GDPR FOR Allen Valleys Community Arts

REGARDING ALLEN VALLEYS FOLK FESTIVAL

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Following recent legislation, please view our privacy and data protection policies here. 

 

Download Privacy Policy | Download Data Protection Policy

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Data protection policy

 

Introduction

Allen Valleys Community Arts (AVCA) is the organisation responsible for running the Allen Valleys Folk Festival (AVFF) and other local events. The company needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, staff, volunteers and other people the organisation has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

 

Why this policy exists

This data protection policy ensures Allen Valleys Community Arts:

• Complies with data protection law and follow good practice 

• Protects the rights of staff, customers and partners

• Is open about how it stores and processes individuals’ data

• Protects itself from the risks of a data breach

 

Data protection law

The General Data Protection Regulation describes how organisations — including AVCA - must collect, handle and store personal information. 

 

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

The Regulation is underpinned by eight important principles. These say that personal data must:

1. Be processed fairly and lawfully

2. Be obtained only for specific, lawful purposes

3. Be adequate, relevant and not excessive

4. Be accurate and kept up to date

5. Not be held for any longer than necessary

6. Processed in accordance with the rights of data subjects

7. Be protected in appropriate ways

8. Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection

 

Policy scope

This policy applies to all staff and volunteers of AVCA and all contractors, suppliers and other people working on behalf of AVFF. It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:

• Names of individuals

• Postal addresses

• Email addresses

• Telephone numbers

• …plus any other information relating to individuals

 

Data protection risks

This policy helps to protect AVCA from some very real data security risks, including:

• Breaches of confidentiality. For instance, information being given out inappropriately.

• Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.

• Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.

 

Responsibilities

Everyone who works for or with AVCA has some responsibility for ensuring data is collected, stored and handled appropriately.

Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles. 

 

However, these people have key areas of responsibility:

• The board of directors is ultimately responsible for ensuring that AVCA meets its legal obligations.

• Peter Aldcroft is responsible for:

o Keeping the board updated about data protection responsibilities, risks and issues.

o Reviewing all data protection procedures and related policies, in line with an agreed schedule.

o Arranging data protection training and advice for the people covered by this policy.

o Handling data protection questions from staff and anyone else covered by this policy.

o Dealing with requests from individuals to see the data AVCA holds about them (also called ‘subject access requests’).

o Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

· Tim Reed is responsible for:

o Ensuring all systems, services and equipment used for storing data meet acceptable security standards.

o Performing regular checks and scans to ensure security hardware and software is functioning properly.

o Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.

 

General staff guidelines

• The only people able to access data covered by this policy should be those who need it for their work.

• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.

• AVCA will provide training to all staff to help them understand their responsibilities when handling data.

• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.

• In particular, strong passwords must be used and they should never be shared.

• Personal data should not be disclosed to unauthorised people, either within the company or externally.

• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.

 

Data storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager.

 

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

• When not required, the paper or files should be kept in a locked drawer or filing cabinet.

• Employees should make sure paper and printouts are not left where unauthorised people could see them, eg on a printer.

• Data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:

• Data should be protected by strong passwords that are changed regularly and never shared between employees.

• If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.

• Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.

• Servers containing personal data should be sited in a secure location, away from general office space.

• Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.

• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.

• All servers and computers containing data should be protected by approved security software and a firewall.

 

Data use

Personal data is of no value to AVCA unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:

• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.

• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.

• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.

• Personal data should never be transferred outside of the European Economic Area.

• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

 

Data accuracy

The law requires AVCA to take reasonable steps to ensure data is kept accurate and up to date.

The more important it is that the personal data is accurate, the greater the effort AVCA should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible. 

• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.

• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.

• AVCA will make it easy for data subjects to update the information AVFF holds about them. For instance, via the company website.

• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.

• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

 

Subject access requests

All individuals who are the subject of personal data held by AVCA are entitled to:

• Ask what information the company holds about them and why.

• Ask how to gain access to it.

• Be informed how to keep it up to date. 

• Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request. 

Subject access requests from individuals should be made by email, addressed to the data controller at peteraldcroft@gmail.com. The data controller will aim to provide the relevant data within 14 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

 

 

Disclosing data for other reasons

In certain circumstances, the GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.

Under these circumstances, AVCA will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

 

Providing information

AVP aims to ensure that individuals are aware that their data is being processed, and that they understand:

• How the data is being used

• How to exercise their rights 

To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.

This is available on request. A version of this statement is also available on the company’s website.

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Privacy statement

 

Allen Valleys Community Arts Ltd ("we", “AVCA”) regard your privacy as important and we comply with the current law.  The Data Protection Act 1998 ("DPA") applies to any personal data that we process, and from 25th May 2018 this will be replaced by the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 ("DPA 2018") (together "data protection laws").  We will only use any personal information you send us for the purposes for which you provide it, or where allowed by law. We will only hold your information for as long as necessary for these purposes and will not pass it to any other parties unless this is made clear to you. All AVFF committee members or volunteers who have access to your personal data or are associated with the handling of that data are obliged to respect the confidentiality of your personal data.

 

Topics covered in this Privacy Notice

 

• Who we are and who is responsible for data privacy

• Our purpose in holding your personal data

• The categories of data that we hold

• Sharing your data with third parties

• Our lawful basis for processing that data

• Our legitimate interests in processing that data

• Your rights in respect of the data we hold

• Transferring your data to other countries for storage or processing

• How long we hold your data for

• The consequences should you choose to withhold data or ask us to remove it from our records

• Whether we use automated decision making

 

Who we are and who is responsible for data privacy

 

The principal responsibility of Allen Valleys Community Arts is to organise an annual festival of folk music in the Allen Valleys.  Our members and our website support that continuing work.  We are the 'data controller' of personal data and we take that responsibility very seriously.  We do not use any third parties as 'data processors'.

 

Our contact address and email is:

 

Appletree house NE47 9BP.

peteraldcroft@gmail.com

 

Our Chairman Peter Aldcroft is responsible for Data Privacy within AVCA.  He can be contacted via the address and email above.  If the matter is urgent please provide a telephone number and he will telephone you if possible.

 

Our purpose in holding your personal data

 

We hold personal data for our officers and for those who wish to be informed about our activities either as potential performers or audiences at our events.

 

We hold limited other basic contact information for those with whom we work on a variety of folk festival related issues such as promoters and organisers of other folk festivals..

 

The categories of data that we hold

 

We hold your name and contact details, including your telephone number and email address where you have provided these.  

 

All information you provide to us is stored on our secure computers and access is limited to our chairman and secretary. Everyone is required to abide by our Data Protection Policy. 

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

We do not gather any personal information through our website other than that required for us to maintain communication with you.  We do not collect IP addresses, we do not use cookies and we do not use any type of data analytic on the website.

 

Sharing your data with third parties

 

We will share your data with our insurers in the event that a claim is made against us which is covered by our insurance poilicy and in which the details of a data subject are relevant.

 

Our lawful basis for processing that data

 

Our lawful basis for processing the personal data of our performers and enquirers is the legitimate interests of Allen Valleys Community Arts.

 

 

Our legitimate interests in processing that data

 

We have carried out a Legitimate Interest Assessment and concluded that we cannot meet the needs and expectations of our members unless we process their personal data.  The Legitimate Interest Assessment is available on request.

 

Your rights in respect of the data we hold

 

You have the following rights in relation to your personal information: 

• the right to be informed about how your personal information is being used;

• the right to access the personal information we hold about you; 

• the right to request the correction of inaccurate personal information we hold about you; 

• the right to request the erasure of your personal information in certain limited circumstances;

• the right to restrict processing of your personal information where certain requirements are met; 

• the right to object to the processing of your personal information;

• the right to request that we transfer elements of your data either to you or another service provider; and

• the right to object to certain automated decision-making processes using your personal information. 

 

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.  For example, we do not use automated decision making in relation to your personal data.  However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

 

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner's website at https://ico.org.uk/for-the-public/.

 

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Who we are" section above.

 

If you are unhappy with the way we are using your personal information, you can also complain to the UK Information Commissioner's Office or your local data protection regulator.  We are here to help and encourage you to contact us to resolve your complaint first.

 

Transferring your data to other countries for storage or processing

 

We do not transfer your data to countries outside the European Economic Area (EEA) for processing including storage.  If the data is held on "Cloud servers" it will only be done where there is a binding agreement with the relevant data authorities to regulate this in line with the data protection laws. 

 

How long we hold your data for

 

Since the Folk Festival is an annual event, we hold your data for as long as we believe there will continue to be such an event. If we decide there will be no more events, your data will be permamently deleted.

 

The consequences should you choose to withhold data or ask us to remove it from our records

 

If you do not agree to our processing of your personal data, we may not be able to inform you of current and future events which we promote and other information which we believe will be of interest to you..

 

Whether we use automated decision making

  

We do not use any automated decision-making tools in any of our processing.

 

The management of data protection in AVCA.

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The current nominee is Peter Aldcroft, our inaugural chairman, who can be contacted by email. We will respond to any request within 14 days.