Privacy Notice

Introduction

Bolton Symphony Orchestra (BSO) is a controller in relation to processing of personal data under the General Data Protection Regulation (GDPR).

This privacy notice provides details of the personal data processed by BSO and is intended to be compliant with the requirements of Article 13 GDPR.

Personal data processed

 

1. BSO members and officials

Purpose: To effectively manage records of players’ membership of BSO, as BSO is a subscription-based membership organisation whereby members pay an annual subscription to enjoy the benefits of membership, including participation in performances.

Lawful basis: Article 6(1)(f) GDPR (legitimate interests), the legitimate interest being the administration of a membership organisation.

 

Personal data processed: Name, postal address, email address, telephone number(s), instrument, membership status, GiftAid status.

 

Retention: Records will be deleted (or transferred to 'other musician' category) as soon as practicable after a person ceases to be either a member or an official, except in cases where GiftAid has been claimed, in which case records are retained for a period of 6 years, in line with HMRC requirements.

2. Other musicians and artistes

Purpose: To manage records of non-members who may be called upon to play with or perform alongside the BSO, as some performances require additional resources from outside of BSO membership.

 

Lawful basis: Article 6(1)(f) GDPR (legitimate interests), the legitimate interest being the maintenance of a pool of performers upon whom BSO can call.

 

Personal data processed: Name, email address, telephone number(s), instrument.

 

Retention: Perpetual, unless person exercises a right to the contrary.

3. BSO paid post-holders and associates

Purpose: To effectively manage contracts of engagement between persons and BSO, as BSO engages a small number of persons in remunerated roles (e.g. musical director, leader, etc.) and, on occasions, engages the services of soloists or other specialists for specific events.

 

Lawful basis: Article 6(1)(b) GDPR (performance of a contract).

 

Personal data processed: Name, postal address, email address, telephone number(s), terms of engagement.

 

Retention: Records will be deleted after a period of 6 years following the completion of the contract, in line with HMRC requirements for data retention.

4. Performers and audience members

Purpose: To capture the artistic output of the Orchestra, as it is important that BSO is able to publicise its work and attract audiences to future events so, occasionally, photographic, audio or video recordings may be made during rehearsals or concerts, and these materials may be used in marketing materials that are designed to promote BSO.

 

Lawful basis: Article 6(1)(f) GDPR (legitimate interests), the legitimate interest being the promotion of the artistic endeavours of BSO.

 

Personal data processed: Still images, motion video and audio recordings including persons present at events.

 

Retention: Not possible to specify, as may be used online or in printed materials.

5. Officials from other organisations

Purpose: To effectively manage BSO business, it is necessary to retain details of officials who act as contact points for organisations with which BSO collaborates (e.g. other ensembles, rehearsal/concert venues, Music Centres, etc.).

 

Lawful basis: Article 6(1)(f) GDPR (legitimate interests), the legitimate interest being the management of the Orchestra and its performances.

 

Personal data processed: Name, postal address, email address, telephone number(s), organisation, role.

 

Retention: Records will be deleted as soon as practicable after the are no longer relevant to BSO operations.

6. Free ticket offer participants

Purpose: To manage the issuing of tickets to events, as BSO will publicise the availability of free tickets for young persons (usually attendees of local Music Service organisations) and their parents/carers, in order to extend access to its artistic endeavours.

Interested persons are invited to submit their name, email address, child’s name(s) and lesson/group attended. The parent/carer’s name and number of tickets required (only) will be passed to the venue’s box office, in order that the tickets can be collected at the event.

 

Lawful basis: Article 6(1)(f) GDPR (legitimate interests), the legitimate interest being the promotion of the artistic endeavours of BSO.

 

Personal data processed: Parent/carer name, email address, child’s name, lesson/group attended, event attending, number of tickets.

 

Retention: Records will be deleted 12 months following the date of the event for which tickets were requested.

General

BSO does not process any data relating to persons booking online or buying tickets in person from concert venues or other outlets.

BSO will not disclose to third parties any personal data without the express consent of the data subject, other than to the extent required by law, e.g. in response to a lawful request from a law enforcement agency.

BSO does not process any special category data.

The BSO website (www.boltonsymphony.org.uk) does not use cookies.

Electronic marketing

Where BSO engages in direct marketing, for example by emailing persons who have expressed an interest in hearing about our events, such communication will be compliant with the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Data subject rights

 

The GDPR gives those whose personal data is being processed certain rights:

  • The right to be informed – you should be informed about how your data is being processed, and this privacy notice provides these details;

  • The right of access – you are entitled to receive a copy of the data being processed about you;

  • The right to rectification – you can have data stored about you corrected if you believe it to be incorrect;

  • The right to erasure – you are entitled to ask for any data stored on you to be deleted;

  • The right to restrict processing – you can ask that the purposes for which your details are processed is limited to certain purposes;

  • The right to data portability – you can ask us to provide you with a copy of your data or to provide it to another controller;

  • The right to object – you are able to request that your data is not processed;

  • Rights in relation to automated decision making and profiling – this is not relevant here as BSO does not undertake these types of processing.

Contacting us regarding processing of personal data

Any requests relating to personal data processed by BSO should be addressed to the Orchestra Manager at privacy@boltonsymphony.org.uk.

Complaints

 

If you are concerned about the way in which BSO is processing data, you have a right to raise this with a data protection supervisory authority in the EU Member State where you live or work, or where you believe an infringement occurred. The supervisory authority for the UK is the Information Commissioner’s Office which can be contacted on 0303 123 1113 or via https://ico.org.uk/make-a-complaint/.

Privacy notice last updated: 3 June 2020

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