I’ve never met a gay person who regretted coming out—including myself. Life at last begins to make sense when you are open and honest.

• Charity – Gay Men’s Chorus of South Florida, Inc., a registered charity.
• GDPR – General Data Protection Regulation.
• Responsible Person – Executive Director of the Gay Men’s Chorus of South Florida, Inc. 
• Register of Systems – a register of all systems or contexts in which personal data is processed by the Charity.

The Charity is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;
2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organizational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.”

1. This policy applies to all personal data processed by the Charity. 
2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy. 
3. This policy shall be reviewed at least annually. 
4. The Charity shall register with the Information Commissioner’s Office as an organization that processes personal data. 

1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems. 
2. The Register of Systems shall be reviewed at least annually. 
3. Individuals have the right to access their personal data and any such requests made to the charity shall be dealt with in a timely manner. 

1. All data processed by the charity must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information). 
2. The Charity shall note the appropriate lawful basis in the Register of Systems.
3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data. 
4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems. 

1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 

1. The Charity shall take reasonable steps to ensure personal data is accurate. 
2. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date. 

1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually. 
2. The archiving policy shall consider what data should/must be retained, for how long, and why. 

1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.  
2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorized sharing of information. 
3. When personal data is deleted this should be done safely such that the data is irrecoverable. 
4. Appropriate back-up and disaster recovery solutions shall be in place. 

1. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website). 

Last updated on July 12, 2022

END OF POLICY

The Gay Men’s Chorus of South Florida, Inc. knows that you care how information about you is used and shared, and we appreciate you trusting that we will do so carefully and sensibly. This Privacy Policy explains our practices and the choices you can make about the way your information is collected and used by the Gay Men’s Chorus of South Florida, Inc. It applies to donor information that we collect both online and offline.

We have updated our Privacy Policy to take into account the new requirements of the General Data Protection Regulation ("GDPR") which means if you are a resident of the EU and your donor records reflect that address, you may be entitled to certain additional protections in accordance with GDPR.

We collect personal information when you voluntarily submit it to us.

For example, donors may provide us with personal information (such as name, address, email address, telephone numbers and/or credit/debit card information). If a donor, or a website visitor, contacts us by email they may provide us with their email address, and name. Providing data is required in these contexts in order for us to process your donations, requests, or respond to inquiries.

In addition to the personal information that you submit to us, we may collect personal information about you from reputable third parties, or automatically collect information using the following technologies:

Web Server Logs. Our web servers may collect certain information such as IP address, pages visited, time of visits, and referring website.

Cookies. Cookies are simple text files stored by your web browser that provide a method of distinguishing among donors and visitors to the website. Gay Men’s Chorus of South Florida, Inc. uses cookies to identify your browser as you visit pages on the Gay Men’s Chorus of South Florida, Inc. website or sites in our media network. Cookies also allow Gay Men’s Chorus of South Florida, Inc. to provide more relevant, targeted content as you travel through sites in the Gay Men’s Chorus of South Florida, Inc. media network as appropriate and are used on our ordering website to keep track of the items in your shopping cart.

Gay Men’s Chorus of South Florida, Inc. is based in the United States, and any information transmitted to us may be stored, accessed, or processed in the United States. Residents of some other countries, including residents of the European Union, should be aware that the laws of the United States do not offer the same protections as the laws of your home country.

We collect information primarily to accept donations, complete our charitable projects, and provide you with information concerning our programs, projects, and activities. We also use information for internal purposes (to better understand our supporter network) and for analytical purposes (to respond to requests for information or merchandise and to improve our website, donor base, and outreach). We may inform you of other purposes at the time that we collect some forms of information. For example, if you apply for a job, we may collect information in order to process your job application.

We do not trade, share, or sell information that you provide to us with other organizations who intend to use it only to market their products or services to you.

There may be instances in which we share your information with others. We may share your information, for example, in conjunction with your sponsorship of a certain project, as required by law, with law enforcement, to comply with legal process, to protect our legal rights, to protect the safety or security of a person, or to protect against fraud, criminal acts, or misconduct. We may also share your information with companies that provide us with services, or with a successor legal entity.

To help prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect. For example, we secure our machines with mandated encryption protocols to secure our user/company data. We also use industry accepted tools and techniques such as SSL and two-factor authentication to protect against unauthorized access to our systems. Additionally, all sensitive information is stored in secure repositories both in-house as well as secure cloud-based, AES encrypted web apps.

If you would like to access the data that we received from you, or make corrections to it, you may contact us at the email or mailing addresses provided at the end of this policy.

If you registered to receive communications from us and later change your mind, you may ask that your name and contact information be removed from our distribution list. You can send such a request to the email or mailing addresses at the end of this policy.

Some web browsers and devices permit you to broadcast a preference that you not be "tracked" online. At this time we do not modify your experience based upon whether such a signal is broadcast.

Behavioral Advertising. We may participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our website, or on other websites.

Links. Our website may contain links to other Web sites. Please note that when you click on one of these links, you are entering another site that is governed by that site’s privacy policy.

Changes to this privacy statement. We may modify this privacy policy from time to time. Any changes will be reflected on this website. If we make a material change to this policy, and need to apply it to personal information that you provided to us before the change was made, we will attempt to contact you and obtain your consent to the change.

Communicating with us. If we need, or are required to, contact you about the privacy or security of your information we may do so by telephone, email, or mail. If you have any questions, concerns, requests, or comments about privacy, you can contact us by email, telephone, or mail at:

Gay Men’s Chorus of South Florida, Inc.

2038 North Dixie Highway Suite 201, Wilton Manors, FL 33305

info@gmcsf.org | (954) 763-2266