Glos Folk Privacy Statement

Glos Folk (Gloucestershire Folk Association) collects data from members, subscribers, supporters, and performers. The legal basis for this is consent. 
The data collected is the minimum necessary for Glos Folk to perform our constitutional objectives, and normally is restricted to names, addresses, telephone numbers, and e-mail addresses. No sensitive data is collected. (except for dates of birth of members under 18). The data collected for the Glos Folk Diary of Events is all in the public domain.
Data is only held when necessary, and deleted when no longer relevant, ie when members leave the organisation.
All members, subscribers, supporters, and performers are entitled to see the information held by us, and to amend when necessary.
Glos Folk does not normally share data with other agencies. An exception might be when booking agencies ask for contact details of performers.
Glos Folk will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. Any security breach will be reported promptly to those affected.
Glos Folk may update this privacy policy by posting a new version on this website. You should check this page occasionally to ensure you are familiar with any changes. 
Other websites. Our web site contains links to other websites. Glos Folk is not responsible for the privacy policies or practices of any third party.
We use a third party provider, Mail Chimp, to deliver our weekly mailing to subscribers. We gather statistics around email opening and clicks using industry standard technologies.

Glos Folk Data Protection Policy (Draft) to be approved at next AGM
1. Introduction
Glos Folk (Gloucestershire Folk Association) needs to collect and use certain types of information about the Individuals or Service Users who come into contact with Glos Folk in order to carry on our work. This personal information must be collected and dealt with appropriately whether it is collected on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the Data Protection Act 1998, and as amended by future legislation and regulations..
2. Data Controller
Glos Folk is the Data Controller under the Act, which means that it determines for what purposes personal information held will be used. It is also responsible for notifying if necessary the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.
3. Disclosure
Glos Folk does not normally share data with other agencies. An exception might be when booking agencies ask for contact details of performers.
The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared.  There are circumstances where the law allows Glos Folk to disclose data (including sensitive data) without the data subject’s consent.   
These are:
a) Carrying out a legal duty or as authorised by the Secretary of State 
b) Protecting the vital interests of an Individual/Service User or other person
c) The Individual/Service User has already made the information public
d) Conducting any legal proceedings, obtaining legal advice or defending any legal rights  
e) Monitoring for equal opportunities purposes – i.e. race, disability or religion
f) Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.
Glos Folk regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.  
Glos Folk intends to ensure that personal information is treated lawfully and correctly.
To this end, Glos Folk will adhere to the Principles of Data Protection, as detailed in the Data Protection Act 1998, and as amended by future legislation and regulations.
Specifically, the Principles require that personal information:
a) Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met, 
b) Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
c) Shall be adequate, relevant and not excessive in relation to those purpose(s) 
d) Shall be accurate and, where necessary, kept up to date,
e) Shall not be kept for longer than is necessary 
f) Shall be processed in accordance with the rights of data subjects under the Act,
g) Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
h) Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.
Glos Folk will, through appropriate management and strict application of criteria and controls:
• Observe fully conditions regarding the fair collection and use of information
• Meet its legal obligations to specify the purposes for which information is used
• Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements
• Ensure the quality of information used
• Ensure that the rights of people about whom information is held, can be fully exercised under the Act. These include: 
o The right to be informed that processing is being undertaken,
o The right of access to one’s personal information
o The right to prevent processing in certain circumstances and 
o The right to correct, rectify, block or erase information which is regarded as wrong information
• Take appropriate technical and organisational security measures to safeguard personal information
• Ensure that personal information is not transferred abroad without suitable safeguards
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
• Set out clear procedures for responding to requests for information


4. Data collection
Informed consent is when
• An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data 
• And then gives their consent.
Glos Folk will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.
When collecting data, Glos Folk will ensure that the Individual/Service User:
a) Clearly understands why the information is needed 
b) Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing
c) As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
d) Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
e) Has received sufficient information on why their data is needed and how it will be used
5. Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised persons.
Information will be stored for only as long as it is needed or required by statute and will be disposed of appropriately.
It is Glos Folk’s responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.
6. Data access and accuracy
All Individuals/Service Users have the right to access the information Glos Folk holds about them. Glos Folk will also take reasonable steps ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, Glos Folk will ensure that:
• It has a Data Protection Officer (appointed at the Annual General Meeting) with specific responsibility for ensuring compliance with Data Protection


• Everyone processing personal information understands that they are contractually responsible for following good data protection practice


• Everyone processing personal information is appropriately trained to do so


• Everyone processing personal information is appropriately supervised


• Anybody wanting to make enquiries about handling personal information knows what to do


• It deals promptly and courteously with any enquiries about handling personal information


• It describes clearly how it handles personal information


• It will regularly review and audit the ways it holds, manages and uses personal information


• It regularly assesses and evaluates its methods and performance in relation to handling personal information


• All officers and members are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them
This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998. This review will take place at the Annual General Meeting.
In case of any queries or questions in relation to this policy please contact the Glos Folk Data Protection Officer:
Peter Cripps (peter@petercripps.co.uk) Tel: 01452780401




Signed:




Position:




Date: 




Review Date:


 
Glossary of Terms


Data Controller – The person who (either alone or with others) decides what personal information Glos Folk will hold and how it will be held or used.


Data Protection Act 1998 – The UK legislation that provides a framework for responsible behaviour by those using personal information.


Data Protection Officer – The person(s) responsible for ensuring that Glos Folk
 follows its data protection policy and complies with the Data Protection Act 1998.


Individual/Service User – The person whose personal information is being held or processed by Glos Folkfor example: a client, an employee, or supporter.


Explicit consent – is a freely given, specific and informed agreement by an Individual/Service User in the processing of personal information about her/him. Explicit consent is needed for processing sensitive data.


Notification – Notifying the Information Commissioner about the data processing activities of Glos Folk, as certain activities may be exempt from notification.


The link below will take to the ICO website where a self assessment guide will help you to decide if you are exempt from notification:  http://www.ico.gov.uk/for_organisations/data_protection/the_guide/exemptions.aspx


Information Commissioner – The UK Information Commissioner responsible for implementing and overseeing the Data Protection Act 1998.


Processing – means collecting, amending, handling, storing or disclosing personal information.


Personal Information – Information about living individuals that enables them to be identified – e.g. name and address. It does not apply to information about organisations, companies and agencies but applies to named persons, such as individual volunteers or employees within Glos Folk.


Sensitive data – refers to data about:
• Racial or ethnic origin
• Political affiliations
• Religion or similar beliefs
• Trade union membership
• Physical or mental health
• Sexuality
• Criminal record or proceedings 







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