Following the intorduction of the General Data Protection Regulation (GDPR) on 25th May 2018 Comber Brass has revised it's Data Protection guidelines and these are posted below.
In order to operate Comber Brass needs to gather, store and use certain forms of information about
These can include members, employees, contractors, suppliers, volunteers, audiences and potential audiences, business contacts and other people the organisation has a relationship with or regularly needs to contact.
This policy explains how this data should be collected, stored and used by Comber Brass in order to meet data protection standards and comply with the General Data Protection Regulations (GDPR).
This policy ensures that Comber Brass:
Roles and Responsibilities
This policy applies to all those handling data on behalf of Comber Brass e.g.:
It applies to all data that Comber Brass holds relating to individuals, including:
Comber Brass is the Data Controller and will determine what data is collected and how it is used. A member of the organisation is appointed as the Data Protection Officer for Comber Brass who, together with the committee, is responsible for the secure, fair and transparent collection and use of data by Comber Brass. Any questions relating to the collection or use of data should be directed to the Data Protection Officer in the first instance.
Everyone who has access to data as part of Comber Brass has a responsibility to ensure that they adhere to this policy.
If Comber Brass uses third party Data Processors to process data on its behalf, it will ensure all such Data Processors are compliant with GDPR.
Data Protection Principles
[a] We fairly and lawfully process personal data in a transparent way.
Comber Brass will only collect data where lawful and where it is necessary for the legitimate purposes
of the organisation.
A member’s name and contact details will be collected when they first join the organisation, and will be used to contact the member regarding organisation administration and activities. Other data may also subsequently be collected in relation to their membership, including their subscription payment history. Where possible Comber Brass will anonymise this data.
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 organisation administration related to
their role. Further information, including personal financial information and criminal record 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.).
An individual’s name and contact details will be collected when they make a booking for an event or when arranging an engagement. This will be used to contact them about their engagement or 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 Comber Brass to communicate with them about and promote organisation activities. See ‘How we get consent’ below.
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 the Comber Brass website’ below.
[b] 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, Comber Brass 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.
[c] We ensure any data collected is relevant and not excessive.
Comber Brass 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 organisation administration, but data on their marital status or sexuality will not be collected, since it is unnecessary and excessive for the purposes of organisation administration.
[d] We ensure data is accurate and up-to-date.
Comber Brass 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.
[e] We ensure data is not kept longer than necessary.
Comber Brass 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 our data retention policy. When the intended use is no longer applicable (e.g. contact details for a member who has left the organisation) the data will be deleted within a reasonable period.
[f] We keep personal data secure.
Comber Brass will ensure that data held by us is kept secure.
[g] Transfer to countires outside the EEA.
Comber Brass 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.
When Comber Brass collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Comber Brass 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 Comber Brass, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
Member to Member Contact
We only share members’ data with other members with the subject’s prior consent. As a membership organisation Comber Brass encourages communication between members.
To facilitate this, members can request the personal contact data of other members in writing via the Data Protection Officer or the Secretary. 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.
How we get consent
Comber Brass may collect data from consenting supporters for marketing purposes. This includes contacting them to promote performances, updating them about organisation news, fundraising and other organisation 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.
Cookies on the Comber Brass web-site
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.
This policy sets out how Comber Brass will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. It forms part of Comber Brass Data Protection Policy.
Roles and responsibilities
Comber Brass is the Data Controller and will determine what data is collected, retained and how it is used. A member of the organisation is appointed as the Data Protection Officer for Comber Brass who, together with the committee, is responsible for the secure and fair retention and use of data by Comber Brass. Any questions relating to data retention or use of data should be directed to the Data Protection Officer in the first instance.
Regular Data Review
A regular review of all data will take place to establish if Comber Brass 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 be undertaken in January 2019.
Data to be reviewed
Who the review will be conducted by
The review will be conducted by the Data Protection Officer with other committee members to be
decided on at the time of the review.
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 Yes 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?
Is the data being used for its original intention?
Continue to use. Delete or remove data.
Continue to use. Either delete/remove or record
lawful basis for use and get consent if necessary.
Is there a statutory requirement Keep the data at least until Delete or remove the data unless
to keep the data? the statutory minimum no we have reason to keep the data
longer applies. under other criteria.
Is the data accurate? Continue to use. Ask the subject to confirm/update
Question Yes No
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.
Data stored by Comber Brass 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
[a] Member data
When a member leaves Comber Brass 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.
[b] Mailing list data
If an individual opts out of a mailing list their data will be removed as soon as is practically possible.
[c] Volunteer and freelancer data
When a volunteer or freelancer stops working with Comber Brass 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.
[d] Other data
All other data will be included in a regular two year review.
What is this guide for?
Whenever we need to collect any of your data, we will let you at that point why we need to do so and what it will be used for, but this guide provides a useful overview of all of those situations and provides more detail on how we keep your data secure and up to date, how long we might hold it for, and what your rights are in relation to it.
Comber Brass is committed to protecting your personal data and will use any personal or sensitive data we collect from you in line with the General Data Protection Regulations (GDPR).
Who’s responsible for data the organisation collects?
Comber Brass is a Data Controller under the GDPR. Comber Brass has a Data Protection Officer
who can be contacted at firstname.lastname@example.org.
What data do we collect and what do we use it for?
Comber Brass collects data from individuals to help us plan, organise and run the day-to-day operations of the organisation (e.g. co-ordinating rehearsals or collecting subscription payments) and to promote and market the organisation’s activities (e.g. marketing mailing lists and photography/video capture).
[a] Members: for administering membership
When you join Comber Brass as a member or during your membership with us, we may need to
collect some of the following information on you:
This data will be used by committee members to manage your membership with Comber Brass and to organise and run our activities.
If you give us your consent to do so, we may also use your contact details to send you
marketing/promotional communications from the organisation. Any
communication we send you will include a clear option to withdraw your consent (e.g. to ‘opt out’ of future emails) and you can also withdraw consent at any point by contacting the Data Protection Officer.
Where you wish to engage or hire the organisation to provide music services, we need to collect data (such as contact information) to arrange this. This data will only be used for administering the services requested and for managing and organising their delivery at the event. This data will not be used to send you marketing/promotional messages from the organisation in the future, unless you have also provided your consent to receive these (see below).
Where our events are ticketed, we need to collect data on the person booking (name and email) in order to allow you access to the event and to send you a confirmation of your reservation/purchase. This data will only be used for administering your access to the event/s for which you have booked and will not be used to send you marketing/promotional messages from the organisation in the future, unless you have also provided your consent to receive these (see below).
Employees & contractors: for administration & legal / regulatory purposes
We may need (for administration or for legal/regulatory reasons) to collect personal or sensitive data on employees or contractors of the organisation. Where this is the case, we will explain what this is for at the point of collection.
We may offer the opportunity to sign up (consent) to receive marketing and promotional information
on the organisation’s activities (e.g. emails about forthcoming events).
When you sign-up to our marketing mailing list we may ask for your name, email, phone number, address and will use this data to send you information about our events and activities (e.g. forthcoming performances, social events and fundraising events). We may also ask for your preferred topics and communication methods. These allow us to tailor the information we provide to suit your preferences (e.g. email vs post).
We will only send you information that is related to the organisation (e.g. we will not use your data to send you marketing messages from 3rd parties).
Anything we send you will include a clear option to withdraw your consent (e.g. to ‘opt out’ of future emails) and you can also do so at any time by contacting the Data Protection Officer.
We will use a pop-up banner to let users know if we are using cookies on their first visit, and they can at any time disable cookies in their browser if they do not wish their (anonym ised) data to be tracked.
You can find out more about cookies at http://www.allaboutcookies.org/.
Do we share your data with anyone else?
We will never pass your details on to third parties for marketing purposes.
If we use third party services to process your data (e.g. Google Dive) we will always ensure they are reputable, secure, and process your data in accordance with your rights under GDPR.
Are there special measures for children’s data?
Where we knowingly collect or store data of children under 13 we will ensure the person with parental responsibility for the child has seen the relevant information relating to the child data or has given consent on behalf of the child.
Once a child is over 13 years old, parental consent to use their data will no longer be sufficient. We will only continue to hold/use the data if the child themselves also gives their consent.
How can you update your data?
You can contact us at any time at email@example.com to update or correct the data we hold on
How long we will hold your data?
The Comber Brass data retention policy is to 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.
Where you have withdrawn your consent for us to use your data for a particular purpose (e.g. unsubscribed from a mailing list) we may retain some of your data for up to two years in order to preserve a record of your consent having been withdrawn.
What rights do you have?
Under the GDPR, you have the following rights over your data and its use:
Though unlikely to apply to the data we hold and process on you, you also have rights related to portability and automated decision making (including profiling).
All requests related to your rights should be made to the Data Protection Officer at firstname.lastname@example.org. We will respond within one month.
You can find out more about your rights on the Information Commission’s Office website
What will we do if anything changes?
If we make changes to our privacy statements or processes we will post the changes here. Where the changes are significant, we may also choose to email individuals affected with the new details. Where required by law, will we ask for your consent to continue processing your data after these changes are made.
What are 'cookies'?
'Cookies' are small text files that are stored by the browser (for example, Internet Explorer) on your computer or electronic device. They allow websites to 'remember' you for a period of time so that they can store things like user preferences and make the website quicker and easier for you to use. Without cookies, some things on websites would not be able to work: for example, without cookies it might not be possible to know whether or not you are logged in on a website, which would prevent you from being able to see content restricted to logged-in users.
A visit to a page on the Comber Brass website may create the following types of cookie:
When you register with Comber Brass, we may generate cookies that let us know whether you are signed in or not. Our servers use these cookies to work out which account you are signed in with, and if you are allowed access to a particular service. It also allows us to associate any comments you post with your username. If you have not selected 'keep me signed in', your cookies get deleted when you either close your browser or shut down your computer.
Every time someone visits our website, software provided by other organisations (Google Analytics,
Wordpress) generates an 'anonymous analytics cookie'.
These cookies can tell us whether or not you have visited the site before and what pages you visit. Your browser will tell us if you have these cookies and, if you don't, we generate new ones. This allows us to track how many individual users we have, and how often they visit the site. We use them to gather statistics, for example, the number of visits to a page, to help us identify if visitors would benefit from more information on a particular area.
How do I turn cookies off?
It is usually possible to stop your browser accepting cookies, or to stop it accepting cookies from a particular website. All modern browsers allow you to change your cookie settings. You can usually find these settings in the 'options' or 'preferences' menu of your browser. To understand these settings, the following links may be helpful, or you can use the 'Help' option in your browser for more details.
Please note: switching off cookies may prevent some aspects of our website from working fully (e.g. you may not be able to access our members-only).
You can find out more about cookies and their use on the internet from www.allaboutcookies.org