Privacy Policy

Privacy Policy for www.soundsymphony.co.uk

Oily Cart and Independent Arts Projects are committed to being transparent about how we collect and use your data, and to protecting your rights and privacy.

The Oily Cart Company is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

The purpose of this policy is to give you a clear understanding of how we collect your personal information from you directly and from third parties, how we use it, and how we keep it secure. If you have any questions about the ways in which we collect and use your personal information, please contact us.

Contact Details

Full name of legal entity: Oily Cart Theatre Company Ltd.

Charity no. 1000799, Company no. 02535040

Email: oilies@oilycart.org.uk

Postal Address: Oily Cart, Smallwood School Annexe, Smallwood Road, London SW17 0TW

Phone: 020 8672 6329

Name of Data Protection Officer: Zoë Lally – Executive Director

Processing of data includes obtaining, disclosing, recording, holding, using, erasing or destroying personal information. Oily Cart is registered with the Information Commissioner’s Office (ICO) and works within the framework of and in compliance with relevant legislation, regulations and ICO Guidance.

Lawful bases for processing an individual’s data

1. Consent: you have given clear consent for us to process your personal data for a specific purpose.

2. Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

3. Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

4. Vital interests: the processing is necessary to protect someone’s life.

5. Public task: the processing is necessary for us 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. (This cannot apply if we are a public authority processing data to perform our official tasks.)

How does Oily Cart protect your data?

We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and that it is secured, managed and accessed in accordance with our Data Protection Policy, and our legal responsibilities under privacy and data protection laws. If you would like a copy of our Data Protection Policy, please contact us using the details at the beginning of the policy.

Sharing Your Data

Only the data required will be processed and for the strict purpose which is specified; access will be restricted according to need and sensitivity.

We will always protect your personal details and will never sell them to, or share them with, other companies for marketing purposes. However, there may be occasions when we need to share your information with a third party; we have made clear where this is the case in the information below.

Some of our suppliers run their operations outside of the EEA. Although they may not be subject to the same data protection laws as companies based in the UK, we will take steps to ensure they provide an adequate level of protection in accordance with UK data protection law.

This website is jointly managed with Independent Arts Projects, Scotland, who may be able to access data that relates to your interaction with the website. The mailing list form sends personal data directly to Oily Cart and this will not be shared unless you specifically agree to this. If you wish to join the mailing list of Independent Arts Project please visit their website: http://www.independentartsprojects.com

How long does Oily Cart keep data?

We will not retain personal data for longer than is necessary for the purpose it is required, and we’ll ensure it is securely deleted when no longer needed. We will review data to reduce the risk of it becoming inaccurate, out of date or irrelevant. Where necessary, we have given further details about data retention policies in the information below.

What information does Oily Cart collect?

We only collect the information that’s necessary to carry out our business or to deliver our charitable objectives, provide the particular service you’ve requested and to keep you informed. The more ways that you engage with us as an organisation, the more data we will require in order to provide the necessary services required.

There are occasions where you can choose to not provide us with the information we require, but this may then impact the service we are able to provide.

We collect information from you when you engage us for obtaining information about the Sound Symphony Show. This information will relate to your name, e-mail address, telephone/mobile number, business or personal address, as is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Information relating to the usage of our website may be collected using cookies. These are text files placed on your computer to collect standard Internet log information and visitor behaviour information. We may use your information collected from the website to personalise your repeat visits to the site.

Why do we need to collect and use your personal data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect from you is essential for us to be able to carry out the services that you require from us effectively.

Where special category data is required, we will obtain your explicit consent to collect and process this information.

Website

When someone visits www.soundsymphony.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be upfront about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

You can opt out of being tracked by Google Analytics here: https://tools.google.com/dlpage/gaoptout

Use of Cookies

Cookies are small text files that are placed on your computer by websites that you visit. We use cookies to collect information about how visitors use our website, such as the number of visitors and the pages they have visited, which we use to compile reports and to help us improve the website. The cookies collect this information in an anonymous form.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

Mailing list

With your consent, we will add you to our mailing lists and contact you to let you know about our shows, tours, training opportunities, events, and the latest news about the company. You may also have told a venue where we perform that you are happy for them to pass your contact information to us to be added to our mailing list.

We will record your name, contact details and either address or location. This is so we can add you to our mailing list, and understand where our audience is from to help us create accessible, inclusive performances that reach a wide audience. We may also send newsletters targeted by area.

We use MailChimp for our email marketing. So, when you subscribe to our newsletter or download one of our reports, the email address, name and location details you submit will be held securely by them and the information also made accessible to us. MailChimp’s servers are based in the United States, so your information may be transferred to, stored, or processed in the US. MailChimp participates in and has certified its compliance with the EU- U.S. Privacy Shield Framework, which certifies that it has adequate safeguards in place. As a respected email marketing provider, MailChimp won’t share your information with any unauthorised third parties or contact you directly at any time – you can read their full privacy policy here: https://oilycart.org.uk/privacy/

In addition to the information you supply at sign-up, MailChimp will also capture data about your interactions with our emails and website, such as which links you click within an email and which pages you go on to visit on our website. It does this using a combination of tracking pixels and cookies. You can learn more about those in the Cookies section of this privacy policy. We use this information to help improve our product and provide more personalised messaging.

By default, we will retain your data in MailChimp for as long as you choose to stay subscribed or such time as we consider your account to be inactive (i.e. you are no longer opening or engaging with our emails). You can update your details or opt-out of our emails at any time using the ‘Unsubscribe’ or ‘Email Preferences’ links found at the bottom of every email we send via MailChimp. If you unsubscribe, MailChimp and Oily Cart will retain the information required (e.g. name, address, email address) for the purposes of a suppression list to ensure that no further marketing messages can be sent unless you actively choose to opt-in again.

Social media

We occasionally save anonymized social media comments or feedback. We use this information for evaluation, marketing and fundraising purposes, to help demonstrate the impact and reach of our work. This information may be shared on our website and social media channels, in materials promoting our work, at events, in documents such as annual company reports or project evaluation reports, or in funding applications or funding reports.

We also collect and track anonymised data on our social media audiences to better understand the ‘groups’ of people who engage with us online. We use this to ensure we engage with audiences and groups of people who are new to us. For more information on how to control your privacy settings for these services, go to the following links:

Facebook – Privacy Policy
Instagram – Privacy Policy
Twitter – Privacy Policy
YouTube – Privacy Policy
LinkedIn – Privacy Policy

Contacting us

If you have contacted us via email, our contact form, social media or phone, your contact details and a record of your message/s may be stored in our contact lists, and/or in our email and social media accounts.

Enquiries regarding research, training or advice will be stored while we handle your request. Any answers we provide may be stored, and an anonymised record of your enquiry will be included in our internal and/or board reports, to help us monitor and respond to requests. Your email address may be stored in our company contact lists or database. We will ask for your consent to email you specific training opportunities in future.

Fundraising

We are a registered charity and we rely on charitable support. We collect information in order to seek out new supporters and to maintain our current relationships. We are committed to fundraising best practice and abide by the Fundraising Regulator’s key principles and behaviours of a fundraising organisation: to be legal, open, honest and respectful. We undertake to comply with relevant law and regulations, including the Proceeds of Crime Act, Data Protection, Tax and Gift Aid legislation and Charity Commission guidance.

We undertake research on our data and through publicly available information in order to ensure that we can present customers with appropriate information and opportunities to learn more, and potentially support the Unicorn, in a number of ways:

Current donors

If you have donated money to us via our website, cheque, cash, or services in kind, we will keep a record of your contact details, the details of the gift (amount, date, purpose) and your Gift Aid status. We will keep this information for 7 years, in line with HMRC reporting guidelines. We do not currently publish this information anywhere, but if we would like to in the future we will contact you.

We will ask all individual donors for their consent for us to email them specific fundraising email communications, or email members invitations as per the benefits of their engagement with us. We will always endeavour to tell members about the aspects of our work that we think are most relevant to their interests. For higher level benefits we ask for permission or preference for accreditation. We respect the rights to anonymity if the donor so requests.

Performances and events

Where Oily Cart manages audience bookings, we will collect personal information such as name, contact details, any access needs, and address (where relevant) so we can contact bookers about the performance / event. Your details will only be shared with the Oily Cart core staff, except your address which will be shared with the wider performance / event team if it involves a visit / items being delivered to your home. We will only keep these details until the end of the relevant tour.

If we collaborate or partner with another named organization to deliver a performance / event and / or find audiences, your information may need to be shared. Where this is the case, both parties will make it clear what will happen to your data when it is shared and will not disclose your personal information.

Zoom Conferencing & Remote Performances

Oily Cart uses Zoom for remote meetings, rehearsals and performances. In order to facilitate these sessions, we may collect information that you provide, such as name, email address and consent for young people to participate.

Individuals engaging through Zoom will need to sign up to the Zoom service, and for their use of the service, Zoom will be the data controller. Data processed via Zoom is processed within the USA and safeguarded by the EU-US Privacy Shield Framework that enables the safe transfer of data under EU law. Visit their website to read the ZOOM Privacy Policy.

We use Zoom partner Otter.ai and live captioners to make remote meetings more accessible. Transcripts are saved and the Oily Cart team are able to access them afterwards. Data processed via Otter.ai is processed within the USA and safeguarded by the EU-US Privacy Shield Framework that enables the safe transfer of data under EU law. Visit their website to read the Otter.ai Privacy Policy.

Feedback and surveys

After our performances and events, we may want to ask for your feedback to find out what you thought for evaluation and reporting purposes, and to help us improve what we do. We will ask how you found out about the event, to help us market our work more effectively, and may ask where you have travelled from, so we can understand how far people travel to see our work. We’ll also ask for monitoring information, including ethnicity; this is to help us better understand our audiences, and to ensure we are offering an equally good service to everyone in our communities and reaching as wide an audience as possible. The information we collect on our feedback forms from you, including sensitive personal data, is saved anonymously and securely. Any forms you complete that identify who you are will be permanently deleted.

We may share some of the feedback for promotional purposes on our website and social media channels, printed marketing materials, at events, with press or with venues that we tour to. We may share collected information in documents such as annual company reports, project evaluation reports, or academic evaluation reports, to evaluate and monitor our work. We may also share the information with our funders or in funding applications, to help demonstrate the impact and reach of our work.

If we run an event in partnership with another named organization, your information may need to be shared. Where this is the case, we will make it clear what will happen to your data when we share it and we will not disclose your personal information. Whenever we share your information, it will always be anonymized and we will not share anything that will identify you.

We use CWC https://countingwhatcounts.co.uk as our Processor to power our Surveys and Participant Communications with you. We have signed a legally-binding agreement with NPO and ACE confirming it will only collect and store information about you according to our instructions, based on how we use their self-serve platform. CWC has taken steps to minimise the amount of personal data it can see or access when processing on our behalf and to make sure it’s appropriately secured. See the CWC Privacy Policy.

Photos & footage

We ask for explicit and informed consent of individuals, or their parent / guardian if they are under 18 or an at risk adult, to capture and share their image. An example of when we might capture photography and footage would be to document our productions and events for marketing and archival purposes, or as part of a preparation resource for a performance or event.

Images may be shared on our website and social media channels, printed marketing materials, at events, and with press or venues that we tour to. They may be shared with the Royal Holloway Archives and Special Collections for archival purposes, and with funders to help demonstrate the impact and reach of our work.

Third Parties we work with

We may also obtain your data from third parties, such as organisations with which we enter into a co-production. These organisations should not pass on your data to us without your knowledge and only if it is required in the performance of a contract. The third party will require your permission in order to share your data with us for marketing purposes and we will always notify you within 30 days of receipt of your data. You should check their Privacy Policy when you provide your information to understand fully how they will process and safeguard your data.

Your rights

As a data subject, you have a number of rights which you can exercise in relation to the information we hold about you – you can contact us about any of these by phoning, emailing or writing using our contact details set out at the top of this Privacy Policy.

You can:

– access and obtain a copy of your data on request;

– require Oily Cart to change incorrect or incomplete data;

– require the company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing; and

– object to the processing of your data where Oily Cart is relying on its legitimate interests as the legal ground for processing.

You have the right to lodge a complaint with the supervisory authority, The Information Commissioner’s Office – www.ico.org.uk

Are you under 18? If you are under 18, please ensure that you obtain your parent / guardian’s consent beforehand whenever you provide personal information to the website. If you don’t have that consent, you must not provide personal information to us.

Subject Access Request

If you would like to request a copy of the information we hold on file about you (either electronically or in physical form) Oily Cart will, in compliance with the Data Protection Act in relation to subject access requests, respond within one month. Any request will be subject to adequate identity checks before processing. Access requests can be made via email to: oilies@oilycart.org.uk.

Oily Cart will process all legitimate subject access requests free of charge unless requests made are deemed to be manifestly unfounded or excessive. In such cases, a reasonable and proportionate administrative fee will be applied to the request or, in exceptional cases, a request may be refused.

This policy was last updated March 2022.

This policy may be updated to take into account changes we have made, or to reflect changes to regulation or legislation. Updates to this policy will be posted on this page – please check back from time to time. We may also inform you of any changes where we hold an appropriate email address for you.

Further information on data protection regulations and laws can be found here:
Data Protection information by the Information Commissioner’s Office (ICO)
Fundraising Regulator – code of fundraising practice