Composer Create is owned by ORA Choir, operating as ORA Singers.
ORA Singers needs to gather and use certain information about individuals. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data will be collected, handled and stored for General Customers (referring to individuals who have opted into our General Mailing List, purchased a ticket to an ORA Singers concert/event, or who have expressed an interest in the activities of ORA Singers) and Donors (referring to an individual who has made a financial gift to ORA Singers), to meet the company’s data protection standards, and to comply with the law.
1. What is the GDPR?
The General Data Protection Regulation (GDPR) is a new data protection law which will come into effect in the United Kingdom on 25th May 2018, replacing the Data Protection Act 1998. It is intended to strengthen and unify data protection for all individuals within the European Economic Area, and will reshape the way that organisations such as ours approach data privacy. Organisations that break this new law could face heavy fines.
2. What does this mean for my communication with ORA Singers?
After 25th May 2018, ORA Singers will be making changes to the way it stores, collects and uses data. ORA Singers will be moving to an opt-in system; we must secure explicit consent from you, our supporters and followers (whether verbal or written) that you wish to hear from us. This means that if you wish ORA Singers to keep in touch with you and to hear about our work, you will need to confirm:
- for General Customers, that we can keep you up to date via our General Mailing List;
- for Donors, that we can keep you up to date via our Donor Mailing List;
- for Donors, that we can list you on our website under ‘Supporters’.
2.1 How do I opt-in?
You can opt-in to communications from ORA Singers via our Mailchimp mailing list here.
2.2 How do I opt-out?
You can opt-out of communications from ORA Singers by clicking the 'unsubscribe' link, which is present in the footer of every marketing email you receive. Alternatively, you can email Natalie Watson at email@example.com who can manually remove you from our mailing list.
3. What data does ORA Singers collect and what will you do with my data?
We may collect personal data on you if you contact ORA Singers or are an individual or business that is related to the work of ORA Singers, e.g. if you are a composer, singer, publisher, choral director, musical scholar etc. This information may be obtained either directly or indirectly.
Directly- We obtain personal data directly from individuals in a variety of ways including when you provide us with a business card, apply for a job, attend meetings or events we host, visit our offices, provide us with feedback or contact us. We may also obtain personal data directly when, for example, we are establishing a business relationship or performing professional services through a contract.
Indirectly- We obtain personal data indirectly about individuals from a variety of sources, including our clients. We may attach personal data to our customer relationship management records (Hubspot) to better understand and serve our business clients and individuals, or to satisfy a legal obligation. Personal data may be obtained from public registers (such as Companies House), news articles and internet searches. We may also use social and professional networking sites to obtain necessary information on you in order to fulfil our aims.
Our website collects analytics about how the site is used (which pages are visited, how long they are visited for, etc) through two toola; Squarespace and Google Analytics. All of this data is completely anonymous.
3.3 General Mailing List
As a General Customer, if you opt-in to our General Mailing List, your name, email address and communications will be recorded via our marketing host, Mailchimp. At present, we do not replicate any of this data on our personal data storage system (Hubspot), but reserve the right to in the future. All General Customers may exercise their ‘right to be forgotten’ by emailing ORA Singers directly by telephone or by emailing firstname.lastname@example.org, whereby all their records will be permanently deleted.
ORA Singers maintains a record of current, former and prospective Donors. The personal data we store and process, the majority of which is given to us by our Donors but some of which we may obtain from other sources (internet searches, ORA team members and other personal contacts). At ORA Singers we usually store the following information:
- name, title and gender;
- email address;
- phone number;
- address (for use in processing Gift Aid and for donors who have requested postal items);
- records of donations and Gift Aid status, where applicable (as required by HMRC);
- records of communications sent to you by ORA Singers or received from you;
- information of your engagement with ORA Singers’ events, groups or networks;
- date of donations received and means of donation (cheque, standing order, bank transfer, online donation).
In the unusual circumstance that we feel it would be beneficial to our practises to store further data, we reserve the right to store the following additional information:
- date of birth;
- links to web pages and social media accounts;
- your occupation and professional activities;
- your recreations and interests;
- family and spouse/partner details and your relationships to other supporters;
- information about your wealth* (although we will never carry out wealth screening, a process which uses third-party partners to automate some of this work).
ORA Singers does not store any credit/debit card details.
3.4 Special categories of personal data
GDPR specifies that any personal data relating to the following subject matters is classed a Special categories of personal data:
- racial or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union memberships;
- genetic data and biometric data;
- sex life or sexual orientation.
ORA Singers will not store any of this data on General Customers, but may store some of this data on our Donors. This data will not be screened, but may be processed in order for ORA Singers to send appropriate invitations and to be sensitive to the needs of our Donors. An example of this might include:
- choosing to not contact a donor about a upcoming event when we are aware of health issues that might prevent their attendance; or
- contacting a donor about a specific project that we believe will be of interest, due to their religious or philosophical beliefs.
We may use information gathered from public sources alongside the information you provide to undertake analysis of who might support ORA Singers and to understand the preferences of our Donors about events, communication and services. By doing this, we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you. Examples of this include:
4. Data Storage, Processing and Sharing
4.1 How does ORA Singers store my data?
4.2 How long will be data by stored for?
The General Data Protection Act 2018's fifth data protection principle requires that personal data is not kept for longer than is necessary. ORA Singers retains all of it's data in accordance with it's document retention policy, which is available upon request. Please note, data on Donors may be retained indefinitely, in order for our financial records to be up to date and so as to retain an accurate history of our fundraising approaches and previous donors.
4.3 Will my data be processed?
Data processing is, generally, "the collection and manipulation of items of data to produce meaningful information." ORA Singers processes data for a number of reasons, for example in order to register a new Donor, to keep up-to-date and accurate records, or to comply with legal and regulatory obligations.
We will only process your personal data for the purpose(s) for which we collected it. If we do need to use your personal data for a new purpose, we will notify you of this and explain the lawful basis we will be relying on. Please be aware that we may process your personal data without your knowledge or consent where this is required or permitted by law.
4.4 Will my data be shared?
ORA Singers does not share or sell any of it's data to third parties. In the unusual circumstance that a reason should arise whereby we might consider sharing your data, ORA will contact the individual/s concerned and ask for consent before proceeding. ORA Singers' data is stored, and therefore shared, with it's external database (see 4.1), but is not shared or sold to any other third parties. This includes transferring your data outside of the European Economic Area.
5. What will you send me if I opt-in on Mailchimp to your General Mailing List?
General Customers can opt-in to our General Mailing List via one of the websites owned by ORA Singers, or by emailing a member of the ORA Singers team.
ORA Singers is a small organisation which only sends limited mailings through our online marketing software, Mailchimp. We do not wish to inundate any individual with mailings, and only send updates with regards to important news, concerts, promotions and album releases. We have never run a telephone campaign and are pleased to say that we have never shared or sold any of our data to other organisations.
6. What will you send me if I donate to ORA Singers?
As individuals belonging to our official clubs (Choral club, ORA100, Major Commission donors, Patrons and Founding Benefactors) you will receive occasional emails from us regarding your memberships. This is because, at this level of sponsorship, you have expressed reasonable interest in our work and are entitled to the benefits of your membership, which include event invitations and ticket offers. These communications will be sent by direct email, and not our marketing host, Mailchimp. All Donors below these level will not receive these communications.
If you explicitly wish for us no longer to contact you after sending your donation, including claiming the benefits of your membership, you will be able to opt-out of all future correspondence.
Once a donation has been processed, all Donors will be asked as to whether their name can appear on our website, whether they would like to be added to our Donor Mailing List, and will be given details on on GDPR policy. The Donor Mailing List is separate to our General Mailing List and includes information specific to our Donors. Donors names will not be added to either our website or the Donor Mailing List unless confirmed via email/telephone. After a Donor has opted-in, they will be able to opt-out at any point by emailing the ORA Singers office, or directly by ‘unsubscribing’ in the footer of all Mailchimp communications. Similarly, if a Donor no longer wishes for their name to appear on our website, they should email the ORA Singers team and will be removed immediately.
7. I opted-out but I still receive communications from ORA Singers
If you have opted-out of receiving ALL communications from ORA Singers, then you shouldn’t hear from us again. If you have chosen not to hear from us via a certain channel or not to receive certain types of communications, we will not send those again. Please let us know if you are receiving communications against your wishes and we will investigate promptly.
If you have recently attended an event or sent a donation, ORA Singers may still send you a letter or email to say thank you and to act as a receipt.
Please note that although those in our database have the ‘right to be forgotten’, if you have previously donated and are a UK taxpayer, we may still need to retain personal data such as name and address for reports to HMRC. Those records are effectively ‘suppressed’ however, and are not included in any mailings.
8. Who can I contact if I have any further questions?
ORA Singers has appointed a Data Protection Officer, Natalie Watson, whom you may have contact with regards to any issues concerning your data. Please email Natalie on email@example.com with your enquiry.
* ORA Singers is the operational name of the incorporated company and charity ORA Choir