This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal data. We may update this Policy from time to time without notice to you, so please check it regularly.
The provision of your personal data to us is voluntary. However, without providing us with your personal data, you will be unable to (as appropriate) join the campaign, sign a petition, make a donation, tell your story or apply to volunteer with us.
1. When do we collect information about you?
(1) When you give it to us DIRECTLY
You may give us your personal data in order to join the campaign, sign a petition, tell your story, answer one of our surveys or questionnaires, donate money to us, apply for employment or to volunteer with us, or when you contact us by phone, email or post.
(2) When you give it to us INDIRECTLY
Your information may be shared with us when you follow us or otherwise interact with us on or via Twitter, when you like and/or join our page on Facebook or Instagram, or interact with us in other ways on or via Facebook or Instagram.
(3) When you give permission to OTHER ORGANISATIONS to share it or it is AVAILABLE PUBLICLY
We may combine information you provide to us with information available from external publicly available sources. Depending on your privacy settings for social media services, we may also access information from those accounts or services. We use this information to gain a better understanding of you and to improve our communications and fundraising activities.
(4) When you visit our WEBSITE
We use the reCAPTCHA service provided by Google. This service allows us to verify that a user is a person rather than a machine in order to prevent forms on our website (such as the campaign sign-up form) from being (ab)used by spam bots (a bot is a computer programme that can interact with systems and can simulate human activity). When you fill in forms on our website, this tool will collect information about your use of the website page, including clicks, mouse movements and your IP address, so that Google can evaluate whether you are a person and not a bot. This information is collected by Google who only provide us with confirmation of whether the user is a real person (but it does not identify a user to us). For more information about Google’s use of information gathered through reCAPTCHA please read their privacy notice here.
2. What information do we collect?
We may collect, store and use the following kinds of personal data:
(1) We will typically hold your name and contact details, including physical address and/or postcode, telephone number, e-mail address, and social media identity. However, we may request other information where it is appropriate and relevant, for example
- Details of why you have decided to join us/support a petition;
- Details of your opinion on a particular issue or petition;
- Your bank details or debit/credit card details; or
- Details of petitions you have supported, details of topics/areas of interest to you, responses to surveys you have completed;
(2) information about your computer and about your visits to and use of this website including your IP address, geographical location, browser type, referral source, length of visit and number of page views;
(3) information about the services you use, services and products of interest to you or any marketing and/or communication preferences you give; and/or
(4) any other information shared with us as per clause 1
Do we process sensitive personal information?
Applicable law recognises certain categories of personal information as sensitive and therefore requiring more protection, including health information, ethnicity and political opinions. In limited cases, we may collect sensitive personal data about you (for example, when you sign a petition about a particular political issue or fill in a survey or questionnaire giving your opinion on a particular political issue). We would only collect sensitive personal data (also known as special category data) if there is a clear reason for doing so; and will only do so where applicable law allows.
3. How and why will we use your personal data?
Personal data, however provided to us, will be used for the purposes specified in this Policy or in relevant parts of the website.
We may use your personal information to:
- Enable you to use and/or learn about all of the services we offer;
- Send you information about our work, campaigns, organisation and any other information, products or services that we provide (this will not be done without your consent);
- Send you member surveys (see section 7 below) including for the purpose of conducting member research and profiling (see section 6 below);
- Provide you with the services, products or information you have requested;
Improve your browsing experience by personalising your interaction with our website;
- Handle the administration of any donation or other payment you make via credit/debit card, cheque, standing order or BACS transfer;
- Collect payments from you and send statements and/or receipts to you;
- Handle the administration of your employment and/or volunteering application;
- Conduct research into the impact of our work;
- Deal with enquiries and complaints made by or about you relating to the website or us in general;
- Make petition submissions to third parties, where you have signed the petition and the third party is a target of the petition;
- Incorporate your personal data into our promotional activities but only with your consent; and/or
- Audit and/or administer our accounts.
4. Signing a petition
If you would like to sign any petition on our website, you must provide us with personal information. We will take reasonable steps thereafter to ensure that your personal information remains accurate and up to date. You do not need to set up an account with us to sign a petition.
5. Uploading a video
You may upload or record a video in support of the campaign using our online video recording tool. When you choose to do this, we will obtain your consent to our use of your video. We will share such videos with third parties relevant to the campaign (such as MPs) who will separately be controllers and we may also use your videos for our own marketing purposes. When we refer to our own marketing purposes, we mean the use of your video to promote (i) a petition or campaign (which may be different to the one you have made a video to support), or (ii) the activities of the Public Campaign for the Arts in general. You always have the right to withdraw your consent to our use of your videos.
6. Member research/profiling
We may use your personal information to undertake research to gather further information about you from publicly accessible sources (as per clause 1 above).
We may combine this information with other personal information you have given us in the past, or which we collect via member surveys (see section 7 below) for this purpose. And we may collect demographic and attitudinal information for this analysis.
This may include creating member ‘personas’ and profiles of your interests. This helps us to get a better understanding of your background, interests and preferences in order to improve our communications and/or interactions with you, to help ensure they are targeted to be relevant and appropriate, and to provide information (sometimes through third parties) about petitions and other aspects of our work which we consider may be of interest to you. It also allows us to understand our membership better so that we can, for example, ensure our membership journey is tailored to our membership. Additionally it allows us to (i) focus our resources on issues of interest to our members, and (ii) send out communications through mediums (for example, we might focus on advertising in publications where most of our members get their news), that are of interest to our members.
We may analyse this information in anonymous/ aggregated form (so that it does not identify you) and share that analysis with key decision makers – for example, to tell MPs that hundreds of Public Campaign for the Arts members in their constituency support protecting arts funding.
We rely on our legitimate interests to undertake data processing for these purposes (see section 13 below). If we use your special category data (see section 2 above) for these purposes, we will obtain your explicit consent where necessary or rely on other conditions under applicable data protection law.
We may use third parties, such as data analysts, to assist us with undertaking this type of research and profiling.
Social media marketing
We may use some of your personal information to participate in Facebook and/or Instagram’s Custom Audience and Lookalike Audience programs, which enable us to display adverts to both existing and prospective supporters when they visit Facebook or Instagram. We may provide your email address to Facebook and/or Instagram so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access their platforms. Some of your data is sent in an encrypted format that is deleted by Facebook/Instagram (a) if it does not match with an account or (b) after they confirm you are a registered account holder. For more detailed information please see https://www.facebook.com/business/help/744354708981227 and Facebook’s data policy at https://en-gb.facebook.com/policy.php.
We also use a Facebook Pixel. This is a tool which lets us know if individuals have visited our website through Facebook, so that we can measure members’ engagement with us through Facebook and whether our use of Facebook is effective.
If you do not want us to share your email address with Facebook or Instagram (even in encrypted form), then you can ask us not to by contacting us at email@example.com. Please be aware that, if you are a Facebook or Instagram user, you may still see advertisements about the Public Campaign for the Arts in your feed even if we do not share your personal data with Facebook or Instagram. You can control what ads you see via your ad settings within Facebook and Instagram; we have no control over this.
7. Member surveys
From time to time (and in accordance with section 8 below) we may contact you (if you are a member) to ask you to complete surveys. Your participation in surveys is entirely voluntary and you do not need to provide us with any personal information you do not want to. We may ask you questions about your background, behaviours, and attitudes. We will then use this personal information for the purposes set out in this Policy, including to understand our membership better as explained in section 6 above. This includes improving our ability to send you more relevant communications. For example, if you tell us, in response to a survey, that you work in a theatre, we may send you information specific to issues affecting theatre staff.
8. Communications, fundraising and marketing
Email communications from the Public Campaign for the Arts are facilitated with Sendinblue.
Where you have provided us with your physical address, we may contact you by post; and where you have provided appropriate consent, also by telephone and e-mail, with targeted communications to let you know about our events and/or activities that we consider may be of particular interest; about the work of the Public Campaign for the Arts; and to ask for donations or other support (or to conduct member surveys – see section 7 above).
We may in the future communicate with you via focus groups, which may include online communications with you, and we may use other online messaging platforms such as WhatsApp.
In particular, where you have provided appropriate consent after signing a petition, we will send you updates in relation to the petition you have signed and from us in relation to other petitions and work undertaken by the Public Campaign for the Arts.
You can choose to stop receiving such communications from us at any time by clicking the “unsubscribe” link at the bottom of our emails.
9. Donations and other payments
Donations on our website are facilitated with Donorbox.
You may also donate to us using PayPal. If you donate using PayPal, your personal information will be provided to PayPal so they can process your donation. Please see their privacy notice for more information about how they use and retain your personal information: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
10. Children’s data
We do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are 15 and under and we are holding your personal information, we will delete that information within a reasonable period and withhold our services accordingly.
11. Other disclosures
12. Security of and access to your personal data
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to your personal information.
Your information is only accessible by appropriately trained staff, volunteers and contractors.
We may also use agencies and/or suppliers to process data on our behalf. We may also merge or partner with other organisations and in so doing transfer and/or acquire personal data.
Please note that some countries outside of the UK and European Economic Area (EEA) have a lower standard of protection for personal data, including lower security requirements and fewer rights for individuals. We may transfer and/or store personal data collected from you to and/or at a destination outside the UK and/or EEA. Such personal data may be processed by agencies and/or suppliers operating outside the UK and EEA. If we transfer and/or store your personal data outside the UK and EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your personal data.
13. Your rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following rights:
(1) Right to be informed – you have the right to be told how your personal information will be used. This Policy and other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
(2) Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will usually have 30 days to comply.
(3) Right of erasure – you can ask us for your personal information to be deleted from our records. In many cases we would propose to suppress further communications with you, rather than delete it.
(4) Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
(5) Right to restrict processing – you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
(6) Right to data portability – to the extent required by applicable data protection laws, where we are processing your personal information (i) under your consent, (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact or (iii) by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
To exercise these rights, please send a description of the personal information in question using the contact details in section 18 below.
Where we consider that the information with which you have provided us does not enable us to identify the personal information in question, we reserve the right to ask for (i) personal identification and/or (ii) further information.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult the Information Commissioner’s Office (“ICO”) guidance – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ – or please contact us using the details in section 18 below.
You are further entitled to make a complaint about us or the way we have processed your data to the ICO. For further information on how to exercise this right, please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us/.
14. Lawful processing
We are required to have one or more lawful grounds to process your personal information. Only 4 of these are relevant to us:
- Personal information is processed on the basis of a person’s consent
- Personal information is processed on the basis of a contractual relationship
- Personal information is processed on the basis of legal obligations
- Personal information is processed on the basis of legitimate interests
We will ask for your consent to use your information to send you electronic communications such as newsletters and marketing and fundraising emails, for targeted advertising and profiling, and if you ever share sensitive personal information with us.
(2) Contractual relationships
Most of our interactions with subscribers and website users are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you apply for employment or to volunteer with us.
(3) Legal obligations
Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
(4) Legitimate interests
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
We will rely on this ground to process your personal data when it is not practical or appropriate to ask for consent.
Achieving our purposes
These include (but are not limited to) promoting any philanthropic or benevolent purpose including without limitation to ensure the views and values of the world’s people shape global decisions
- Internal and external audit for financial or regulatory compliance purposes
- Statutory reporting
Publicity and income generation
- Conventional direct marketing and other forms of marketing, publicity or advertisement
- Unsolicited commercial or non-commercial messages, including petitions, newsletters, income generation or charitable fundraising
- Analysis, targeting and segmentation to develop and promote or strategy and improve communication efficiency
- Personalisation used to tailor and enhance your experience of our communications
- Employee and volunteer recording and monitoring for recruitment, safety, performance management or workforce planning purposes
- Provision and administration of staff benefits such as pensions
- Physical security, IT and network security
- Maintenance of suppression files
- Processing for historical, scientific or statistical purpose
Purely administrative purposes
- Responding to enquiries
- Delivery of requested products or information
- Communications designed to administer existing services including administration of campaigns and financial transactions
- Thank you communications and receipts
- Maintaining a supporter database and suppression lists
Financial Management and control
- Processing financial transactions and maintaining financial controls
- Prevention of fraud, misuse of services, or money laundering
- Enforcement of legal claims
- Reporting criminal acts and compliance with law enforcement agencies
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
15. Data retention
In general, unless still required in connection with the purpose(s) for which it was collected and/or is processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time.
In the event that you ask us to stop sending you direct marketing/fundraising/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
16. Policy amendments
17. Third party websites
18. Updating information
You can check the personal data we hold about you, and ask us to update it where necessary, by emailing us at firstname.lastname@example.org.
We are not required by law to have a “Data Protection Officer” – however we have a Data Protection Manager.
Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed by either emailing the Data Protection Manager at email@example.com or by writing to us at the following address:
The Data Protection Manager
Public Campaign for the Arts
24 Ashwin Street
London E8 3DL
Last updated: 30.07.20