Purpose of policy
We are committed to protecting your personal information and being transparent about what information we hold about you.
Using personal information allows us to develop a better understanding of our patrons and in turn to provide you with relevant and timely information about the work that we do - both on and off stage. As a charity, it also helps us to engage with potential donors and supporters.
The purpose of this policy is to give you a clear explanation about how we collect and use the information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
· What information we may collect about you
· How we may use that information
· In what situations we may disclose your details to third parties
· Information about how we keep your personal information secure, how we maintain it for and your rights to be able to access it
If you have any queries about this policy, please contact the Data Protection Officer at Stephen Joseph Theatre or email us.
Who we are
Scarborough Theatre Trust (trading name Stephen Joseph Theatre) is a charity and is funded by Arts Council England & Scarborough Borough Council as well as various trusts, foundations and individual donors and supporters. Our registered charity number in England and Wales is 253606 and we are registered as a company in England and Wales under registration number 815227. A company called Scarborough Theatre Development Trust manages our building; this company was set up with the single purpose of managing the building for the theatre.
We collect various types of information and in a number of ways:
Information you give us
For example, when you register on our website, buy tickets or make a donation, we’ll store personal information you give us such as your name, email address, postal address, telephone number and card details. We will also store a record of your purchases and donations.
Information about your interactions with us
For example, when you visit our website, we collect information about how you interact with our content and ads. When we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.
Information from third parties
We occasionally receive information about you from third parties. For example, we may use third party research companies to provide general information about you, compiled using publicly available data.
Sensitive personal data
Data Protection law recognises that certain categories of personal information are more sensitive such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our patrons unless there is a clear reason for doing so. [As an example, we collect health information about participants in our programme of classes and courses.] Any other sensitive personal data will only be collected anonymously for statistical reporting only.
There are three bases under which we may process your data:
When you make a purchase from us or make a donation to us, you are entering into a contract with us. In order to perform this contract, we need to process and store your data. For example, we may need to contact you by email or telephone in the case of cancellation of a show, or in the case of problems with your payment.
Legitimate business interests
In certain situations, we collect and process your personal data for purposes that are in our legitimate organisational interests. However, we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
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.
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about.
We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may object to receiving these at any time using the contact details at the end of this policy. In the case of email, we will give you an opportunity to opt out of receiving them during your first purchase with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.
We may also contact you about our work by telephone however we will always get explicit consent from you before doing this. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases (as above).
Other processing activities
In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:
· We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
· We may analyse data we hold about you in order to identify and prevent fraud.
· In order to improve our website we may analyse information about how you use it and the content and adverts that you interact with.
· We may use profiling techniques or third party wealth screening and insight companies to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you about potential philanthropic support. Such information is compiled using publicly available data about you.
In all of the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out the tasks above that are for your benefit.
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
· To the subsidiaries described above when it is necessary for them to be able to provide you with products or services that you’ve requested.
· To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
· Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
· To specific named visiting companies whose performances you have attended. In these cases we will always ask for your explicit consent before doing so.
· To approved audience development organisations to analyse anonymised data to provide marketing insights to inform our business decisions. In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
The SJT operates a CCTV system for the purposes of public safety and crime prevention. For further information contact the Theatre Manager.
Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your basket) as well to provide website operators with information on how the site is being used.
Your debit and credit card information
If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find more information about this standard here.
We optionally allow you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.
Maintaining your personal information
We store your personal information indefinitely such that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.
If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging in to your account through our website. Alternatively, please use the contact details at the end of this policy.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
Security of your personal information
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
Your rights to your personal information
You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please use the contact details at the end of this policy if you would like to exercise this right.
Contact details and further information
Stephen Joseph Theatre
Westborough, Scarborough, YO11 1JW
If you have any concerns regarding our handling of your data or if you wish to find out any further information on the law regarding data protection you can contact the Information Commissioner’s Office (ICO) on 0303 123 1113 or click here.
NHS Test and Trace recording staff, customer and visitor details: how we use your information
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.
By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.
As a customer/visitor of Stephen Joseph Theatre you will be asked to provide some basic information and contact details.
The following information will be collected:
· the names of all customers or visitors
· a contact phone number for each customer or visitor
· date of visit and arrival time and departure time
As the data controllers for the collection of your personal data, the SJT will be responsible for compliance with data protection legislation for the period of time it holds the information. When that information is requested by the NHS Test and Trace service, the service would at this point be responsible for compliance with data protection legislation for that period of time.
The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.
In addition, if you only interact with one member of staff during your visit, the name of the assigned staff member will be recorded alongside your information.
NHS Test and Trace have asked us to retain this information for 21 days from the date of your visit, to enable contact tracing to be carried out by NHS Test and Trace during that period. We will only share information with NHS Test and Trace if it is specifically requested by them.
For example, if another customer at the venue reported symptoms and subsequently tested positive, NHS Test and Trace can request the log of customer details for a particular time period (for example, this may be all customers who visited on a particular day or time-band, or over a 2-day period).
We will require you to pre-book appointments for visits or to complete a form on arrival.
Under government guidance, the information we collect may include information which we would not ordinarily collect from you and which we therefore collect only for the purpose of contact tracing. Information of this type will not be used for other purposes, and NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order). In addition, where the information is only collected for the purpose of contact tracing, it will be destroyed by us 21 days after the date of your visit.
However, the government guidance may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you (perhaps, for example, your name, date of birth and phone number). Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.
Your information will always be stored and used in compliance with the relevant data protection legislation.
The use of your information is covered by the General Data Protection Regulations Article 6 (1) (c) – a legal obligation to which we as a venue/establishment are subject to. The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.
By law, you have a number of rights as a data subject, such as the right to be informed, the right to access information held about you and the right to rectification of any inaccurate data that we hold about you.
You have the right to request that we erase personal data about you that we hold (although this is not an absolute right).
You have the right to request that we restrict processing of personal data about you that we hold in certain circumstances.
You have the right to object to processing of personal data about you on grounds relating to your particular situation (also again this right is not absolute).
If you are unhappy or wish to complain about how your information is used, you should contact a member of staff in the first instance to resolve your issue.
If you are still not satisfied, you can complain to the Information Commissioner’s Office. Their website address is www.ico.org.uk.
We keep our privacy notice under regular review, and we will make new versions available on our privacy notice page at https://www.sjt.uk.com/misc/privacy_policy
This privacy notice was last updated on 4 June 2021.