The Britten-Pears Foundation (the “Foundation”) is a company limited by guarantee registered in England and Wales (number 2071223) and is also registered as a charity (number 295595); its Registered Office is The Red House, Golf Lane, Aldeburgh, Suffolk IP15 5PZ.
The Britten-Pears Foundation is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
Data Protection Legislation means the Data Protection Act 2018 which incorporates the General Data Protection Regulation (GDPR), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legislation implemented in connection with the General Data Protection Regulation which is the governing legislation that regulates data protection across the EEA. This includes any replacement legislation coming into effect from time to time.
This Policy also applies to the wholly owned subsidiary of the Foundation, The Britten Estate Limited, a company limited by shares (registered number 2063903). The Britten Estate is the beneficiary of the royalty income from performances of Britten’s music which in turn is gift aided to the Foundation and accounts for the great majority of that organisation’s income.
What data do we hold?
We only collect information that we know we will genuinely use and in accordance with data protection legislation. The Foundation may hold data relating to you from a number of sources. The majority of personal data we hold is that which you have provided by signing up to our services, when you send us an update, volunteer your time, attend an event, make a donation, submit an enquiry or engage with us in any other way.
Our records may include:
- names of individuals
- postal addresses
- email addresses
- telephone numbers
- photographic likeness
- personal details – for example disability and dietary preferences for event management purposes
- your preferences – to help us engage with you in your preferred way
- plus any other information relating to individuals.
We may, in further dealings with you, extend this information to include your purchases, services used, and subscriptions, records of conversations and agreements and payment transactions.
- You are under no statutory or contractual requirement or obligation to provide us with your personal information; however we require at least the information above in order for us to deal with you as a member or service user in an efficient and effective manner.
The legal basis for processing your data is based on your specific consent/performance of a contract/compliance with a legal obligation/your vital interest or legitimate interest that we will have stated at the point the information was initially provided, therefore we will not store, process or transfer your data outside the parties detailed above unless we have an appropriate lawful reason to do so. (Different conditions apply to personal data held within the historic papers in the archive, which are retained permanently on the grounds of archiving in the public interest.)
Some personal information may be considered “sensitive personal data” under applicable data protection laws. Personal data revealing the following types of information are considered officially sensitive:
- racial or ethnic origin, political opinions, religious or philosophical beliefs;
- trade-union membership;
- genetic data or biometric data processed solely to identify a human being;
- health-related data;
- data concerning a person’s sex life or sexual orientation.
We will only process these data in accordance with applicable data protection laws.
How do we collect data from you?
We obtain information about you when you use our website, for example, when you contact us by email to make an enquiry, or buy a ticket for one of our events, or to make a donation, or if you register to receive our newsletter.
How do we use your data?
The Foundation primarily uses your data to communicate our activities. This can include:
- sending you e-newsletters and our events brochure
- inviting you to events
- selling you tickets
- seeking your views or comments on the services we provide
- asking you to support the Foundation by giving your time, experience or financial support.
- to contact you, following your enquiry, reply to any questions, suggestions, issues or complaints you have contacted us about;
These activities may include an element of direct marketing.
Communications may be sent to you by post, telephone, email, text or electronic means (for example through social media) depending on the communication preferences you have requested.
If you wish to amend your marketing preferences, you can do so by email email@example.com or by calling our office on 01728 451700.
The Foundation reviews the retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems only for as long as is necessary for the relevant activity.
Lawful basis for processing
There are three main bases under which we may process your data:
Contract purposes: When you made a purchase from us or make a donation to us, you are entering into a contract. In order to fulfill this contract, the Foundation needs to process and store your data. For example, we may need to contact you by email or telephone in the event of change of arrangements for one of the events, or in the case of problems with your payment.
Legitimate business interests: In certain situations the Foundation collects and processes your personal information for purposes that are in our legitimate interests. However, we only do this if there is no overriding prejudice to you by using your personal information in this way. The situations where we may use this basis for processing are archiving and research work, copyright requests and recording copyright holders, deposits and newsletters.
With your explicit consent: For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
In addition, information within our archive of historic documentation is held under the basis of archiving in the public interest. When information about an individual is held within this material – the papers of Britten, Pears, or allied individuals or organisations – it will be retained permanently, but processed in such a way as to ensure the privacy of the individual concerned during their lifetime and the period immediately after this. A separate Data Protection Policy exists for material held in the archive.
How will we share your data?
We may share your personal data with other organisations in the following circumstances:
- If the law or a public authority says we must share the personal data;
- If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
- We may pass your information onto our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary for them to deliver the service and they abide by Data Processing Agreements that require them to keep your information secure and not to use it for their own direct marketing purposes.
- Data may also be disclosed to other external organisations acting as agents for the Foundation, for example mailing houses for the mailing of publications or approved volunteers acting on behalf of the Foundation.
- Data in documents held within the archive of historic papers will be made available to the public but only if this does not infringe the privacy of the data subject. Any
The Foundation does not sell data to third parties or allow third parties to sell on data where data is shared with them.
How do we protect your data?
Data security is of great importance to the Foundation and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your collected data.
Your data is held securely on the Foundation’s computers and within emails. The servers are accessible to the Foundation’s staff all of whom have received the Foundation’s data protection training.
The Foundation ensures that appropriate data sharing agreements are in place prior to sharing your personal data with any external organisations.
Non-sensitive details (your email address etc) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, whilst we strive to protect your personal information, we cannot guarantee the security in transit of any information you send to us, and you do so at your own risk. Once we receive your information, we will make our best effort to ensure its security on our systems.
We take security measures to protect your information including:
- Limiting access to our buildings to those that we believe are entitled to be there (by use of passes, key card access and other related technologies);
- Implementing access controls to our information technology
- Using appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices and stores.
Your rights and preferences
Right to Access Your Personal Information
You have the right to access the personal information that we hold about you in many circumstances, by making a request. This is sometimes termed ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge and aim to do so within 30 days from when your identity has been confirmed.
We would ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If you would like to exercise this right, please contact us as set out below.
Right to Correction Your Personal Information
If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it.
If you would like to exercise this right, please contact us as set out below.
Right to Stop or Limit Our Processing of Your Data
You have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.
If you would like to exercise this right, please contact us as set out below.
Right to Object to Processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms, you have the right to do so. You also have the right to object where we are processing your personal data for direct marketing purposes. We will assess your objection and explain to you whether or not we have decided to stop processing your data (in some cases, we may demonstrate that we do have compelling legitimate grounds to process your information which override your rights and freedoms). You may appeal to the Information Commissioner if you are unhappy with any decision we take.
Right to Request the transfer of your personal data to you or to a third party
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right may only apply to automated information which you initially provided consent for The Foundation to use or where The Foundation used the information to perform a contract with you.
Right to Withdraw Consent
Where The Foundation is relying on consent to process your personal data, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. The Foundation will advise you if this is the case at the time you withdraw your consent.
If you no longer wish to receive communications by post, telephone, text email or other electronic means, please contact the Data Protection Officer, Dr Christopher Hilton, at 01728 451700 or firstname.lastname@example.org.
When contacting us pleased provide your name and other means by which we can identify you. Please also specify if you wish to unsubscribe from all communications or from specific communication types or channels.
If you ask us to delete your data, we will maintain a skeleton record comprising your name and postcode to ensure that we do not inadvertently contact you in the future. We may also need to retain some financial records for statutory purposes (for example Gift Aid).
For more information about your privacy rights
The Information Commissioner’s Office (ICO) regulates data protection and privacy matters in the UK. They make a lot of information accessible to consumers on their website and they ensure that the registered details of all data controllers such as ourselves are available publicly. You can access them here https://ico.org.uk/for-the-public.
You can make a complaint to the ICO at any time about the way we use your information. However, we hope that you would consider raising any issue or complaint you have with us first. Your satisfaction is extremely important to us, and we will always do our very best to solve any problems you may have.
How long we keep your information
We retain a record of your personal information in order to provide you with a high quality and consistent service. We will always retain your personal information in accordance with data protection legislation and never retain your information for longer than is necessary.
Unless otherwise required by law, your personal data will be stored for a period of two years after our last contact with you or some other identifiable action or period, at which point it will be deleted.
If you have submitted a historical enquiry to the archive team, after two years your personal details will be removed from the record of that enquiry, making it anonymous, but the factual substance of the enquiry and its answer will be retained in order to help the team if the same question arises again in future.
Giving your reviews and sharing your thoughts
When using our website (www.brittenpears.org) you may be able to share information through social networks like Facebook and Twitter: for example, when you ‘like’, ‘share’ or review our Services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so that you are comfortable with how your information is used and shared on them.
To control cookies use the controls in your browser. A summary of these is available on the All About Cookies website: http://www.allaboutcookies.org/manage-cookies/.
For more information on the law and cookies see the EU Cookie law page on the Information Commissioner’s Office website https://ico.org.uk/for-organisations/guide-to-pecr/cookies/
Essential Cookies: These cookies ensure the website performs and you can use all of its features.
Information cookies: These cookies collect anonymous information about how a website visitor uses the website. They are anonymous and don’t collect any information that could identify you. The benefit of this is it allows us to see how the website performs and which bits people want to use.
Website functions cookies: These cookies remember any preferences you might set when using the website. For example, if you set the text size and any customisation options. They can include comments and other forms completed on our website as well.
Third party cookies: Most third party cookies allow links to other websites. In particular this type of cookie connects to social and sharing websites like Facebook and Twitter. Using these cookies allows you to share interesting content without leaving the website.
Measuring website usage (Google Analytics)
We use Google Analytics to collect information about how people use this site. We do this to make sure it’s meeting its users’ needs and to understand how we could do it better.
Google Analytics stores information about what pages you visit, how long you are on the site, how you got here and what you click on. It also gathers general information about you such as your location, the language you use, and the type of device you use to view the site, and feeds that information to us in a general statistical overview. We do not receive, collect or store any of your personal information (e.g. your name or address) so this information cannot be used to identify who you are.
We also collect information on the number of times particular search terms are used and the number of failed searches. We use this information to improve access to the site and to identify gaps in the information content so we can plan appropriate expansion of the system. Unless the law allows us to, we do not:
- use this information to identify individuals.
- share any of the information we collect about you with others
This Privacy Notice will be kept under review. Any changes will be updated on our website and communicated to you as appropriate. This Privacy Notice was last updated in March 2019.
The Foundation’s Data Protection Officer is responsible for monitoring compliance with relevant legislation in relation to personal data and can be contacted at email@example.com.
You can also contact the DPO if you have any queries or concerns about the Foundation’s processing of your personal data. You have a right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns.