Charity means WMVC , a registered charity.
GDPR means the General Data Protection Regulation.
Responsible Person means Membership Secretary
Register of Systems means a register of all systems or contexts in which personal data is processed by the Charity.
1. Data protection principles
The WMVC is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:
a. processed lawfully, fairly and in a transparent manner in relation to individuals;
b. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
f. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General provisions
a. This policy applies to all personal data processed by the WMVC.
b. The Responsible Person shall take responsibility for the ongoing compliance with this policy.
c. This policy shall be reviewed at least annually.
d. The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a. To ensure its processing of data is lawful, fair and transparent, WMVC shall maintain a Register of Systems.
b. The Register of Systems shall be reviewed at least annually.
c. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner.
4. Lawful purposes
a. All data processed by the WMVC must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
b. The Charity shall note the appropriate lawful basis in the Register of Systems.
c. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
d. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the choirs systems.
5. Data minimisation
a. WMVC shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
b. WMVC will only store data that is relevant to the current choir members.
a. WMVC shall take reasonable steps to ensure personal data is accurate.
b. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
c. Membership information will be reviewed every 12 months.
7. Archiving / removal
a. To ensure that personal data is kept for no longer than necessary, WMVC shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
b. The archiving policy shall consider what data should/must be retained, for how long, and why.
a. WMVC shall ensure that personal data is stored securely using modern software that is kept-upto-date.
b. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c. When personal data is deleted this should be done safely such that the data is irrecoverable.
d. Appropriate back-up and disaster recovery solutions shall be in place.
e. Members must use Bcc / blind carbon copy when you want to email a person privately. Any members on the Bcc line of an email are not visible to others on the email.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
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Last updated 04/2021
‘Data protection is about ensuring people can trust you to use their data fairly and responsibly’ (Information Commissioner’s Office 2018). These protocols outline how WMVC committee works to the best of its ability, to achieve this aim.
Protocols to support WMVC Data Protection Policy.
WMVC collects and retains chorister, Music Team members, and ‘Friends’ personal information as follows:
The DPO/Membership Secretary shall retain personal data records for choristers, Music Team members and ‘Friends’ for as long as they are subscribed as a chorister or ‘Friend’ or appointed as a member of the Music Team plus one further year.
• WMVC Data Protection Officer (DPO/Membership Secretary), Treasurer, Public Relations Officer (PRO), shall retain the following data for each chorister, Music Team member and ‘Friend’ of the choir for communication and administration purposes;
o Full name
o Date of Birth
o Name of spouse or partner
o Emergency contact information
o Postal address
o Email address
o Telephone numbers (Home and/or Mobile)
o Data sharing consent
• The Membership Secretary and Treasurer shall also retain information about individual choristers and ‘Friends’ subscription status, records of payment and Gift Aid consent.
• Section representatives (First Tenors, Second Tenors, Baritones and Basses) shall retain personal information of choristers in their sections for communication and administration purposes.
• Committee members shall retain other committee members’ personal information for communication and administration purposes.
• The ‘100 Club’ administrator shall retain personal data for choristers, Music Team members and ‘Friends’ of the choir for communication and administration purposes.
• The Uniform Officer shall retain choristers’ personal data for communication and administration purposes.
The DPO/Membership Secretary shall review any retained personal data at least annually to ascertain if he/she should archive or permanently delete individual chorister’s data in accordance with the Retention Policy.
Under Global Data Protection Regulations (GDPR) WMVC can process personal data for archiving purposes beyond the stated retention period if doing so is in the public interest, or for historical, scientific or statistical purposes. WMVC DPO will ensure that archiving does not contravene the rights and freedoms of data subjects and that appropriate technical and organisational safeguards are in place, such as data minimisation and password protection.
Register of Systems;
WMVC choristers, Music Team and ‘Friends’ personal data, as specified above, shall be stored on password protected laptops or personal computers and/or password protected electronic spreadsheets. Current data spreadsheets (February 2021) include;
• Annual Subscriptions Data (choristers and ‘Friends’)
• Data Protection Consent Records
• General database spreadsheet including all data listed above
Only the DPO/Membership Secretary and the Treasurer shall be able to access and edit personal data spreadsheets to ensure that personal data, including subscription payment records, are accurate and up to date.
The Membership Secretary shall retain any archived personal data on a password protected personal computer or laptop.
Internal Sharing of Personal Data:
WMVC data holders should only use individual chorister, Music Team or ‘Friends’ personal data to support the conduct of their choir responsibilities.
WMVC choir members, ‘Friends’ and members of the music team will be asked for their consent to allow their personal data to be shared with other choir members, ’Friends’ and members of the music team. Choristers and ’Friends’ will indicate consent on the annual subscription form. The DPO/Membership Secretary will ask for consent from music team members.
The WMVC DPO/Membership Secretary shall keep a record of the personal data preferences of individual choristers, ’Friends’ and Music team members. The DPO/Membership Secretary shall inform all choristers, ‘Friends’ and members of the music team about those who do not wish their personal information to be shared.
END OF POLICY
Review date; April 2022
The law requires any organisation involving young people and vulnerable adults to take all reasonable measures to ensure that the risks of harm to their welfare are minimised, and where there are concerns, to share them with other local agencies. The relevant legal requirements arise from:
– The Children’s Act 1989
– The Human Rights Act 1998
– The Protection of Children Act 1999
– The Sexual Offences (Amendments) Act 2006
– The UN Convention on the Rights of the Child. The relevant government guidance includes Safe from Harm 1993
– Working Together to Safeguard Children 1999
– Caring for the Young and Vulnerable 2000
WMVC recognises that it is not the role of our organisation to decide whether a child or vulnerable adult has been abused or not. This is the role of the Social Services department who have legal responsibility or the NSPCC who have powers to investigate child protection concerns under the Children Act.
In developing this policy, WMVC has taken advice from the national amateur music performance association Making Music.
Who are Children or Vulnerable Adults?
In this context anyone up to the age of 19 is a child and anyone over 18 years who is or may be unable to take care of themselves or unable to protect themselves against significant harm or exploitation is a vulnerable adult.
How WMVC Operates
WMVC is a Registered Charity, composed of amateur choir members. Officers are elected and others co-opted to serve on the Committee. Rehearsals are run by our self-employed Musical Director or a substitute on occasion, with two self- employed Accompanists. These are neither employed staff nor volunteers in the conventional sense.
WMVC does not advertise itself as an activity suitable for children or vulnerable adults. Most choir members are independent adults. It happens only rarely that a young person or vulnerable adult joins, rehearses and performs with us.
Choir rehearsals and performances are group activities, and there is no need for a member of the choir to be alone with another member of any age. WMVC is therefore unlikely to be targeted by a person seeking opportunities to abuse children or vulnerable adults. Nonetheless WMVC recognises the need to safeguard any young and vulnerable members and the Committee has therefore agreed the following Safeguarding Policy.
WMVC’s Safeguarding Policy
1. WMVC will publicise its Safeguarding policy on its website (www.worcestermalevoicechoir.org.uk) and draw it to the attention of members at the Annual General Meeting.
2. Young people will be welcome to participate in choral works requiring children and/or youth voices with WMVC as long as they bring a parent or other responsible adult who remains responsible for them throughout rehearsals and performances.
3. The Committee has identified the Stage Manager’s role to include the brief for Safeguarding and for the SM to be trained to Safeguarding Officer Level 3.
4. Choir members will report any concerns relating to young people and vulnerable adults to the Designated Person. Detailed Guidance is available from the Designated Person.
5. In the absence of the Designated Person the matter should be reported to the Secretary of the WMVC. A permanent confidential record will be kept of the report.
6. If WMVC should need to recruit staff, then the Choir Committee will apply safeguarding principles to ensure that appointees are suitable to work with young or vulnerable people.
7. The policy and procedures will be reviewed annually at a Choir Committee meeting.
END OF POLICY