Birmingham Symphonic Winds (BSW) is committed to protecting and respecting your privacy. At BSW, Registered Charity no. 1085058 (“we” or “our” or “us”) want to make sure all the personal information we have collected about you is safe and secure whether we collect it through our website at www.bsw.org.uk (“Site”) or from other sources. This Policy set outs our commitments to you, in compliance with and beyond the General Data Protection Regulation (commonly known as the GDPR) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but our Secretary has overall responsibility for data protection compliance in our organisation. If you have any questions about this Policy or what we do with your personal information, their contact details are set out in the "Contact" section below. Collecting specific, relevant personal information is a necessary part of us being able to provide you with any services you may request from us or in providing services to our customers and members or just managing our relationship with you.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
When you interact with us: We collect the personal data that you give when you interact with us, for example when booking a ticket, joining our mailing list or communicating with us. The information will be retained for contractual and legitimate interest reasons and comprises of:
- Personal details (name, email, address, telephone number)
- Financial information (payment information such as membership subscriptions, or whether donations are gift-aided. We do not hold any credit/debit card details.)
- Interaction history (ticket history, attendance history)
- Details of correspondence sent to you, or received from you.
When you get involved with us:
We collect details of how you get involved with us, whether that’s as a playing member, soloist, volunteer (e.g. as a Trustee), or supporting our fundraising and marketing activities. This information will be retained for legitimate interest reasons.
If you subscribe as a playing member of BSW, then we’ll keep records of you, your contact details and financial information (such as a Gift Aid declaration). This information will be retained for legitimate interest reasons.
If you make a financial donation to us, then we’ll keep records of you, your contact details, how much you give to a particular cause and we’ll note anything relevant that you may tell us. This information will be retained for legitimate interest reasons.
WHAT DO WE DO WITH YOUR INFORMATION?
When we ask you to provide your personal information we will let you know why we are asking, and how we will use your data, by directing you towards this notice.
If you have interacted with us, for example as a ticket buyer
We will send you essential communications, regardless of your contact preferences, deemed necessary to fulfil our contractual obligations to you. If you book a ticket online, this would be information related to your booking.
We will send you marketing and/or fundraising communications only if you have explicitly stated that you are happy for us to do so via a preferred channel(s) (joining our mailing list, email, phone or post). Marketing information covers information from BSW about upcoming concerts and other news. Fundraising information covers appeals for specific projects and how you can support our work as a charity.
We may use tools to monitor the effectiveness of our communications with you, including email tracking, which records when an e-newsletter from us is opened and/or how many links are clicked within the message. The data from this tracking is used in an aggregated and anonymised form.
If we contact you by email, every message we send you will include a link to opt-out of receiving future messages if you change your mind. If we contact you by other means and you want to change how – or if – you receive our communications, please email admin@bsw.org.uk.
If you are involved with us as a player:
We will send you essential communications, such as rehearsal schedules and performance details, deemed necessary to fulfil our obligations to you as a BSW member/player.
If you are involved with us as a donor:
All of the above applies. We will also send you letters thanking you, detailing any benefits you’re entitled to and invitations related to the work you have supported.
If you are involved with us as a volunteer (i.e. trustee):
We need to use your personal data to manage how you are involved with us, for example, as a trustee, to contact you about Board meetings or for Charity Commission requirements.
WHO MIGHT WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not disclose personal data to any third parties or external organisations, other than data processors carrying out work on our behalf. Outside of that we do not disclose your personal information unless we are required to do so by law. An example of a data processor would be HMRC in respect of Gift Aid claims. Any such companies or organisations are acting as approved data processors for BSW and we retain full responsibility for your personal data. Data processors will act only on our instructions.
If we transfer personal information about you outside the European Economic Area (EEA), we will let you know and ensure that all reasonable security measures are taken and that any third party processors will be required to process the information in accordance with information protection laws and we will notify you in your privacy notice if we are the information controller.
Your data will never be sold or passed to any third party for any other purpose.
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
We will only use and store your data for as long as it is required for the purposes it was collected for. The period of retention depends on the information in question, what it is being used for and in some cases, statutory legal requirements (for example the collection of Gift Aid). We keep a data retention policy detailing all of this information. When we no longer need to store your data we will dispose of it securely.
HOW CAN I ACCESS THE INFORMATION ABOUT ME, AND/OR CORRECT OR DELETE INFORMATION?
You can ask us if we are keeping any personal data about you and you can also request to receive a copy of that personal data – this is called a Subject Access Request. To make a Subject Access Request you will need to provide adequate proof of identity such as a copy of your passport, birth certificate and/or driving licence before your request can be processed. Please try to be as clear as possible about the information you are seeking including where the data is likely to be held and the date range of the information you wish to access.
Once we have received your Subject Access Request, and proof of identity, you will receive a response from us within 30 calendar days and you will be able to get copies of any information we hold on you. However, exemptions to disclosure may apply in some circumstances.
At any time you may request that we correct or delete your personal information - which we will do as long as there are no legitimate, legal reasons (as outlined in the general data protection regulation) for us to retain and process that data, for example if it’s necessary for us to carry out the purpose for which you have provided it to us.
To exercise any of these rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contact" section below. You can also unsubscribe from any direct marketing by clicking on the unsubscribe link in the marketing messages we send to you.
For further information see the Information Commissioner’s guidance on the Information Commissioner’s Office website.
OTHER IMPORTANT INFORMATION
Linking with third party sites
Our Site may, from time to time, contain links to and from the websites of partners such as concert venues, guest soloists, funders and trade bodies. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
In addition, if you linked to our Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Security
We employ a variety of technical measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.
Social Media
We use social media (including Facebook and Twitter) to broadcast messages about our news and events. Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to this Policy in the future will be posted to this page and will apply from the time we post them. Where appropriate, these will be notified to you by email. When we change this Policy in a material way, we will update the version date at the bottom of this page.
CONTACT
If you have any comments on our privacy notice, or information we hold about you please contact our Data Protection Compliance Officer at admin@bsw.org.uk or by writing to us at: BSW, Rose Cottage, Bonds End Lane, Sibford Gower, Oxfordshire, OX15 5RT. Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
Version Date: 16 May 2018