Policy prepared by: Laura Saxton, Programmes Manager Policy approved by: Jo Hunter, CEO
Policy reviewed: October 2020
Next review date: March 2022
1.1 We are committed to safeguarding the privacy of staff, participants, audiences and partners.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to 64 Million Artists. For more information about us, see Section 14.
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In this Section 3 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
3.2 We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address and telephone number. The source of the contact data is you and/or your employer.
3.3 We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
3.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content.
3.5 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as
well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations – We may process your personal data e.g. name and payment details for our operations. This data is processed for the purposes of providing our services, generating invoices, and bills and other payment-related documentation. The legal basis for this processing is legitimate interests, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.3 Publications and reports – We may process your data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.
4.4 Relationships and communications – We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, participants and audiences, the maintenance of relationships, and the proper administration of our website, services and business.
4.6 Recruitment – We may process information that you provide to us when you apply for a job, associate role or a position on our board e.g names and contact details of applicants, and diversity data such as age, gender, ethnicity, religion, sexual orientation and disability. We may process this data to monitor our recruitment practices and ensure we are an equal opportunities employer in line with the Equalities Act and to consider applications and decide who to offer the job or role to. The legal basis for this processing is consent and legitimate interests.
4.7 Surveys – We may process information that you provide to us through surveys or interviews e.g. names, contact details, and possibly socio-economic data such as ethnicity, disability, age, gender, age, sexual orientation. We may process this data to enable us to monitor the outputs, outcomes and impact of our work, enable us to understand the views and perspectives of participants and enable us to understand our impact on the different protected characteristics set out in the Equalities Act. The legal basis for this processing is public task, legitimate interests and legal obligation.
4.8 Research and analysis – We may process information that you provide to us as part of our research projects. The data, including personally identifiable information will be held securely using an encrypted USB stick and will be destroyed securely at the end of the study. WhatsApp uses computer servers that are located in America, therefore the data you share on WhatsApp will be travelling outside of the European Economic Area. The data will be processed for the purposes of researching and analysing the impact of the study. The legal basis that would be used to process your personal data will be the provision of your consent.
4.9 Record keeping – We may process information that you provide to us through our project work including your name, email address and job title. The data may be processed for the purposes of providing our services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.10 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
4.11 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.12 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.13 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
5.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal data will be stored on the servers of our hosting services providers identified at WordPress.
5.3 We may disclose contact data to our suppliers or subcontractors insofar as reasonably necessary for communication.
5.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You
can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy.
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside the United Kingdom and the European Economic Area (EEA).
6.2 The hosting facilities for our website are situated in the UK with 123Reg. The competent data protection authorities have made an “adequacy decision” with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from here.
6.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data for business purposes and archive purposes in accordance with legal and regulatory requirements and business needs.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
- 8.1 In this Section 8, we have listed the rights that you have under data protection law.
- 8.2 Your principal rights under data protection law are:
- (a) the right to access – you can ask for copies of your personal data;
- (b) the right to rectification – you can ask us to rectify inaccurate personal data and to
complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection -regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
11. Cookies used by our service providers
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cooki es (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
- 12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
- 12.3 If you block cookies, you will not be able to use all the features on our website.
- 13.1 We may update this policy from time to time by publishing a new version on our website.
- 13.2 You should check this page occasionally to ensure you are happy with any changes to
13.3 We may notify you of significant changes to this policy by email.
14. Our details
- 14.1 This website is owned and operated by 64 Million Artists.
- 14.2 We are registered in England and Wales under registration number 09078048, and our
Our registered office is at The Exchange Co-Working Space, Somerset House Trust, Somerset House, Strand, London, WC2R 1LA
14.3 Our principal place of business is at The Exchange Co-Working Space, Somerset House Trust, Somerset House, Strand, London, WC2R 1LA
14.4 You can contact us:
(a) by post, to the postal address given above;
(d) by email, using firstname.lastname@example.org
15. Data protection officer
15.1 Our data protection officer’s contact details are: Laura Saxton – email@example.com.