R Community Choirs – Birmingham CIC
Data Protection Policy
| Document Control | ||
| Version and date | Date of next review – at least annually | Reviewer |
| V1.0 – 1/07/26 | Before July 2027 | Andy Boxall Director |
| Organisation | means R Community Choirs – Birmingham CIC |
| Responsible Person | means Andy Boxall who can be contacted at rcommunitychoirs@gmail.com |
1. Data protection principles
R Community Choirs – Birmingham CIC is committed to processing data in accordance with its responsibilities under the Data Protection Act 2018. All personal data will be:
a) processed lawfully, fairly and in a transparent manner in relation to individuals; b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes; and
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
2. General provisions
a) This policy applies to all personal data processed by the organisation.
b) The Responsible Person shall take responsibility for the organisation’s ongoing compliance with this policy.
c) This policy shall be reviewed at least annually.
d) The organisation shall register with the Information Commissioner’s Office as an organisation that processes personal data.
3. Lawful, fair and transparent processing
a) To ensure its processing of data is lawful, fair and transparent, the organisation shall maintain a record of personal data processing reviewed at least annually.
b) Individuals have the right to access their personal data and any such requests made to the organisation shall be dealt with in a timely manner.
4. Lawful purposes
a) All data processed by the organisation must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests. b) Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
c) Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent will be clearly available.
5. Purpose limitation
a) The organisation shall ensure that personal data is only used according to the purpose for which it was processed.
6. Data minimisation
a) The organisation shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
7. Accuracy
a) The organisation shall take reasonable steps to ensure personal data is accurate. b) Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
8. Retention
a) To ensure that personal data is kept for no longer than necessary, the organisation shall review archiving/destruction of data annually.
9. Security
a) The organisation shall ensure that personal data is stored securely using modern software that is kept up to date.
b) Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
c) When personal data is deleted, this should be done safely such that the data is irrecoverable.
d) Appropriate back-up and disaster recovery solutions shall be in place.
10. Breach
a) In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the organisation shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.
11. Individual rights
An individual is entitled to:
a) Confirmation of whether we are processing their personal data.
b) A copy of the personal data that is being processed, subject to exemptions. c) For their personal data to be rectified or completed if not accurate. d) To be erased if consent is withdrawn or we no longer have a valid reason to process it, subject to exemptions.
Please send all requests and queries to the Responsible Person named at the top of this policy.