New data protection laws, known as GDPR, mean that people have to be shown to have opted in to receive information etc from organisations, and also that any organisation, including charities such as CCS, have to ensure that all the data they hold on individuals is held for a genuine reason.
This policy ensures you are aware of what data CCS currently holds, why it holds it and for how long it is retained.
The new regulations also give people the right to see the data held on them, and to amend it or have it removed (subject to any legal requirements for it to be retained). This applies as much to CCS as any other group, and if anyone wishes to see or amend any data they can do so by contacting firstname.lastname@example.org or coming in to CCS during Saturday sessions and contacting our data protection lead Sidney Swann. All requests will be handled within a reasonable period of time (usually 48hrs excluding Sundays, but note that the office is manned irregularly during the week so this may not always be possible).
CCS has four prime sources of data:
• Registration sheets filled in when a child first joins CCS
• Standing order forms for those giving to CCS on a regular basis
• Gift Aid forms for those who donate to CCS enabling us to reclaim tax from HMRC
• Event and miscellaneous list
additionally there is specific information kept relating to staff and volunteers for wage, expenses and Child Protection administration purposes. Information on this is available on request.
We do NOT share individual data with any other organisation, though we do share aggregated data, for example a funder may need to know the age range and total numbers of boys/girls we worked with during the last year, or the total amounts we might expect to have raised from donations. Aggregated data is deemed ‘anonymous’ as no individual is identifiable from it, and is not covered by the new legislation.
All original forms are kept securely in the CCS office. The data thereon is transferred to a digital database, which is in a secure location within the Office computer.
REGISTRATION FORMS contain the following information:
Your Child -
Name, date of birth and, where appropriate, name of school/nursery
(we use these to ensure your child is in the correct group, help us plan age related material, and know if there are schools/area we could leaflet further to make CCS better known)
Your child’s health and musical background. We need to know this to be aware of any medical issues that may arise during sessions (eg epipen needed) and because funders sometimes ask about it and we are able to provide aggregated data. Musical background is useful, particularly for older children as we are able to help and encourage them where they have already learnt or begun to learn to play a particular instrument.
Your details (parent/carer)
Name, address and postcode, mobile number, email address
We need these to be able to contact you in the event of an emergency, medical or otherwise, during a session. In the first instance we would always try the mobile number(s) provided.
Data on addresses is aggregated to show funders and Southwark Council that we are reaching local children. Email addresses are used to provide you with information relating to CCS such as concert dates and details, term dates etc. You can opt out of these at any time by replying please unsubscribe to the email.
Permission for your child to be photographed during sessions; how did you hear about CCS and ethnicity details
We do take photographs and video clips during sessions, which are helpful to us in two ways (1) to look at what we’ve done and improve how we do it (2) publicity - this may be for use on our website or a leaflet, or for example, on a report back to a funder to show what we’ve done with the money they’ve given us. Where a parent/carer has ticked the no box we endeavour not to include them in photos/videos. Photos are considered as data under the new GDPR regulations.
How you heard about CCS is useful to us in gauging the effectiveness of our publicity via posters, leaflets, webpages and personal recommendations etc. Ethnicity is important for the purposes of aggregated data, as this is a statistical area that almost every funder requires information on, and also helps us to see that we are reaching a wide range of children.
REGISTRATION FORMS are generally kept for 4 CCS years, unless a child continues to be at CCS, in which instance they will be retained for a further period of time defined by their time at the project.
GIFT AID FORMS contain the following information
Your name, address including postcode, email and contact number
Name, house number and postcode are required by law to enable us to reclaim any tax paid. Email is used to contact you, for example if you require a statement of contributions for your tax return, and your phone number helps us to contact you if there is a problem.
GIFT AID FORMS are kept for a period of 6 years from the date to which they relate (ie the form for a one off donation will be kept for 6 ensuing tax years, an ongoing monthly donation will be kept until a period of 6 years has passed from the date of the last payment) This is a legal requirement by HMRC.
To help with our processing and monitoring of Gift Aid, all forms are also transferred to an electronic database which is kept securely in the office as above.
STANDING ORDER FORMS
CCS forms are in 2 parts - one relates to whether or not we are able to claim Gift Aid on your donations, and contains the same data as above, and is handled in a similar manner. The second half is the actual instruction to your bank to carry out the regular payment to our CCS account.
The data contained therein is Your bank’s name and address; your sort code and account number; the amount and frequency of payment.
Standing order forms are not recorded electronically but are copied (the original goes to your bank) and retained in a secure location in the office with Gift Aid forms, and are retained for a similar length of time.
EVENT AND MISCELLANEOUS LISTS
From time to time CCS may organise, for example, a concert for which tickets and/or donations are made. Normally the information recorded would include the person(s) name, postcode, email and a contact number to help us administer the event.. Where a donation is made and Gift Aid can be reclaimed, information will be treated as in Gift Aid above, otherwise, the list of names etc is retained for two years.
Data collected for concert etc administration is not used for emails about future events etc unless the person(s) concerned have indicated in a positive way that they so wish to be kept informed.
The above may not apply to donations to CCS via Local Giving, CAF, Virgin Money, Just Giving and other third party organisations. Each of these are required by law to have their own individual data protection/GDPR policy, so data supplied to them is not necessarily covered by CCS’s policy, but is subject to the respective organisation’s own policy.