Registered Charity No: 1116343

St Helens Sinfonietta


40 Howards Lane


St Helens

WA10 5HY

Phone: 01744 600630



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 The St Helens Sinfonietta              May 2018


Data Protection and Privacy Policy

Adopted at the committee meeting, 31st May 2018

Forward.  Although the regulations are complicated, the data requirements of The St Helens

Sinfonietta (SHS) are quite simple. We collect names and contact details, and details of payments made to us or by us and use these to support the purchase of services, the running of events, the administration of our ticket sales and of the various groups that we operate: Mailing, Donors and Patrons, and The Friends and 100 Club memberships. We send out marketing information to those who have opted-in for this via the Mailing List, including details of forthcoming events and invitations to donate as a Donor or Patron, or to join The Friends or the 100 Club.  We do not collect any data about our contacts from third parties nor supply such details to them, unless they have a legal right to it, without the express permission of those contacts.

It is important that people who give SHS their information have a clear understanding about the data we will record and what we will do with it.  SHS must have a clear mandate to hold this data by, for example, a data-subject completing one of the several forms that we use for people to join one of the above groups or by volunteering contact details when doing business with us.

The Policy in detail.

1) Data collected.  For the people we deal with (called data-subjects) we collect and use only sufficient data to allow us to fulfil the activities and services that our contacts have requested us to provide for them or for services provided by them to us.

a) Personal:  We collect, as appropriate, names and contact details including, where provided to us, postal addresses, phone numbers and email addresses.

b) Financial:  We keep information about fees paid or received, donations (including Patronage donations), Gift-Aid declarations, pre-payments of ticket monies and details of the events being booked, and of Friends and 100 club membership fees as appropriate.   

2) Data security.

a) Form of records.  We will keep securely the original paper-based information and permissions supplied by data subjects but may transfer this into an electronic record as well. Where information and permissions are given orally, we may keep a paper transcription and/or an electronic record.

b) Who keeps it.  Data will be kept and used by the officers, committee and other people connected with SHS who perform administrative tasks for it.   

c) Where kept.  Where the data is electronic this will be kept on password protected computers at the homes of the people described above; a copy may held ‘in the cloud’ and password protected on an external server (for example: Microsoft’s OneDrive, Dropbox or similar).  We believe that these servers, which may lie outside the EU and the UK, by complying with EU-US Privacy Shield standards also comply with the requirements of the GDPR and the Privacy and Electronic Communications regulations.  They are secure, and the data is not shared with any unauthorised persons by the server administrators.


3) What we do with the data (Data processing).

a) Administration:  We use it to administer our players’ event bookings, for buying services or providing services to others, for audience ticket accounts and for our Donors, Patrons, Friends,  Mailing-list and 100 Club members. We will keep records of Gift-Aid declarations and related donations.

b) Marketing: We send out marketing information to those who have opted to receive it.  This comprises details about our forthcoming events: concerts and recitals and fund-raising activities, and invitations to support SHS in other ways by joining or subscribing to one of the above groups.

c) Electronic Communications:  We will use the ‘hidden recipient’ (Bcc) option to ensure privacy of addresses.

d) Destruction of redundant data.  When data is no longer needed to fulfil the purposes for which it was collected it will be removed from all storage devices involved.

4) Consent and Accuracy.

a) ‘Legitimate Interest’:  In some instances, permission to collect and use the data in the ways described above is covered by our legitimate interests.  It is obviously necessary for SHS to administer its players’ event bookings, contracts for buying services or providing services to others, ticket orders and gift-aid-declared donations. Specific consent is not required for this.

b) Consent.  Specific consent is required where we send out marketing information to named contacts or by electronic means.  This is achieved by use of a Mailing List to which datasubjects need to sign up.  There will be a separate opt-in (tick box) for electronic marketing.  Where data is provided orally (including by telephone) we will ask people (orally) if they wish to receive electronic marketing from us and keep a written and electronic record of that consent.

c) Ring-Fencing of data usage.  We will not use data obtained for one purpose for a different purpose for which separate consent would be required without first obtaining that permission. For example, a subject’s details provided for ordering tickets will not be transferred to a mailing-list without instruction from the data subject.

d) Accuracy:  We will periodically check the accuracy of subjects’ data and consents.  The frequency of checking will depend primarily on the uses to which the data is put; for membership of the mailing list and other groups, this will be between one and three years. For other contacts, this will be on an ad-hoc basis, likely when new contact is made with them or they update it themselves.

5) Data Subjects’ Rights:

a) To have a copy of information held.  At any time, a data subject may request a copy of the information we hold on them.  The address to use for this request will be displayed on the communications we send them.

b) To correct inaccurate information.

c) To ‘be forgotten’. They may request the removal of their details from our databases; we may not always be able to comply fully with this – for example, where donations have been gift-aid declared we would have to keep records of previous donations for the Inland Revenue for a period of six years.

d) To opt-out of electronic marketing.  This can be done independently of receiving marketing by ordinary mail.

6) Third-parties.  We don’t pass any of our data-subjects’ information to any person outside of SHS, or to any other organisations, except where they have a legal right to have it.  Nor do we obtain information about our data-subjects from third party organisations.