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We take our own responsibilities under data protection just as seriously, including upholding the data subject’s right to transparency. This privacy notice contains information about what data we collect and store about you, how we use it, the legal basis for using it and how long we keep it. It also tells you who we share this information with, what we do to protect your data and how to get in touch with us.
Who We Are?
Centenary Theatre Company (also referred to as ‘CTC’ or ‘Centenary’) is a registered charity with the Charities Commission, registration number 1080693. We collect, use and are responsible for certain categories of your personal information. When we do this we are the ‘controller’ of this information for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws, including the Data Protection Act 2018.
Information collected by us
We may collect personal data about you as follows:
• Your name and contact details (including your address, email and phone numbers); • If you choose to become a chaperone we will hold the results of an enhanced DBS check on file.
• Personal information that may be included in communications with us;
• Your taxpayer status if you choose to gift aid any donations.
• Payment information and financial information that relates to our relationship including bank details, bank account
• Personal information is given to us in relation to your membership with Centenary including past performances at other societies.
You may also give us information that is classified as ‘special categories’ under GDPR however we do not routinely request this information. We will explain this to you if we need to start processing this type of data, or if we are acting as a Data Processor then the Data Controller will explain this to you. More information about ‘special categories’ can be found here.
Information Collected From Other Sources
We may also collect the same categories of information from third parties such as:
• Public bodies such as the government (for DBS checking where applicable);
• Information on public record including social media;
We look after all personal data in the same way, regardless of where it has come from and whether we are acting as a data controller or a data processor.
How We Use Your Personal Information
We use your personal information for the following purposes:
• To promote and market Centenary Theatre Company, its performances and charitable work;
• To our financial obligations;
• To engage with individuals who want to perform with us, be part of the backstage team or to attend one of our events;
• To engage with third parties who provide us with services such as sound engineers, band/orchestra members;
• To manage any queries or complaints you have about the theatre company;
• To comply with legal obligations to act in the public interest and uphold the rule of law.
Legal Reasons We Collect And Use Your Personal Information
We have a legal basis for all the data we process. We rely on a different legal basis depending on the data we are processing and the reason we are processing it. We rely on the following legal basis in these circumstances:
In some cases you will give us consent to use your information in a certain way. If you have given us consent to use your data in a certain way, and we have no other legal basis for doing so, we will rely on your consent. The activities where we rely on your consent are:
Sending you marketing information including offers and information about our services in a direct manner
You always have the right to withdraw your consent at any time. If you wish to withdraw your consent then please contact us using any of the details below (‘Get in touch’).
We will rely on our legal obligations to process information for the following purposes:
Complying with obligations to HMRC regarding records keeping of our financial activity, including information relating to transactions, billing and payments.
Defending a legal claim should the necessity arise or upholding the rule of law.
Performance of a Legal Contract
We will process information that relates to the theatre company’s activities and the services we are providing you with, or receiving from you, that are bound by our constitution and it’s rules. The areas where we are processing data to enter into, or fulfil a legal contract are:
When we are processing information from you to arrange a contract between us, such as when you give us your details to be able to perform with us, or help as part of the production team, backstage crew or technical team.
Performance of any agreement as a member, audience member, production team member or supplier for services such as printing, photographic work, design, set or costume provision. This list is not exhaustive.
We may rely on a legitimate interest to process information. When we do this we will have assessed our legitimate interest to consider the rights and freedoms of the data subject.
Who Will We Share Your Personal Information With?
We take confidentiality very seriously and will not share any information entered into any of our software or platforms unless required to do so by law. Other information we process we may share with:
• Our accountants that are engaged by us to provide services required by law, such as filing financial information with HMRC;
• We may use data processors, such as software providers, in the course of running the theatre company including email communication platforms, social media platforms and standard software packages.
• We will use 3rd party hosting providers to provision and host our software and platforms;
• Performance spaces in order for them to manage your safety and provide you access to relevant areas of the building
• Set and costume providers.
Any partners, suppliers or third parties we share data with will be bound by strict agreements that meet the requirements of GDPR.
We will share personal information with official bodies if required by law including the ICO, the police, law enforcement and intelligence agencies.
Transfer Of Your Information Outside The European Economic Area (EEA)
It may be necessary to transfer your personal information outside the EEA or to an international organisation in order to perform your instructions. We do not routinely transfer data outside of the EEA, and if we do we will notify you of the reasons, the legal basis for doing so, any relevant risk assessments that we want to make you aware of, and the safeguards in place to protect your rights and freedoms.
Clients can access our systems outside of the EEA by logging in through the cloud based portal. In these cases and when we are acting as a data processor, the means and purposes of processing (including transfer outside of the EEA) is decided entirely by our client.
How Long Will We Store Your Personal Data?
We will only keep your information for as long as necessary to complete the purposes we have described above. We use the following retention periods and review these periodically to make sure we are only keeping what we need (If information can be kept for two different periods, we will keep it for the longer of those two periods):
• Member information – We will keep information about you as a member for a period of 6 years after your membership has ended unless we have another legal basis to process that information;
• Audition application information – If you are unsuccessful becoming a member of the society we will retain your information for 1 year after the date of your audition.
• Audience information – we do not process ticket sales ourselves however if you have provided your consent for us to contact you about tickets this will be retained for a period of 2 years following the last performance you attend.
• System information – Any information you enter into our platforms will be kept for a maximum of 1 year after the contract ends. For most of this time, the information will be kept secure and deleted at the end of that period;
• Financial Transactions – Information about you and any financial transactions, including fees paid and payments for services, we will keep for a period of 7 years to comply with HMRC requirements to keep accurate records that can be audited;
• Contact information - Information used in marketing with your consent or to pursue a legitimate interest will be kept for 30 days once you have withdrawn your consent.
Under the GDPR, you have a number of important rights that you can exercise free of charge. In summary, these rights are:
• Transparency over how we use your personal data and fair processing of your information (which includes the right to be given the information in this notice)
• Access to your personal information and other supplementary information;
• Require us to correct any mistakes or complete missing information we hold on you;
• Require us to erase your personal information in certain circumstances;
• Receive a copy of the personal information you have provided to us or have this information be sent to a third party, this will be provided to you or the third party in a structured, commonly used and machine readable format;
• Object at any time to processing of your personal information for direct marketing;
• Object in certain other situations to the continued processing of your personal information;
• Restrict our processing of your personal information in certain circumstances;
• Request not to be subject to automated decision making which produce legal effects that concern you or affect you in a significantly similar way;
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual's rights under the GDPR.
If you want to exercise any of these rights, please contact us (see ‘get in touch’ for contact details) and let us know who you are and what right you want to exercise. We may need to ask for additional information regarding your identity, and we may also need some information from you on specific categories of data, types of processing activities or periods of processing activities that you wish to focus your request around.
We will respond to you no later than one month from when we receive your request.
How To Make A Complaint
If something does go wrong or you are in any way unhappy with how we have treated your data then please do not hesitate to contact us using the details in the “Get in Touch” section.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority. The UK supervisory authority is the Information Commissioner’s Office who can be contacted at https://ico.org.uk/concerns/.
Centenary puts information security and confidentiality at the forefront of our considerations. We have implemented a number of measures to protect your information including:
• Policies and procedures that cover information security and data protection legislation;
• Security functions in systems such as IP locks, administration controls and logging;
• Password requirements for any systems that hold data;
• Volunteer awareness.
We do not intend to process your personal information for any reason other than stated within this privacy notice. If this changes, we will update this privacy notice on our website and in any documentation we will send to you.
Changes To This Privacy Notice
This privacy was published in February 2020. It is due for review no later than February 2021. We regularly review our internal privacy practices and may change this policy from time to time. When we do we will inform you by updating our website and telling you in any documentation or messages we send you.
Get In Touch
If you have any questions about this privacy notice or the information we hold about you, please contact us and let us know it is in relation to your data. We will make sure you speak to the right person: