The Maltings (Berwick) Trust Ltd. is committed to protecting the rights and privacy of our customers. In accordance with General Data Protection Regulations 2018, this Privacy Notice outlines the basis on which any personal data we collect from you, or that you provide to us, will be stored, processed and deleted.
WHO WE ARE AND HOW TO CONTACT US
The Maltings (Berwick) Trust Ltd is the Data Controller. Our address is The Maltings, Eastern Lane, Berwick-upon-Tweed TD15 1AJ. Our phone number is 01289 330 999. We are registered as a data controller under the Data Protection Act 1998, and our Data Protection Register number is ZA178296. Our designated Data Controller is Ros Lamont, Executive Director
INFORMATION WE MAY COLLECT FROM YOU
We’ll only collect enough personal data from you to provide you with the service you’ve requested. When we ask you to provide your personal information, we’ll let you know why we are asking, and how we will use your data, by directing you towards this Privacy Notice.
(i) information you give us
You may give us information about yourself by filling in forms on paper and on our website (www.maltingsberwick.co.uk) or by corresponding with us by phone, email or by visiting one of our venues in person. This includes information you provide when you register to use our website, subscribe to our services, search for a product, book tickets, access our social media functions, enter a competition or promotion, when you report a problem with our site or services, fill in membership or donation forms, sign up for e-newsletters and complete visitor surveys.
The information you give us may include but may not be limited to your name, address, email address and phone number, financial and credit card information, communication preferences.
(ii) information we collect about you
During each of your visits to our website, we may automatically collect the following information – the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
We will also collect and hold information about any contact you have with us as a visitor or supporter of The Maltings (Berwick) Trust including details of contact preferences, gift information (including Direct Debit bank details where applicable), Gift Aid status, details of correspondence sent to you/received from you, donor status and wealth assessment information, employment information and professional activities, selected media coverage, any other information provided by yourself at the request of The Maltings (Berwick) Trust.
(iii) sensitive personal data
We may collect sensitive personal information about you including information about your racial or ethnic origin. Such Sensitive Personal Data will only be collected after obtaining your explicit consent to do so, or where it is necessary to do so to comply with legal requirements.
HOW WE’LL USE THE INFORMATION YOU GIVE US AND THE LEGAL BASIS WE’LL ADOPT FOR PROCESSING YOUR DATA
General Data Protection Regulations require us to process data based on the following six criteria:
1. Consent: the individual has given clear consent for The Maltings (Berwick) Trust to process their personal data for a specific purpose.
2. Contract: the processing is necessary for a contract The Maltings (Berwick) Trust has with an individual, or because they have asked us to take specific steps before entering into a contract.
3. Legal obligation: the processing is necessary for The Maltings (Berwick) Trust to comply with the law (not including contractual obligations).
4. Vital interests: the processing is necessary to protect someone’s life.
5. Public tasks: the processing is necessary for The Maltings (Berwick) Trust to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
6. Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
Depending on your relationship with The Maltings (Berwick) Trust and the preferences you’ve indicated, data we hold may be used for the following purposes:
- processing a ticket or a membership purchase, making a reservation for a service eg. an event or performance at The Maltings.
- analysing box office data, to understand the reach, levels of engagement, and impact of our programme, marketing, public relations and social media activity
- sending you promotional, marketing or fundraising information by post, telephone or electronic means. This can include (i) informing you of other products, services or events related to The Maltings (Berwick) Trust, such as exhibitions, performances, events (ii) ensuring existing customers are aware of similar performances, events, courses, services, appeals and activities available at The Maltings (Berwick) Trust or offered by third party theatre companies, events or festivals associated with The Maltings (Berwick) Trust (iii) sending news and updates about The Maltings (Berwick) Trust, such as marketing or supporter e-newsletters.
- informing our fundraising activities, including occasional targeted requests to consider giving financial support to The Maltings (Berwick) Trust, or to ask you to consider supporting us in other ways.
- data screening and cleansing, to check if we have accurate contact details for you.
- wealth screening and research, to help us understand our Friends, donors and potential donors, including gathering information from publicly available resources to give an insight into your philanthropic interests and ability to support The Maltings (Berwick) Trust.
- sending you surveys, and for market research purposes.
Tools may be used 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 generally used in an aggregated and anonymised form.
There are some Friends and donation communications that we’re required to send regardless of your contact preferences. These are essential communications, deemed necessary to fulfil our contractual obligations to you. This would include Direct Debit confirmations and advanced notices, thankyou letters, Friends benefits such as membership cards, renewal reminders, Gift Aid confirmation letters and querying returned mail or bounced Direct Debit payments with you.
You can opt out of any/all of our communications by contacting firstname.lastname@example.org.
WHO PROCESSES YOUR DATA
Your data will only be processed by designated employees of The Maltings (Berwick) Trust, in particular the Box Office, Marketing, Fundraising and Venue Management teams. Your data will not be shared with third party organisations without your specific consent.
HOW YOUR DATA WILL BE STORED AND MANAGED
All data, including name, address, age, communication preferences and email address will be stored by Spektrix Ltd, 3 Dorset Rise, London EC4Y 8EN. Your data will not be transferred outside the European Economic Area.
HOW WE UPDATE, SCREEN AND ANALYSE YOUR INFORMATION
We continuously review records to ensure your data is as accurate as possible. We may consult alternative sources in order undertake these checks, such as:
- Royal Mail National Change of Address database (NCOA);
- BT Operator Services Information System (OSIS);
- Reviewing employment information that you have made publicly available via social media;
- Newspaper articles, publications and company websites;
- Companies House and other company information databases;
- Charity Commission and Office of the Scottish Charity Regulator (OSCR) registers;
- Any other publicly available sources.
Where we appoint an external party to undertake a screening of information, any such arrangements will be subject to a formal agreement between The Maltings (Berwick)Trust Ltd. and that organisation, to protect the security of your data.
We may segment the information we hold about you in our database based on a proprietary score. These scores are calculated using personal data and how engaged you’ve been with us previously, as indicators of future engagement. This analysis helps us understand our Friends, donors and potential donors to ensure that we only send you relevant communications.
You can opt-out of your data being utilised for wealth screening, data cleaning or analysis by contacting email@example.com.
HOW WE MIGHT SHARE YOUR DATA
We do not disclose or sell personal data to any third parties or external organisations, other than data processors carrying out work on our behalf.
Examples of such data processors would be mailing houses for sending out our programme brochure, bulk email distribution services, telephone fundraising agencies working on our behalf, or wealth screening and data cleaning organisations. Any such companies are acting as approved data processors for The Maltings (Berwick) Trust Ltd., and we retain full responsibility for your personal data. Data processors will act only on our instructions.
We are required to ensure any transfers of data will be done securely, in accordance with best practice, and in compliance with the Data Protection Act 1998.
HOW WE KEEP YOUR INFORMATION SECURE
We have implemented security procedures, rules and technical measures to protect the personal data that we have under our control from unauthorised access, improper use/disclosure, and unauthorised modification.
All our employees and data processors, who have access to, and are associated with the processing of personal data, are legally obliged to respect the confidentiality of our customers’ and supporters’ personal data.
We store your data for processing purposes for specific lengths of time, as shown. These timescales vary for different legal and operational criteria:
- Customers booking performances, screenings, events, courses or workshops – 5 years
- Customers making reservations in our catering outlets – 5 years
- Customers with Friends memberships – during membership and for 3 years afterwards
- Artists submitting requests to exhibit work – 1 year
- Parents & guardians of young people engaging with our creative learning activities – 2 years
At the end of the time periods noted above, we we’ll contact you to ask you to sign up for further data processing and communications with The Maltings (Berwick) Trust if appropriate. If not, your data will be removed from our system.
You have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to:
- request access to personal information – this is usually known as making a data subject access request and it enables you to receive a copy of the personal information we hold about you and to check that we’re processing it lawfully.
- request corrections to personal information – this enables you to have any inaccurate or incomplete personal information we hold about you corrected.
- request the erasure of personal information – this enables you to ask us to delete or remove personal information where there’s no compelling reason for us to store it.
- restrict the processing of personal information – this enables you to ask us to suspend the processing of personal information, eg. if you contest its accuracy and want us to verify it.
- object to the processing of personal information – this enables you to ask us to stop processing personal information where we’re relying on the legitimate interests of the business as our legal basis for processing, and there’s something relating to your particular situation which makes you decide to object.
MAKING AN ACCESS REQUEST, OR MAKING CORRECTIONS TO THE DATA WE HOLD
You can ask us if we’re keeping any personal data about you at any time, and you can also request a copy of that personal data – this is called a Subject Access Request.
To make a Subject Access Request, you’ll need to provide proof of identity such as a copy of your passport, birth certificate or driving licence before your request can be processed. There may also be a fee of up to £10 depending on the volume of work required. Please try to be as clear as possible about the information you are requesting. Once we’ve received your Subject Access Request, the agreed fee and proof of identity, you’ll receive our response within 40 days and you’ll be able to get details of the information we hold on you. However, exemptions to disclosure may apply in some circumstances.
Subject Access Requests should be sent to Data Controller, The Maltings, Eastern Lane, Berwick-upon-Tweed TD15 1AJ or requested by email to firstname.lastname@example.org.
You may ask us to delete or correct your personal information at any time. If you wish to correct any information on you held by The Maltings/BVA, simply contact email@example.com
INFORMATION COMMISSIONER’S OFFICE (ICO)
The Maltings (Berwick) Trust Ltd. has a duty to report certain types of data breach to the ICO, and in some cases to contact you (eg. when it could result in discrimination, damage of reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage to you).
If you think your data has been misused or that The Maltings (Berwick) Trust hasn’t kept it secure, you should contact our Data Controller in the first instance (Ros Lamont, Executive Director).
If you’re unhappy with our response or need any further advice, you should contact the ICO directly by phoning 0303 123 1113 or GOV.UK website HERE.
CHANGES TO OUR PRIVACY NOTICE
We regularly review our Privacy Notice and may make changes to it from time to time. Any changes made will be posted to this page, and will apply from the time we post them. This privacy notice was last reviewed in March 2020.