Data Protection Officer [DPO]: Rob Syers, IT Operations Manager, data-protection@wacarts.co.uk
Privacy Policy
Wac Arts respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Wac Arts collects and processes your personal data.
It is important that you read this privacy policy together with any other privacy policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supersedes all previous privacy policies.
Controller
Wac Arts is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Wac Arts
Email address: info@wacarts.co.uk
Postal address: Old Town Hall, 213 Haverstock Hill, London, England, NW3 4QP
Telephone number: 020 7692 5800
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in March 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
www.wacarts.co.uk and our social media platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
Special Categories of Personal Data and Criminal Offence Data
We may ask for Special Categories of Personal Data (which may include your medical history and/or ethnicity) or information relating to criminal offences, if you are signing up to one of our activities. This will be collected with your consent and we will use this to:
(i) (in the case of information about any medical conditions) ensure your safety and wellbeing when participating in one of our activities;
(ii) ensure we can target our interventions at relevant audiences;
(iii) enable us to report on impact in line with our charitable objects; and
(iv) measure the effectiveness of our work in providing our public benefit.
For more information about the purposes for which we collect this data and who we may share it with, please refer to the relevant application form that will have been provided to you.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- visit our website;
- make a donation or payment;
- join our mailing list;
- sign up to an activity (such as a class, course, workshop or similar);
- sign up for an event;
- attend an event;
- make a space hire booking;
- enquire about an activity or service;
- lease or licence an office or studio space;
- sign up as a volunteer;
- complete a parental consent form;
- create an account on our website;
- enter a competition, promotion or survey;
- give us feedback or contact us;
- make a complaint; or
- visit our building.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy https://www.wacarts.co.uk/cookie-policy for further details.
- Third parties. We may receive Contact, Financial and Transaction Data from partners or agencies with whom we work to carry out the business services of our charities. We may also receive Contact details if you have been introduced to us by a mutual contact.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where you have provided us with your consent to use your personal data for a purpose that we have described to you. Where this is the case, you have the right to withdraw your consent at any time by contacting us.
Sections 5 and 12 below describe the types of lawful basis that we will rely on to process your personal data.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose | Type of data | Lawful basis for processing including basis of Wac Arts’ legitimate interest |
|---|---|---|
| To manage any ticket, room and activity bookings that you make online or through our reception, administrative or events team | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Special Category Data (for activities only) (f) Criminal offence data (for activities only) | (a) Performance of a contract with you (b) Consent (for processing Special Category Data and criminal offence data only) |
| To maintain our accounts and records and collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction | Necessary for our legitimate interests |
| To contact you in the event of an alteration or cancellation of one of our services | (a) Identity (b) Contact | Performance of a contract with you |
| To fulfil our legal and / or regulatory duties | (a) Identity (b) Contact (c) Financial | (a) Necessary to comply with a legal and / or regulatory obligation |
| To send you communications about our work, for example, information about our campaigns, fundraising activities, how you can donate to us and availability of our services. | (a) Identity (b) Contact (c) Marketing and Communications | Consent |
| To claim Gift Aid on your donations | (a) Identity (b) Contact | Consent |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to understand how clients and customers use our products/services, to develop them and grow our charitable business services) |
| To administer our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our charitable business, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation |
| To use data analytics to improve our website, services and marketing | (a) Technical (b) Usage | Necessary for our legitimate interests (to keep our website updated and relevant, to develop our services and to inform our marketing and engagement strategy) |
6. Marketing and fundraising
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We offer regular emails to let you know about our programmes and success stories, our services and to inform you of the latest events and showcases for our participants and communities. We may also invite you to take part in surveys about our programmes or issues affecting Wac Arts.
We will only contact you with marketing communications relating to fundraising if you explicitly give us permission to do so. You have the right to withdraw your consent at any time by contacting our data privacy manager. If you have been introduced to us by a mutual contact, we will obtain your explicit consent prior to collecting your personal data to ensure that you agree to hearing from us about our activities.
As for marketing communications that do not relate to fundraising, we may rely on what is known as the ‘soft opt-in’. This means, for example, that if you are an existing contact of ours who recently signed up to an activity, gave us your details and did not opt out of marketing messages, then we may write to you about similar activities even if you have not specifically consented. We will only do so where we have given you a clear chance to opt-out, both when we first collected your details and in every subsequent message we send.
Wac Arts may personalise the message content based on any information you provide to us and your use of our platforms.
You can update your communications preferences and stop receiving any future emails at any time by following the convenient links located at the bottom of our emails.
If you believe you have received unwanted, unsolicited emails sent by or purporting to be from Wac Arts, please forward a copy of that email with your comments to info@wacarts.co.uk for review.
If you give us permission, we’ll use your email address and/or postal address to contact you with news about Wac Arts, to inform you about future events, services or to let you know about our fundraising campaigns. We will not share your data with third parties.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or signed up to one of our services and you have not opted out of receiving that marketing.
Opting out
You can ask us or third parties (see External Third Parties below) to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
If you’re 13 or under
If you are aged 13 or under, you must get your parent / guardian’s permission before you provide any personal information on our website. Wac Arts will ask for parent consent when any information is received from a young person who is under 13.
We will always explain to children why we require the personal data we have asked for, and what we will do with it, in a way which they can understand. Our privacy notices are clear and written in plain, age-appropriate language.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of www.wacarts.co.uk may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.wacarts.co.uk/cookie-policy
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties
- Service providers acting as processors who provide IT services, process our donations, send our mailings or analyse data.
- Professional advisers acting as joint controllers including lawyers, bankers, auditors and insurers.
- HM Revenue & Customs, regulators, awarding bodies and other authorities (such as boroughs for whom we deliver contracted services) acting as joint controllers who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer or merge parts of our charitable business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
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.
8. International transfers
Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK, namely to the EEA, which has been deemed to provide an adequate level of protection for personal data.
9. Data security
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
10. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by contacting us.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us our data privacy manager.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means consent that is freely given and requires a positive action to opt-in or, in cases of explicit consent, is expressly confirmed in words, rather than by any other positive action.