CODA MUSIC TRUST DATA PROTECTION POLICY
Coda Music Trust needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organization has a relationship with or may need to contact.
Why this policy exists
This data protection policy ensures Coda Music Trust
- 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 data breach
Data protection law
The data protection act 1998 describes how companies/organisations – including Coda Music Trust – 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 Data Protection Act is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to
- The head office/music centre of Coda Music Trust
- All staff and volunteers of Coda Music Trust
- All contractors, suppliers and other people working on behalf of Coda Music Trust
It applies to all data that the organization holds relating to identifiable individuals, even if that information technically falls outside of the Data protection Act 1998. 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 Coda Music Trust 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 organisation uses data relating to them
- Reputational damage. For instance, the organization could suffer if hackers successfully gained access to sensitive data
Everyone who works for or with Coda Music Trust 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 Trustees is ultimately responsible for ensuring that Coda Music Trust meets its legal obligations
- The CEO, Phil Hallett, is responsible for:
- Keeping the board updated about data protection responsibilities, risks and reviews
- Reviewing all data protection procedures and related policies, in line with an agreed schedule
- Arranging data protection training and advice for the people covered by this policy
- Handling data protection questions from staff and anyone else covered by this policy
- Dealing with requests from individuals to see the data Coda Music Trust holds about them (also called ‘subject access requests’)
- Checking and approving any contracts or agreements with third parties that may handle the organisation’s sensitive data
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards
- Performing regular checks and scans to ensure security hardware and software is functioning properly
- Evaluating any third-party services the organization is considering using to store or process data. For instance, cloud computing services
- The Marketing Officer is responsible for:
- Approving any data protection statements attached to communications such as emails and letters
- Addressing any data protection queries from journalists or media outlets like newspapers
- Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles
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 manager
- Coda Music Trust will provide training to all employees 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 unauthorized 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
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorized 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 files should be kept in a locked drawer or filing cabinet
- Employees should make sure paper and printouts are not left where unauthorized people could see them, like 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 unauthorized 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 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 organisation’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
Personal data is of no value to Coda Music Trust unless the organization 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.
- 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.
The law requires Coda Music Trust 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 Coda Music Trust 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
- Coda Music Trust will make it easy for data subjects to update the information Coda Music Trust 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
Subject access requests
All individuals who are the subject of personal data held by Coda Music Trust are entitled to:
- Ask what information the organization 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 organisation is meeting its data protection obligations
If an individual contacts the organization requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the CEO/data controller at firstname.lastname@example.org.
The CEO/data controller will aim to provide the relevant data within 14 days
The CEO/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 Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
Under these circumstances, Coda Music Trust will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the organisation’s legal advisers where necessary.
Coda Music Trust 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 organization has a privacy statement, setting out how data relating to individuals is used by the organization.
We use IP addresses to analyses trends, administer the site, track user’s movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information. Additionally, for systems administration, detecting usage patterns and troubleshooting purposes, our web servers automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within this Company on a need-to-know basis. Any individually identifiable information related to this data will never be used in any way different to that stated above without your explicit permission.
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Notification of Changes
Coda Music reserves the right to change these terms and conditions from time to time as it sees fit and your continued use of the site will signify your acceptance of any adjustment to these terms. You are therefore advised to re-read this statement on a regular basis.