Data Protection and GDPR Policy

Policy owner: Live Wire Ensemble Will Summers-Davies 
Effective date:  5/11/2026
Review date: Annually, or when required
Applies to: All ensemble members, including members aged 16–18, the Musical Director, committee members, volunteers and anyone handling members’ personal information.

1. Purpose of this policy

Live Wire Ensemble is committed to protecting the privacy and personal information of its members. We recognise the importance of handling personal data responsibly, securely and in accordance with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, as amended.

The purpose of this policy is to explain what personal information we collect, why we collect it, how we use and protect it, and the rights members have over their information.

Our primary purpose for collecting members’ personal data is to facilitate the effective running of the ensemble and to communicate essential information relating to rehearsals, performances and ensemble activities.

2. Personal information we collect

Live Wire Ensemble may collect and maintain the following information where necessary:

  • Contact information: Names, email addresses and telephone numbers.
  • Ensemble membership information: Instrument played, musical experience where relevant, membership status and attendance records.
  • Rehearsal and performance information: Availability, rehearsal attendance, performance commitments, schedules and part allocations.
  • Emergency contact information: The name and contact details of a nominated emergency contact, where provided.
  • Parental or guardian contact information: Where appropriate for members under 18, particularly for safeguarding and essential communications.
  • Administrative information: Information necessary to manage membership, fees or other ensemble-related administration, where applicable.

We will only collect information that is reasonably necessary for the operation of Live Wire Ensemble.

We will not routinely collect sensitive personal information unless there is a legitimate and necessary reason to do so, appropriate safeguards are in place and a valid legal basis and any additional required condition for processing have been identified.

3. How we use personal information

Members’ personal information may be used for the following purposes:

  • Communicating rehearsal dates, times, locations and changes to arrangements.
  • Sharing performance dates, concert details, call times and other essential event information.
  • Distributing sheet music, arrangements, rehearsal resources and instrument-specific information.
  • Organising instrumental sections, seating, parts and ensemble activities.
  • Managing membership, attendance and availability.
  • Contacting members in the event of cancellations, emergencies or other important changes.
  • Communicating essential administrative information relating to the ensemble.
  • Maintaining appropriate emergency contacts and supporting safeguarding arrangements.
  • Meeting legal obligations and protecting the safety and welfare of members.

Personal information will not be used for unrelated purposes without an appropriate lawful basis and, where required, the member’s consent.

4. Lawful basis for processing

Live Wire Ensemble will identify an appropriate lawful basis under the UK GDPR for each purpose for which personal information is processed.

Depending on the circumstances, these may include:

  • Legitimate interests: To organise and administer the ensemble, communicate with members and coordinate rehearsals and performances, where these interests are not overridden by members’ rights and freedoms. We will consider and document a legitimate interests assessment where required.
  • Contract: Where processing is necessary to fulfil a membership agreement or take steps requested by a member before entering into such an agreement.
  • Legal obligation: Where information must be processed to comply with a legal requirement.
  • Vital interests: Where necessary to protect someone’s life or in an emergency, where the legal conditions are met.
  • Consent: Where consent is the appropriate legal basis, particularly for optional activities such as certain publicity, photography or video recording.

We will not rely on consent as a blanket justification for all membership administration. Members will be informed of the relevant lawful basis where required.

5. Communication with members

Live Wire Ensemble may communicate with members through email, telephone calls, text messages or agreed messaging platforms, such as WhatsApp, where appropriate.

These communications will be limited to information relevant to ensemble membership and activities.

Where a group email or messaging group is used, we will take reasonable steps to protect members’ contact details and privacy. For example, email recipients will normally be added using BCC when their email addresses do not need to be visible to other recipients.

Members should be aware that participating in third-party messaging groups may reveal their name, telephone number, profile information or messages to other group participants, depending on the platform and its settings.

We will use the minimum personal information necessary for communications and will not add members to unrelated mailing lists or use their contact details for unrelated promotional activities without an appropriate lawful basis.

Live Wire Ensemble may communicate with members through email, telephone calls, text messages and WhatsApp. These communication methods will be used to share essential information relating to rehearsals, performances, ensemble activities and membership administration.

WhatsApp groups

Live Wire Ensemble may operate a WhatsApp group to facilitate communication between members and the Musical Director. The group may be used for:

  • Sharing rehearsal dates, times, locations and changes to arrangements.
  • Communicating performance details, concert schedules and important announcements.
  • Sharing rehearsal resources, sheet music updates and instrument-specific information.
  • Coordinating availability and other necessary ensemble arrangements.
  • Sharing relevant updates to help the ensemble operate effectively.

Participation in WhatsApp groups is intended to make communication easier and more efficient. Members should be aware that joining a WhatsApp group may make their telephone number, profile name, profile photograph and messages visible to other group participants, depending on their privacy settings and the group configuration.

Members will be informed about the purpose of the group and the potential visibility of their information. An alternative method of receiving essential ensemble communications will be available for members who do not wish to participate in a WhatsApp group.

WhatsApp is a third-party service and is subject to its own privacy policy and terms of service. Members should avoid sharing sensitive personal information in the group. Any personal information shared must be relevant to the ensemble and handled respectfully.

Where members are under 18, particular care will be taken to ensure that WhatsApp communications remain appropriate, relevant to ensemble activities and consistent with Live Wire Ensemble’s safeguarding arrangements.

Email and other communications

When communicating by email, Live Wire Ensemble will normally use BCC for group messages where recipients do not need to see one another’s email addresses.

Members’ contact details will not be used for unrelated marketing or shared unnecessarily. Access to membership contact lists will be restricted to authorised individuals who require the information to administer the ensemble.

All communication methods will be used proportionately, with the aim of protecting members’ privacy while ensuring that everyone receives the information necessary to participate in Live Wire Ensemble.

6. Members aged under 18

Live Wire Ensemble welcomes members aged 16–18 and is committed to handling their personal information appropriately.

For members under 18, we will:

  • Explain how their personal information is used in clear and accessible language.
  • Collect only the information necessary to administer membership and support members’ safety.
  • Keep contact and emergency information secure.
  • Involve a parent or guardian in communications where appropriate, necessary or agreed, taking account of the member’s age, understanding, welfare and safeguarding needs.
  • Take particular care when sharing information that could identify or locate a young member.
  • Avoid disclosing personal information to parents, guardians or other individuals automatically where doing so would be inappropriate or unlawful.

Where a parent or guardian’s details are required for emergency or safeguarding purposes, these will be collected and used only as necessary.

7. Sharing personal information

Live Wire Ensemble will not sell members’ personal information or routinely share it with unrelated third parties.

Information may be shared where necessary and appropriate with:

  • The Musical Director, committee members or authorised volunteers who need the information to carry out their responsibilities.
  • A venue, event organiser or performance partner, but only where necessary to organise an activity.
  • Emergency services or relevant safeguarding authorities where necessary and lawful.
  • Professional advisers, service providers or software platforms that support the administration of the ensemble, subject to appropriate safeguards.
  • Relevant authorities where disclosure is required by law.

Where a third-party service provider processes personal information on our behalf, we will take appropriate steps to ensure that the information is protected and that any required contractual arrangements are in place.

We will not disclose members’ personal contact details to other members unless there is an appropriate reason and lawful basis to do so.

8. Storage and security of information

Live Wire Ensemble will take reasonable and proportionate measures to protect personal information against loss, theft, unauthorised access, accidental disclosure, alteration or destruction.

These measures may include:

  • Storing digital records in password-protected accounts or secure systems.
  • Restricting access to personal information to authorised individuals.
  • Avoiding the unnecessary sharing of contact lists or membership records.
  • Keeping paper records in secure locations.
  • Using appropriate security settings on email and messaging platforms.
  • Removing access to membership information when a person no longer requires it for their role.
  • Disposing of information securely when it is no longer required.

Anyone given access to members’ personal information as part of their role must handle it confidentially and only use it for authorised ensemble purposes.

9. Data retention and deletion

Personal information will be kept only for as long as reasonably necessary for the purpose for which it was collected, taking account of legal obligations and any legitimate need to retain records.

As a general approach:

  • Contact details: Retained while a person is an active member and deleted or reviewed when membership ends.
  • Rehearsal and attendance records: Retained while needed for ensemble administration and then securely deleted or anonymised.
  • Emergency contact information: Reviewed regularly and deleted when no longer necessary.
  • Financial and accounting records: Retained for the period required by applicable legal and accounting obligations.
  • Safeguarding or incident records: Retained separately and securely for an appropriate period based on the nature of the matter, applicable guidance and legal requirements.

When information is no longer required, it will be securely deleted, destroyed or anonymised where appropriate.

10. Photography, video and publicity

Photographs, videos or recordings may be taken at rehearsals, concerts or other ensemble activities for legitimate operational purposes or publicity.

Where identifiable images or recordings are intended for public use, such as on the Live Wire Ensemble website, social media or promotional materials, we will explain the intended use and obtain consent where consent is the appropriate legal basis.

Consent for optional publicity will be separate from essential membership administration. Declining publicity consent will not, in itself, prevent someone from participating in the ensemble.

Particular care will be taken when photographing, recording or publicising members under 18. Appropriate permissions and safeguarding arrangements will be followed.

11. Members’ data protection rights

Under applicable data protection law, members may have the right to:

  • Access their personal information.
  • Rectify inaccurate or incomplete information.
  • Request erasure of their information in circumstances where the law provides this right.
  • Restrict processing in certain circumstances.
  • Object to processing based on legitimate interests.
  • Receive or transfer certain information in a portable format, where the legal requirements are met.
  • Withdraw consent where processing is based on consent.

These rights are subject to applicable legal conditions and exemptions.

Members wishing to exercise their rights or ask questions about how their information is used should contact the person responsible for data protection at Live Wire Ensemble.

Data protection contact: Will Summers-Davies, hello@livewire-ensemble.co.uk

We will respond to requests within the applicable legal time limits.

12. Data breaches

A personal data breach may include the loss of a membership list, accidental disclosure of members’ email addresses, unauthorised access to records or the loss or theft of a device containing personal information.

Any member, volunteer or representative who becomes aware of a possible data breach should report it promptly to the person responsible for data protection.

Live Wire Ensemble will assess the incident, take appropriate steps to contain it, and determine whether notification to the Information Commissioner’s Office (ICO) or affected individuals is legally required. Where required, the ICO must generally be notified within 72 hours of becoming aware of the breach.

13. Responsibilities

The person responsible for administering Live Wire Ensemble, together with any authorised committee members or designated representatives, is responsible for ensuring that personal information is handled in accordance with this policy.

All individuals who access members’ personal information must:

  • Use it only for legitimate ensemble purposes.
  • Keep it confidential and secure.
  • Avoid unnecessary copying, downloading or sharing.
  • Report suspected data breaches promptly.
  • Follow this policy and any relevant safeguarding procedures.

14. Complaints and further information

Members who have concerns about the handling of their personal information should first contact Live Wire Ensemble using the details above so that the matter can be investigated.

Members also have the right to raise a complaint with the UK Information Commissioner’s Office (ICO).

Website: https://ico.org.uk/

15. Review of this policy

This policy will be reviewed at least annually and whenever there are significant changes to the ensemble’s activities, the information collected or applicable data protection requirements.

Live Wire Ensemble will communicate any significant changes to members where appropriate.

Approved by: Will Summers-Davies
Date approved: 5 November 2026