Published : 1 April 2025

Data Protection Policy - Overview

Key details

• Policy prepared by: Peter Cross

• Approved by Committee on: 01/04/2025

• Next review date: 31/03/2027

Introduction

To operate, Veterans Community Choirs (VCC) must gather, store, and use certain types of information about individuals.

These can include members, employees, contractors, suppliers, volunteers, audiences, potential audiences, business contacts, and other individuals with whom the VCC has a relationship or regularly communicates.

This policy outlines the procedures for collecting, storing, and using data to ensure compliance with VCC data protection standards and the General Data Protection Regulation (GDPR).

Why is this policy important?

This policy ensures that Veterans Community Choirs

• Protects the rights of our members, volunteers and supporters

• Complies with data protection law and follows good practice

• Protect the group 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 VCC e.g:

• Committee members

• Employees and volunteers

• Members

• Contractors/3rd-party suppliers

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

• Names

• Email addresses

• Postal addresses

• Phone numbers

• Any other personal information held (e.g. financial)

Roles and responsibilities

VCC is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for VCC is Peter Cross. They, together with the committee, are responsible for the secure, fair and transparent collection and use of data by Veterans Community Choirs. Any questions relating to the collection or use of data should be directed to the Data Protection Officer.

Everyone with access to data as part of VCC has a responsibility to ensure they adhere to this policy.

VCC may use commercially available third-party Data Processors [(e.g. Google Drive, Wix, Making Music)] to process data on its behalf. VCC will ensure all Data Processors are compliant with GDPR.

We fairly and lawfully process personal data in a transparent way

VCC 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 VCC 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, VCC will anonymise this data

  • Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to VCC 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 VCC 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 VCC 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 VCC 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 on the VCC website’ below.

  • Lawful basis for processing this data: Consent (see ‘How we get 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, VCC will always provide a clear and specific privacy statement that explains to the subject why the data is required and how it will be used.

We ensure any data collected is relevant and not excessive

VCC will not collect or store more data than is necessary 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.

We ensure data is accurate and up-to-date

VCC will ask members, volunteers and staff to check and update their data on an annual basis. Any individual can update their data at any time by contacting the Data Protection Officer.

We ensure data is not kept longer than necessary

VCC will retain records for no longer than necessary to meet the intended purpose for which they were collected (unless there is a legal requirement to retain them).

The storage and intended use of data will be reviewed in line with the VCC 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

VCC 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
   

 

Transfer to countries outside the EEA

VCC 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 VCC collects, holds and uses an individual’s personal data, that individual has the following rights over that data. VCC will ensure that its data processing complies with these rights and will make all reasonable efforts to fulfil requests from an individual in relation to these rights.

Individual’s rights

• Right to be informed: Whenever VCC collects data, it will provide a clear and specific privacy statement explaining why the data is being collected and how it will be used.

 

• Right of access: individuals can request to see the data VCC 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. VCC will request that members, staff, and contractors check and update their data on an annual basis. Any requests for data updates will be processed within one month.

 

• Right to object: individuals have the right to object to their data being used for a specific purpose. VCC will always provide a way for an individual to withdraw consent in all marketing communications. If we receive a request to stop using data, we will comply unless we have a lawful reason to continue using the data for legitimate interests or contractual obligations.

 

• Right to erasure: individuals can request for all data held on them to be deleted. VCC's data retention policy ensures that data is not held for longer than is reasonably necessary in relation to the purpose for which it was originally collected. If a request for deletion is made, we will comply with the request unless:

 

• 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, VCC will restrict the data while it is verified).

Though unlikely to apply to the data processed by Veterans Community Choirs, we will also ensure that rights related to portability and automated decision-making (including profiling) are complied with where appropriate.

 

Member-to-member contact

As a membership organisation, VCC promotes communication among its members. However, we only share members’ data with other members with the subject’s prior consent

To facilitate this:

• Members can request the personal contact data of other members in writing via the Data Protection Officer or Membership 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 VCC obtains consent

VCC will regularly collect data from consenting supporters for marketing purposes. This includes contacting them to promote performances and 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 (e.g. a ‘tick box’)

• A clear and specific explanation of what the data will be used for (e.g. ‘Tick this box if you would like VCC to send you email updates with details about our forthcoming events, fundraising activities, and opportunities to get involved’)

Data collected will only be used in the manner described and as consented to (e.g., we will not use email data to market third-party products unless this has been explicitly consented to).

Every marketing communication will contain a method by 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

 

VCC takes any breach of data seriously. A data breach could be deliberate or accidental:

• Loss of data – e.g. 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 – e.g. changing data without permission or good reason or changing it with permission or good reason but incorrectly, either by VCC staff, volunteers or third parties

• Unauthorised use of data e.g. sending an email that requires consent where consent has not been given.

• Unauthorised access to data – e.g. an (unauthorised) third party gains access to data stored by VCC

• Unauthorised disclosure of data – e.g., VCC passing data to a third party without a lawful basis.

 

VCC acknowledges that a data breach can occur through both intentional and unintentional actions on the part of the Data Controller or Processor.

 

 

How we prevent Data breaches

 

VCC 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, VCC changes.

• Automatic and manual processes ensure mass communications are only sent in line with mailing preferences.

 

 

 

If a Data breach occurs

 

If anyone associated with VCC believes a data breach has occurred, it should be reported to the Data Protection Officer/Committee immediately.

 

The Data Protection officer/committee 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 trustees are informed

• Report the breach to the Information Commissioner's Office. 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 any other relevant regulators.

• Report the breach to the data subjects affected, informing them of what has happened, the possible and likely impacts it might have on them and what we are doing to manage the breach and reduce the risk of future occurrences

• 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.

• 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 Directors.

• 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 the VCC website

 

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.

VCC uses cookies on our website, www.veteranscommunitychoirs.org, to monitor and record user activity. This allows us to improve users’ experience of our website by, for example, enabling a ‘logged in’ state and by providing us with useful insights into how users as a whole are engaging with the website.

We have implemented a pop-up box on www.veteranscommunitychoirs.org that will activate each new time a user visits the website. This will allow them to click to consent (or not) to continue with cookies enabled or to ignore the message and continue browsing (i.e. give their implied consent).

It will also include a link to our Privacy Policy, which outlines the specific cookies used and how to disable them in the most common browsers.

Data retention policy

Introduction

This policy outlines VCC's approach to data retention and establishes processes to ensure that we do not retain data for longer than necessary. It forms part of the VCC Data Protection Policy.

Roles and responsibilities

VCC is the Data Controller and determines what data is collected and retained and how it is used. The Data Protection Officer for VCC is Peter Cross. They, together with the committee, are responsible for the secure and fair retention and use of data by VCC. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.

A regular review of all data will be conducted to determine if VCC still has a valid reason to retain and utilise 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 will elapse between reviews. The first review will take place on 31st March 2027

Data to be reviewed

• VCC stores data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members.

• Data stored on third party online services [(e.g. Google Drive, WIX, Making Music)]

• 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 appointed 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.

Criteria

The following criteria will be used to determine which data to retain and which to discard.

Question

Action

 

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 the 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 a reason to retain 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 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

 

Statutory Requirements

Data stored by VCC may be retained in accordance with statutory requirements for data storage, excluding data protection regulations. This might include but is not limited to:

• Gift Aid declarations records

• Details of payments made and received (e.g. in bank statements and accounting records)

• Committee meeting minutes

• Contracts and agreements with suppliers/customers

• Insurance details

• Tax and employment records

 

 

Other data retention procedures

Member data

• When a member leaves VCC 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

• Unless consent has been given, data will be removed from all email mailing lists

• 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 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 VCC 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, data will be removed from all email mailing lists

• All other data will be stored safely and securely and reviewed as part of the next two-year review

Other data

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