This policy aims to explain fully and clearly what data we collect from you, what happens to that data, and what your rights are in relation to your data.
If we can clarify anything, or if we can improve the explanations we give, don’t hesitate to get in touch at firstname.lastname@example.org
This policy covers:
- Who are we?
- What data do we collect and why?
- – Statistical data
- – Contact data for the mailing list
- – Participant Data
- – Storing Participant Data
- – General Data Hosting
- – Photos and Film Footage
- – Take Down Policy
- – Working with Partners
- – When contacting us via email
- – Google Analytics
- How long will I stay on the mailing list?
- How can I stop you from sending me emails?
- What are my rights?
- Can I complain about how you are using my personal data?
This policy may be updated from time to time so please check back occasionally to make sure you’re happy with any changes.
By using our website or services you’re agreeing to be bound by this policy.
If you have any questions about this policy or our privacy practices you can email us at email@example.com or call us on +44 (0) 161 546 5334.
WHO ARE WE?
Brighter Sound is a creative music charity based in Manchester working across the North and nationally.
- Music making and creativity should be part of the lives of all children and young people
- Emerging musicians should be supported to develop their artistic confidence and originality
- The music sector should be equal and diverse
As a charity, we exist to provide services to support the above, and this includes providing useful information to our communities about music making opportunities, which are predominantly free of charge to attend. Our communities include young and emerging musicians, (including parents of young musicians and children), and other organisations and individuals that support young and emerging musicians. As this is our purpose as a charity we reserve the right to contact members of our community about opportunities that connect with our purpose as a charity, and to include any participants or applicants to our projects as part of our charity’s community. You can unsubscribe at any time by clicking ‘Unsubscribe’ at the bottom of our mailers.
Our registered address is:
Brighter Sound Ltd
c/o Chittenden Horley
456 Chester Road
We are a registered charity, number 1154803 and our company number is 5100495.
WHAT DATA DO WE COLLECT AND WHY?
We collect and use a number of different types of data, some of which is personally identifiable and some of which isn’t. We collect data to analyse and report on our projects and events to our funders, to help us communicate with subscribers and participants about opportunities and projects, and to improve our online reach and relevance.
You can read details of these below:
Brighter Sound collects information from all website visitors using statistics tools. This information includes (but is not limited to) the date and time of visit, browser name and version, IP address, and referring website. This information is used for evaluating and further developing the website for our digital audiences. No personal data is collected via statistics tools.
CONTACT DATA FOR THE MAILING LIST
When you sign up to our online mailing list we ask you to enter personal data in the form of your name, email address, your postcode and any preferences around what you’ll receive. Your email address is collected so we can send you updates about our work, and your postcode is used to identify the general location of our audiences, to inform our programme and to report to our funders which include Arts Council England, Youth Music, Manchester City Council, Greater Manchester Combined Authority, PRSf and Help Musicians UK, on the overall development of our audiences. The information we share with funders is not connected to personally identifiable information and is made up of aggregated data. We ask for your consent when joining our mailing list and this forms the lawful basis for us holding the data.
If you take part in a Brighter Sound project as a participant, we will collect data from you when you join or enrol which may include personal data: name, email, address, postcode, phone number, date of birth, gender, sexuality, ethnicity, and if required by the funder, may include information about barriers to learning, information about disabilities, emergency contact information, medical information, attendance information, information about progress and achievements.
This data is held securely and can only be accessed by members of the Brighter Sound team for whom it is relevant and necessary for them to do their job.
We will use our own internal database (GoodCRM) or Survey Monkey to register and store participant info. You can read Survey Monkey’s GDPR policy here. (For GoodCRM, see GENERAL DATA HOSTING below.
We will only ask for information that is required
- for reporting purposes by the funder or funders of the project, and our reports don’t include any personally identifiable information.
- for Brighter Sound to meet our duty of care and deliver our projects safely and to the highest standard.
- to notify participants of other useful opportunities via email communication
By signing up as a participant you agree to be contacted about opportunities and your contact information will be added to our mailing list. This enables us to inform you of changes or information about the project and future projects that may be of interest to you. You can unsubscribe from emails anytime by clicking the Unsubscribe button at the bottom of our emails.
STORING PARTICIPANT DATA
We keep information from our projects on record for seven years on our secure database (see ‘GENERAL DATA HOSTING’ below) so that we can analyse the progress and impact of our programmes, report to funders, and support participants to progress through our programmes – e.g. from project to project.
You can request that your personal information be removed from our database at anytime by requesting in writing to firstname.lastname@example.org. If you do this, we are required by our funders to retain any statistical and demographic data (attendance, ethnicity, postcode, gender, date of birth) but we will delete anything that identifies you individually (name, email, address, phone number etc.) Any data from your time as a participant will then be kept anonymously.
GENERAL DATA HOSTING
In order to store data and maintain our services we share your information (which we do so by uploading it to our database (Customer Relationship Management (CRM) system), including personal information and participation data, with third party service providers who perform various functions to enable us to provide our services and help us operate our business, such as contact management, sending email communications or performing analytics. Information is secured and encrypted on these sites.
Our contracts with these third parties require them to maintain the confidentiality of the Personal Information we provide to them, only act on our behalf and under our instructions, and not use Personal Information for purposes other than the product or service they’re providing to us or on our behalf.
Our mailing list is hosted by Good CRM using the following hosting providers: UKFast and Amazon hosting. You can read their data security policies here:
All data and assets are hosted on secure servers in Manchester and London.
PHOTOS AND FILM FOOTAGE
Photos and film are classed as personal information. We will from time to time photograph projects, including performances, workshop activity to use as evidence to report to our funders, to recruit participants for projects and in our general marketing. If you are over 18, by signing up as a participant you are agreeing to have your photo taken and be included in film footage unless you tell us otherwise when the photographer is present. We will always notify participants that a photographer or film maker will be at a session or event, and by bringing to our attention that you do not want to be photographed or filmed when this happens, we can ensure the photographer is aware of this at the time. If you are under 18, your parents will be asked for permission to capture your image through photo and film at the point you sign up. Those who do not receive permission must then also follow the clause below – ‘for those wishing not to be photographed or filmed’.
We may also from time to time photograph and film events. If this is the case, clear signage will be displayed to notify audience members that this is happening.
FOR THOSE WISHING NOT TO BE PHOTOGRAPHED OR FILMED
Any participants or audience members not wishing to be filmed or photographed must bring this to the attention of a member of staff, the photographer or the filmmaker so that measures can be taken to enable this. It is essential for the participant or audience member to work with the Brighter Sound team and the photographer / film maker so that we can take measures not to photograph or film you, as we rely on the ability to capture and use images to support our work, our recruitment and our marketing.
DISPLAYING PHOTOS AND FILM FOOTAGE
Photos and films are a central component of our marketing and are used in news pieces, event posts, blogs, social media and newsletters to represent our projects. This includes the use of photos from past projects being used to represent forthcoming projects. We do not share photos and film footage with third parties, other than funders with whom we have an obligation to share images for reporting purposes.
In using photos and film footage in this way, it is rare that names of subjects are featured with photos, however, occasionally we will include the names of subjects alongside a photo, or captioned in a film, with the following conditions:
Under 18s: We will not link an image with a name online or in print without additional express permission from a parent. Even with permission we will only seek to use first names for people under 18 years of age. Any participants not wishing to appear in photos or film of a project they are participating in must adhere to the clause above ‘For those wishing not to be photographed or filmed’.
Over 18s: With the exception of participants and audiences who have adhered to the clause above, (‘For those wishing not to be photographed or filmed’) Brighter Sound will use photos and film captured at projects and events. This may include naming participants connected with those photos, or tagging them in social media posts. If you are named in a publicly available piece of marketing content alongside a photo of you, even if you did not abstain from being photographed or filmed, you can contact us about this at anytime and we will investigate any changes you wish us to make, including removal of your name where possible, or by reverting to the Take Down Policy (below).
TAKE DOWN POLICY
Brighter Sound has a Take Down Policy which means that if you see a photo or a film in the public domain in which you appear where you have requested not to be included in line with the above clause (‘For those wishing not to be photographed or filmed’), you can inform us in writing to email@example.com with details of the photo or film and we will remove it immediately or take measures to edit accordingly where possible.
WORKING WITH PARTNERS
In order to deliver our projects we may need to share your information with GDPR compliant partners. These are organisations directly involved in the project itself and are usually other charities and arts organisations. This will be managed through a clear data sharing agreement. Your data will not be shared beyond the partners or passed to any third parties. The purpose of sharing data will be for reporting, managing safety at events or projects, and to support the sharing of relevant opportunities.
We will clearly display links to partners’ Privacy Policies at the point of sign up to events and projects.
WHEN CONTACTING US VIA EMAIL
If you contact the company via email – to any of our staff or other email addresses such as firstname.lastname@example.org or email@example.com you will not be added to our mailing list. Your email will be used by those email accounts only for correspondence relating to your enquiry or business issues relevant to you resulting from your email.
We use Google Analytics to inform us about our digital audience demographics, including: the age and gender of our users, along with the interests they express through their online travel and purchasing activities. We will use the data provided by Google Analytics to develop our website and content around our users’ interests. The data is provided in aggregate and is not personally identifiable to us.
HOW LONG WILL I STAY ON THE MAILING LIST?
Brighter Sound will regularly review our mailing list and refresh it by asking anyone that doesn’t open an email from us for twelve consecutive months to acknowledge their wish to keep receiving emails, or otherwise. You can unsubscribe at any time by clicking the Unsubscribe link at the bottom of emails.
HOW CAN I STOP YOU FROM SENDING ME EMAILS?
Under the GDPR you have the right to withdraw your consent to us holding your personal data. Should you choose to do this we are obliged to act on your request as soon as possible and at least within one month.
Every email we send you will have an unsubscribe option at the bottom and additionally you can send us an email at any time to firstname.lastname@example.org
WHAT ARE MY RIGHTS?
Under the General Data Protection Regulation (GDPR) anyone whose personal data is stored by Brighter Sound has a set of rights relating to it. Those rights are as follows:
- The right to be informed
- The right of access
- The right to rectification
- The right to erase
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
If you would like to exercise one or more of the rights in relation to the data we hold about you please let us know in writing and we will be happy to help.
For information on what these rights mean please visit the Information Commissioner’s Office website here
CAN I COMPLAIN ABOUT HOW YOU ARE USING MY PERSONAL DATA?
If you think we are handling your data incorrectly you should approach us in the first instance and we will do everything possible to rectify the situation. If you are not happy with our response you have a right to contact the supervisory authority, in this case the Information Commissioner’s Office.
You can lodge a complaint through their website here and in turn, they will deal with it.