ICO), which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data. You can find out how to do this by visiting www.ico.org.uk.

What if this policy changes?

We may make changes to this Privacy Policy from time to time. Any changes we make will be posted on this page. We may also notify you by email if significant changes are made.