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Privacy Statement

Introduction

In order to operate, Nottingham Bach Choir (hereafter NBC) needs to gather, store and use certain forms of information about individuals, who may be members, contractors, suppliers, volunteers, audience and potential audience, business contacts or other people NBC 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 NBC data protection standards and comply with the General Data Protection Regulations (GDPR).

Why is this policy important?

This policy ensures that Nottingham Bach Choir:

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

Who and what does this policy apply to?

This applies to all those handling data on behalf of Nottingham Bach Choir:

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

It applies to all data that NBC holds relating to individuals, including:

  • Names
  • Email addresses
  • Postal addresses
  • Phone numbers

Roles and responsibilities

Nottingham Bach Choir is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Nottingham Bach Choir, together with the trustees/committee, is responsible for the secure, fair and transparent collection and use of data by NBC. Any questions relating to the collection or use of data should be directed to the Data Protection Officer.

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

Nottingham Bach Choir uses third party data processors (e.g. Mail Chimp) to process data on its behalf. NBC will ensure that all data processors are compliant with GDPR.

Fairly and lawfully processing personal data in a transparent way.

Nottingham Bach Choir will only collect data where lawful and where it is necessary for its legitimate purposes. This includes, but may not be limited to:

  • Members: 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. Where possible NBC will anonymise this data.

Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to NBC completing tasks expected as part of the individual’s membership).

  • Volunteers and contractors: name and contact details 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 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 NBC completing tasks expected as part of working with the individuals),

  • Individuals making bookings: name and contact details will be collected when they make a booking to attend 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 NBC completing tasks expected as part of the booking).

  • Communication with Individuals: 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 NBC to communicate with them about and promote its activities.

Lawful basis for processing this data: Consent.

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, Nottingham Bach 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 (the Right to be Informed – below)

We ensure any data collected is relevant and not excessive

Nottingham Bach Choir will not collect or store more data than the minimum required for its intended purpose.

We ensure data is accurate and up to date

Nottingham Bach Choir will ask members, volunteers and staff to check and update their own data on an annual basis. Any individual will be able to update their data at any point by contacting the Data Protection Officer.

We ensure data is not kept longer than necessary

Nottingham Bach 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 for a specified time period).

The storage and intended use of data will be reviewed in line with NBC’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.

We keep personal data secure

Nottingham Bach 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 (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 any 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.
  • When Nottingham Bach Choir collects, holds and uses an individual’s personal data that individual has the following rights over that data. NBC will ensure its data processes comply with those rights and will make all reasonable efforts to fulfil requests from individuals in relation to those rights.

Individuals’ rights

  • Right to be informed: whenever NBC 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 NBC 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. NBC will request that members 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.
  • Withdrawal of consent: NBC 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 all data held on them to be deleted. NBC’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, NBC will restrict the data while it is verified).

Though this is unlikely to apply to the data processed by Nottingham Bach Choir, NBC will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate. We only share members’ data with other members with the subject’s prior consent.

Nottingham Bach Choir will regularly collect data from consenting supporters for marketing purposes. This includes contacting them to promote performances, updating them about NBC news, fundraising and other NBC 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 (e.g. a ‘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. 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

You can read our Cookies Policy here

[this is not included in this document but treated separately]

Data Retention

This section sets out how Nottingham Bach Choir will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary. It forms part of Nottingham Bach Choir Data Protection Policy.

A regular review of all data will take place to establish if NBC still has good reason to keep and use the data held at the time of the review. This review will be held every two years, and no more than 27 calendar months after the previous review.

Data to be reviewed

  • Data stored on digital documents (e.g. spreadsheets) stored on personal devices held by committee members/trustees/role holders
  • Data stored on third party online services [(e.g. MailChimp)]
  • Physical data stored at the homes of committee members

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 and whether data will be deleted

  • Physical data will be destroyed safely and securely, e.g. by 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 (i.e. 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.

Criteria

The following will be used to make decisions about whether to keep or delete data.

  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? Continue to use Delete or remove data
Is the data being used for its original intention? Continue to use Either delete/remove or record lawful basis for use and get consent if necessary
Is there a statutory requirement to keep the data? Keep the data at least until the statutory minimum no longer applies   Delete or remove the data unless we have reason to keep it under other criteria
Is the data accurate? Continue to use Ask the subject to confirm/update details
Where appropriate do we have consent to use the data? (This consent may be implied by previous use and engagement by the individual) Continue to use Get consent. If not given then delete/remove
Can the data be anonymised? Anonymise data Continue to use in current form where required

Statutory Requirements

Date stored by Nottingham Bach Choir may be retained based on statutory requirements for storing data which are not data protection regulations. These include but are not limited to:

  • Gift Aid declarations records
  • Details of payments made and received
  • Trustee meeting minutes
  • Contracts and agreements with suppliers/customers
  • Insurance details

Reviews

Member data

  • When a member leaves Nottingham Bach Choir and all administrative tasks relating to their membership have been completed, any potentially sensitive data held on them, including bank details, will be deleted.
  • All other data will be stored safely and securely and reviewed as part of the next two-year review.

Mailing list data

  • If an individual opts out of a mailing list their data will be removed as soon as is practically possible.
  • All other mailing list data will be stored safely and securely and reviewed as part of the next two-year review

Volunteer and freelancer data

  • When a volunteer or freelancer stops working with Nottingham Bach Choir 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. Unless consent has been given their data will be removed from all email mailing lists

Other data

  • All other data will be included in the regular two-year review.

Policy History

Policy prepared by: Elizabeth Dunford

Approved by Board/committee on: 6 June 2022

Reviewed: August 2024

Updated by: Gordon Stoner, August 2025

Approved by NBC Trustees on: 22 September 2025