In this document The Community and Youth Music Library will be shown as CYML.
Overview
Key details
- Policy prepared by: CYML Administrator
- Approved by trustees on: 25th May 2018
- Next review date: 2023
Introduction
This policy explains how data will be collected, stored and used in compliance with the General Data Protection Regulations (GDPR).
This covers the operation, gathering, storage and use of certain forms of information about individuals.
These can include borrowers, employees, volunteers and contractors.
This policy is important because it ensures that:
CYML:
- Protects the rights of borrowers, volunteers and employees
- Complies with data protection law and follows good practice
- Protects the organisation from the risks of a data breach
Roles and Responsibilities
This policy applies to all those handling data on behalf of CYML e.g.:
- Trustees
- Employees and volunteers
- Contractors/Third party suppliers
It applies to all data that CYML holds relating to individuals, including:
- Names
- Name of your group
- Email addresses
- Postal addresses
- Phone numbers
- Any other personal information held (e.g. financial)
The Administrator of CYML is its Data Controller and Data Protection Officer, and will determine what data is collected and how it is used. The Administrator and the Trustees are responsible for the secure, fair and transparent collection and use of data by CYML. 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 CYML has a responsibility to ensure that they adhere to this policy.
Data Protection Principles
a) We fairly and lawfully process personal data in a transparent way
CYML will only collect data where lawful and where it is necessary for legitimate purposes.
- A borrower’s name and contact details will be collected when they hire music from CYML and will be used to contact and invoice the borrower regarding their music hire.
- The name and contact details of volunteers, employees and contractors will be collected when they take up a position and will be used in relation to their role.
b) We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes
CYML will make available a Privacy Policy explaining why the data is required and what it will be used for.
c) We ensure any data collected is relevant and not excessive
CYML will not collect or store more data than the minimum information required for its intended purpose.
d) We ensure data is accurate and up-to-date
CYML will update data whenever new information is provided. 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
CYML 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 longer).
f) We keep personal data secure
CYML will ensure that data held by us is kept secure.
- Electronically-held data will be held within a password-protected and secure environment.
- Physically-held data (e.g. invoices) will be stored in a locked room.
- Keys for locks securing physical data files will be collected by the Data Protection Officer from any individual with access if they leave their role/position.
- The Data Protection Officer will decide who is to have access to electronic and physical data.
Individual Rights
When CYML collects, holds and uses an individual’s personal data that individual has the following the rights over that data. CYML 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.
Individual’s rights
- Right to be informed: CYML will provide a clear Privacy Policy, available to all on its website.
- Right of access: individuals can demand to know what data CYML holds on them and to be told 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 normally within one month.
- Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. 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. Where CYML receives a request to stop using data we will comply unless we have a lawful reason to continue to use the data.
- Right to erasure: individuals can request that all data held on them be deleted. CYML’s Data Retention Policy will ensure 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:
- 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, CYML will restrict the data while it is verified).
Cookies on The Community and Youth Music 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.
You do not have to provide any personal information in order to browse this website.
When you use the CYML website, we may collect tracking information such as your browser type, the type of operating system you use, the name of your internet service provider and pages visited on the site.
We obtain this information without using cookies to increase the functionality and user-friendliness of our website and to better tailor our website to your needs. For example, we may want to know how long the average visitor spends on our website or which pages get the most attention. Information such as this will only be used in aggregate form and does not identify you personally.
We collect information on our website visitors for a variety of purposes, including to reply to your enquiries more efficiently through the services we provide. We also use information in aggregate form (your individual details cannot be identified) to audit usage of the site.