Privacy Policy

Privacy Policy (Last Updated: 22 May 2018)

Sunderland Culture (we, our or us) is a new organisation created to bring together the cultural programmes of Sunderland City Council, University of Sunderland and Music, Arts and Culture (MAC) Trust (the Partner Organisations) into a single, independent, resilient delivery model and realise the ambition of a city brimming with creative potential.

Sunderland Culture works in National Glass Centre and Northern Gallery for Contemporary Art, Sunderland Museum & Winter Gardens, Arts Centre Washington, The Fire Station and delivers programmes of cultural engagement and events across the whole city. It works across the city to ensure the power of great art, culture and creativity is harnessed for the benefit of Sunderland, its residents and visitors. Sunderland Culture’s mission is to improve life for everyone in Sunderland through culture.

In order to run the Sunderland Culture campaigns for the benefit of Sunderland, its residents, businesses and visitors, we liaise and engage with you, as an employee, representative or agent of our Partner Organisations; as a stakeholder or investor; as a patron, advisor, sponsor, business partner, a member of an associated community group or a business contact in any other capacity (our Stakeholders).

We are committed to respecting your privacy and the security of your personal data, and this policy sets out the basis on which any personal data we collect from you, or that you provide to us], will be processed.  We are the Data Controller of any personal data we hold on you for our purposes, and when we share this data with any of our Partner Organisations, they will be a joint data controller.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Please use the sections below to read about how we process your personal data.

  1. Changes to our privacy policy

    • Any changes we may make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.
  2. Information we may collect from you

    • Personal data, or personal information, means any information about an individual from which that person can be identified.
  3. In some circumstances we may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes.

    We may collect, use, store and transfer different kinds of personal data about you, depending on the nature of our relationship with you and the ways in which you engage with us, which are listed in Purposes for which we use your personal data.

    • Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

    We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We may use special category personal data about you if you make that information manifestly public, for example if you are a representative of a political party and we invite you to an event in your official capacity.

    Where we need your data for the performance of our contract or a legal obligation, and you fail to provide it, it may mean we have to cancel that contract, so we will notify you at the time of the information we need.

  4. How is your personal data collected?

  5. We use different methods to collect data from and about you.

    • You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you, come along to an event and give us your business card, sponsor or support Sunderland Culture, take part in events or campaigns we are running, or otherwise express your interest or intent of involvement with us. We may also receive personal data about you from various third parties and public sources, including Sunderland City Council, Companies House, and LinkedIn.
    • As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookie. Please see our section on Cookies for further details.
  6. Purposes for which we will use your personal data

  7. We have set out below a description of the ways in which we may use your personal data, and what our legal basis under the General Data Protection regulation (GDPR) for that processing is.  We have also identified what our legitimate interests are where appropriate.

    A Legitimate Interest is an interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

    Purpose/Activity

    Lawful basis for processing

    To send you newsletters and keep you updated with Sunderland Culture. We will add you to our database if you sign up for our newsletters or marketing communications; if you ask to be added; or if we meet you at a business or networking event and you give us your contact details. We will then be contacting you on the basis of your consent, or our legitimate interest to foster business and stakeholder relationships for the purposes of the aims of Sunderland Culture.
    We may also send you updates, newsletters, listings or other information regarding the other Sunderland Culture venues and campaigns. We will only contact you for these purposes if you give us your consent, or in line with your marketing preferences.
    To send you service message updates and regular business communications regarding campaign or event details. This is on the performance of our contract with you.
    To manage payments and transactions We need to do this in performance of our contract with you.
    Asking you to leave a review or take a survey in relation to any of our campaigns We do this for the legitimate interest of improving the service we provide to businesses and the community.
    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);  to deliver relevant website content and understand the effectiveness of our publicity and advertising communications; We may need to use some technical data with is capable of identifying you. We do this on the legitimate interest of developing Sunderland Culture, our processes and strategy to create campaigns and events that are of maximum benefit to the community.

    Images

    We have a legitimate business interest to use photos of our events in marketing documents, communications, in annual reports and on our website or publicity documents. If you attend an event where we may be taking photos, you will see signs notifying you of this. If you are identifiable from any image that we wish to use, we will take every reasonable step to ask for your consent to use this image. If we do not have your consent, we will not use an image which we believe identifies you in any campaign posters, publications, or other publicly available documents. We may however use images from events on our social media. If we do use an image which you believe identifies you, and you would like us to take it down please contact [email protected]. We keep images on file for 7 years.

    Marketing

    If we contact you with newsletters or other news and updates regarding events, offers or promotions, we will either ask you for your consent, or alternatively we will send you materials we believe may be of interest to you as a legitimate business development interest. Whenever we send you marketing information, whether via email, post or text, we will provide you with an opportunity to object to this use of your personal data.

    We will not send you email updates or any other marketing communications if you indicate that you do not wish to receive them. You can change your marketing preferences anytime, by contacting [email protected].

    Social Media

    We like to engage with our Stakeholders via various social media platforms. Where you may have engaged with us on social media, we will liaise with you via the platform through which you are engaging, but we do not use the personal data you have made available on social media outside of that platform. The use of personal data on social media is governed by that platform’s own privacy policy or terms and conditions.

  8. Disclosure of your personal data

  9. We may share your personal information with the Partner Organisations and venues listed above. Sunderland Culture will manage your personal data securely to contact you only for the purposes of your relationship with us, and in line with your marketing preferences.

    We may share your information with selected third parties including:

    • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, which includes payment providers such as PayPal; newsletter service providers such as MailChimp
    • analytics and search engine providers that assist us in the improvement and optimisation of our Site; and
    • credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

    We may disclose your personal information to third parties:

    • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
    • if all, or substantially all, of our assets are acquired by a third party, in which case personal data held by us about our stakeholders will be one of the transferred assets; and
    • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of our stakeholders, or others.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

    We do not transfer personal data outside the European Economic Area (EEA).

    Data Retention

    We only keep your personal data as already indicated above, of for as long as is necessary for the purposes which it is provided. We will contact you from time to time to make sure you want to stay on our marketing database, and by law we have to keep basic information about our stakeholders for six years after they cease being stakeholders for tax purposes.

    Where the information we have on you is not for marketing or purchase transitions, the Sunderland Culture personal data is retained in line with our stakeholder retention policy, which is available here: https://www.sunderland.ac.uk/help/corporate-legal/publication-scheme/policies-and-procedures/

    As we continue to update and revise our data protection procedures and practices we may update this retention policy. Please check back from time to time or contact [address] to see how long your data may be held on file.

    In some circumstances you can ask us to delete your data: see Right to be forgotten below for further information.

    In some circumstances we may anonymise your personal data so that it can no longer be associated with you, for historic, research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  10. Security

  11. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. However, the transmission of information via the internet is not completely secure. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  12. Cookies

  13. Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience.

    We use cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer and/or device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer and/or device.

    This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage, but will not store, save or collect personal information.

    Third-party cookies

    We work with third-party suppliers who may also set cookies on our Site, for example Twitter, Facebook and LinkedIn. These third-party suppliers are responsible for the cookies they set on our website. If you want further information please go to the website for the relevant third party.

    How to turn off cookies

    If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to: www.aboutcookies.org or www.allaboutcookies.org

    Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.

  14. Your rights

  15. You have the right to:

    Request access to your personal data, known as a “data subject access request”.

    Request correction of any inaccurate personal data that we hold about you.

    Request erasure of your personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for legal reasons.

    Object to processing of your personal data where we are relying on a legitimate interest. In some cases, we may demonstrate that we have compelling grounds to continue processing your information which override your request.

    You also have the right to object where we are processing your personal data for direct marketing purposes.

    Request restriction of processing of your personal data while we establish the data’s accuracy; if our use is unlawful; to hold it on file in order to establish, exercise or defend legal claims; while we process your request to object to processing based on a legitimate interest.

    Request the transfer of your automated personal data in a structured machine-readable format where we used the information to perform a contract with you, or you gave us your consent to process it.

    Withdraw consent at any time where we are relying on consent to process your personal data.

    Complain you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

  16. Contact

  17. Questions, comments and requests regarding this privacy policy are welcomed. Please contact us at [email protected]