PRIVACY POLICY

Arts4Wokingham Privacy Policy

Contents

Introduction

Definitions and who we are
Data Protection Principles
General Provisions
Lawful, Fair and Transparent Processing
Lawful Purposes
Data Minimisation
Accuracy
Retention/Removal
Security
Breach
The data we collect about you
How is your personal data collected?
How we use your personal data
Disclosures of your personal data
International transfers
Your legal rights
Glossary

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Introduction

Welcome to the Arts4Wokingham privacy policy.

Arts4Wokingham takes the privacy of your information very seriously. This privacy policy provides information on how Arts4Wokingham collects and processes your personal data that you may provide via our website, by post, email, telephone or in person.

Our website is not intended for children, and we do not knowingly collect data relating to children.

By using our website or any services we offer, you are consenting to the collection, use and disclosure of the information you provide in accordance with this privacy policy, and you are agreeing to be bound by this privacy policy.

It is important that you read this privacy policy together with our cookie policy. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1. Definitions and who we are

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Arts4Wokingham

Postal Address: 1 Peach Street, Wokingham, RG40 1XJ

Email Address: info@arts4wokingham.com

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would however appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 07/01/22. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. Data Protection Principles

A4W is committed to processing data in accordance with its responsibilities under the GDPR. Article 5 of the GDPR requires that personal data shall be:

a) Processed lawfully, fairly and in a transparent manner in relation to individuals;

b) 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;

c) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d) 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;

e) 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 organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

f) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

3. General Provisions

a) This policy applies to all personal data process by the Charity.

b) The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.

c) This policy shall be reviewed at least annually.

d) The Charity shall register with the Information Commissioner’s Office as an organisation that processes personal data.

4. Lawful, Fair and Transparent Processing

a) To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.

b) The Register of Systems shall be reviewed at least annually.

c) 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.

5. Lawful Purposes

a) 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).

b) The Charity shall note the appropriate lawful basis in the Register of Systems.

c) Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.

d) 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.

6. Data Minimisation

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

7. Accuracy

a) The Charity shall take reasonable steps to ensure personal data is accurate.
b) 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

8. Retention/Removal

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

9. Security

a) The Charity shall ensure that personal data is stored securely using modern software that is kept up to date. Electronic transfer of information on the internet cannot be 100% secure. Appropriate and up to date security will be used if transfer of personal information is required.

b) Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

c) When personal data is deleted this should be done safely such that the data is irrecoverable.

d) Appropriate back-up and disaster recovery solutions shall be in place.

10. Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised 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).

11. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact data includes postal address, email address and telephone numbers.
Financial data includes bank account and payment card details.
Transaction data includes details about payments to and from you and other details of
products you have purchased from us and donations you have made.
Technical data includes internet protocol (IP) address, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and platform, and
other technology on the devices you use to access this website.
Profile data includes purchases or orders made by you, donations made by you, your
interest, preferences, feedback and survey responses.
Usage data includes information about how you use our website, products and services.
Marketing and communications data includes your preferences in receiving marketing from
us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions or offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the contract you have with us but we will notify you if this is the case at the time.

12. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Apply for our products, services or make a donation;
Subscribe to our publications;
Request information to be sent to you;
Enter a competition, promotion or survey; or
Give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set our below:

Search information providers such as Google;
Publicly available sources such as Companies House;
Providers of technical, payment and delivery services;
Data brokers or aggregators;
Partner organisations

13. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you;

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide what products, services and opportunities may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or entered into a contract with us and you have no opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of any kind of transaction.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when website set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent in compliance with the above rules, where this is required or permitted by law.

14. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

External third parties
Specific third parties such as landowners for public art installations
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

15. International transfers

To the best of our knowledge, we do not transfer your personal data outside the UK.

16. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

17. Glossary

Lawful Basis

Legitimate Interest means the interest of our charity in conducting and managing our business to enable us to give you the best service, product or opportunities and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

External Third Parties

Service providers
Professional advisers including lawyers, bankers, auditors and insurers.
HM Revenue & Customs, regulators and other authorities who require reporting of
processing activities in certain circumstances.

Your Legal Rights

You have the right to:

Request access to your personal data commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed our information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data’s accuracy
Where our use of the data is unlawful but you do not want us to erase it
Where you need us to hold the data even if we no longer require it as you need it to
establish, exercise or defend legal claims
You have objected to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applied to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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