The Friends of St Mary's Perivale
Legitimate interests assessment (LIA), Balancing exercise and Proportionality Considerations
16. We use personal data only in legal ways solely in pursuance of the stated Objectives of ‘The Friends of St Mary's Perivale'. We believe that our collection and use of contact information (primarily e-mails) conforms to the guidance from the Information Commissioner's Office (ICO): "Legitimate interest is likely to be most appropriate where you use people's data in ways they would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for the processing".
17. We have applied the ICO tests as follows:
1- identify a Legitimate Interest
Our Legitimate Interest is the performance of classical music at the concerts that we organise in accordance with our three Objectives, and that is the sole purpose of us contacting our potential audience.
2 - the data processing is necessary to achieve it
The processing is primarily the collection, storage and responsible use of e-mail addresses (and for a small number of people their mobile phone numbers) - since e-mailing and text messaging are the most time- and cost- effective way of informing people about our concerts. We collect e-mail addresses and mobile phone numbers only where we have good reason to believe that the person is interested in hearing classical music performed at our concerts.
3 - balance it against the individual's interests, rights and freedoms
We currently hold contact information on approximately 2,400 people. This includes Membership information on about 200 Members. We do not collect or hold sensitive information on our contacts (such as their health condition) and within our operational limits we take reasonable and appropriate steps to safeguard the information that we do hold - recognising that ‘The Friends of St Mary's Perivale' is run solely by a group of unpaid volunteers operating from home. We consider our use of personal data to be low risk.
We consider that sending information about our forthcoming concerts by e-mail and text message, in a well-established time pattern, is not intrusive (whereas ‘cold calling' for instance would be intrusive), especially since e-mails can easily be deleted and we provide a means to Unsubscribe. We therefore consider that any risks are more than out-weighed by the benefits to our contacts in terms of the information they receive about our concerts. Moreover, we do receive a gratifying number of e-mail, verbal and Questionnaire Survey expressions of appreciation for the way in which we run our concerts, and we have not received any complaints from attenders or those receiving our e-mails. Overall, we consider that we have attained a good balance in our use of personal information and that our practices are proportionate in complying with the requirements of the General Data Protection Directive.
Access to Information
18. We will be pleased to provide anybody with copies of the information that we hold about them. Requests should be sent in the first instance to our Chairman (at: firstname.lastname@example.org or on 020 8997 7691), who will keep a record of the request and response.
Correction and updating
19. We will correct and update any information that we hold as soon as is reasonably possible after being notified of the need to do so.
Disclosure and Erasure
20. ‘The Friends of St Mary's Perivale' does not share or disclose to other persons or organisations, or sell to advertisers or other Third Parties, any of the personal information that we hold except as follows:
contact names and e-mail addresses to our Third Party e-mailing system, Mailchimp. (Each mail includes an option for the recipient to Unsubscribe and to see the personal data we hold on them);
contact names and mobile numbers to our Third Party text messaging platform, trading as ‘ text local' (and run by London-registered company IMImobile);
Lloyds Bank (the bankers for ‘The Friends of St Mary's Perivale') and the CAF Bank, as necessary for the use of their services by us;
our concert video recordings are held on a Dropbox storage system, with the relevant copy mailed through a Dropbox link directly to the musician/s concerned. With the express consent of the musician/s, part or all of the recording of their concert may be placed on our St Mary's Perivale YouTube channel and can then be accessed by anybody worldwide. Currently there are about 250 such recordings on our Channel;
photographs of each concert and a very brief summary of it are posted by us on Facebook and Twitter; and
any information that we might be required to disclose to a Government authority under British law.
21. If a Member Unsubscribes we may contact them to reconfirm whether or not they do wish to cease receiving e-mails (in case they have accidentally pressed the Unsubscribe link.
22. If a Member wishes to resign and asks explicitly to have their personal information deleted we will delete that information from our Membership list, and lists for past years, but their names and related details will remain in our accounting system to the extent required by any law.
23. We will keep a record of all explicit requests for the deletion of personal information.
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