PURPOSE OF POLICY
We are committed to protecting your personal information and being transparent about what information we hold about you.
Using personal information allows us to develop a better understanding of our customers and participants and in turn to provide you with relevant and timely information about the work that we do. As a charity, it also helps us to engage with potential donors and supporters.
The purpose of this policy is to give you a clear explanation about how we collect and use the information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
• What information we may collect about you
• How we may use that information
• In what situations we may disclose your details to third parties
• Information about how we keep your personal information secure, how we maintain it and your rights to be able to access it
If you have any queries about this policy, please contact the Data Protection Officer at Contact by email: firstname.lastname@example.org.
WHO WE ARE
Manchester Young People’s Theatre Ltd, trading as Contact (referred to hereafter as Contact) is a charity and is funded by Arts Council England, Greater Manchester Combined Authority, Manchester City Council, University of Manchester as well as various trusts, foundations, individual donors and supporters. Our registered charity number in England and Wales is 501953 and we are also registered as a company in England and Wales under registration number 01066757.
We collect various types of information and in a number of ways:
• Information you give us
For example, when you register on our website, buy tickets or make a donation or take part in one of our participatory projects, we’ll store personal information you give us such as your name, email address, postal address, telephone number and card details. We will also store a record of your purchases or donations.
• Information about your interactions with us
For example, when you visit our website, we collect information about how you interact with our content and adverts. When we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.
• Information from third parties
We occasionally receive information about you from third parties. For example, we may use third party research companies to provide data about you, compiled using publicly available data.
• Sensitive personal data
Data Protection law recognises that certain categories of personal are more sensitive, such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our customers and participants unless there is a clear reason for doing so. As an example, we may collect important health information (existing conditions, allergies etc.) about project participants.
There are four ways in which we may process your data:
• Contract purposes
When you make a purchase from us, procure any services from us, or make a donation to us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example, we may need to contact you by email or telephone in the event of a cancellation of a show, or in the case of problems with your payment.
• Legitimate organisational interests
In certain situations we collect and process your personal data for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
• With your explicit consent
For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
• Legal obligation
On occasion it may be necessary for us to process data in order to comply with a legal obligation, for example as a result of a court order.
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about.
We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may object to receiving these at any time using the contact details at the end of this policy. In the case of email, we will give you an opportunity to opt out of receiving them during your first purchase with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.
We may also contact you about our work by telephone however we will always get explicit consent from you before doing this. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases (as above).
OTHER PROCESSING ACTIVITIES
In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:
The Development team may contact potential funders by email or post under the legitimate organisational interest basis, sending season, show, event and organisational information and invitations. You may object to receiving these at any time using the contact details at the end of this policy. In the case of email, we will give you an opportunity to opt out of receiving them during your first purchase with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.
We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
We may analyse data we hold about you in order to identify and prevent fraud.
In order to improve our website we may analyse information about how you use it and the content and adverts that you interact with.
We may use profiling techniques or third party wealth screening and insight companies to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you about potential philanthropic support. Such information is compiled using publicly available data about you.
In all of the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out tasks above that are for your benefit.
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around the security of personal data.
Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example government bodies and law enforcement agencies).
To specific named visiting companies whose performances you have attended. In these cases we will always ask for your explicit consent before doing so.
Your data will not be sent outside of the EU to businesses and organisations that do not comply with GDPR.
Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your basket) as well as to provide website operators with information on how the site is being used.
YOUR DEBIT AND CREDIT CARD INFORMATION
If you use your debit or credit card to make a purchase or from us or make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find out more about this standard here https://www.pcisecuritystandards.org/pci_security/.
We optionally allow you to store your card details for use in future transactions. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.
MAINTAINING YOUR PERSONAL INFORMATION
We store your personal information indefinitely such that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.
If there are any aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging in to your account through our website. Alternatively please use the contact details at the end of this policy.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
SECURITY OF YOUR PERSONAL INFORMATION
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
YOUR RIGHTS TO YOUR PERSONAL INFORMATION
You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please use the contact details at the end of this policy if you would like to exercise this right.
CONTACT DETAILS AND FURTHER INFORMATION