- Policy prepared by: Robyn Keynes (Producer) on 10 February 2020
- Approved by board/management: 2 March 2020
- Policy became operational on: 3 March 2020
- Next review date: 3 March 2021
Purpose of policy
We are committed to protecting your personal information and being transparent about what information we hold about you.
Using personal information allows us to develop a better understanding of our customers and in turn to provide you with relevant and timely information about the work that we do – both on and off stage. As a charity, it also helps us to engage with potential donors and supporters.
The purpose of this policy is to give you a clear explanation about how we collect and use the information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
- What information we may collect about you
- How we may use that information
- In what situations we may disclose your details to third parties
- Information about how we keep your personal information secure, how we maintain it for and your rights to be able to access it
- If you have any queries about this policy, please contact the Data Protection Officer at HighTide Francesca Clark via 0207 566 9765 or email: email@example.com / firstname.lastname@example.org.
Who we are
HighTide Festival Productions Ltd (HighTide) is a charity and is funded by Arts Council England as one of their National Portfolio Organisations (NPO), as well as various trusts, foundations and individual donors and supporters. Our registered charity number in England and Wales is 1124477 and we are also registered as a company in England and Wales under registration number 6326484.
We collect various types of information and in a number of ways:
Information you give us
For example when you register on our website, buy tickets or make a donation, we’ll store personal information you give us such as your name, email address, postal address, telephone number and card details if you select it to. We will also store a record of your purchases and donations.
This storing is all done via Spektrix, who are our ticketing, sales and database system. Spektrix is a level 1 PCI Compliant service provider meaning that they handle card data securely without having to defer it to a third party. HighTide are PCI DSS Compliant via Lloyds Bank Cardnet and SagePay.
Information about your interactions with us
For example, when you visit our website, we collect information about how you interact with our content and ads. When we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.
Information from third parties
We occasionally receive information about you from third parties. For example, we may use third party research companies to provide general information about you, compiled using publicly available data.
Sensitive personal data
Data Protection law recognises that certain categories of personal information are more sensitive such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our patrons unless there is a clear reason for doing so i.e. your access requirements which relate to your visit to us. In this case we will always ask for your consent before recording this information and only store information relevant to your visit with us.
There are three bases under which we may process your data:
When you make a purchase from us or make a donation to us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example we may need to contact you by email or telephone in the case of cancellation of a show, or in the case of problems with your payment.
Legitimate business interests
In certain situations we collect and process your personal for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
With your explicit consent
For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about.
We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may object to receiving these at any time using the contact details at the end of this policy. In the case of email, we will give you an opportunity to opt out of receiving them during your first purchase with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.
Other processing activities
In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:
We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
We may analyse data we hold about you in order to identify and prevent fraud.
In order to improve our website we may analyse information about how you use it and the content and ads that you interact with.
In all of the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out tasks above that are for your benefit.
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
To specific named visiting companies whose performances you have attended. In these cases we will always ask for your explicit consent before doing so.
Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your basket) as well to provide website operators with information on how the site is being used.
Your debit and credit card information
If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find more information about this standard here.
We optionally allow you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.
Maintaining your personal information
We store your personal information for a period of five years since your last engagement with us. We class contact as opening an email from us, emailing or writing to us, purchasing a ticket or giving a donation. We store this personal information so that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.
If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging in to your account through our website. Alternatively please use the contact details at the end of this policy.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
Security of your personal information
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
Your rights to your personal information
You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please use the contact details at the end of this policy if you would like to exercise this right.
Contact details and further information
HighTide Festival Productions Ltd (HighTide)
24a St John Street
London, EC1M 4AY
Last Updated: March 2020