The Sixteen is committed to protecting your privacy. We will use the information that we collect about you in accordance with, the Privacy and Electronic Communications Regulations 2003, the Data Protection Act 1998 (DPA) and any replacement laws, and, from May 2018, the General Data Protection Regulation (GDPR).
Who we are
The Sixteen Ltd is a national arts organisation, a registered charity (No. 326917) and company limited by guarantee (No. 1930741). The Sixteen Productions Ltd (Registered in England No. 04252277) consists of CORO and CORO Connections and is a subsidiary and wholly owned by The Sixteen Ltd. Wherever The Sixteen is referred to in the policy it includes both The Sixteen Ltd and The Sixteen Productions Ltd.
What information do we collect?
The personal information that we collect includes:
• name, title, date of birth and gender
• contact details including postal address, email, phone numbers and links to social media accounts
• transaction history (we never store your whole card number, although we may keep a note of the last four digits to help us identify transactions)
• access requirements (for example if you require wheelchair access) and whether you have a disability defined by the Equality Act 2010
• details of visits to our website including traffic data, location data, operating system, browser usage, and the resources that you access
• other background personal information you provide to us (for example when you apply for a job, tell us your story, provide a reason for making a donation or correspond with us).
How do we collect your information?
You give us your information when you buy a ticket, buy something online (e.g. CDs, downloads etc), sign up for one of our events, update your preferences on our website, make a donation, apply for a job, or communicate with us. We also keep your details when you sign up to receive emails from us.
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 websites, we receive and store certain details whenever you use The Sixteen 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.
We may also receive information from external sources which enables us to gain a better understanding of our audiences and supporters and to improve our fundraising and marketing methods. These sources include:
Social media – we use social media to broadcast messages and updates about events and news. On occasion we may reply to comments or questions you make to us on social media platforms. You may also see adverts from us on social media that are tailored to your interests. Depending on your settings and the privacy policies used by social media and messaging services like Facebook, LinkedIn or Twitter, we may receive non-personally identifying demographic or analytical information from these services that enables us to better understand the reach and effectiveness of our advertising.
Information available publicly – this may include information found in places such as CompaniesHouse your biography on your work website or information that has been published in articles/ newspapers.
How we keep your details safe and secure
Your personal data will be held and processed on The Sixteen’s systems or systems managed by suppliers on behalf of The Sixteen.
We always seek to hold your data securely. Access to customer information is strictly controlled. The CRM system can only be accessed by people who need it to do their job. Certain data, for example sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it.
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 Shopify, payment services Secure Trading and SagePay, Email and Mail distribution services. We have agreements in place with each to ensure that your data is secure at all times, and cannot be accessed or used for any other purpose.
Our basis for processing your personal information and what we use it for
We aim to be clear when we collect your data and not to do anything you wouldn’t reasonably expect. We may process your personal data because it is necessary for the performance of a contract. For example, if you make a purchase, sign up for an event or give a donation.
We may process personal data because it is in our legitimate interests to do so. For example we may use your personal information to understand your reasons for donating to us, to better understand your interests, to carry out screening on potential donors and to conduct due diligence on major donors, to tailor our communications to you and/or to give you an exceptional experience at our events. We may also collect information about how you use our services (including our website) to analyse our customer base and improve our processes. The Sixteen also records and uses film, photographs and audio for promotional purposes on its website, social media accounts and other formats under its legitimate interests basis for processing where it would not be necessary, appropriate or practicable to obtain your specific consent (for example, we may seek specific consent for prominent or impactful uses, but typically not for group shots, background inclusion or internal use).
We may also process your personal data (including sensitive personal data) where:
• it is necessary for medical purposes (for example, in a medical emergency)
• it is necessary to protect your or another person’s vital interests
• we have your consent to do so (for example to monitor the diversity of visitors to events by The Sixteen).
Giving you control
We may tell you about events, concerts, shop offers and priority booking. You can opt out from these marketing communications at any time – every email sent to you will tell you how to do this. Please email email@example.com
If you have opted out of marketing communications, we may still get in touch with you in order to fulfil a contract. For example we may email you to give you important information about the events you’ve booked or to tell you about any changes.
Receiving fundraising communications
The Sixteen relies on charitable support to maintain our world-class activities and to make this available to everyone. We will occasionally tell you about our current campaigns and invite you to consider ways that you could make a real difference to our work along with invitations to events where you and your family can get closer to our artistic programme by joining one of our Patrons Circles.
We invite some people who might be interested in joining one of our supporter groups to special events eg. drinks receptions or rehearsals or to tell you about extra benefits including priority booking. Guests we invite might include current supporters, Patrons, people who have given donations in the past and audiences who attend concerts and events regularly.
Research, profiling and ‘wealth screening’
We want to ensure our communications to our supporters are personal, relevant and timely and we want to give you an enhanced experience when you attend events by introducing you to artists or members of staff that we think you might enjoy meeting. To ensure that our communications are relevant to you and your interests and to assess your likely ability to make, and interest in making, donations to The Sixteen, we may use additional information such as geographical information and measures of affluence where available from external sources to assist us. This will be a combination of publicly-available information, for example drawn from company resources and news media, with what you have provided to us, such as past donations and career information. We may use the services of external screening/profiling companies, and publicly available data from social media sites like LinkedIn, Facebook and Twitter, depending on your privacy settings and/or interaction with us.
The Sixteen may hold personal data that has been created by us from other personal data that we already hold about you, either from internal or external research/profiling. This may be carried out by automated or manual processes, and enables us to better understand you as our supporter and make appropriate requests for support.
If you do not wish The Sixteen to undertake this activity, please email firstname.lastname@example.org.
We may need to disclose your details:
• if we run an event in partnership with another named organisation so that they can help us run the event
• in order to comply with any legal obligation to do so. This includes the police and other crime protection and detection agencies or regulatory bodies
• to our legal advisors
• for the purposes of regulatory or inspection compliance, for example to the Charity Commission
• to funding bodies, particularly Arts Council England, who may use anonymised personal information to analyse our audience development programmes, ticket sales and self-generated funding to understand the impact of investment made in The Sixteen
• Data processing services acting in an accordance with our instructions, and subject to confidentiality obligations
We do not sell personal details to third parties for any purpose nor will we share your personal data with any other organisations or promoters.
How long do we keep your information?
The personal data collected by The Sixteen 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 The Sixteen if you do not wish your data to be held.
Under the DPA you have the following rights:
• to obtain access to, and copies of, the personal data that we hold about you
• to require that we cease processing your personal data if the processing is causing you damage or distress
• to require us not to send you marketing communications
Once the GDPR takes effect in May 2018, you will also have the following additional rights:
• to require us to correct the personal data we hold about you if it is incorrect
• to require us to erase your personal data
• to require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal)
• to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller
• to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
Patrons and Donors
What data do we process?
We will process your personal data only for specified purposes in order to provide you with a more efficient and personalised service. We collect the following data:
Names, address, phone number or email address. This information, provided by you, enables us to contact you about events and activities by The Sixteen, which in turn allows you to show interest in or support such activities.
Information regarding your relationship with The Sixteen, including events you have attended, donations you have made and communications you have had with members of staff.
Details of any donation you have made to The Sixteen including how it was received, date of receipt, whether it is giftaidable.
Information regarding your personal preferences, philanthropic history and capacity to donate. This may include information provided through publicly available sources such as LinkedIn etc.
We have ambassadors who promote the work of The Sixteen. They may provide us with information on those they consider to have a legitimate interest in our work. We will never contact an individual unless they have given us or our ambassadors permission to do so.
What do we use your data for?
To fulfil our obligations to supporters in terms of acknowledgement of their gift and agreed stewardship activities
To administer donations or other payments (concert tickets etc)
To keep you updated with activities of The Sixteen To offer you opportunities to engage further with our activities
To administrate giftaid claims
To prepare for events that you attend. The Development team will compile event briefing notes for our senior volunteers including information about your relationship with The Sixteen and your philanthropic interests. This information is kept strictly confidential.
How do we store your data?
Your data is kept on our encrypted server on our password protected database/computer only available to staff with a login.
Any personal data on hard copy is stored in locked cupboards. We also store bank and other payment details in secure systems.
What is the lawful basis for processing your data?
Current and former supporters
We rely on legitimate interest and fulfilment of contract when processing information relating to current supporters and recent former supporters
New or prospective supporters
For new or prospective supporters we will rely on an individual’s consent.
How long do we retain your data?
The personal data we collect are evaluated annually to determine whether they are current and still need to be held. There may be legal requirements for us to retain your data – e.g. tax regulations and the Charities Act 2011.
How to opt out
In accordance with Data Protection Law, you have a choice about whether you want to receive information about our fundraising activities and by which channels (e.g. telephone, email, post). Every effort will be made to contact you using your preferred contact method and to limit the frequency of non-personalised communications. You may opt out from receiving correspondence from the Development team at any time by emailing email@example.com, or calling 020 7936 3420.
General Administration: Trustees, staff, players, suppliers and business contacts
We collect information about our employees, musicians and contractors (e.g. agents, promoters, suppliers) for administrative and management purposes only. We retain and process it so that we can run our organisation and manage our relationship with you effectively, lawfully and appropriately. We must also process your personal data in order to comply with contractual and legal obligations, pursue the legitimate interests of our organisation, and protect our legal position in the event of legal proceedings. If you do not supply this data we may be unable in some circumstances to comply with our obligations. If this is the case we will tell you about the implications of that decision.
What data do we process and what do we use it for?
There are a number of areas of activity where we process data for staff, players and suppliers. In some instances we collect all or some of the following for general administrative purposes:
Company name (where relevant)
Bank details (for payment only)
Instrument played (where relevant)
Date of birth
National insurance number
Tax residence and status
For the administration of touring and logistics we collect:
Previous travel history
Names and details of family members
Relevant medical details
Biographical profile information
Photographs / film material
For on-going administration we keep a history of previous interactions, for example correspondence about fee agreements, project-related information etc, emergency contact details and references created at your requests for mortgage, employment or other purposes.
Your data is processed by the relevant Sixteen department to support the activity for which you have been engaged. We will only store and process your data when it is necessary to do so in order to support the activity for which you have been engaged.
For recruitment we collect:
Name, address, telephone number, email address
Work profile information and history
This information is collected exclusively for the purposes of recruitment for specific advertised posts. It is always given to us by candidates with a stated interest in such positions and is always deleted from our records once the recruitment process has been completed unless specific consent has been given to us to continue to hold the data.
For personnel administration we collate:
Contracts (including all personal data contained in them)
Right to work documents
Records of holiday, sickness and other absence (employees only)
Information needed for equal opportunities monitoring policy
Personnel-related information, for example appraisal and review of employees
For governance we collect:
Information about trustees (e.g name, address, contact details etc)
This information is collected in order to comply with submissions with external authorities, for example Companies House, the Charity Commission, auditors and banks.
We will only store and process your data when it is necessary to do so in order to support the activity for which you have been engaged by The Sixteen and we will never process your data where these interests are overridden by your own interests.
How we store your data
Your data will be kept confidential and is stored on our password protected computers on an encrypted server. Personal data on hard copy is stored in locked cupboards.
What is the lawful basis for processing your data?
Whenever you are engaged professionally with The Sixteen, you enter into a contract with us. In order to fulfil this contract we need to store and process your data.
We have a legitimate interest as an organisation in processing other data that help us effectively carry out our business – e.g. previous correspondence and project data for future touring. In all such cases we balance interests carefully and ensure there is no overriding prejudice to you by using your personal information in this way.
In such an event that the above lawful bases are not sufficient, we would ask for your consent. We only share your data with third-party organisations in a manner that is in your interests, that you would reasonably anticipate and that is necessary to support your professional engagement with us.
We are legally required to share personal data relating to work of The Sixteen with auditors and HRMC etc.
How long do we retain your data?
We are required to keep financial and most employment records for up to seven years. Some employment records need to be retained permanently. Passport and previous visa information are retained for no more than ten years. This is a requirement in some visa processing.
Where an artist has worked with us we may need to retain contact and payment details in order to make royalty payments. We also retain contracts, schedules, programmes and related biographical information, including audio-visual media on an indefinite basis.
How do you opt out?
You are entitled to object to us processing your personal data for any or all of the purposes set out in this privacy notice and may do so at any time. If you wish to do so, please contact firstname.lastname@example.org giving clear details of the processing and/or personal data to which your objection relates. Please note that if you do decide to opt out in this way, we may not be able to comply with our obligations and we will inform you of the possible implications of that decision.
What are your rights?
You have the right to:
Request a copy of the information we hold about you
Update or amend any incorrect information we hold about you
Ask us to stop processing your personal data and/or to remove it from our records
Raise a concern about how your information is being used
Make a complaint to The Sixteen using the email@example.com email address
Lodge a complaint relating to the use of your personal data with the Information Commissioner’s Office