Privacy

 

Privacy Policy

How we respect privacy when we deal with personal information collected by our organisation

 

This Privacy Policy applies to information we ([Capital Age Arts]) collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it.

If you have any comments or questions about this notice, feel free to contact us at [capitalagearts@gmail.com].

1. Personal data that we process

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed.

Purpose

Data (key elements)

Basis

Enquiring about our organisation and its work

Name, email, message

Legitimate interests - it is necessary for us to read and store your message so that we can respond in the way that you would expect.

Subscribing to email updates about our work

Name, email

Consent - you have given your active consent.

Making a donation

Name, email, address, payment information

Legitimate interests - this information is necessary for us to fulfill your intention of donating money and your expectation of receiving a confirmation message.

Signing up as a member

Name, email

Contract - by paying your membership fees you have entered into a contractual relationship with us as set out in our membership terms and conditions.

Website functionality

Website activity collected through cookies

Legitimate interests

- it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.

 

2. How we use your data

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.

For example, we may use your personal information to:

  • reply to enquiries you send to us;

  • handle donations or other transactions that you initiate;

  • where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.

3. When we share your data

We will only pass your data to third parties in the following circumstances:

  • you have provided your explicit consent for us to pass data to a named third party;

  • we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or

  • we are required by law to share your data.

In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.

4. How long we keep your data

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required.

Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

5. Rights you have over your data

You have a range of rights over your data, which include the following:

  • Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).

  • You have the right to ask for rectification and/or deletion of your information.

  • You have the right of access to your information.

  • You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.

A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.

Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

6. Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.

Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose.  Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users' computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google's privacy policy is available at http://www.google.com/privacypolicy.html.

7. Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we'll notify people whose personal data we hold and is affected.

Data Protection Policy

[Capital Age Arts]

 

Last updated

MAY 2018

Definitions

Charity

Capital Age Arts (Registration 1145294)

GDPR

General Data Protection Regulation.

Responsible Person

Company Secretary.

Register of Systems

Membership, consented contact.

1. Data protection principles

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 whhat 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 organisational 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 unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

  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 organisation that processes personal data.

3. Lawful, fair and transparent processing

  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.

4. Lawful purposes

  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.  

5. Data minimisation

  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.

  2. Capital Age Arts will only use data relevant for the purposes of the charity and will not pass on any personal details to a third party or for marketing by any other organisation.

6. Accuracy

  1. Capital Age Arts 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.

  3. Capital Age Arts will review information annually deleting where appropriate or if a contact has expressed a wish to be removed from any data list.

7. Archiving / removal

  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.

8. Security

  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 unauthorised 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.

9. 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).

 

END OF POLICY

 
 

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