Harworth Brass Band Data Protection Policy
This Policy explains when and why we collect personal information about players who register with us, as well as the personal information about Band Committee members that we gather. It also explains how we use this information, the conditions under which we may disclose this information to others and how we keep this information safe. This Privacy Notice applies where we are acting as a data controller with respect to your personal data of players and Band Committee members; in other words, where we determine the purposes and means of the processing of that personal data. We may be required to change this Privacy Notice when in line with current legislation. If any changes are implemented into our policies, you will be informed and signposted to the relevant documents. Any questions regarding this Privacy Notice and our privacy practices should be sent by email to secretary@harworthbrass.co.uk
Who are we? Harworth Brass Band is a local community brass band, located at Harworth & Bircotes Town Hall, Scrooby Road, Bircotes, Doncaster, DN11 8JN. All correspondence should be sent directly to the Bands treasurer Matthew Colley at 12 Milne Drive, Bircotes, Doncaster, Dn11 8AR.
1.1 What type of data do we collect from you? PLAYER REGISTRATIONS - USING PLAYER REGISTRATION FORM: Form QR105
● Full Name
● Date of Birth
● Postal address and postcode
● Telephone number
● Player Signature
● Band committee Signature
● Player photo
● Relevant medical information including allergies
● Next of Kin name and contact number
CONTACT INFORMATION FOR BAND COMMITTEE MEMBERS: Form QR106
● Full Name
● Date of Birth
● Postal address and postcode
● Telephone number
● Player Signature
● Band committee Signature
● Committee Members photo
● Relevant medical information including allergies
● Next of Kin name and contact number
PLAYERS UNDER THE AGE OF SIXTEEN YEARS OF AGE – Form QR107
● Full Name
● Date of Birth
● Postal address and postcode
● Contact number
● Parents/legal guardian’s signature
● Band committee Signature
● Committee Members photo
● Relevant medical information including allergies
● Parent/Legal Guardian name and contact number
PLAYERS IN EDUCATION UPTO THE END OF YEAR 11. – Form – Standard Child Performance and Activities Licence Application Form (England)
● Name, address and contact number of registered GP
● Child's photograph
● Name and address of school attended
● A copy of Birth Certificate
1.2 Where do we store the data?
1.2.1 Player Registration Forms are physically stored in a folder in a lockable filing cabinet in Harworth Brass bands Storage room located within the Harworth Town Hall.
1.2.2 A digital copy of the New Player Registration Form is stored on our Google drive.
1.2.3 Band Committee information is stored physically in a folder in a lockable filing cabinet in Harworth Brass Bands Storage room located within the Harworth Town Hall, a digital copy is also held on our Google Drive.
1.2.4 Players up to the age of sixteen – QR107 is physically stored in a folder in a lockable filing cabinet in Harworth Brass Bands storage room located within Harworth Town Hall.
1.2.5 A Digital copy is held on the Google Drive
1.2.6 Standard Child Performance and Activities Licence Application Form (England) no Physical copy is held. Only a digital copy is held securely on the Google Drive in a separate “Child Performance licence” secure folder.
1.2.7 A physical copy of the Authorised “Child's Performance Licence” will be held in a secure lockable filing cabinet
1.2.8 A digital copy will be held in a secure folder on the Google Drive, which will only be accessible by the “Child Protection Officer”, “Deputy Child Protection Officer”, “Chair”, and Secretary which will remain password protected.
1.3 How do we protect and document the data we have? PROTECT DATA
1.3.1 Harworth Brass Band’s committee members only have full access to the Google Drive which is password protected, this is accessed by their own PC/Laptop/Phone all of which are password-protected, meaning that only Harworth Brass Band Committee Members can access personal information. The Google drive cannot be accessed any other way.
1.3.2 Players in education up to the end of year 11 – are only accessible by the Chairman, Child Protection Officer and deputy child protection officer.
1.3.3 Harworth Brass Bands emails are password-protected, meaning that only the Chair, secretary, Child Protection officer can access our email system - which includes the Band Committee information, as well as player data.
1.3.4 The physical data for every player (New Player Registration Forms QR105 and Players in education up to the end of year 11 - QR107) is stored in a folder in a secure lockable filing cabinet in the Harworth Brass Bands secure Storage room, based within the Harworth Town Hall.
1.3.5 The physical data for “band committee members” form QR106 is held in a physical folder which is kept in a secure lockable filing cabinet, located within the secure storage room within Harworth Brass band room.
1.3.6 A Digital copy is held in a secure folder on the Google Drive, which is only accessible by all committee members; this folder is password protected.
DOCUMENT DATA
1.3.7 Player and Committee members data is manually inputted onto our Google Drive by Harworth Brass band Committee Members. This is kept on Google Drive to enable us to access personal information when away from the Band room playing concerts etc.
1.3.8 Emails/contact numbers for players are used to alert them to new pieces of music, band information, changes to rehearsals, updates from Committee Meetings etc. players information will not be shared with any other band member without full consent of the owner in the first instance.
1.3.9 All emails sent to band members are completed using the BCC function to hide other band members information.
1.3.10 Contact details of all players will be accessible by all committee members for the purposes as stated in 1.3.7
1.3.11 Band Committee data is manually inputted onto the Google Drive. This data is then used by the Committee to contact the relevant Band committee if/when required. This data is also given out to another Band Committee who wish to contact another Band Committee member directly to discuss anything relating to the band.
1.3.12 Standard Child Performance and Activities Licence Application Form (England) – information is sent to Harworth Brass email and saved into the secure “Performance Licence” folder, the sole purpose of this information is to enable us to apply for a child’s Performance licence or make amendments to current Performance licence.
1.4 How long do we plan to keep the data for? This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
1.4.1 Player data on the Google Drive is to be kept for 12 months after leaving the band.
1.4.2 Player data which is stored on New Player Registration Forms QR105 in filing cabinets is to be kept for 12 months after leaving the band. This will remain stored in the filing cabinet for 12 months, then shredded.
1.4.3 Band Committee members' data on the Google drive to be kept for 12 months after leaving the committee.
1.4.4 Band Committee members Data stored in Folder in Filing cabinet will be kept for 12 months from date of leaving the committee. This will remain in the filing cabinet for 12 months, then shredded.
Data is not shared with any external organisation for commercial purposes. However, should the player wish to remain on our “Deps” List, they can give permission for their data to be retained by Harworth Brass Band for the sole purpose of contact where a shortage of players for a concert requires a substitute player to be sought. The data will then be kept indefinitely until a request has been received in writing for their information to be destroyed. 1.5 Do we have a function/ reason for every piece of data we collect? The lawful basis for processing the personal data below is due to the legitimate interests of the organisation. It is the legitimate interest of Harworth Brass Band to request and hold information for:
● The purpose of communication throughout the band,
● Tracing of band equipment,
● Giving and communicating information
● Use in the event of an emergency should it arise. PLAYER REGISTRATIONS - VIA NEW PLAYER REGISTRATION Form QR105
● Full Name
● Date of Birth
● Postal address and postcode
● Telephone number
● Player Signature
● Band committee Signature
● Player photo
● Relevant medical information including allergies
● Next of Kin name and contact number
All of the above items of data are used to register a player to the band. CONTACT INFORMATION FOR BAND COMMITTEE MEMBERS Form QR106
● Full Name
● Date of Birth
● Postal address and postcode
● Telephone number
● Player Signature
● Band committee Signature
● Committee Member photo
● Relevant medical information including allergies
● Next of Kin name and contact number
All the above items of data are used when Harworth Brass Band Committee Members or players wish to contact the Band Committee in relation to official band information, rehearsals, meetings etc. This list is not exhaustive. In addition to the specific disclosures of personal data set out in this section, we may disclose your
personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. What is the process if someone requests what data we hold on them? You may instruct us in writing to provide you with any personal information we hold about you; provision of such information will be subject to: The supply of appropriate evidence of your identity (for this purpose, we will usually accept a visual sight of a valid passport or valid driving licence plus an original copy of a utility bill/bank statement/HMRC documentation showing your name and current address).
Where the information is in relation to a child under the age of 16 years old, it is expected to be requested by the parent/guardian, proof of identification must be of the parent and must also include visual evidence of birth certificate. We may withhold personal information that you request to the extent permitted by law. 1.6 DATA DELETION 1.6.1 PLAYER A player is only removed from the band's Player List when their registration is cancelled. This cancellation process is requested by the Band Committee and is processed by Harworth Brass Band. The player is deleted off the band's Player List on the Google Drive, but their data will remain on the Google drive for 12 months, or indefinitely if they wish to remain as part of the Deps List. The player's New Player Registration Form QR105 is moved from their band's active players section to the Cancelled players section in our secure lockable filing cabinets, where it remains for 12 months before being shredded.
1.6.2 BAND COMMITTEE A Band Committee members data is only removed in the following two instances: a) A Band Committee members current data has changed (e.g., moved to a new house) b) They have resigned from their post The committee members form QR106 is moved from their band's active committee members list section to the Cancelled committee members section in our secure lockable filing cabinets, where it remains for 12 months before being shredded.
1.7 ADMINISTRATION
1.7.1 A regular audit process is in place to ensure that the information we hold for all players and committee members remains relevant. The process for this will be as follows: at each band committee meeting a check of all information held will be completed. Any information needing to be destroyed or amended will be completed at the next band rehearsal.
1.7.2 An annual review of all band players/committee members data will be completed to ensure all information held on record are accurate and remain current.
1.7.3 Any breaches in the data held by Harworth Brass Band must be declared to the DPO as soon as it has become apparent. It will be the responsibility of the DPO to inform the person whose data has been breached and inform the ICO immediately of any breach. If any breaches should occur this should be dealt with immediately and sensitively by the DPO and they must ensure that this is fully documented on the Data Breaches form QR108 and be communicated across to the band committee members so lessons can be learned.