Last updated 9 May 2018
Protecting your privacy: The Arts Development Company
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here but we want you to be fully informed about your rights, and how The Arts Development Company uses your data.
For example, we will explain things such as our newsletter databases and course/workshop booking procedures.
We hope the following sections will answer any questions you have but if not, please do get in touch with us.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
- What is The Arts Development Company?
The Arts Development Company – which we’ll refer to as ‘ADC’ in this document – is a UK-based community interest company (CIC) formed in 2015. We are a public service mutual working in Dorset and beyond.
For simplicity throughout this notice, ‘we’ and ‘us’ means ADC and all our projects including Culture+.
- Explaining the legal bases we rely on:
The law on data protection sets out several different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you sign up to one of our courses we may need to collect information that includes your address and unique tax reference.
If you wish to be on our artistic workshop provider directory and offer workshops to children we will ask for up-to-date DBS checks. Likewise, we would ask for references in this scenario when commissioning an artist for project work or to employ you fully as a member of staff.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting ADC to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we may use your history to send you or make available personalised offers. These may include but are not limited to, notice of courses or special events.
We also combine the booking history and feedback of many people to identify trends and develop new products/services.
We may also use your address details to send you direct marketing information by post, telling you about events and services that we think might interest you.
- When do we collect your personal data?
When you visit our website, and buy products and services, in a workshop or event, or online.
When you engage with us on social media.
When you contact us by any means with queries, complaints etc.
When you ask one of our team to email you information about a product or service.
When you enter prize draws or competitions.
When you book any kind of appointment with us or book to attend an event, for example a Culture+ workshop.
When you choose to complete any surveys we send you.
When you comment on or review our products and services. Any individual may access personal data related to them, including opinions. If your comment or review includes information about the team member who provided that service, it may be passed on to them if requested.
When you fill in any forms. For example, if an accident happens at one of our events, an ADC team member may collect your personal data.
When you’ve given a third-party permission to share with us the information they hold about you.
We collect data from publicly available sources (such as Companies House) when you have given your consent to share information or where the information is made public as a matter of law.
When you use our car parks and premises which may have CCTV systems operated for the security of both tenants, customers, members of the public and staff. These systems may record your image during your visit.
When we employ or engage you in connection with courses, workshops or programmes that we manage.
- What sort of personal data do we collect?
If you book a course or event with us we may collect some or all of the following: your name, title, job title, gender, ethnic origin, age, business address/home address, business name, size of business, company unique tax reference or registration number, company registered address, date of first engagement with Dorset Growth Hub, referral information, email, unique tax reference number, artistic practice, disability, access needs, dietary requirements and telephone number.
If we employ or engage you in connection with courses, workshops or programmes that we manage we may also collect and store your bank details so that we may pay you.
Details of your interactions with us through courses, advice and partnership working.
For example, we may collect notes from our conversations with you, details of any complaints or comments you make, details of courses and events you attended, and how and when you contact us.
Copies of documents you provide to prove your age or identity where the law requires this. (including your passport and driver’s licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
Details of your artistic interests.
For example, which of our courses, events or sessions you have shown interest in and/or attended.
Your comments and reviews.
Your car number plate may be recorded at some of our car parks to manage parking restrictions.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, and any search terms you entered.
Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
- How and why do we use your personal data?
We want to give you the best possible advice and experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our clients and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
For example, if you’ve asked us to let you know when we are next running a specific workshop, we can’t do that if you’ve withdrawn your general consent to hear from us.
Here’s how we’ll use your personal data and why:
To process any bookings that you make by using our website, third party apps or websites. If we don’t collect your personal data during booking, we won’t be able to process your booking and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the workshop or event that you booked. We may keep your details for a reasonable period afterwards to fulfil any contractual obligations. Data collected for Culture+ courses and workshops will be kept until at least 31 December 2033 for evaluation purposes. After then it will be destroyed in a secure manner.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our business and your account from fraud and other illegal activities.
To protect our clients, premises, assets and team members from crime, we may operate CCTV systems in our buildings and car parks which record images for security. We do this on the basis of our legitimate business interests.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, we will process this data for the purposes of preventing or detecting unlawful acts. We aim to protect the individuals we interact with from criminal activities.
With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email, web, text, telephone about relevant products and services including courses, workshops, events, tailored special offers, discounts, promotions, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, and legally required information relating to your booking. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law.
To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time by notifying one of our team members in writing.
To process your booking/appointment requests (such as with a mentor).
Sometimes, we’ll need to share your details with a third party who is providing a service (such as an artist providing a training course or workshop, or a funding partner). We do so to maintain our arrangement with you. Without sharing your personal data, we’d be unable to fulfil your booking or carry out the activity you wish to engage with. Funding partners that we may share your data with include Dorset Growth Hub and WSX Enterprise.
- How we protect your personal data
We know how much data security matters to all our clients and partners. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
Access to your personal data is password-protected.
We regularly monitor our system for possible vulnerabilities and attacks.
- How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
An example of client data retention periods:
Culture+: Data collected for Culture+ courses and workshops will be kept until at least 31 December 2033 for evaluation purposes and to report to the Department for Communities and Local Government for monitoring purposes. After that time it will be destroyed in a secure manner.
- Who do we share your personal data with?
We sometimes share your personal data with trusted third parties for evaluation and monitoring purposes.
For example, artists and advisers running workshops or courses, funding partners, associated arts organisations.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
Google/Facebook to show you events and items that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
Sharing your data with third parties for their own purposes.
We will only do this in very specific circumstances, for example:
With your consent, given at the time you supply your personal data, we may pass that data to a third party for evaluation and monitoring purposes.
For example, if you participate in a Culture+ workshop we will share data with Dorset Growth Hub and WSX Enterprise. Data from participants on the Stepping Into Nature programme is shared with Public Health Dorset for evaluation purposes. Data from children taking part in the Short Breaks project is shared with project commissioners, Dorset County Council.
For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our clients into consideration.
For further information please contact our Data Protection Officer.
- What are your rights over your personal data?
An overview of your different rights. You have the right to request:
Access to the personal data we hold about you, free of charge.
The correction of your personal data when incorrect, out-of-date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
Review by an ADC team member of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
Right to be forgotten: Under Article 17 of the GDPR individuals have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.
You can contact us to request to exercise these rights at any time as follows:
To ask for your information please contact Sarah James, The Data Protection Officer, The Arts Development Company, The Little Keep, Barrack Road, Dorchester, DT1 1SQ. Email email@example.com
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent:
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest:
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity:
To protect the confidentiality of your information, we may ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
- How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
Click the ‘unsubscribe’ link in any email communication that we send you.
Write to The Arts Development Company, The Little Keep, Barrack Road, Dorchester, DT1 1SQ. Email firstname.lastname@example.org
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
- Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
- Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
Email us on email@example.com
Or write to us at:
Data Protection Officer
The Arts Development Company
The Little Keep
Our website: www.theartsdevelopmentcompany.org.uk
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Dorset Arts Development Service CIC Trading as The Arts Development Company. Registered UK company number 9517916. Registered Office: The Little Keep, Barrack Road, Dorchester, DT1 1SQ