Last Updated: 20 August 2020

Orchestra Europa is committed to protecting your privacy. We use the most up-to-date technologies to keep the information you give us secure and confidential, and to prevent unauthorised access to it.

The data we collect, process or use about our audiences and patrons is managed securely and in accordance with this privacy policy, the General Data Protection Regulation 2018, and the Privacy and Electronic Communications Regulations 2003.

This policy was updated 20 August 2020.

WHO WE ARE

Orchestra Europa is an arts organisation and a registered charity. We receive income from the public, commercial work and concert engagements, ticket sales, sponsorship, individual donations and trusts and foundations.

This privacy policy is provided on behalf of the following: Orchestra Europa Limited is a company limited by guarantee (registration number 05877721) and a registered charity (charity number 1116082).

OUR PRIVACY AND DATA PRINCIPLES

We are committed:

• To provide clear, honest and open information about how we use your data
• To give you the choice about how we use your data
• To use your data appropriately and in a way that would be reasonably expected by you
• To treat our supporters and donors with respect
• To only share your data with other organisations where you have given your consent for us to do so, or where we need to do so in order to fulfil our contract with you
• To be accountable and responsible: to take active steps to protect your data from harm, and to have separate and enhanced procedures for the use of sensitive data (such as data relating to under-18s or disability)
• To ensure our staff and partners (including suppliers and artists) understand these principles and their responsibilities in delivering them
   

WHAT INFORMATION DO WE COLLECT?

Buying tickets and making donations:

We store securely the information you give us when you buy a ticket or a membership, sign up for one of our events, make a donation or gift aid declaration, or communicate with us.

This may include:

• Name
• Postal address
• Telephone number(s)
• Email address
• Ticketing history
• Billing/payment information (we do not store your credit card details, except to process direct debits where applicable)
• Donation history
• Communications preferences
• Access requirements
• Information acquired via Cookies (see Cookie policy)
• Qualitative opinions or attitudes about our services and programme through surveys
• Other feedback (eg. complaints or compliments) you choose to send us

Email, Web Activity and Social Media:

We keep a record of the emails we send you, and we may track whether you receive or open them so we can make sure we are sending you the most relevant information. We may then track any subsequent actions online, such as buying a ticket.

Like most organisations, we receive and store certain details whenever you use the Orchestra Europa website. We use “cookies” to help us make our site – and the way you might use it – better. Cookies mean that a website will remember you and enable online transactions. It also helps us understand how you use our website, where we can make improvements and how best to tell our audiences about events they might be interested in, through recommendations on our own site, or adverts elsewhere on the internet.

More on our use of Cookies

From Third Parties:

Your name, email address, postal address and booking details may be shared with us by other organisations and websites, but only when you have indicated that you give your consent to be contacted by us. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

Information available Publicly:

This may include information regarding directorships or positions held on Trustee/governing boards found in places such as Companies House, the Charity Commission for England and Wales, your biography on your work website or LinkedIn, or as well as on other charity and arts organisations’ websites.

Sensitive data:

Any data regarding under 18s, disability or medical need, religion, political affiliation, sexuality or ethnicity is regarded as sensitive, and we take steps to ensure that any such information is only collected where necessary, is subject to enhanced security measures, used only for the purposes agreed, and erased when no longer necessary.

Details of payment card numbers and expiry dates etc. go through a secure server and to which Orchestra Europa does not have direct access. We do not keep your payment information for any purpose, except in order to process direct debits, the data for which are securely held.

WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

We aim to be open and transparent when we collect your personal data and we will not do anything you would not reasonably expect.

We will use your personal information to:

• Provide information you have asked us for.
  Make offers and complete orders of goods and services.
• Process donations that you make to us and keep you informed of how your donations are used to help the orchestra.
• Notify you of any changes to events or services, including our concerts and membership schemes, which may be relevant to you.
• Keep a record of your relationship with us.
• Analyse your personal information to create a profile of your interests and preferences so that we can contact you with information most relevant to you.
• Ask you to participate in surveys and market research.
• Improve our understanding of our audience through basic profiling, tracking of your activity on our website and your response to emails (or other communications) that we send you.
• Combine information you provide to us with information available from external sources, in order to gain a better understanding of our audiences, visitors and supporters. This helps us to make appropriate requests to customers and supporters who may be able and willing to give more than they already do. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would.
• Personalise adverts on social media that are tailored to your interests (depending on your settings or the privacy policies on social media and messaging services like Facebook, Twitter and Instagram, you might give third parties like Orchestra Europa permission to access information from those accounts or services).

*See Appendix 1 at the bottom of this policy for a table outlining the legal basis for processing the information outlined above.

SHARING YOUR INFORMATION

We will not share any personal details with any other third parties without your agreement, unless required in order to fulfil our contract with you, or allowed by law.

In general, the third-party providers used by us to fulfil our contract with you will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. These providers include our Ticketing Systems providers and Email and Mail distribution services. We have agreements in place to ensure that your data is secure at all times, and cannot be accessed or used for any other purpose.

We may share personal information with other organisations, particularly The Audience Agency, which uses it to analyse ticket sales for national and regional research into patterns of arts attendance in England. This assists with reporting to funders and strategic planning, helping us to make better business decisions. Your personal data is never used by them to contact you, nor passed or sold on to any other agencies or companies, and we have agreements in place to ensure this.

HOW LONG DO WE KEEP YOUR PERSONAL DETAILS?

The personal data collected by Orchestra Europa is evaluated periodically to determine whether it is current and still needs to be held.

Data is held by us for as long as is legally or practically necessary for our business. Once that period of necessity has passed, we have a regular programme of data suppression and deletion. This ensures that your data is not held indefinitely on our systems.

Subject to any legal retention requirements (e.g. VAT regulations require appropriate financial records to be retained for six years, Gift Aid regulations require appropriate records to be retained for seven years), you may notify Orchestra Europa if you do not wish your data to be held.

KEEPING YOUR DETAILS SAFE AND SECURE

When you book a ticket or tickets through Orchestra Europa directly your personal information is entered into our secure database.

If we collect your data on a paper form your personal data will be uploaded securely, once that process is complete, your personal data will not be kept in hard copy.

Your data is always held securely. Access to customer information is strictly controlled, and can only be accessed by people who need it to do their job. Certain data, for example some sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

We will only ever share your data in other circumstances if we have your explicit and informed consent as detailed above.

All information received by us is retrieved using secure technology. In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration.

RECEIVING FUNDRAISING COMMUNICATIONS

Orchestra Europa is a registered charity and we rely on generous philanthropic donations from our supporters. We are committed to treating our donors with respect.

We may send you information about our fundraising appeals, events and high-level memberships by post. To identify whether or not these might be suitable, we may look at your ticket history, if you have made a donation in the past, if your name has been suggested by a current supporter, or a volunteer member. We will only send these when we feel they would be relevant and of interest to you. If you would prefer not to receive any information about our fundraising activities, please be in touch using the contact details at the end of this policy.

GIVING YOU CONTROL

If you would rather NOT receive postal communications from us about relevant events and opportunities to support our work, you can ask to be removed from these lists (full details at the bottom of the policy).

When supplying your email address as part of a booking, you will be given the option to 'opt-out' of marketing communications about similar concerts and events, and unless you do so we will continue to send you information of this kind by email. You can unsubscribe at any point, using the link on each email, or by contacting us.

If you have opted out of marketing communications, we may still get in touch with you regarding your booking. For example, we may email you to give you important information about the event you’ve booked for with any changes that affect you.

If you have opted out of fundraising communications via email, we may still get in touch with you to service any active memberships of updates regarding existing event bookings (for example: artist or time changes for an Open Rehearsal).

If you do not respond to communications from Orchestra Europa for up to 10 years, we will not contact you again unless you re-activate your engagement with the Orchestra (i.e. request to receive marketing communications or book a ticket to a concert or attend an event).

YOUR RIGHTS

You have certain rights related to your personal data, which are outlined here. These include:

• The right to request a copy of personal information held about you
• The right to request that inaccuracies be corrected
• The right to request us to stop processing your personal data
• The right to lodge a complaint with the Information Commissioner's Office or Fundraising Regulator 

CONTACT US

Please contact us if you have any questions about how your data is used, wish to be removed from any communications or data processing activities, or employ any of the rights listed above.

Email us admin@orchestraeuropa.org

Or write to us at: Orchestra Europa, 23 Nevill Street, Abergavenny, Monmouthshire, NP7 5AA, United Kingdom

Last Updated: 20 August 2020

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