The great thing about GDPR is that it offers us the chance to personalise how we communicate with our supporters, contacts, clients and colleagues. This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
About us
https://englishconcert.co.uk/ is a site operated by The English Concert. We are a registered UK charity and our registration number is 271765. We are responsible for protecting your personal information as a “data controller” under applicable data protection legislation. If you have any queries about this policy or how we use your personal information, please contact us using the details listed below at How to get in touch.
What data do we collect?
- We usually collect personal data from you when you get in touch with us in some way. For example, this could be when you sign up to our mailing list, become a supporter of the orchestra, attend one of our events, make a donation or make a purchase with us. In these circumstances we will collect your name, address, email address, contact details. In the case of making a donation or purchase, we will collect your payment details, a history of your transactions with us, plus any other relevant information that you give us.
- We may collect information that is available in the public domain, for example: newspaper or online media items, publicly available posts on social media sites or Companies House listings.
- We also gather general information about the use of our website, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in emails. We may use this information to personalise the way our website is presented when users visit, to make improvements to our website and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our website.
Do we receive data from third parties?
- When you buy tickets to our events directly from a venue, such as the Barbican or Wigmore Hall, they often ask for your consent at the point of sale whether they can share your data with us. This is most commonly the case with venues that are funded by the Arts Council as it is a stipulation of their funding. In order to protect your data, we will only receive details from one of these organisations if we have a data sharing agreement in place and a safe mechanism within which to share the information. When we do receive data from a third party we firstly send a welcome message to make sure that you still want to hear from us. There is a clear mechanism to unsubscribe from our mailing list at this point, as in all of our communications.
- We also receive some audience data from The Audience Agency. All data from The Audience Agency is anonymised – i.e. we do not receive names or contact details – and focuses on audience attendance figures. A report from The Audience Agency will tell us a number of things about our audiences, such as how many people attended a concert. This figure can be broken down by postcode and show what percentage of our audience came from, for example, N1, in addition to their cultural backgrounds. We gather this data to help improve the quality of our concerts and to gain a better understanding of broader demographic and geographic trends.
What do we do with your personal data?
- We process your personal data to promote the charitable aims of The English Concert.
- Primarily, we will use your personal data to provide you with products or services you have requested, and to stay in touch, whether by post, by email or by telephone in accordance with your marketing preferences.
- This includes providing you with information you have requested and information that we think would be of interest to you, such as sending you our annual season brochure, regular updates on our forthcoming concerts, our latest news and notices of any special offers on the horizon.
- We may also send you information about seasonal fundraising drives such as the Big Give Christmas Challenge, as well as invitations to fundraising Galas, receptions and other events.
- We will send you details of any important changes that have occurred, especially if you are coming to one of our concerts.
We will only use your personal information for electronic marketing purposes if we are allowed to do this by law or if we have your consent. If you agree to us providing you with marketing information, you can always opt out at a later date. If you would rather not receive marketing material from us, please let us know at any time using the contact details at How to contact us.
Additional uses of data that we receive from you
We may also ask an external company to perform a wealth-screening survey of our contacts. This helps us to gain a better understanding of your interests, how you engage with us, how you might be willing to support us, and accordingly the amount of support that it might be appropriate for us to ask you for. We are not trying to be greedy, but we understand that everyone has a different budget to work from. It also enables us to better target our conversations about fundraising and generate funds cost-effectively. We want to make sure that when we launch a fundraising campaign we engage with supporters who are in a suitable position to help. If a fundraising scheme is seeking large donations of £100,000, for example, we don’t think it is very fair to ask those who would prefer to donate a much smaller sum.
What is the legal basis for processing your personal data?
The new GDPR regulations set out 6 legal basis for processing your data. Processing sounds like a scary term, but it simply refers to using your data. That might be as simple as giving you a call, sending you an email, or posting materials to you.
We process your personal information in order to conduct and manage our work, and to achieve the charitable aims of the orchestra. This includes managing our staff and business functions, our relationships with donors, and our fundraising activities. We will only use your personal data when the law allows us to.
Most commonly, The English Concert will use your personal data in the following circumstances:
- For our customers, clients (which includes our musicians) and suppliers, we will process your data so that we might fulfil our contracts with you or in order to service invoices.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests, on the condition that your fundamental rights are not overridden in the process. ‘Legitimate interest’ means the interest of The English Concert in conducting and managing our work to achieve our charitable purpose as effectively as possible. We make sure that 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.
- Where we need to process your data to comply with our legal obligations, for example to pass on some of your details to HMRC when we make a Gift Aid claim.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct fundraising communications to you, for example where you have signed up to our mailing list to receive our newsletters and other important updates and communications about our activities and fundraising. You have the right to withdraw your consent to receiving this marketing information at any time by contacting us.
How long will we keep your data?
In general, we will keep your data for no longer than is necessary. For example:
- If you join our mailing list or become a supporter of the orchestra, we will keep your data until you tell us otherwise.
- If you would like to unsubscribe from one of our mailing lists or memberships, we will store some of your data on our ‘Do Not Contact’ list to make sure that your wishes are respected. It might sound strange, but is important for us to keep a record of your decision not to be contacted, or if you change your contact preferences, and it is important to retain enough information to identify you from someone else with a similar name. From time to time the ICO may conduct an audit of our data practices, and we will need to demonstrate how we comply with your requests. Understandably it will be a bit tricky to demonstrate that we have made Mr & Mrs X’s requested changes if we have deleted all record of them.
- For financial matters, HMRC requires that we keep records for at least 7 years. So if you have made a donation or made a purchase, or even if we have made an outgoing payment, we are obliged to keep a record.
If you have any questions about how long we keep your information, please contact us on the details set out at How to contact us.
How do we protect your personal data?
- We take appropriate technical and organisational measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
- Much of your personal data is securely stored in password protected systems like Clearbooks (for accounting) or our members and payment system Salesforce. For all other occasions, we will encrypt our files where necessary. Passwords for these systems are also kept securely behind recognised password management software which is encrypted. When your data is sent to us by third parties, such as concert venues, these are often transferred to us via password-protected mechanism such as Purple7. When we share your data with third parties as detailed below, we will also endeavour to protect them in transit through the same means.
- We use a secure service when you make a donation through our website, via a virtual gateway operated by Stripe. Our online payment system is Payment Card Industry Data Security Standard compliant.
- Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates, for example to concert venues where you can purchase tickets. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
You should be aware that the use of the Internet is not entirely secure and although we will do our best to protect your personal data we cannot guarantee the security or integrity of any personal information which is transferred from you, or to you, via the Internet. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features such as encryption to try to prevent unauthorised access.
Who do we share your data with and why?
- If you become a supporter of the orchestra and would like us to collect Gift Aid on your donations (and have completed a Gift Aid declaration), we are obliged to provide some of your details to HMRC, including your name and address, in order to make a Gift Aid claim.
- We know that when you buy tickets from us it can be very easy to misplace them. We would hate for anyone to miss one of our performances for this reason, and so we supply a list of names and their seat allocations to the box office departments of any venues we visit so that they can assist you if there is a problem.
- From time to time we send out printed communications such as our annual season brochure and invitations to various events such as our fundraising galas. We are not experts in printing lovely booklets and getting them to you in the post, so we employ third parties to do this for us. In these situations we will share your name and postal addresses with them, and we will have a data sharing agreement in place to make sure that your data is protected. On the occasions that we engage a company to perform a wealth-screening survey, we will also make sure your data is protected in a data sharing agreement between ourselves and the third party which complies with the requirements of the applicable data protection legislation.
- If you make a payment or donation to us we will need to share your information with our payment processor. By paying via our payment processor you agree to accept their terms and conditions for the use of their services, including their privacy policy. We suggest that you read their privacy policy when using their service as we are not responsible for data you share with them.
- We may also need to disclose your information if required to do so by law or as expressly permitted under applicable data protection legislation.
Communication preferences
Please allow up to 7 days for any changes to your communication preferences to take effect. While we will endeavour to update your preferences and requests as fast as possible, we often schedule our communications some time in advance, so please be aware that you may still receive some communications after submitting your request. We do hope that this won’t be an inconvenience.
Your rights
You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’).
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records.
We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided us with changes, for example if you change your email address, name, payment details, or if you wish to cancel your registration, please let us know using the contact details at How to contact us.
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’). This right does not apply where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest. Similarly, as set out above, it is important that we retain some information so that we can accurately record your wishes and preferences.
You have a right to ask us to restrict our processing of your information (‘right to restriction’) if:
- you contest its accuracy and we need to verify whether it is accurate;
- the processing is unlawful and you ask us to restrict use of it instead of erasing it;
- we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims;
- you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests;
- you exercise your right to restrict processing, we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.
You have a right to prevent us from processing your data for the purposes of marketing.
If you would like to exercise any of your rights above, please let us know using the contact details at How to contact us. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113.
Our website:
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The cookies we place on your computer do not contain any personal or identifiable information.
You can find out more information about cookies and what they are here: https://www.allaboutcookies.org
You can delete any cookies we have placed on your computer and block us from placing any more cookies by following the instructions here: https://www.allaboutcookies.org/manage-cookies but doing so may result in the loss of some functionality on the website.
Links to Other Sites
This site may contain links to external sites. These sites have their own policies with regard to privacy and we are not responsible for the privacy policies or the content of these external sites.
Future changes and amendments to this policy
Occasionally we need to change the way we do things to overcome new obstacles, or indeed to rectify older, but as yet uncovered issues. While this Privacy Policy has been written with the intention of covering all foreseeable eventualities, there may be cause for further amendment in the future. Furthermore, because the GDPR regulations are so new, there is little or no case law which have put all GDPR’s implications to the test. Therefore, we will do our very best to keep up to date as this develops and change our procedures and documentation where necessary. When such changes are required, we will notify all of those in our database of the forthcoming amendments.
This Privacy Policy was last reviewed in June 2018.
How to contact us:
If you would like to talk to us about your data you can do so in any of the following ways:
- By post:
The English Concert, Somerset House (West Wing), Strand, London, WC2R 1LA - By telephone:
020 3962 2322 - By email:
ec@englishconcert.co.uk
Helpful links:
ICO: https://ico.org.uk/