Documents
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Sturminster Newton Orchestra
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CONSTITUTION
Revised and updated April 2024
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Short history and introduction
The orchestra was formed as an Orchestral Society in April 1990 by a
group of musicians from Sturminster Newton and the surrounding area.
In 1998 its title was changed to Orchestra Workshop to reflect its
purpose as a teaching orchestra. However, as the orchestra developed
and expanded, it was decided in 2004 to change the name again to the
current Sturminster Newton Orchestra.
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1. Name
The name of the orchestra is Sturminster Newton Orchestra, referred
to as ‘the orchestra’ throughout the document.
2. Aims/purpose
The aims of the orchestra are:
a. To provide opportunities for musicians to participate in regular
group music-making in an informal atmosphere which teaches,
encourages, challenges, develops their playing, and also
enhances and broadens personal musical experiences.
b. To advance, improve, develop and maintain public education in,
and appreciation of, music in all its aspects, by any means the
committee see fit, including public concerts in a variety of musical
styles and periods.
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3. Membership
a. The orchestra does not conduct auditions and welcomes young
people, students and more mature musicians, irrespective of
their background and experience. A skill level minimum Grade 2
is recommended, but not essential.
b. All aspects of running the orchestra will be governed and
managed by a committee of no less than four individuals, which
must include chairperson, treasurer, and secretary. The Director
of Music will also attend if appropriate. (see 4 below).
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4. The Committee
a. Committee members, other than the Director of Music, must be
paid-up members of the orchestra, and have voting rights.
b. Any member of the orchestra can be appointed to the
committee by a vote of the members at the appropriate time –
normally the Annual General Meeting (AGM).
c. The Committee shall consist of no more than ten (10) members
of the orchestra. These will include: chairperson, treasurer,
secretary, librarian, webmaster, publicity secretary, membership
secretary, safeguarding officer, orchestral leader. NB: these
roles can be combined if required. If there is a vacancy, any
member of the orchestra may be co-opted to attend, at the
committee’s discretion, as an ‘invited attendee’ – this to be
reviewed annually before the AGM.
d. The Director of Music may not necessarily be a committee
member but may attend meetings which are appropriate and
relevant. However, the committee will decide as to whether
he/she should or should not attend meetings involving decisions
relating to their role. This includes, but is not limited to:
performance in their role, contract negotiations and payment.
e. Committee members will serve on an annual basis, which can
be renewed at the AGM.
f. Committee members can be removed if (i) they cease to be
members of the orchestra (ii) they resign in writing (iii) they are
absent without notification from all committee meetings held
within a twelve month period (iv) a two-thirds majority of the
committee feel it is the best interests of the orchestra, in which
case the member must be given at least 21 days written notice
of the meeting where the issue is to be discussed. Any decision
to remove must be communicated to the committee member in
writing within 7 days of the meeting.
g. The Committee has the power to terminate the membership of
any individual in the orchestra, provided that the decision of the
Committee (with the exception of the individual concerned if a
member of the Committee, and any member of the Committee
making or connected with the complaint against the individual)
is unanimous both as to the termination and as to there being
good reason for it, and provided that the individual concerned
shall have the right to be heard by the Committee, accompanied
by a friend if desired, before a final decision is made.
h. No committee member will be paid for their role, except for
necessary expenses in connection with the orchestra, except
the Director of Music.
i. Committee members must declare any conflict of interests or
loyalties between themselves and the orchestra.
j. The committee has ultimate legal responsibility for the
orchestra.
5. Meetings and proceedings of the committee
a. The committee will meet at least once a term.
b. Any committee member can request the chairperson call a
meeting additional to the minimum. If requested, the
chairperson must call a meeting within 30 days.
c. A minimum of four members, to include the chairperson, will
form the necessary quorum for committee meetings and no
decisions can be made without a quorum present.
d. All decisions shall be made by a majority vote of those present
at the committee meeting.
e. Minutes of all committee meetings will be kept by the secretary
and shared with the committee as soon as possible after the
meeting.
f. The committee may make collective decisions by email if
required, with the exception of financial matters. Any such
decisions must be reported and minuted at the next committee
meeting.
6. Rules/Powers
a. The committee can establish rules and procedures outside of
this document to assist with the day to day running of the
orchestra, in furtherance of its aims and purpose. This may
include, but is not limited to:
i. raising funds and inviting contributions, provided that in
doing so, no substantial permanent trading activities are
undertaken.
ii. buying, leasing or exchanging any property of the
orchestra felt necessary to aid its advancement.
iii. co-operating with other orchestras of similar purpose and
exchanging information and advice with them.
b. Nothing in any rules or procedures will contradict anything in
this document.
7. Repertoire
The musical direction of the orchestra is vested in the Director of
Music, who, along with the Leader of the Orchestra, makes
recommendations as to the purchase of new sheet music, and selects
the music to be played at each concert. Individual members are
always welcome to make suggestions and a full list of available items
can be found on the orchestra’s website –
www.sturminsternewtonorchestra.com
8. Finance
a. The financial year shall end on 31st March.
b. The orchestra is entirely self-financing. There is no joining fee, but
members are required to pay a termly subscription, reviewed
termly at a Committee meeting. This will cover regular outgoings
such as, but not exclusively, the weekly hire of rehearsal premises
and payments to the Director of Music (whose terms and
conditions will be reviewed annually and recorded). In cases of
financial hardship, members are asked to make personal contact
with the chairperson or secretary to discuss possible alternative
arrangements.
c. (i) A bank account will be held in the name of the orchestra. All
payments must be authorised by two committee members, who
shall normally be the chairperson and treasurer.
(ii) A cash account balance up to £50 can be held by the treasurer,
who can make payments from this of up to £25 at his/her
discretion. Higher sums should be confirmed by one other account
signatory. Receipts must be obtained for all such cash payments
and all payments and receipts to be recorded in a petty cash
account log, which should be reviewed periodically by one other
account signatory.
d. The orchestra is a not-for-profit orchestra and any income and
property of the orchestra will be applied solely towards promoting
the aims of the orchestra, as set out in this document.
e. The distribution of profits and assets among its members is
expressly prohibited.
f. Payment of legitimate expenses is allowed. Also, any ‘gifts of
appreciation’ for tasks performed ‘beyond the normal call of duty’ at
the Committee’s discretion.
9. Accounts
a. The financial accounts will be prepared after each financial year by
the Treasurer and audited by a person who is independent of the
Committee.
b. The accounts will be presented at the AGM.
10. Annual General Meeting (AGM)
a. An AGM will be held every twelve months, to which all members
will be invited to attend by email from the secretary or
chairperson, at least one month prior to the meeting.
b. The agenda will include the following recurring items:
i. Apologies for absence
ii. Minutes of the previous AGM
iii. Accounts for the previous financial year
iv. Written reports from the chairperson, treasurer and
Director of Music. Other committee members may report if
appropriate.
c. Election/re-election of committee members. All committee
members are automatically considered for re-election unless
they have notified the secretary in advance of the meeting. Any
volunteers to fill a vacancy must be proposed and seconded.
The election will be conducted by a show of hands at the
meeting.
d. Any member wishing to raise a matter at the AGM must do so in
writing to the secretary at least three weeks before the meeting,
in order that the committee has time to consider any response.
e. The secretary (or other person appointed by the committee)
shall keep a full record of the proceedings and distribute this to
all members within one month of the meeting.
11. Insurance
a. The orchestra is insured against third party liability and personal
accidents at rehearsals and concerts through the umbrella
orchestra “Making Music”. This insurance also includes
orchestral property such as percussion instruments and the
large library of sheet music.
b. The insurance of personal instruments and belongings is a
matter for each individual member of the orchestra, who is
advised to identify such on their household contents insurance.
12. Modifications to this Constitution
No alteration or addition to this Constitution may be made except by a
resolution carried by a majority of at least two-thirds of the members
present at the AGM (or an Extraordinary General meeting - EGM).
13. Dissolution
In the event of the orchestra being wound up, any assets remaining
after the payments of debts and liabilities will be donated to a not-for-
profit orchestra with similar musical objectives to the orchestra. This
will be decided by the committee. No remaining assets will be
distributed to members.
ADDENDUM
The following policies are to be attached to this Constitution and will also
be available on the orchestra’s website:
• Data Protection policy and Privacy Notice
• Equality, Diversity and Inclusion policy
• Health and Safety policy
• Safeguarding policy
• Potential Conflict of Interest policy
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Sturminster Newton Orchestra
Safeguarding Policy
Published June 2017
Updated August 2019 (updated terminology from ‘vulnerable adults’ to ‘adults at risk’, updated About this policy section to add definition of adults at risk).
Safeguarding Policy – Sturminster Newton Orchestra – overview
Commitment to safeguarding: Sturminster Newton Orchestra believes that a child, young person or adult at risk should never experience abuse of any kind. We recognise that we have a responsibility to promote the welfare of all children, young people and adults at risk. We are committed to safeguarding the well-being of all children, young people and adults at risk we come into contact with and to protecting them from harm.
About this policy
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This policy applies to; all members, staff (whether employees or freelances), volunteers and anyone working on behalf of Sturminster Newton Orchestra or taking part in Sturminster Newton Orchestra activities.
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The purpose of this policy is to provide members, staff and volunteers with the overarching principles that guide our approach to the protection of all vulnerable people
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This policy recognises vulnerable people as:
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Children up to the age of 16 or young people aged 16-18.
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Adults aged over 18 at risk as defined by the Safeguarding Vulnerable Groups Act 2006. This might include adults with a learning or physical disability, a physical or mental illness, chronic or otherwise, including an addiction to alcohol or drugs, or reduced physical or mental capacity. This policy also recognises risk is determined by the activity an adult is taking part in and not solely on the personal characteristics or circumstances of the adult, as such any adult can be at risk, and the risk can be temporary.
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This policy aims to:
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Protect children, young people and adults at risk who are; members of, receive services from, or volunteer for, Sturminster Newton Orchestra.
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Ensure members, staff and volunteers working with children, young people and adults at risk are carefully recruited and understand and accept responsibility for the safeguarding of those vulnerable individuals they are interacting with.
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Ensure that safeguarding of children, young people and adults at risk is a primary consideration when Sturminster Newton Orchestra undertakes any activity, event or project.
How Sturminster Newton Orchestra might work with vulnerable people:
Membership is open to those over 16 years of age.
We run regular rehearsals for members and put on concerts for the general public. As such our involvement with vulnerable people might include, but is not limited to:
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Members of the group who attend rehearsals and concerts
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Relatives and friends of members who attend rehearsals and concerts in a volunteering capacity
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Audience members at public concerts
Named safeguarding person: Sally Bedborough has responsibility for safeguarding issues. All queries and concerns relating to safeguarding should be referred to Sally Bedborough in the first instance. If Sally Bedborough is unavailble, any queries or concerns must be raised to Deputy Safeguarding Leads, Justine Henry or Rosie Nye.
Any projects, events or other activities that will involve vulnerable people must be planned with the involvement of Sally Bedborough and in line with established procedures and ground rules (see below).
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Procedures and ground rules: A further document – ‘Ground rules, ways of working and procedures’ is available and forms part of this policy.
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Policy review: This policy will be reviewed and amended (if necessary) on an annual basis by the Sturminster Newton Orchestra Committee. It will also be reviewed in response to changes in relevant legislation, good practice, or in response to an identified failing in its effectiveness.
Safeguarding policy – Sturminster Newton Orchestra -
Ground rules, ways of working and procedures
This document forms part of the Sturminster Newton Orchestra Safeguarding policy
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The policy applies to; all members, staff (whether employees or freelances), volunteers and anyone working on behalf of Sturminster Newton Orchestra or taking part in Sturminster Newton Orchestra activities.
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The policies purpose of this policy is to provide members staff and volunteers with the overarching principles that guide our approach to the protection of vulnerable people.
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This policy recognises vulnerable people as:
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Children up to the age of 16 or young people aged 16-18.
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Adults aged over 18 at risk including those defined as vulnerable by the Safeguarding Vulnerable Groups Act 2006; this might include adults with a learning or physical disability, a physical or mental illness, chronic or otherwise, including an addiction to alcohol or drugs, or reduced physical or mental capacity.
This document includes:
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Recruitment practices around safeguarding
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Ground rules and ways for working regarding safeguarding of vulnerable people
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Procedures for raising safeguarding concerns and incidents of abuse
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Procedures for dealing with concerns and incident of abuse
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Recruitment practices around safeguarding:
If an existing or potential new member, staff member or volunteer will be working with vulnerable people as part of the Sturminster Newton Orchestra activities the appropriate level of DBS will be requested before that work is undertaken.
The level of DBS check required will be decided by the committee and in line with DBS rules regarding regulated activity. The results of any check to inform a decision will be used confidentially and in line with the Sturminster Newton Orchestra equal opportunities policy.
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Ground rules and ways for working regarding safeguarding of vulnerable people:
When Sturminster Newton Orchestra organises an activity or event where they will be responsible for vulnerable people they will ensure:
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Planning is carried out in line with this policy and procedures.
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The event is attended by an appropriate number of DBS checked adults – this will be a minimum of one but more when practically possible.
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Where practically possible the total number of adults in attendance (not necessarily DBS checked) compared with the total number of children will be in line with the ratio table below - as per Ofsted recommendations.
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There is a main contact for safeguarding on the day - this will be an individual who has been DBS checked.
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The main contact has access to emergency contact details and other relevant details (e.g. information about picking up arrangements for vulnerable people).
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That if vulnerable people of different gender will be taking part in activities adults of different gender will be in attendance too.
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A vulnerable person is not be left alone with an adult, unless that adult is DBS checked and carrying out regulated activity.
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Two adults (one DBS checked) should be the last to leave a venue once the activity has finished and will be responsible for ensuring vulnerable people get home safely.
Child to adult ratio table
Childs age Number of adults Number of children
0-2 1 3
2-3 1 4
4-8 1 6
9-12 1 8
12-18 1 10
Working with parents/guardians: If a vulnerable person wishes to take part in Sturminster Newton Orchestra activities written permission (email is fine) should be obtained from parents/guardians where appropriate, and before the activity takes place. Written permission should include: emergency contact details of any relevant pick-up arrangements – including permission for another adult to pick up the vulnerable person after the activity has finished.
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Procedures for raising safeguarding concerns and incidents of abuse:
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If any member, staff or volunteer in Sturminster Newton Orchestra witnesses, suspects or is informed of a witnessed or suspected case of abuse they should immediately report it to the named safeguarding officer; Sally Bedborough, Justine Henry or Rosie Nye.
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If the named person is not available, or is involved in or connected to, the abuse, it should be reported to the group chair Rosie Nye or a DBS checked adult: Rosie Nye, Sally Bedborough.
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If an individual wishes to report an incident of abuse against themselves they should report it to the named safeguarding officer or an individual they trust.
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Procedures for dealing with concerns and incidents of abuse:
The Named person (or person reported in their absence) will first make a decision based on the immediacy of the concern and the following two factors:
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If the vulnerable person is in immediate danger or needs emergency medical attention – call the police and/or ambulance service.
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If the person at the centre of the allegation is working with vulnerable persons at the current time – remove them, in a sensitive manner, from direct contact with vulnerable people and follow the procedures below.
If none of the above applies the named person will:
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Make a note of the concerns reported to them.
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Speak with committee members to decide how to handle the reported abuse. Excluding any committee members who of involved in the incident.
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Escalate the report by either:
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Raising concerns with the police – for serious or possible criminal offences.
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Requesting an assessment by the local authority social care department about whether a vulnerable person is in need of protection.
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An internal investigation – for less serious incidents where they feel internal mediation will be successful.
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Where cases are escalated the committee will cooperate with the police or local authority in dealing with the reported incident.
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Where an internal investigation takes place the committee will:
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Inform all parties involved of the reported abuse as soon as possible.
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Inform the family/guardians of the person reported as being been abused of the incident.
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Arrange separate meetings with both parties within 10 days of the reported incident. A joint meeting may be arranged if appropriate.
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Both parties should be given the chance to bring a friend or representative to the meeting.
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Meetings will be attended by the named safeguarding officer and at least one other committee member.
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All parties will also be invited to submit a written statement in advance of the meeting.
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Once meetings have taken place the committee will decide on next steps and communicate them to all parties in writing within 5 days. They will be either:
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Escalate the incident to the relevant authority.
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Further investigation – with established procedures and timelines to work towards a resolution.
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A decision or resolution.
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Resolution and disciplinary action:
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If abuse is found to have taken place any final resolution or decision will be taken in the best interest of the person who has suffered the abuse and the best interests the Sturminster Newton Orchestra.
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Any disciplinary action will be taken in line with the Sturminster Newton Orchestra constitution.
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​Sturminster Newton Orchestra
Potential Conflict of Interest Policy
Published June 2017
Updated Sep 2018
This policy applies to all Commitee Members of Sturminster Newton Orchestra.
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A ‘conflict of interest’ arises when the best interests of an individual Committee Member are, or could be, different from the best interests of the Sturminster Newton Orchestra itself.
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The Committee acknowledge that it is inevitable that conflicts of interest will occur. They are however committed to managing these potential conflicts in order to protect both the Sturminster Newton Orchestra and the Committee Member from any impropriety or appearance of impropriety.
Statement of Intent
Sturminster Newton Orchestra is committed to ensuring its decisions and decision-making processes are, and are seen to be, free from personal bias and do not unfairly favour any individual connected with the Sturminster Newton Orchestra.
Policy
It is the policy of Sturminster Newton Orchestra to:
•Ensure every Committee Member understands what constitutes a conflict of interest and that they have a responsibility to recognise and declare any conflicts that might arise for them.
•Document the conflict and the action(s) taken to ensure that the conflict does not affect the decision making of the orchestra.
Procedure
When a Committee Member identifies that they have a potential conflict of interest they must:
•Declare it as soon as they become aware of it.
•Ensure it is entered in the conflict of interest register (ongoing conflicts), and/or appropriately minuted (one-off conflicts).
•Not take part in any Committee discussions relating to the matter.
•Not take part in any decision making related to the matter.
•Not be counted in the quorum for decision making related to the matter. In the interests of frank and open discussion, a Committee Member affected by a conflict of interest must leave the room while related discussion / decision making is taking place, unless there is good reason for them to stay.
The minutes should state:
•The declared conflict.
•That the Committee Member left the room, or the reason they were asked to stay.
•That the Committee Member took no part in discussion or decision making on the matter.
•That the meeting was quorate (not counting the affected Committee Member).
•Any other actions taken to manage the conflict.
If a Committee Member is unsure what to declare, they should err on the side of caution and discuss the matter with the Chair of the Committee of Sturminster Newton Orchestra for confidential guidance.
Policy adopted on [insert date]
ANNUAL COMMITTEE MEMBER CONFLICT OF INTEREST DECLARATION
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Name of organisation: Sturminster Newton Orchestra
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Name of [COMMITTTEE MEMBER]:
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Date conflict of interest identified (put n/a if no conflict identified):
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Details of conflict: e.g.
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•being paid to carry out work or services for Sturminster Newton Orchestra
•being the direct or indirect beneficiary of a contract entered into by Sturminster Newton Orchestra (e.g. your partner works for the contractor)
•other directorships or trusteeships which could create a conflict of loyalty (e.g. trustee of a community building used for rehearsals)
•being the recipient of a gift in excess of £50
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This is not an exhaustive list, but just gives some examples relevant to Sturminster Newton Orchestra Committee Members. Essentially, they can be summarised as: benefits to Committee Members or a person related to them; or conflicts of loyalty; For more information, please see the Charity Commission’s guidance: https://www.gov.uk/government/publications/conflicts-of-interest-a-guide-for-charity-trustees-cc29/conflicts-of-interest-a-guide-for-charity-trustees
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Who does it relate to? (e.g. self, connected person – please specify)
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How was it notified? (e.g. verbal at Board meeting, letter, annual declaration)
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Committee Member signature:
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Date of signature:
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Conflict of Interest Register for Committee Members
Sturminster Newton Orchestra
Date identified Name of Committee members Details of conflict Who does it relate to? How notified*Action taken**Follow up needed? (Y/N)End date conflict/currentReason for resolution***1
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Sturminster Newton Orchestra
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Data Protection Policy
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Version history:
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Published: March 2018
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Updated: September 2018 – addition of Data breach clauses
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Key details
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Policy prepared by: Rosie Nye
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Approved by Board/committee on:
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Next review date:
Introduction
In order to operate, Sturminster Newton Orchestra 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 Sturminster Newton Orchestra data protection standards and comply with the General Data Protection Regulations (GDPR).
Why is this policy important?
This policy ensures that Sturminster Newton Orchestra;
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Protects the rights of our members, volunteers and supporters
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Complies with data protection law and follows good practice
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Protect the group from the risks of a data breach
Who and what does this policy apply to?
This applies to all those handling data on behalf of Sturminster Newton Orchestra e.g.:
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Committee members
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Employees and volunteers
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Members
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Contractors/3rd-party suppliers
It applies to all data that Sturminster Newton Orchestra holds relating to individuals, including:
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Names
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Email addresses
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Postal addresses
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Phone numbers
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Any other personal information held (e.g. financial)
Roles and responsibilities
Diana Harris is the Data Controller and will determine what data is collected and how it is used. The Data Protection Officer for Sturminster Newton Orchestra is Diana Harris. They, together with the Chair, are responsible for the secure, fair and transparent collection and use of data by Sturminster Newton Orchestra. 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 Sturminster Newton Orchestra has a responsibility to ensure that they adhere to this policy.
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We fairly and lawfully process personal data in a transparent way
Sturminster Newton Orchestra will only collect data where lawful and where it is necessary for the legitimate purposes of the group.
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A member’s data will be collected when they first join the group, and will be used to contact the member regarding group membership administration and activities. Other data may also subsequently be collected in relation to their membership, including their payment history for ‘subs’. Where possible Sturminster Newton Orchestra will anonymise this data
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Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Sturminster Newton Orchestra, completing tasks expected as part of the individual’s membership).
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The name and contact details of volunteers, employees and contractors will be collected when they take up a position, and will be used to contact them regarding group administration related to their role.
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Further information, including personal financial information and criminal records information may also be collected in specific circumstances where lawful and necessary (in order to process payment to the person or in order to carry out a DBS check).
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Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Sturminster Newton Orchestra completing tasks expected as part of working with the individuals),
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An individual’s name and contact details will be collected when they make a booking for an event. This will be used to contact them about their booking and to allow them entry to the event.
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Lawful basis for processing this data: Contract (the collection and use of data is fair and reasonable in relation to Sturminster Newton Orchestra completing tasks expected as part of the booking),
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An individual’s name, contact details and other details may be collected at any time (including when booking tickets or at an event), with their consent, in order for Sturminster Newton Orchestra to communicate with them about and promote group activities. See ‘How we get consent’ below.
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Lawful basis for processing this data: Consent (see ‘How we get consent’)
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Pseudonymous or anonymous data (including behavioural, technological and geographical/regional) on an individual may be collected via tracking ‘cookies’ when they access our website or interact with our emails, in order for us to monitor and improve our effectiveness on these channels. See ‘Cookies on the Sturminster Newton Orchestra website’ below.
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Lawful basis for processing this data: Consent (see ‘How we get consent’)
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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, Sturminster Newton Orchestra 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.
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We ensure any data collected is relevant and not excessive
Sturminster Newton Orchestra 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.
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We ensure data is accurate and up-to-date
Sturminster Newton Orchestra 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.
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We ensure data is not kept longer than necessary
Sturminster Newton Orchestra 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 Sturminster Newton Orchestra 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.
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We keep personal data secure
Sturminster Newton Orchestra will ensure that data held by us is kept secure.
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Electronically-held data will be held within a password-protected and secure environment
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Passwords for electronic data files will be re-set each time an individual with data access leaves their role/position
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Physically-held data (e.g. membership forms or email sign-up sheets) will be stored in a locked cupboard
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Keys for locks securing physical data files should be collected by the Data Protection Officer from any individual with access if they leave their role/position. The codes on combination locks should be changed each time an individual with data access leaves their role/position
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Access to data will only be given to relevant trustees/committee members/contractors where it is clearly necessary for the running of the group. The Data Protection Officer will decide in what situations this is applicable and will keep a master list of who has access to data
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Transfer to countries outside the EEA
Sturminster Newton Orchestra 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.
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When Sturminster Newton Orchestra collects, holds and uses an individual’s personal data that individual has the following the rights over that data. Sturminster Newton Orchestra 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.
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Individual’s rights
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Right to be informed: whenever Sturminster Newton Orchestra collects data it will provide a clear and specific privacy statement explaining why it is being collected and how it will be used.
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Right of access: individuals can request to see the data Sturminster Newton Orchestra holds on them and confirmation of how it is being used. Requests should be made in writing to the Data Protection Officer and will be complied with free of charge and within one month. Where requests are complex or numerous this may be extended to two months
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Right to rectification: individuals can request that their data be updated where it is inaccurate or incomplete. Sturminster Newton Orchestra will request that members, staff and contractors check and update their data on an annual basis. Any requests for data to be updated will be processed within one month.
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Right to object: individuals can object to their data being used for a particular purpose. Sturminster Newton Orchestra will always provide a way for an individual to withdraw consent in all marketing communications. Where we receive a request to stop using data we will comply unless we have a lawful reason to use the data for legitimate interests or contractual obligation.
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Right to erasure: individuals can request for all data held on them to be deleted. Sturminster Newton Orchestra data retention policy will ensure data is not held for longer than is reasonably necessary in relation to the purpose it was originally collected. If a request for deletion is made we will comply with the request unless:
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There is a lawful reason to keep and use the data for legitimate interests or contractual obligation.
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There is a legal requirement to keep the data.
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, Sturminster Newton Orchestra will restrict the data while it is verified).
Though unlikely to apply to the data processed by Sturminster Newton Orchestra, 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 Sturminster Newton Orchestra encourages communication between members.
To facilitate this:
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Members can request the personal contact data of other members in writing via the Data Protection Officer or Membership Secretary. These details will be given, as long as they are for the purposes of contacting the subject (e.g. an email address, not financial or health data) and the subject has consented to their data being shared with other members in this way
Sturminster Newton Orchestra 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:
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A method for users to show their positive and active consent to receive these communications (e.g. a ‘tick box’)
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A clear and specific explanation of what the data will be used for (e.g. ‘Tick this box if you would like Sturminster Newton Orchestra to send you email updates with details about our forthcoming events, fundraising activities and opportunities to get involved’)
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.
Sturminster Newton Orchestra takes any breach of data seriously. A data breach could be the deliberate or accidental:
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Loss of data – e.g. not knowing where physical or digital data is stored or how to access it, including devices being lost or stolen.
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Destruction of data – both physical and digital
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Corruption of data – e.g. changing data without permission or good reason or changing it with permission or good reason but incorrectly, either by Sturminster Newton Orchestra staff, volunteers or third parties
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Unauthorised use of data e.g. sending an email that requires consent where consent has not been given.
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Unauthorised access to data – e.g. an (unauthorised) third party gains access to data stored by Sturminster Newton Orchestra.
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Unauthorised disclosure of data – e.g. Sturminster Newton Orchestra passing data to a third party where we do not have a lawful basis to do so.
Sturminster Newton Orchestra acknowledges that a data breach can occur through both action and inaction on the part of the Data Controller or Processor.
How we prevent Data breaches
Sturminster Newton Orchestra has the following safeguards to ensure against possible data breaches:
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Data is stored on secure systems with access controlled by passwords
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Automatic, and manual, processes ensure passwords are updated on a regular basis, including as soon as an individual’s role within, or relationship to, Sturminster Newton Orchestra, changes.
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Automatic, and manual, processes ensure mass communications are only sent in line with mailing preferences.
If a Data breaches occurs
If anyone associated with Sturminster Newton Orchestra thinks a data breach has occurred then it should be reported to the Data Protection Officer immediately.
The Data Protection Officer will work with relevant individuals to investigate the potential breach. The response plan will include the following steps:
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Establish if a breach has occurred.
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Investigate if any measures can be taken to contain or minimise the breach.
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Establish the full extent and nature of that breach – including what the breach was, how many data subjects are affected and who they are.
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Establish if the data breach has, or is likely to, pose a significant risk to the data subjects rights and freedoms:
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If the breach does pose a significant risk to the data subjects rights and freedoms we will:
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Ensure all trustees are informed
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Report the breach to the ICO. This will be done in-line with their guidelines and as soon as possible, but no later than 72 hours after the breach occurred
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Report the breach to any other relevant regulators, including the Charity Commission and OSCR.
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Report the breach to the data subjects affected, informing them of what has happened, possible and likely impacts it might have on them and what we are doing to manage the breach and reduce risk of future occurrences
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If the breach does not pose a significant risk to the data subjects rights and freedoms we will:
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Document details of the breach and the decision making process involved in assessing the severity and risk of the breach.
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Ensure the breach is reported to the Committee at the next planed full Committee meeting.
Conduct an internal investigation into how the breach happened and what measures need to be taken to minimise the risk of similar breaches occurring in the future.
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Data retention policy
Introduction
This policy sets out how will approach data retention and establishes processes to ensure we do not hold data for longer than is necessary.
It forms part of Data Protection Policy.
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Roles and responsibilities
Diana Harris is the Data Controller and will determine what data is collected, retained and how it is used. The Data Protection Officer for Sturminster Newton Orchestra is Diana Harris. They, together with the Committee are responsible for the secure and fair retention and use of data by Sturminster Newton Orchestra. Any questions relating to data retention or use of data should be directed to the Data Protection Officer.
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A regular review of all data will take place to establish if Sturminster Newton Orchestra 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 1st June 2024.
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Data to be reviewed
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Sturminster Newton Orchestra stores data on digital documents (e.g. spreadsheets) stored on personal devices held by committee members.
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Data stored on third party online services [(e.g. Google Drive, Mail Chimp)]
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Physical data stored at the homes of committee members
Who the review will be conducted by
The review will be conducted by the Data Protection Officer with other committee members to be decided on at the time of the review.
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How data will be deleted
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Physical data will be destroyed safely and securely, including shredding.
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All reasonable and practical efforts will be made to remove data stored digitally.
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Priority will be given to any instances where data is stored in active lists (e.g. where it could be used) and to sensitive data.
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Where deleting the data would mean deleting other data that we have a valid lawful reason to keep (e.g. on old emails) then the data may be retained safely and securely but not used.
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Criteria
The following criteria will be used to make a decision about what data to keep and what to delete.
Question | Action
| Yes | No
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 | Keep the data at least | Delete or remove the data unless we have reason
to keep the data? | until the statutory | to keep the data under other criteria.
| minimum no longer |
| applies. |
---------------------------|----------------------|-----------------------------------------------
Is the data accurate? | Continue to use | Ask the subject to confirm/update details
---------------------------|----------------------|------------------------------------------------
Where appropriate do we have | Continue to use | Get consent
consent to use the data. | |
This consent could be implied | |
by previous use and engagement | |
by the individual | |
---------------------------|----------------------|------------------------------------------------
Can the data be anonymised | Anonymise data | Continue to use
---------------------------|----------------------|------------------------------------------------
Statutory Requirements
Data stored by Sturminster Newton Orchestra may be retained based in statutory requirements for storing data other than data protection regulations. This might include but is not limited to:
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Gift Aid declarations records
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Details of payments made and received (e.g. in bank statements and accounting records)
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Committee meeting minutes
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Contracts and agreements with suppliers/customers
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Insurance details
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Tax and employment records
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Member data
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When a member leaves Sturminster Newton Orchestra and all administrative tasks relating to their membership have been completed any potentially sensitive data held on them will be deleted – this might include bank details or medical data
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Unless consent has been given data will be removed from all email mailing lists
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All other data will be stored safely and securely and reviewed as part of the next two year review
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Mailing list data
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If an individual opts out of a mailing list their data will be removed as soon as is practically possible.
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All other data will be stored safely and securely and reviewed as part of the next two year review
Volunteer and freelancer data
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When a volunteer or freelancer stops working with Sturminster Newton Orchestra and all administrative tasks relating to their work have been completed any potentially sensitive data held on them will be deleted – this might include bank details or medical data
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Unless consent has been given data will be removed from all email mailing lists
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All other data will be stored safely and securely and reviewed as part of the next two year review
Other data
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All other data will be included in a regular two year review.
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