Privacy and Cookie Policy
At the London Sinfonietta, we respect your right to privacy and take it very seriously. We promise to respect any personal information you share with us and to keep it safe.
This policy explains who we are, what information we collect, how and why we use it, how it is stored, how we fundraise, which partners we work with, and your rights with regard to any information you share with us.
Please read this information carefully, as by providing your data to us you acknowledge you have read this policy and understand we will process your data in accordance with its terms.
Please revisit this document on a regular basis to see any updates or changes to our Privacy Policy.
Who we are
Sinfonietta Productions Limited (“London Sinfonietta”, “we”, “us” and “our”) is an independent registered charity registered in England and Wales (Charity number 225095). We are registered with the Fundraising Regulator and are compliant with the Fundraising Code of Practice.
For the purpose of UK GDPR, the data controller is Sinfonietta Productions Limited, London Sinfonietta, Kings Place, 90 York Way, London, N1 9AG (ICO registration Z7581838).
We promise to use the information we collect about you in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act (DPA 2018) and the Privacy and Electronic Communications Regulations (PECR, 2003). We aim to be clear when we handle your data, and not do anything you wouldn’t reasonably expect.
Contact us
If you have any comments, queries or requests about this Privacy Policy please contact us at info@londonsinfonietta.org.uk
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.
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:
- for the purposes of equal opportunities monitoring
- 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.
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, is analysed anonymously, and not linked to individual data subject records.
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.
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:
- for the purposes of equal opportunities monitoring
- 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.
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.
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:
- for the purposes of equal opportunities monitoring
- 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.
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 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 Pioneers, Sinfonietta Circle or Entrepreneurs schemes
- Sign up to receive marketing communications from us
- Sign up to Couch to Concert or other audience participation schemes
- Sign up to our Curious? scheme for under 30s
- 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 (Un.Titled) 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 partner Un.Titled.
Artists
We will collect your information when you work with us as an artist or musician.
If you are an artist who has not yet worked with the London Sinfonietta, due to the nature of the classical music sector it is possible that we will obtain your personal information from a third party which may include recommendations from other organisations/clients, recommendations from internal members of the organisation or publicly available information about you from your website or that of your agent.
Suppliers
We will collect your information when we engage your services or enter into a contract with you.
We may collect your information if you are prospecting work e.g. share a business card, send an introductory email, or if you have been recommended to us.
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.
You provide several pieces of information to us directly during the recruitment exercise.
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.
Should you be successful in your application, we will gather further information from you, for example, your bank details and next of kin details, once your employment begins. Further details can be found in our Privacy Notice for Employees which will be issued to you upon employment.
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).
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 info@londonsinfonietta.org.uk
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 by post. 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 info@londonsinfonietta.org.uk or 020 7014 2826.
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.
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 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, or to take steps to enter into a contract or agreement; or we will need to maintain that information for the general purposes of the ongoing relationship including performing the employment or other contract; or
- Processing the personnel data is necessary to comply with a legal obligation (e.g., employment law, DBS checks, Health and Safety legislation and ensuring tax and NI is paid where appropriate); 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 keep a record of your relationship with us; undertake the effective administration of our work including programmes of work with our artistic partners; ask you to participate in surveys about your experience and provide feedback in focus groups where necessary; publish artists information including audio visual material on our website, in event programmes, and in donor and funder communications
- Your consent (where we require it)
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. 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 professional work with LS. 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 (WSM Partners LLP), according to your status
- Appropriate external regulators and authorities (such as HMRC and HSE)
- Pension Providers (Aviva), according to your status
- DBS check agency (Care Check)
- Travel and transport suppliers such as travel agents and transport companies for booking travel and accommodation
- Organisations we are partnered with or delivering work for such as schools and Higher Education Institutes
- Orchestra Managers, Promoters and Fixers within professional and recognised orchestras and ensembles
- Providing references to prospective employers, when our name has been put forward by the supplier or artist
- 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 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.
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 (WSM Partners LLP), 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.
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 will use your information for the purposes listed below under one of the following legal bases:
- Processing the personnel data is necessary to comply with a legal obligation (e.g., carrying out checks in relation to your right to work in the UK, ensuring compliance with Health & Safety legislation; making DBS checks where necessary at the point of application and making reasonable adjustments for disabled applicants); 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 make recruitment decisions in relation to both initial and subsequent employment; making decisions about salary, contractual benefits or other benefits to provide to you; assessing training and development needs; dealing with legal claims made against us; preventing fraud; keep a record of your relationship with us; ask you to participate in surveys about your experience as an applicant
- Your consent (where we require it); for example to inform you of further employment opportunities which may be relevant to you
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 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.
Data is shared with third parties for the following reasons: anonymous equality and diversity monitoring, and in order to make DBS checks, as advised, and in accordance with, the requirements of the role.
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.
We do not share your data with bodies outside of the European Economic Area.
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:
Activity requiring your data | Legal basis |
---|---|
Carry out the employment contract that we have entered into with you e.g. using your name, contact details, education history, information on any disciplinary, grievance procedures involving you | Performance of the contract |
Ensuring you are paid | Performance of the contract |
Ensuring tax and National Insurance is paid | Legal obligation |
Carrying out checks in relation to your right to work in the UK | Legal obligation |
Making reasonable adjustments for disabled employees | Legal obligation |
Ensuring a safe and healthy working environment | Legal obligation |
Ensuring effective and safe management of work travel and touring where appropriate to your role | Legitimate interests |
Making recruitment decisions in relation to both initial and subsequent employment e.g. promotion | Legitimate interests |
Making decisions about salary and other benefits | Legitimate interests |
Ensuring efficient administration of contractual benefits to you | Legitimate interests |
Effectively monitoring both your conduct, including timekeeping and attendance, and your performance and to undertake procedures where necessary | Legitimate interests |
Maintaining comprehensive up to date personnel records about you to ensure, amongst other things, effective correspondence can be achieved and appropriate contact points in the event of an emergency are maintained | Legitimate interests |
Implementing grievance procedures | Legitimate interests |
Assessing training needs | Legitimate interests |
Implementing an effective sickness absence management system including monitoring the amount of leave and subsequent actions to be taken including the making of reasonable adjustments | Legitimate interests |
Gaining expert medical opinion when making decisions about your fitness for work | Legitimate interests |
Managing statutory leave and pay systems such as maternity leave and pay etc | Legitimate interests |
Business planning and restructuring exercises | Legitimate interests |
Dealing with legal claims made against us | Legitimate interests |
Preventing fraud | Legitimate interests |
Ensuring our administrative and IT systems are secure and robust against unauthorised access | Legitimate interests |
Providing employment references to prospective employers, when our name has been put forward by the employee/ex-employee, to assist with their effective recruitment decisions | Legitimate interests |
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.
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 info@londonsinfonietta.org.uk
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.
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 info@londonsinfonietta.org.uk.
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.
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 info@londonsinfonietta.org.uk
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 info@londonsinfonietta.org.uk.
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.
We only keep your data for as long as we need it for, which, in relation to unsuccessful candidates, is six months to a year.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for one year once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future position vacancies, and you have provided consent, we will keep your data for two years once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
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 info@londonsinfonietta.org.uk
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.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
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 info@londonsinfonietta.org.uk.
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.
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 info@londonsinfonietta.org.uk.
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.
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.
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.
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.
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 info@londonsinfonietta.org.uk or call 020 7014 2826.
Cookie Policy
At the London Sinfonietta, we respect your right to privacy and we are committed to protecting your personal data. This cookie notice will inform you as to how and what cookies are used on this site.
For details about your privacy rights and how the law protects you please see our Privacy Notice which can be viewed above.
Cookies
In order to provide you with the best browsing experience, our website uses cookies. Cookies are small text files that are stored in your web browser (e.g Google Chrome, or Microsoft Edge) on your computer, tablet or mobile phone, to enable functionality on a website. Cookies are used for the following purposes: to enable certain functions; provide analytics, store your preferences, and for online advertising.
You can set your browser to refuse browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may not function properly. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit All About Cookies.
How does this website use cookies?
This website places cookies for Google Analytics, which enables the behaviour of users on a website to be analysed, to help identify what kind of content site visitors like and don't like and to help us to provide the best user experience. All the data we collect is anonymous and cannot be used to identify individuals; it is used for statistical purposes only and the data never shows any confidential information. The data itself is only visible to staff at the London Sinfonietta, our web development team at Un.titled and teams at Google where the data is processed.
This website also places cookies for Google Display Network and Facebook advertising, which means if you visit our site, you may see London Sinfonietta adverts when browsing the internet or Facebook’s network (which includes Instagram). Should you not want to view these adverts, you can delete your cookies at any time by clearing your browser’s cached history.
This website also includes video/audio content from Spotify, Vimeo and Youtube, and you should be aware these external websites may set cookies while you're accessing this content through the London Sinfonietta website, which may include advertising content. The London Sinfonietta is not responsible for external website’s cookies.
Who to contact if you have any questions or concerns
If you require further information about how your data is used, or have any concerns regarding how your personal data is processed, please email info@londonsinfonietta.org.uk or call 020 3869 0801.
How to make a complaint
If you wish to make a complaint about how we are using your data, please email info@londonsinfonietta.org.uk
Where you take the view that your personal data is processed in a way that does not comply with the UK GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then inform you of the progress and outcome of your complaint. The supervisory authority in the UK is the ICO.
You can contact the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: ico.org.uk
Subject Access Requests
The right of access, commonly referred to as subject access, gives individuals the right to obtain a copy of their personal data, as well as other supplementary information. It helps them to understand how and why we are using their data, and check we are doing it lawfully. The request is known as a Subject Access Request (SAR).
If you wish to make a SAR, a Subject Access Request form should be completed. Please write to London Sinfonietta, Kings Place, 90 York Way, London, N1 9AG or email info@londonsinfonietta.org.uk
On receipt of your Subject Access Request form we will aim to respond to all legitimate requests within 30 days. Occasionally it may take us longer if your request is particularly complex or if you have made a number of requests, in which case we will keep you notified and updated. We may require specific details of your request and may require proof of identification.
Changes to this privacy notice
We may update this privacy notice from time to time. This privacy notice was last updated on 24 April 2023.