PRIVACY POLICY

A. The types of information we collect

We only collect the information that is necessary to carry out normal business operations, to provide any good or services you’ve asked for, and to keep you updated about our current and future activities.

• Title, first name and last name
• Postal address
• Contact telephone number(s)
• Email address
• Date of birth
• Gender
• Payment information
• Gift Aid information
• Ticketing, membership and/or donation history
• Communications preferences
• Access requirements
• Photographs and/or video footage of audiences
• Any other information you provide to us by email, letter, telephone, social media, via our website or in person
• Anonymous information including demographic information you provide via surveys

Special categories of data

Some of the information that you give us, due to its nature, has more potential to cause harm if not handled correctly. “Special category data” is specific personal data that is often sensitive in nature and must be treated with extra care. The sensitive personal data we collect and hold about you will be collected anonymously and may include:

• Ethnicity
• Sexual orientation
• Religion
• Disability or long term health conditions

Such information shall only be collected after having obtained your explicit consent. We sometimes request sensitive personal data in our customer surveys, in order to assist us with our diversity monitoring, which we are required to report on as part of our funding. This data is not obligatory to provide, is analysed anonymously, and not linked to individual customer records.

B. How we collect your information

You give us information when you:

• Buy a ticket from one of our partner venues and have consented to share your data with us
• Buy a ticket from the Southbank Centre
• Make a donation
• Sign up for one of our events or workshops
• Join our supporter/membership scheme, audience participation or other schemes
• Sign up to receive marketing communications from us
• Visit our website
• Download our Clapping Music app
• Communicate with us via email, telephone, post or social media
• Fill out a survey
• Enter a competition or promotional event

Information received from third parties 

As a National Portfolio Organisation (NPO) of Arts Council England, the London Sinfonietta is required to enter into data sharing agreements with other NPOs, including the partners and venues we work with. This means that if you book a ticket for a London Sinfonietta event through one of these venues, you may be asked if you are happy to hear from us. If you do not wish to hear from the London Sinfonietta, you can leave this question blank (it often takes the form of an opt-in box) and we will not have access to your personal data nor be able to contact you. However, if you do wish to hear from us, please opt in at the point of booking, and you will receive an email from us shortly after the event has taken place, and be added to our mailing list. Your data will always be stored securely in our CRM system, and you are free to opt out of these communications at any time.

We may combine information you provide to us with information publicly available from external sources in order to gain a better understanding of our audiences, visitors and supporters to improve our fundraising methods. To make sure you only receive fundraising communications which are relevant, we may undertake research to help us better understand our supporters and to contact appropriate people who may be able to support us further.

As part of our fundraising, we may to seek to supplement booking information with qualified information such as publicly available information relating to your wealth, whether you are a trustee of a charity or have previously donated to similar charities, or raised funds for charitable purposes, in addition to your interest in the arts.

We achieve this by using resources to assist us in our fundraising, including using publicly available sources such as the Electoral Register, Companies House, the Charity Commission for England and Wales, your biography on your work website or LinkedIn, and other charity and arts organisations’ websites.

We also raise funds for our work using the online donation service donate2.com which is owned and operated by Lynch, Incorporated d/b/a L2 Interactive. If you donate to the London Sinfonietta through Donate2, they may share your personal details with us. Any donations that you give to the London Sinfonietta through Donate2 are covered under its terms and conditions.

The London Sinfonietta is the sole owner of the information collected on this website. Our website development partner has access to this information for website maintenance purposes only.

This website contains booking links to external sites, which are not governed by our privacy policy. We do not process payments of any kind through our website, and no financial or sensitive information is stored on our server, or on that of our web developer.

C. What we will use your personal information for

We will only collect the personal data that we need and use it on relevant lawful purposes as permitted by the current data protection legislation (UK GDPR, DPA 2018, and PECR).

We will use this information to:

• keep a record of the relationship we have with you;
• fulfil our contract with you;
• administer any donations you have made to us, including processing Gift Aid
• administer membership records, patrons’ records and giving schemes;
• ensure that our fundraising resources are used in the most effective and efficient manner and that any communications we may send you about fundraising are appropriate;
• inform you about any relevant events, services or activities that we believe may be of interest to you
• provide a personalised service and ensure that you have the best possible experience with the London Sinfonietta;
• ensure the information we hold is accurate and up to date;
• ensure we know how you prefer to be contacted;
• assist us with reporting and analysis for our own needs or for the needs of our funding partners;
• analyse your information and carry out a segmentation so that we can better understand customer and donor behaviour;
• Use this segmentation to tailor adverts on social media
• notify you about changes to our service;
• administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• improve our website to ensure that content is presented in the most effective manner for you and for your personal device;
• send you invitations to take part in research surveys, research discussion groups or interviews to give your opinions about our productions and services (whether or not you have agreed to receive other communications). Some of these may be carried out by market research agencies working for the London Sinfonietta and partner venues;
• conduct desktop research and fundraising activities to promote the interests of the London Sinfonietta as a charity;
• measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to protect against fraud or any unlawful activity;
• to ensure compliance with policies, procedures and law.

Our legal bases for processing your information

We aim to be clear when we collect your data and not to do anything you wouldn’t reasonably expect.

We will use your information for the purposes listed below under one of the following legal bases:

• Processing the personal data is necessary for the purpose of carrying out the contract, for example; Processing your donations and payments including making gift aid claims and enabling completion of orders of goods and services
• Processing the personal data is necessary for the purposes of our legitimate interests as the data controller (except where such interests are overridden by the interests, rights or freedoms of the individual), for example: keep you informed of how your donations are used; keep a record of your relationship with us; analyse your personal information to create a profile of your interests and preferences; use basic profiling, tracking activity on our website and your response to emails (or other communications) that we send you; combine information you provide to us with information available from publicly available external sources; personalise adverts on social media that are tailored to your interests; inform you by post of events and opportunities to support our work which may be of relevance to you; ask you to participate in surveys;
• Your consent (where we require it), for example to send you information you have asked for

Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email [email protected]

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to.

Fundraising communications 

We may send you information about our fundraising campaigns, events and our membership schemes. To identify whether or not these might be suitable, we may look at your ticket history, if you have made a donation in the past, or if your name has been suggested by a current London Sinfonietta supporter. We will only send these communications when we feel they would be relevant and of interest to you. If you would prefer not to receive any information about our fundraising activities, please contact us on [email protected].

Sharing your data with third parties 

Your personal data is never sold to any agencies or companies. We will only share data with third party providers on the legal bases as listed below:

Contract: 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 include services such as our CRM system (Tessitura), email service (WordFly), payment platform (Donate2) and mailing houses. We have agreements in place with each provider to ensure your data is secure and cannot be accessed or used for any other purpose.

Legitimate interests: we may make data available to approved suppliers and funders for analysis and research purposes, for example identifying sales trends, assessing campaign effectiveness, or postcode mapping etc (e.g., The Audience Agency, Counting What Counts Ltd). This assists us with reporting and with our strategic planning, helping us apply our resources more intelligently. All such agencies will be carefully checked and have a separate data processing agreement with us including non-disclosure agreements, and their Privacy Policies will have to be at least as secure as our own.

Sharing data outside the EU 

As part of the services offered to you, the personal information you provide may be transferred to countries outside the European Economic Area (EEA). For example, this may happen if any of the computer servers used to host our CRM system are located in a country outside of the EEA. If the London Sinfonietta transfers your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

D. How long we keep your data

We will keep personal data for no longer than is strictly necessary, having regard to the original purpose for which the data was processed. Once a retention period has passed, the personal data will be retained, erased, or securely destroyed in line with the retention policy listed in the London Sinfonietta’s Data Survey.

How we store your data  

Your personal data will be securely held and processed on the London Sinfonietta’s systems or systems managed by suppliers on behalf of the London Sinfonietta. We take steps to ensure that data is accurate, complete and up to date, and we regularly run checks to review our data. If you wish to correct any inaccuracies in your data, please email [email protected]

In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration. Access to customer information is strictly controlled, and can only be accessed by people who need it to do their job. Certain data, for example some sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors. We will only ever share your data in other circumstances if we have your explicit and informed consent as detailed above.

As a Resident Orchestra at Southbank Centre, we are also a member of its Tessitura Consortium; a CRM system managed by Southbank Centre and licenced by the Tessitura Network and Metropolitan Opera. We use it to securely store our customer data. Access to this data is strictly controlled, and can only be used by relevant staff members who need it in order to process communications and reports.

We use Tessitura as our main CRM system and therefore use it to hold and process our customer data, whether you are a customer of Southbank Centre or have consented for us to process your data via another venue or channel.

E. Your individual rights in relation to your data

Under data protection law, you have rights including:

• Your right of access: you have the right to ask us for copies of your personal information.
• Your right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Your right related to automated decision making including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

A. The types of information we collect

We only collect the information that is necessary to carry out normal business operations. We keep several categories of personal data on our artists and suppliers in order to carry out effective and efficient processes.

Specifically, we may hold the following types of data, as appropriate to your status and varies depending on whether you are an artist or a supplier:

• personal details such as title, name, postal address, contact telephone number(s), email address
• date of birth
• name and contact details of your next of kin
• instrument played (where relevant)
• national insurance number
• tax residence and status
• criminal convictions
• company name, business address, business contact telephone number(s), business email address
• bank account details
• PPL number
• Information relating to your work with us
• Access, health or dietary requirements
• Photographs, audio and/or video footage of you
• Biographical, educational and/or career information
• Any other information you provide to us by email, letter, telephone, social media, via our website or in person
• Anonymous information including demographic information you provide via surveys

Touring Information

If you are likely to tour with the Orchestra, or are visiting us from overseas, we will hold details purely for the purposes of visa processing, specifically:

• Passport details (including scans of key pages and visas)
• Names and details of family members
• Details of instruments
• Travel history
• Relevant medical details (if you choose to inform us).

Special categories of data

Some of the information that you give us, due to its nature, has more potential to cause harm if not handled correctly. “Special category data” is specific personal data that is often sensitive in nature and must be treated with extra care. The sensitive personal data we collect and hold about you may include:

• Disability and long-term health conditions
• Sexual orientation
• Ethnicity
• Religion

We carry out processing activities using special category data:

1. for the purposes of equal opportunities monitoring
2. to report to funders such as Arts Council England on the demographic of its workforce
3. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

1. you have given explicit consent to the processing
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
4. you have already made the data public.

We sometimes request sensitive personal data in our artist, participant and workforce surveys, in order to assist us with our diversity monitoring, which we are required to report on as part of our funding. This data is not obligatory to provide, and is analysed and reported anonymously on an aggregated basis. Where you have given explicit consent to do so, we may hold records of sensitive personal data against your individual data subject record. This consent can be withdrawn at any time by contacting the London Sinfonietta office.

Criminal Conviction Data

We will ask you to undertake a Disclosure and Barring Service (DBS) check when working with young people or vulnerable adults. We will retain the certificate on your behalf for proof that these processes were followed.

B. How we collect your information

D. How long we keep your data

We will keep personal data for no longer than is strictly necessary, having regard to the original purpose for which the data was processed. Once a retention period has passed, the personal data will be retained, erased, or securely destroyed in line with the retention policy listed in the London Sinfonietta’s Data Survey.

In some cases, we will be legally obliged to keep your data for a set period. Examples are below:

Income tax and NI returns, income tax records, and correspondence with HMRC: We are obliged to keep these records for not less than 7 years after the end of the financial year to which they relate.

Wage and salary records: We are obliged to keep these records for 7 years. Some employment records must be retained for longer.

Passport and visa details: We are obliged to keep these records for 10 years.

Where an artist has worked with us, we may need to retain contact and payment details in order to make royalty payments (e.g., for a recording or broadcast). These data will only be deleted after we are confident that no further royalty payments are due.

We also retain contracts, schedules, programmes and related biographical information for our artistic and Participation & Learning programmes, including images, audio and video material on an indefinite basis to use for future artistic planning and for reporting to funders including Arts Council England. As a publicly funded charity we will retain data, including anonymised data, on an indefinite basis in order to report, analyse and maintain public records of historical value.

How we store your data  

Your personal data will be securely held and processed on the London Sinfonietta’s systems or systems managed by suppliers on behalf of the London Sinfonietta. We take steps to ensure that data is accurate, complete and up to date, and we regularly run checks to review our data. If you wish to correct any inaccuracies in your data, please email [email protected].

In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration. Access to customer information is strictly controlled and can only be accessed by people who need it to do their job. Certain data, for example some sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors. We will only ever share your data in

E. Your individual rights in relation to your data

Under data protection law, you have rights including:

• Your right of access: you have the right to ask us for copies of your personal information.
• Your right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Your right related to automated decision-making including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

A. The types of information we collect

We only collect the information that is necessary to carry out normal business operations. We keep several categories of personal data on participants in our schemes in order to carry out effective and efficient processes. We keep this data in recruitment files relating to each programme and we also hold the data within our computer systems.

The types of information we hold may include:

• Personal details such as title, pronoun, name, postal address, contact telephone number(s), email address;
• name and contact details of your next of kin;
• Photographs, audio and/or video footage
• Gender
• Date of birth;
• Nationality
• Access, health or dietary requirements
• information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
• references from former education providers
• details on your career and education history
• Passport information or birth certificate
• Any other information you provide to us by email, letter, telephone, social media, via our website or in person
• Anonymous information including demographic information you provide via surveys

Special categories of data 

Some of the information that you give us, due to its nature, has more potential to cause harm if not handled correctly. “Special category data” is specific personal data that is often sensitive in nature and must be treated with extra care. The sensitive personal data we collect and hold about you may include:

• Disability and long term health conditions
• sexual orientation
• ethnicity
• religion

We carry out processing activities using special category data:

1. for the purposes of equal opportunities monitoring
2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

1. you have given explicit consent to the processing
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
4. you have already made the data public.

We sometimes request sensitive personal data in our applicant and participant surveys, in order to assist us with our diversity monitoring, which we are required to report on as part of our funding. This data is not obligatory to provide, is analysed anonymously, and not linked to individual data subject records.

B. How we collect your information

You provide several pieces of information to us directly during the applicant recruitment process via a form. In some cases, we will collect data about you from third parties, such as current and former teachers, or from educational institutions, when gathering references.

We may ask parents/guardians or schools to supply information about under 18s for participation in our projects or for performance licensing purposes.

Should you be successful in your application to our scheme, we will gather further information from you prior to and during your participation in the programme, for example, relevant medical information and access requirements.

C. What we will use your personal information for

We will only collect the personal data that we need and use it on relevant lawful purposes as permitted by the current data protection legislation (UK GDPR, DPA 2018, and PECR).

Our legal bases for processing your information 

We aim to be clear when we collect your data and not to do anything you wouldn’t reasonably expect.

We will use your information for the purposes listed below under one of the following legal bases:

• Processing the personal data is necessary for the purpose of carrying out the contract or agreement, for example for fulfilling recruitment for the scheme you have applied for;  making payments; or we will need to maintain that information for the general purposes of the ongoing relationship including fulfilling the scheme itself
• Processing the personnel data is necessary to comply with a legal obligation (e.g., Child Licensing, DBS checks, Health and Safety legislation); or
• Processing the personal data is necessary for the purposes of our legitimate interests as the data controller (except where such interests are overridden by the interests, rights or freedoms of the individual); for example, ask you to participate in surveys about your experience and provide feedback in focus groups where necessary; undertake the effective administration of our schemes including programmes of work with our partners; publish lists of participants names in programmes, and within selected donor and funder communications; and on occasion photos or audio-visual material; inform you of other schemes and participation & learning opportunities which may be of relevance to you;
• Your consent (where we require it), such as: publish names, photos or audio-visual material of under-18 participation & learning participants

Failure to provide data 

You are under no obligation to provide us with your data, however we may not be able to process, or continue with (as appropriate) your application for one of our projects or schemes if you do not.

Sharing your data with third parties  

We may share your data with third party organisations as listed below. All data shared will be in a manner that is in your best interests, that you would reasonably anticipate and is necessary to support your involvement with LS’s programme. We take steps to ensure that third parties have implemented appropriate technical and organisational measures to ensure the security of your data. These will include data processing agreements such as with software systems providers.  Your personal data is never sold to any agencies or companies.

Our professional advisers

• IT system providers (finance software system and arts management software)
• Payroll provider, according to your status
• Appropriate external regulators and authorities (such as HMRC and HSE)
• Local Education Authorities to apply for child licensing, where appropriate and necessary
• DBS check agency (Care Check)
• Travel and transport suppliers such as travel agents and transport companies for booking travel and accommodation
• Orchestra Managers, Promoters and Fixers within professional and recognised orchestras and ensembles
• Organisations we are partnered with or delivering work for such as schools and Higher Education Institutes
• Press and Social Media channels for event promotional purposes
• Funders such as Arts Council England, for reporting purposes and diversity monitoring

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us.

Sharing data outside the EU 

The personal information you provide may be transferred to countries outside the European Economic Area (EEA). For example, this may happen if any of the computer servers used to host our Arts management software system are located in a country outside of the EEA. If the London Sinfonietta transfers your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

D. How long we keep your data

We will keep personal data for no longer than is strictly necessary, having regard to the original purpose for which the data was processed. Once a retention period has passed, the personal data will be retained, erased, or securely destroyed in line with the retention policy listed in the London Sinfonietta’s Data Survey.

We will store personal information of participants and applicants for our participation & learning schemes in our database system(s) for a maximum of seven years. You  have the right to withdraw your consent for the processing of your data at any time. To withdraw your consent, please email [email protected]

Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to. There will be no consequences to withdrawing your consent.

We retain schedules, programmes and related biographical information for our artistic and participation & learning programmes, including images, audio and video material on an indefinite basis to use for future planning and for reporting to funders including Arts Council England. As a publicly funded charity we will retain data, including anonymised data, on an indefinite basis in order to report, analyse and maintain public records of historical value.

How we store your data 

We take steps to ensure that data is accurate, complete, and up to date, and we regularly run checks to review our data. If you wish to correct any inaccuracies in your data, please email [email protected].

Your data is always held securely. In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration.

Access is strictly controlled, and can only be accessed by people who need it to do their job. Certain data, for example some sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors. We will only ever share your data in other circumstances if we have your explicit and informed consent as detailed above.

E. Your individual rights in relation to your data

Under data protection law, you have rights including:

• Your right of access: you have the right to ask us for copies of your personal information.
• Your right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Your right related to automated decision-making including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

A. The types of information we collect

We only collect the information that is necessary to carry out normal business operations. We keep several categories of personal data on our prospective employees in order to carry out effective and efficient recruitment. We keep this data in recruitment files relating to each vacancy and we also hold the data within our computer systems, for example, recruitment logs.

Specifically, we hold the following types of data:

• Personal details such as title, name, postal address, contact telephone number(s), email address;
• your photograph, audio and/or video footage depending on recruitment method;
• your gender;
• Gender
• Date of birth;
• Access, health or dietary requirements
• information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
• right to work documentation
• references from former employers
• details on your education and employment history
• driving licence
• criminal convictions
• Any other information you provide to us by email, letter, telephone, social media, via our website or in person

Special categories of data 

Some of the information that you give us, due to its nature, has more potential to cause harm if not handled correctly. “Special category data” is specific personal data that is often sensitive in nature and must be treated with extra care. The sensitive personal data we collect and hold about you may include:

• Disability and long term health conditions
• Sexual orientation
• Ethnicity
• Religion

We carry out processing activities using special category data:

1. for the purposes of equal opportunities monitoring
2. to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

1. you have given explicit consent to the processing
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
4. you have already made the data public.

B. How we collect your information

A. The types of information we collect

We only collect the information that is necessary to carry out normal business operations. We keep several categories of personal data on our employees, former employees and workers in order to carry out effective and efficient processes. We keep this data in a personnel file relating to each individual and we also hold the data within our computer systems.

Specifically, we hold the following types of data, as appropriate to your status:

• personal details such as title, name, postal address, contact telephone number(s), email address;
• name and contact details of your next of kin;
• your photograph;
• your gender;
• marital status;
• information of any disability you have or other medical information;
• right to work documentation;
• Demographic information gathered for equality monitoring purposes;
• information gathered via the recruitment process such as that entered into a CV or included in a CV cover letter;
• references from former employers;
• details on your education and employment history etc;
• driving licence;
• Vehicle insurance details (where driving for work purposes)
• criminal convictions;
• National Insurance numbers;
• bank account details;
• tax codes;
• CCTV footage;
• building access card records;
• IT equipment use including telephones and internet access
• Any other information you provide to us by email, letter, telephone, social media, via our website or in person
• Information including anonymous information you provide via surveys
• information relating to your employment with us, including:
  • job title and job descriptions;
  • your salary;
  • your wider terms and conditions of employment;
  • details of formal and informal proceedings involving you such as letters of concern, disciplinary and grievance proceedings, your annual leave records, appraisal and performance information;
  • internal and external training undertaken; and
  • information on time off from work including sickness absence, family related leave etc.

Touring Information: If you are likely to tour with the Orchestra, we may also collect the following:

• Passport details (including scans of key pages and visas);
• Names and details of family members;
• Travel history; and
• Relevant medical details (if you choose to inform us).

B. How we collect your information

You provide several pieces of data to us directly during the recruitment period and subsequently upon the start of your employment.

In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references, or credit reference agencies. Personal data is kept in individual files or within the Company’s HR and IT systems.

C. What we will use your personal information for

We will only collect the personal data that we need and use it on relevant lawful purposes as permitted by the current data protection legislation (UK GDPR, DPA 2018, and PECR).

Our legal bases for processing your information

We aim to be clear when we collect your data and not to do anything you wouldn’t reasonably expect.

We will use your information for the purposes listed below under one of the following legal bases:

Special Category Data

Some of the information that you give us, due to its nature, has more potential to cause harm if not handled correctly. “Special category data” is specific personal data that is often sensitive in nature and must be treated with extra care. Special category data we may collect about you include: racial and ethnic origin, religious or philosophical beliefs, sexual orientation, and health data.

Special categories of data are data relating to your:

• health
• sex life
• sexual orientation
• race
• ethnic origin
• political opinion
• religion
• trade union membership
• genetic and biometric data.

We carry out processing activities using special category data:

• for the purposes of equal opportunities monitoring
• in our sickness absence management procedures
• to determine reasonable adjustments

Most commonly, we will process special categories of data when the following applies:

• you have given explicit consent to the processing
• we must process the data in order to carry out our legal obligations
• we must process data for reasons of substantial public interest
• you have already made the data public.

Criminal Conviction Data 

We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment. We use criminal conviction data to determine your suitability, or your continued suitability for the role. We rely on the lawful basis of legitimate interests to process this data.

Failure to provide data

Your failure to provide us with data may mean that we are unable to fulfil our requirements for entering into a contract of employment with you. This could include being unable to offer you employment, or administer contractual benefits.

Sharing your data with third parties

Employees within our company who have responsibility for recruitment, administration of payment and contractual benefits and the carrying out performance related procedures will have access to your data which is relevant to their function. All employees with such responsibility have been trained in ensuring data is processing in line with UK GDPR. We may share your data with third party organisations as listed below:

• Our professional advisers
• Appropriate external regulators and authorities (such as HMRC and HSE)
• Payroll provider (WSM Partners LLP)
• Pension Providers (Aviva)
• DBS check provider (Carecheck)
• Film and photography may be shared with media and social media outlets for promotional purposes
• Travel and transport suppliers such as travel agents and transport companies for booking travel and accommodation
• With other organisations we are partnered with (such as schools)
• We may also publish names, job titles and photos of staff in our printed literature and on our website

We may also share your data with third parties as part of a Company sale or restructure, or for other reasons to comply with a legal obligation upon us. We take steps to ensure that third parties have implemented appropriate technical and organisational measures to ensure the security of your data. These will include data processing agreements such as with software systems providers.

Sharing data outside the EU

The personal information you provide may be transferred to countries outside the European Economic Area (EEA). For example, this may happen if any of the computer servers used to host our arts management software system is located in a country outside of the EEA. If the London Sinfonietta transfers your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy.

D. How long we keep your data

We will keep personal data for no longer than is strictly necessary, having regard to the original purpose for which the data was processed. Once a retention period has passed, the personal data will be retained, erased, or securely destroyed in line with the retention policy listed in the London
Sinfonietta’s Data Survey.

In some cases, we will be legally obliged to keep your data for a set period. Examples are below:

• Income tax and NI returns, income tax records, and correspondence with HMRC: We are obliged to keep these records for not less than 7 years after the end of the financial year to which they relate.
• Wage and salary records: We are obliged to keep these records for 7 years. Some employment records must be retained for longer.
• Passport and visa details: We are obliged to keep these records for 10 years.

We also retain contracts, schedules, programmes and related biographical information, including images, audio and video material on an indefinite basis to use for future artistic planning and for reporting to funders including Arts Council England. As a publicly funded charity we will retain data, including anonymised data, on an indefinite basis in order to report, analyse and maintain public records of historical value.

How we store your data

Your personal data will be securely held and processed on the London Sinfonietta’s systems or systems managed by suppliers on behalf of the London Sinfonietta. We take steps to ensure that data is accurate, complete and up to date, and we regularly run checks to review our data. If you wish to correct any inaccuracies in your data, please email [email protected].

In order to provide a safe and secure environment for your personal information we use up to date technology with a view to protecting that information against loss, misuse or unauthorised alteration. Access to customer information is strictly controlled and can only be accessed by people who need it to do their job. Certain data, for example some sensitive information, is additionally controlled and is only made visible to members of staff who have a reason to work with it.

We may need to disclose your details if required to the police, regulatory bodies or legal advisors. We will only ever share your data in other circumstances if we have your explicit and informed consent as detailed above.

E. Your individual rights in relation to your data

Under data protection law, you have rights including:

• Your right of access: you have the right to ask us for copies of your personal information.
• Your right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
• Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.
• Your right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
• Your right related to automated decision-making including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

More information can be found on each of these rights in our separate policy on employee rights under UK GDPR.

Data integrity

We take steps to ensure that data is accurate, complete, and up to date, and we regularly run checks to review our data. If you wish to correct any inaccuracies in your data, please email [email protected]