This policy was last updated on 25 May 2018 in line with the introduction of the General Data Protection Regulation (GDPR).
Further information on data protection regulations and laws can be found here: https://ico.org.uk/for-the-public
Slung Low Limited is a company registered in England and Wales with the company number 07720259, registered at The HUB, 67-71 Bath Road, Holbeck, LS11 9UA. You can contact us via this address or via email at email@example.com if you have questions regarding your personal information or its use.
Slung Low Limited is the Data Controller of your personal information and will ensure it is used and stored in accordance with the Data Protection Act (1998), the Privacy and Electronic Communication Regulations (2003) and as of the 25th of May 2018, the EU General Data Protection Regulation (EU 2016/679).
WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW?
We may collect and retain information which provides information about you that can be used to identify you. We only collect the information that is necessary to carry on our business activity, provide the particular product or service you have requested and to keep you informed.
The type of personal data that we collect and how it is used depends on where and when it is gathered.
Information we obtain directly from you:
• When you ask to subscribe to our email newsletter we will collect your email address. We also give you the option to provide further personal information such as your name, age and where you live via the sign-up form on our website.
• When you sign up to the HUB Choir or apply to take part in a course or workshop we collect your name, email address, contact phone number and home address.
• When you get in touch to request use of the HUB space or technical equipment we collect your name, email address and contact phone number.
• When you get in touch to request use of the Slung Low vans we collect your name, email address, contact phone number, age, home address and driving license details to ensure that you meet insurance requirements.
• When you make a financial transaction directly with Slung Low such as a donation via the PayPal button on our website we may collect your name, email address, contact phone number(s), billing address and details of the amount donated.
• When you reserve a ticket via our box office partner Quaytickets we may collect your name, email address, contact phone number(s) and home address.
• If you have any access or dietary requirements.
• When you send an email to Slung Low, we will keep your email address for correspondence.
• We also keep a record of your interactions with us, such as what shows you have booked tickets to, any projects you may have participated in or supported and whether you have received, opened or clicked through any emails we may have sent.
• We collect information from feedback forms, both hard copy and online.
• When you post something about Slung Low publically on social media (eg Twitter, Facebook) we may record the post for use in publicity or for evaluation purposes. We also may reply to comments or questions you make to us on social media platforms.
• Job-related information, if you apply to work with us.
• Equal opportunities monitoring and other sensitive personal data. Only in certain circumstances and with your explicit consent would we look to request sensitive personal data such as ethnic origin, gender, gender identity, disability, age, sexual orientation and/or social-economic background for equal opportunities monitoring purposes. This data would be anonymised. We take steps to ensure that any sensitive personal data is only collected where necessary, is subject to enhanced security measures, used only for the purposes agreed, and erased when no longer necessary.
• When you visit our premises, we use CCTV recording equipment in and around our premises for monitoring and security purposes. CCTV cameras operate in the ‘front of house’ public areas of Slung Low’s HUB such as the bar and yard. They do not operate in private areas such as washrooms.
• When we are recording live, audio or still images to document an event, workshop or performance we will always have clear signage up stating why we are recording. Please speak to a member of staff at the time if you wish to not be recorded. These images may be used for archive or promotional purposes.
• When you visit websites run by Slung Low we may collect the following information:
– Automatically populated IP address: a public IP address is a unique number which allows a computer, group of computers or other internet connected device to browse the internet. The log file records the time and date of your visit, the pages that were requested, the referring website (if provided) and your internet browser version. This information is collected to help diagnose and manage the website, to audit the geographical make-up of visitors, and to establish how they have arrived at the website.
– Cookies: A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Some web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Information we obtain independently from you:
We may also collect information available publically such as information found in places such as Companies House, your biography on your work website or information that has been published in articles/ newspapers.
This is not an exhaustive list and we may retain different types of information for different individuals based on our activity and the service we are providing. We have defined retention periods for your personal data based on the nature of the relationship we have with you. For information on how long we retain your data for, please contact Slung Low’s Producer using the contact details at the end of this policy.
WHY AND HOW WE USE PERSONAL INFORMATION
We may use your information for the purposes listed below either on the basis of:
• performance of your contract with us and the provision of our services to you;
• your consent (where we request it);
• where we need to comply with a legal or regulatory obligation; or
• our legitimate interests (see below for further explanation).
Where we refer to using your information on the basis of our ‘legitimate interests’, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:
• personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
• detecting and preventing fraud and operating a safe and lawful business;
• improving security and optimisation of our network, sites and services; and
• providing you with customer service.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please get in touch using the contact details below.
Specifically, we use the information we collect from you in the following ways:
In the normal course of running our business, and to provide a service or carry out a contract with you:
• To fulfil ticket, booking or donation requests.
• To process payments.
• To contact you with important changes or information relating to your bookings.
Where we have your consent:
• To send you our general marketing newsletter with information about what’s on, offers and news or about supporting us.
• To share your details with other arts organisations whose work you may have seen at Slung Low’s HUB or co-producing partners.
• To collect sensitive personal date for Equal Opportunities monitoring or safeguarding.
• To process any job applications submitted to us and set up payroll, pension plan etc. for new employees.
Where we have justifiable reason (including legal obligation and legitimate interest):
• To keep in contact with you about our news, events, new site features, services, or productions that we believe may be of interest to you (on the basis of our legitimate interests to provide you with marketing communications where we may lawfully do so). This will be targeted and determined on a case-by-case basis; not to be confused with our general marketing newsletter for which consent is required.
• To interact with users on social media platforms including Facebook and Twitter, for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals).
• To carry out aggregated and anonymised research about general audience engagement with our sites and services (on the basis of our legitimate interest in providing the right kinds of services to our site users and audiences).
• To enable us to comply with laws, our policies and procedures, to enforce protect or defend, legal rights (including those of third parties such as producers of shows performed at the theatre), or to protect the rights, property or safety of our employees and to share information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
• To protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
• If we are required by law or requested by the police or a regulatory or government authority investigating potentially illegal activities to provide information concerning your activities, we will do so. We may also disclose personal data to appropriate third parties to assist in anti-fraud checks and investigations.
SHARING YOUR DATA WITH THIRD PARTIES
Slung Low will never share, sell, rent or trade personal information to any third parties for marketing purposes without your prior consent. We will ask for your consent to share personal information with like-minded organisations such as those who perform at our venue in Holbeck or our co-producing partners.
Some of our service providers may have access to personal data in order to perform services on our behalf such as payment processing. Those who provide such a service for Slung Low enter into an agreement with us and meet our standards for data security. We will ensure their compliance with the GDPR and they will not use the data for anything other than the clearly defined purpose relating to the service that they are providing.
There may be other instances when we are obliged to share personal data, for example if required to do so by the police or a regulatory or government authority investigating illegal activities.
HOW WE PROTECT PERSONAL DATA
Slung Low is committed to protecting the personal information entrusted to us. Only employees and approved contractors/developers appointed by Slung Low’s senior management team and who need the information to perform a specific job are granted access to personally identifiable information. We adopt robust and appropriate technologies and a Data Management Policy to protect your data from unauthorised access and improper use.
Slung Low may transfer your data to the USA to organisations such as Microsoft or Google. The USA has weaker data protection laws than that of the EEA and therefore we will ensure that only organisations who are a part of the EU privacy shield initiative will handle personal information. More details on this certification can be found at www.privacyshield.gov/welcome
Please note: Slung Low is not responsible for the privacy notices and practices of other websites even if accessed using links from www.slunglow.org and we recommend that you check the policy of each website you visit and contact its owner or Data Protection Officer if you have any concerns or questions.
Despite all our precautions, no data transmission over the internet is 100% secure. This means that we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention to the fact that you do so at your own risk.
GIVING YOU CONTROL
Personal data is your data and we want to make sure you feel in control of it.
If you are under 18, please ensure that you obtain your parent/guardian’s consent beforehand whenever you provide personal information to the website. If you don’t have that consent, you must not provide personal information to us.
We want it to be easy for you to access and amend the personal information that we hold on you, or request that we stop contacting you.
You can contact us by emailing or writing using our contact details below.
At any time you have the right to ask Slung Low to amend or stop how it uses your personal information, including for marketing purposes.
If you would like to see what information we hold about you, you can request full details of personal information we hold about you under The General Data Protection Regulation, by contacting Slung Low’s Producer via the contact details below. Please send a description of the information you would like to see, together with proof of your identity.
You have the right to have any of your personal data that is held by us corrected. If you have any concern about the accuracy of your personal data, please let us know using the below contact details.
If you would like us to remove the personal information we hold about you, please contact us using the below contact details.
You have the right to lodge a complaint with the supervisory authority, The Information Commissioner’s Office – www.ico.org.uk
Please contact us if you have any questions about how your data is used, or wish to be removed from any communications or data processing activities:
Email us: firstname.lastname@example.org
Or write to us at: Slung Low, The HUB, 67-71 Bath Road, Leeds LS11 9UA