Data Protection Law
TW complies with all data protection legislation. We have reviewed our policy in the light of recent changes. The General Data Protection Regulation (GDPR) applies in the UK and across the EU from May 2018. It requires personal data shall be:
1. Processed lawfully, fairly and in a transparent manner in relation to individuals;
2. Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research or statistical purposes shall not be considered to be incompatible with the initial purposes;
3. Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by GDPR in order to safeguard the rights and freedoms of individuals;
6. Processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
7. The controller shall be responsible for, and be able to demonstrate, compliance with the principles
TW DATA PROMISE STATEMENT
By registering for TW Activity, signing up to a TW mailing list, or by accepting our Data Promise Policy and Website Terms and Conditions, you give TW your consent to the collection, storage and use of your personal data in accordance with this Policy.
OUR METHODS OF INFORMATION COLLECTION
We collect personal information from you when:
* you visit our website
* you make ticket bookings and other purchases from us
* you take part in our activities or join one of our ensembles
* you support the organisation (including as a donor, member, volunteer or sponsor)
* you sign up to our e-newsletter or otherwise ask to receive information from us
* you complete audience surveys
* you enquire about our activities, services or job vacancies via direct emails, web forms, phone conversations, post or social media
* your details are passed on to us by a family member or occasionally by a third party where you have given them permission to share the data with us (e.g. a music venue or event organiser)
* or you otherwise provide us with personal information
We may also use information about you which is publicly available e.g. in newspapers.
THE TYPE OF PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
The types of personal information we collect and how we use that personal information depends on your relationship with TW and the consents that you have given about the use of your information.
It is important that you are aware that it is not compulsory that you provide any of this information. However, providing us information helps us to deliver services to you and if you do not provide this information it may impede our ability to communicate with you and provide any special or tailored services.
AUDIENCE MEMBERS, DONORS, FRIENDS, ALUMNI, AND PARENTS/GUARDIANS OF PARTICIPANTS UNDER 18
We may collect your name, home address, email address, telephone numbers, country of residence, bank or credit card details, your opinions about an event, product, service or issues, why you have decided to donate or support us and other information that you choose to provide to us.
We may then use that information to:
* provide you with event tickets, merchandise, and other goods and services which you have asked for
* process donations and Gift Aid
* keep a record of your relationship with us
* administer our various donor support and membership schemes
* send you information by post, telephone – and if you have given your consent, electronic means – about our gigs, albums, educational, fundraising and social programmes and events, our website, policies and occasionally about the products and services of our sponsors and supporters
* conduct fundraising activities including fundraising, marketing and reporting project updates and results to funders
* ask you to participate in surveys
* carry out market research
* create a profile of your interests, preferences and potential future donations (we may use additional publicly available information) so that we can contact you in the most appropriate way and with the most relevant information and ensure our fundraising resources are used in the most effective and efficient manner
* improve our understanding of audience, customer, participant and donor make-up and behaviour (including audience diversity so that we can measure our effectiveness and impact and report this to our funders) including through research and the creation of customer segments
* run, administer, operate and make improvements to our musical and charitable activities
* maintain data about our alumni information
FOR CURRENT PARTICIPANTS IN OUR ENSEMBLES, WORKSHOPS AND OTHER PROGRAMMES AND EVENTS
We may collect your name, postal address, email address, telephone numbers, date of birth, country of residence, any of the above details for your parent, guardian or next of kin, details of any medical conditions or allergies, access needs, details of your current and past schools, your opinions about our programmes and events, experiences of musical participants and other information that you choose to provide to us.
We use the information to:
* help us run, administer, develop and improve our educational and developmental programmes, events and ensembles
* send you information by post, telephone – and if you have given your consent, electronic means – about our educational, development and social programmes and events, our gigs, albums, CDs, educational, fundraising and social programmes, our website, policies and
* ask you to participate in surveys and market research
FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
* Participant records and records of parents of participants are retained for 3 years following their last known participation in a TW activity, with only an
outline record kept thereafter of name, dates, and activity except for alumni of the main band
* Individual donor records are kept for 6 years after the last donation
* On leaving any of our YADP ensembles main band, TW alumni will be invited to indefinitely join the TW alumni records
* Mailing list recipients and other contacts records are kept for 6 years from the last contact
* Financial records are kept for 6 years after the end of the financial year to which it pertains.
We will not send you marketing or fundraising information by email or other electronic means of communication without you expressly opting in your consent.
SHARING YOUR PERSONAL INFORMATION
Your personal information may be passed to third parties who provide services to us or with whom we run events or programmes but only for the purposes and uses of TW outlined above (e.g. to companies providing us with banking, ticketing, data-processing, survey-management and email distribution services). In such circumstances, we will wherever appropriate and feasible review their data protection policies and seek to obtain appropriate confidentiality and data-use undertakings to ensure appropriate protections for your data.
Except as set out above, and unless obliged to do so by law, we will not share your information with third parties (including for their marketing purposes) without your express consent.
UNSUBSCRIBING OR WITHDRAWING CONSENT
You can choose at any time to unsubscribe from marketing and fundraising communications by simply clicking the ‘unsubscribe’ link found in all of our marketing emails.
You also have a right to ask us to stop processing your personal data if your consent is required for that processing. To request this simply email the TW Data Controller at email@example.com
Some of the information which we collect from you (for example where you apply to take part in one of our education projects) may constitute sensitive personal data. We will only ever use this in accordance with our data protection policy and in order to carry out our objectives. TW shall maintain necessary measures to protect this information and its confidentiality. We will only use case studies about specific individuals where we have the consent of that individual or their parents or guardians.
SECURITY OF YOUR DATA
We will ensure that the personal information that you provide will be held securely, that there are appropriate technical controls in place to protect it and that only appropriately trained staff, volunteers and contractors have access to that information.
Unfortunately, the transmission of information via the internet to us is not completely secure. Although we will do our best to protect your personal information once we receive it, we cannot guarantee the security of your information as it is transmitted to our site and related servers. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
USERS UNDER 18
Where under 18’s are engaging with TW, it must be their parents/guardians providing that young person’s personal data, and consenting to TW’s use of that data.
LINKS TO THIRD PARTY WEBSITES
TW is not responsible for the privacy notices and practices of other websites even if accessed using links from our website. We recommend that you read their privacy policies.
TRANSFER OF YOUR PERSONAL INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA
Whilst the computer servers used to facilitate our website are located in the UK, by the nature of the Internet it is possible that the personal information you provide to TW may be transferred to countries outside the European Economic Area (EEA). For example, some of our suppliers including Dropbox and Mailchimp may run their operations outside the European Economic Area (EEA). We will take steps to try to ensure that they provide an adequate level of protection in accordance with the GDPR. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA (including in the United States).
HOW CAN YOU ACCESS THE INFORMATION WE HOLD ABOUT YOU?
You have the right to know what personal information we hold about you, and request to receive a copy of that information. To make a request, please send a description of what you want to see and proof of identity and address to the Data Controller at our postal address shown below. We will seek to respond within 30 days of receiving your request.
CONTACTING US AND UPDATING YOUR PERSONAL INFORMATION
We endeavour to keep your personal data accurate and up-to-date. If your information changes, you become aware of errors or inaccuracies, or if you have any questions about this Data Promise, including how we determine our legitimate interest and our full data management policy please email the TW Data Controller firstname.lastname@example.org call +44 (0)20 8424 2811, or write to us:
Tomorrow’s Warriors 73 Canning Road Harrow
HA3 7SP United Kingdom
Any complaints about this Policy or the use of your data should be made by email addressed to the Data Controller at info@tomorrowswarriors,org . If you are not satisfied with the response you also have the right complain to the Information Commissioner’s Office (ICO).
CHANGES TO THIS POLICY
This Policy was last updated on 30 April 2018.