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.
When you visit our site, you will be presented with a cookie notification pop up. By clicking “I agree” a permanent cookie will be set on your machine. This cookie will remember your preference and you will no longer be presented with a pop-up each time you visit our site.
Data protection principles
a) We fairly and lawfully process personal data in a transparent way
Suffolk Sinfonia 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 ‘subs’. Where possible Suffolk Sinfonia will anonymise this data
- Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Suffolk Sinfonia 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 Suffolk Sinfonia 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 Suffolk Sinfonia 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 or at an event), with their consent, in order for Suffolk Sinfonia 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' above.
- Lawful basis for processing this data: Consent (see ‘How we get consent’)
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, Suffolk Sinfonia 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
Suffolk Sinfonia 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 or sexuality will not be collected, since it is unnecessary and excessive for the purposes of group administration.
d) We ensure data is accurate and up-to-date
Suffolk Sinfonia 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
[Group name’s] 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 Suffolk sinfonia's 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.
f) We keep personal data secure
Suffolk Sinfonia 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. membership forms or email sign-up sheets) will be stored in a locked cupboard
- Keys for locks securing physical data files should be collected by the Data Protection Officer from any individual with access if they leave their role/position. The codes on combination locks should be changed each time an individual with data access leaves their role/position
- Access to data will only be given to relevant trustees/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 and will keep a master list of who has access to data
g) Transfer to countries outside the EEA
Suffolk Sinfonia 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 Suffolk Sinfonia collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Suffolk Sinfonia 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 Suffolk Sinfonia 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 Suffolk Sinfonia 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. Suffolk Sinfonia 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. Suffolk Sinfonia 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. Suffolk Sinfonia'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:
- 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, Suffolk Sinfonia will restrict the data while it is verified).
Though unlikely to apply to the data processed by Suffolk Sinfonia, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.