To operate, North Wales International Music Festival needs to gather, store and use certain forms of information about individuals. These can include members, employees, contractors, suppliers, volunteers, audiences and potential audiences, business contacts and other people the group has a relationship with or regularly needs to contact.
This policy explains how this data should be collected, stored and used in order to meet the North Wales International Music Festival data protection standards and comply with the General Data Protection Regulations (GDPR).
This policy ensures that North Wales International Music Festival:
Who and what does this policy apply to?
This applies to all those handling data on behalf of the North Wales International Music Festival e.g.:
It applies to all data that the North Wales International Music Festival holds relating to individuals, including:
North Wales International Music Festival is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for the North Wales International Music Festival is the Festival Manager, Caroline Thomas. They, together with the trustees and committee are responsible for the secure, fair and transparent collection and use of data by the North Wales International Music Festival. 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 the North Wales International Music Festival has a responsibility to ensure that they adhere to this policy.
North Wales International Music Festival uses third party Data Processors (e.g. Mail Chimp) to process data on its behalf. North Wales International Music Festival will ensure all Data Processors are compliant with GDPR.
a) We fairly and lawfully process personal data in a transparent way
North Wales International Music Festival will only collect data where lawful and where it is necessary for the legitimate purposes of the group.
b) We only collect and use personal data for specific, explicit and legitimate purposes and will only use the data for those specified purposes.
When collecting data, North Wales International Music Festival will always provide a clear and specific privacy statement explaining to the subject why the data is required and what it will be used for.
c) We ensure any data collected is relevant and not excessive
North Wales International Music Festival will not collect or store more data than the minimum information required for its intended purpose.
E.g. we need to collect telephone numbers from members in order to be able to contact them about group administration, but data on their marital status or sexuality will not be collected, since it is unnecessary and excessive for the purposes of group administration.
d) We ensure data is accurate and up-to-date
North Wales International Music Festival will ask members, volunteers and staff to check and update their data on an annual basis. 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
North Wales International Music Festival 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).
The storage and intended use of data will be reviewed in line with the North Wales International Music Festival’s data retention policy. When the intended use is no longer applicable (e.g. contact details for a member who has left the group), the data will be deleted within a reasonable period.
f) We keep personal data secure
North Wales International Music Festival will ensure that data held by us is kept secure.
g) Transfer to countries outside the EEA
North Wales International Music Festival will not transfer data to countries outside the European Economic Area (EEA), unless the country has adequate protection for the individual’s data privacy rights.
When the North Wales International Music Festival collects, holds and uses an individual’s personal data that individual has the following the rights over that data. North Wales International Music Festival 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.
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, North Wales International Music Festival will restrict the data while it is verified).
Though unlikely to apply to the data processed by North Wales International Music Festival, we will also ensure that rights related to portability and automated decision making (including profiling) are complied with where appropriate.
We only share members’ data with other members with the subject’s prior consent
As a membership organisation North Wales International Music Festival encourages communication between members.
To facilitate this:
North Wales International Music Festival will regularly collect data from consenting supporters for marketing purposes. This includes contacting them to promote performances, updating them about group news, fundraising and other group activities.
Any time data is collected for this purpose, we will provide:
Data collected will only ever be used in the way described and consented to (e.g. we will not use email data in order to market 3rd-party products unless this has been explicitly consented to).
Every marketing communication will contain a method through which a recipient can withdraw their consent (e.g. an ‘unsubscribe’ link in an email). Opt-out requests such as this will be processed within 14 days.
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.
We will implement a pop-up box on www.nwimf.com that will activate each new time a user visits the website. This will allow them to click to consent (or not) to continuing with cookies enabled, or to ignore the message and continue browsing (i.e. give their implied consent).
This policy sets out how the North Wales International Music Festival will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.
It forms part of the North Wales International Music Festival Data Protection Policy.
North Wales International Music Festival is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for North Wales International Music Festival is Caroline Thomas. They, together with the trustees and committee are responsible for the secure and fair retention and use of data by the North Wales International Music Festival. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.
A regular review of all data will take place to establish if North Wales International Music Festival still has good reason to keep and use the data held at the time of the review.
As a general rule a data review will be held every 2 years and no more than 27 calendar months after the last review. The first review will take place on the 1st January 2019.
The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.
The following criteria will be used to make a decision about what data to keep and what to delete.
|Is the data stored securely?||No action necessary||Update storage protocol in line with Data Protection policy|
|Does the original reason for having the data still apply?||Continue to use||Delete or remove data|
|Is the data being used for its original intention?||Continue to use||Either delete/remove or record lawful basis for use and get consent if necessary|
|Is there a statutory requirement to keep the data?||Keep the data at least until the statutory minimum no longer applies||Delete or remove the data unless we have reason to keep the data under other criteria.|
|Is the data accurate?||Continue to use||Ask the subject to confirm/update details|
|Where appropriate do we have consent to use the data. This consent could be implied by previous use and engagement by the individual||Continue to use||Get consent|
|Can the data be anonymised||Anonymise data||Continue to use|
Date stored by North Wales International Music Festival may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
Take the A55 towards Conwy
Leave A55 at Junction 27A (A525 Denbigh)
Continue on Chester Street into St Asaph
The Cathedral is visible from the mini roundabout at the top if Chester Street.
Pay and display car park: take FIRST exit from the mini roundabout and then first RIGHT.
From Rhyl: Take the A525 Vale Road out of Rhy and follow the signs for St Asaph (Llanelwy)
From Conwy: Take the A55 towards Chester and exit at Junction 27
Continue on the A525 (The Roe) into St Asaph
Turn LEFT at the next roundabout going over the bridge and onto the High Street
The Cathedral can be seen on the LEFT at the top of the High Street
Take the THIRD exit from the mini roundabout and then the first RIGHT for the pay and display car park.