West Sussex Music Trust
Privacy Notice
Version: 3
Date: 1 January 2023
Review date: 1 January 2025
Author: James Underwood, Chief Executive, West Sussex Music Trust
Responsible
Trustee: Chairman of West Sussex Music Trust
2 – Privacy Notice
This is the privacy notice of West Sussex Music Trust. In this document, “we”, “our”, or “us” refer to West Sussex Music Trust.
We are company number 88524556 registered in England. Our registered office is at Herbert Shiner School, South Grove, Petworth, West Sussex GU28 0EE.
Introduction
1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately. This may affect the services we are able to provide to you.
3. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
4. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
6. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org.
7. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The basis on which we process information about you.
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
1. Information we process because we have a contractual obligation with you.
When you create an account on our website, hire an item, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1. process a lesson application or lesson enquiry for your child that you have submitted
2. provide you with an instrument hire
3. process a donation or gift aid submission that you have made
4. deal with a volunteering enquiry
5. respond to an ’expression of interest’ in one of our offerings
6. seek your views or comments on the services we provide
7. notify you of changes to our services
8. send you communications which you have requested and that may be of interest to you. These may include information about excursions, events, concerts, musical opportunities, appeals or other fundraising
9. advertise activities, promotions of our associated hub partner goods and services
10. process a job application.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We will do this to comply with our contractual and regulatory obligations in respect of reporting to the Arts Council.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business,( including job opportunities, musical events, excursions, instrument hire, volunteering, becoming a patron donations, gift aid and any other of our musical opportunities and products and services,) you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists. You may withdraw your consent at any time by instructing us music@westsussexmusic.co.uk. However, if you do so, you may not be able to use our website or our services further.
3. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
4. Vital interests
This applies when processing the data is necessary to protect a person’s life or in a medical situation.
Specific uses of information you provide to us
5. Complaints regarding content on our website
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
6. Information relating to your method of payment
In the event that we require you to provide your payment information, we take the following measures to protect your payment information:
6.1. We keep your payment information encrypted on our servers
6.2. We prevent any other third party from carrying out a transaction without your consent
6.3. Access to your payment information is restricted to authorised staff only.
At the point of payment via our website, you are transferred to a secure page on the website of WorldPay or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
7. Information about Direct Debit (where available)
When you agree to set up a Direct Debit arrangement, the information you give to us through our secure portal is passed to your bank for processing according to instructions.
We are registered under the Direct Debit Guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct Debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.
8. Job application and employment
If you send us information in connection with a job application, we may keep it for up to 6 months in case we decide to contact you at a later date. We will ask for your consent if we wish to retain your details for longer than 6 months.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
9. Volunteering
If you send us information in connection with a volunteering application, we may keep it for up to 6 months in case we decide to contact you at a later date. We will ask for your consent if we wish to retain your details for longer than 6 months.
If you join us as a volunteer, we collect information about you and your volunteer service from time to time throughout the period of your volunteering with us. This information will be used only for purposes directly relevant to your volunteer activities. After your time as a volunteer has ended, we will keep your file for one year before destroying or deleting it.
10. Gift Aid Forms
If you agree to Gift Aid, we must keep your signed Gift Aid declaration record for 6 years under HMRC rules.
11. Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our organisation.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.
12. Complaining
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems when you visit our website
13. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.
We use cookies in the following ways:
13.1. to track how you use our website
13.2. to record whether you have seen specific messages we display on our website
13.3. to keep you signed in our site
13.4. to record your answers to surveys and questionnaires on our site while you complete them
13.5. to record the conversation thread during a live chat with our support team
We provide more information about the cookies we use in our cookie policy.
14. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
15. Credit reference
To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.
16. Data may be processed outside the European Union
Our websites are hosted in the United Kingdom.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
Access to your own information
17. Access to your personal information
17.1. At any time you may review or update personally identifiable information that we hold about you, by emailing music@westsussexmusic.co.uk.
17.2. To obtain a copy of any information that is not provided on our website you may send us a request at music@westsussexmusic.co.uk.
17.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
18. Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at music@westsussexmusic.co.uk
This may limit the service we can provide to you.
19. Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
20. Use of site by children
20.1. If you are under 18, you may use our website or services only with consent from a parent or guardian
20.2. We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.
20.3. Such child users and visitors will inevitably visit other parts of the site and will be subject to whatever on-site marketing they find, wherever they visit.
21. Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
22. How you can complain
22.1. If you are not happy with our privacy policy, or if have any complaint, then you should tell us by email. Our address is music@westsussexmusic.co.uk
22.2. For further information about our complaint handling procedure, email music@westsussexmusic.co.uk.
22.3. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
22.4. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
23. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
23.1. to provide you with the services you have requested;
23.2. to comply with other law, including for the period demanded by our tax
authorities;
23.3. to support a claim or defence in court.
24. Compliance with the law
Our privacy notice has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you. However, ultimately it is your choice as to whether you wish to use our website and/or our services.
25. Review of this privacy notice
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy notice, please contact us.