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Data Protection and GDPR

Charity Registration Number: 294979
Policy Effective Date: July 2026
Next Review Date: July 2027
Data Protection Lead: Chair of trustees

Introduction and Purpose

As a registered charity, Havering Singers (the “Society”) needs to collect and use certain types of information about the individuals who interact with us. These include current, past and prospective choir members, audience members, donors, soloists, the musical director, accompanists and trustees.

This policy ensures that the Society complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. It outlines how we collect, handle and store personal data legally, fairly and securely.

Data Protection Principles

The Society is committed to processing data in accordance with the six core principles of GDPR. Personal data must be:

  1. Processed lawfully, fairly and transparently.
  2. Collected for specified, explicit and legitimate purposes (Purpose Limitation).
  3. Adequate, relevant and limited to what is necessary (Data Minimisation).
  4. Accurate and, where necessary, kept up to date (Accuracy).
  5. Kept in a form which permits identification for no longer than is necessary (Storage Limitation).
  6. Processed in a manner that ensures appropriate security (Integrity and Confidentiality).

Policy Review Framework and Version Control

To demonstrate compliance with the GDPR Accountability Principle, this policy must be systematically maintained and updated. Reviews fall under two categories.

Scheduled regular reviews

Triggered event reviews

This policy must be reviewed and updated outside the standard annual schedule without undue delay if any of the following occur:

Document audit trail

VersionDate of reviewName of reviewerKey changes madeNext scheduled review
v1.02 June 2026Sarah LuheshiCreation of the draft documentReview of draft
V1.17 June 2026Trevor MarlowReview of the draft documentIncorporate changes
V1.27 June 2026Sarah LuheshiFinal draftCommittee meeting
V2.020 July 2026CommitteePolicy sign-offJuly 2027

The Types of Data We Collect

To run the Choral Society effectively, we hold different categories of personal data:

Category of individualTypes of data collected
Choir membersName, address, email, telephone number, voice part (for example, soprano), subscription payment records, attendance logs, Gift Aid declarations and dates of birth or birthdays. Names and phone numbers of next of kin or emergency contacts may also be held.
AudienceName, email, phone number and ticket purchase history.
Friends of the ChoirName, address, email and possibly financial details or Gift Aid declarations.
Hired professionals and applicantsName, email, phone number, CVs, cover letters, references, bank details for paying invoices, contractual or employment agreements (for example, for Musical Directors and Accompanists), and DBS certificates for Musical Directors and Accompanists.
Guest soloistsName, email, phone number, performance biography, promotional photographs, dietary or accessibility requirements, bank details for fee payments and agent contact details where applicable.
TrusteesName, address, email and contact details, and DBS certificates.

Lawful Bases for Processing Data

We only process personal data where we have a valid lawful basis to do so:

Recruitment and Booking of Professional Musicians

When the Society recruits or books professional artistic roles, such as a Musical Director, Accompanist or Guest Soloist, we collect specific personal data to assess suitability, conduct auditions or interviews and finalise agreements.

Recruitment of the Musical Director and Accompanist

Hiring and Engagement of Concert Soloists

The Society engages independent guest soloists for public concerts, either booked directly or through professional agents.

Data Storage and Management for Hired Professionals and Soloists

Once a Musical Director, Accompanist or Soloist is formally contracted, their data is handled under strict security protocols appropriate for financial and personnel records.

Secure storage of personnel and contractor data

Ongoing retention

Practical Procedures for General Data Handling

Data storage and security

Data sharing

Individual Rights under GDPR

All individuals whose data is held by the Society, including contracted staff, soloists and job applicants, have the right to look at, correct, limit or request the complete deletion of the personal information we hold about them, subject to statutory legal holding requirements, such as financial records required by HMRC.

Data Breach Procedures

A data breach is any unauthorised access, alteration, loss or destruction of personal data, such as losing a laptop containing the member database or accidentally sending a soloist’s contract containing bank details to the wrong email recipient.

In the event of a breach, the Data Protection Lead will take immediate steps to contain it. If the breach is likely to result in a risk to individuals’ rights and freedoms, the Society will notify the Information Commissioner’s Office (ICO) within 72 hours.