We process personal data relating to clients, customers and members, and to those who are interested our organisation.
We are committed to complying with our legal obligations in respect of data protection and privacy.
This statement sets out the principles we apply when processing personal data. This statement describes the types of personal data we may collect about you. This statement also describes what we do with any data we collect about you, how we will keep it secure and the legal bases on which we rely for processing your data. This statement also informs you of your rights and how you can contact us.
Last updated: May 2018
1. About Hallam Sinfonia
Hallam Sinfonia is an amateur orchestra based in Sheffield, charity number 1112838
We provide orchestral live performance entertainment.
We are a Data Controller for the purposes of current data protection legislation.
Our contact details are:
Hallam Sinfonia firstname.lastname@example.org
2. What personal data do we collect from you?
Personal data is any information relating to an identifiable living individual. We only collect the personal data we need to be able to provide you with the information and services you have asked us to provide or tell you about.
Personal/contact information – this can include your name, contact address, email addresses, telephone numbers.
Payment information – your bank details if we are to make a payment to you.
Photographs – you may be included in photographs taken at our events.
Digital information – IP addresses, and details of your interaction with our website and social media, should you engage with us through these channels.
Correspondence – information relevant to any specific enquiries, communication with members of the orchestra, and communication with interested parties about the orchestra.
Other – any other information you choose to provide to us.
3. When do we collect personal data?
We will collect information about you when you enter into a contract with us, make enquiries about us, visit our website and engage with us on social media.
4. What is our lawful basis for processing your data?
We may only process personal data where we have a lawful basis to do so. We may collect and process your personal data when:
it is necessary for the performance of contracts with you;
it is necessary for the purposes of our legitimate interests as an organisation. In these cases we will do so in a way which might reasonably be expected from our relationship with you, and which does not impact materially on your fundamental rights, freedom and interests. We will not process your personal data on this basis if we believe your rights override ours. Instead, we may seek your specific consent, and/or another legal basis;
it is necessary for compliance with legal obligations;
we have your consent to do so, for example in relation to marketing by electronic means.
Please see below for more detailed information about how we will use your data and on what basis.
If you have any concerns about our data processing please contact us: see Contact. Please also see Your rights, below.
5. How will we use your personal data?
We may process the information we collect about you:
to perform any contract or agreement we have agreed with you, or to respond to any enquiries you make in this connection before we enter into a contract or agreement. The lawful basis for this processing is performance of a contract with you or because you have asked us to take specific steps before entering into a contract in respect of these activities and services.
to communicate vital or relevant information with you (as a member of the orchestra) about engagements requiring your involvement. to respond to any other enquiries or complaints. We need the information you supply to enable us to respond.
to protect our organisation from fraud and other illegal activities. This processing is necessary for our legitimate interests by ensuring the proper management of our business and financial risks.
to provide you with information by email (with your consent) about other opportunities, services or events similar in nature to those you currently receive or have previously asked about. Information we may process for this purpose includes your name and email address. This processing is necessary for marketing our services, which is a legitimate business interest.
We will only send marketing information to you by email if we have your consent. You have the right to withdraw your consent at any time. Please email us: see Contact below.
to send you communications required by law or which are necessary to inform you about changes to our operations, for example, updates to this Privacy Statement, and any information legally required which relates to any contracts or agreements between us. These service messages will not include any promotional content and do not require prior consent when sent by email. This processing is necessary for us to comply with our legal obligations.
to administer our website, and 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. This processing is necessary for development of our organisation, which is a legitimate interest of our business. We have a legitimate interest to do so as this helps make our products or services more relevant to you. You are free to opt out of receiving these requests from us at any time by contacting us.
to design our promotional materials. This includes the use of photographs which may feature you. Before using images where you may be a prominent feature, we will ask for your permission before using them in printed or online promotions. You may contact us at any time asking to remove an image which features you, however we cannot guarantee that we can collect any materials already printed or distributed before the request is made.
6. Who do we share your data with?
In some circumstances we may need to share your data with the following:
Our accountants/auditors in cases where we are required to do so to be compliant with our financial obligations as an organisation.
Conductors, soloists or other professionals working with the orchestra (members only) in cases where they need to communicate outside of rehearsal time.
We may also share your data with third parties, such as our website service and social media content providers to support the efficient running of our organisation’s online presence.
If this is necessary, we will provide only the information they need to perform the services we require. They will only use the data for the purposes we specify. We require third parties to maintain appropriate security to protect information from unauthorised access or processing.
In some circumstances, we may need to share your personal data with other third parties (including legal or other advisers, regulatory authorities, courts and government agencies) to enable us to enforce our legal rights, or where such disclosure may be permitted or required by law.
Unless we tell you otherwise, your data will not be processed outside the European Economic Area.
7. How long will we keep your data?
We will only keep personal data for as long as is necessary for appropriate operation of our organisation, to provide our services, or for as long as we reasonably need to keep the information for the lawful business purposes or to comply with a statutory or other legal requirement.
8. Data security
We will take appropriate technical and organisational measures to protect the personal data we transmit, store or otherwise process against accidental or unlawful destruction, loss, alteration or unauthorised disclosure or access. Only Hallam Sinfonia committee members, or approved service providers (see 6: Who do we share your data with) will have access to stored data and any computers and mobile devices used to access or process data are password protected, with passwords only known to the person accessing the data.
9. Your rights
You may exercise your rights by contacting us using the details in 11. Contact below. We aim to handle any requests within a reasonable period and, in any event, within one calendar month of the original request.
Right to information and access – You have the right to be informed about what personal data we collect about you, why, on what lawful basis and what your rights are. This Privacy Statement is the key document we use to inform you about this. You also have a right to request access to the information that we hold about you, and to receive a copy of this information, along with other information which is generally contained in this Privacy Statement.
Right to rectification – You have the right to request that inaccurate personal data be rectified, or completed if it is incomplete.
Right to erasure and restriction – You have the right to ask us to limit or cease processing or erase information we hold about you in certain circumstances. When responding to such requests, we will tell you how such restrictions or deletions may affect our ability to fulfil any contracts with you or otherwise affect your interests.
Right to object – You have the right to object to our using your information for direct marketing. You can also ask us to stop using your information, where we are processing it on the basis of our legitimate interest. We will do so unless we believe we have a legitimate overriding justification to continue processing your personal data.
Right to withdraw consent – If you have given us any specific consent to use your personal data, you have the right to withdraw it any time. If you wish to tell us that you are withdrawing your consent, please email us at email@example.com
If you are unhappy with the way we process your personal data, please contact us using the information provided below. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 or 01625 545 745
If you have any questions about this policy, or you wish to exercise any of your rights, please email us at firstname.lastname@example.org
12. Updates to this statement
We may change this privacy statement from time to time. We will post updates to this privacy statement on our website, and where appropriate, we may notify you by post or email. Please check our website to stay up to date.