City Music Foundation Data Protection and Privacy Policy

We are committed to protecting the privacy of your personal data. We will respect any personal data you share with us and keep it safe. We aim to be clear when we collect your personal data and not do anything you wouldn’t reasonably expect.

Please read this Policy carefully to understand our practices regarding your personal data and how we will collect, use and store your personal data.  We may update this policy from time to time so please check it regularly. If there are significant updates, we will inform those people with whom we are in regular contact.

Who we are

CMF or City Music Foundation refers to registered charity number 1148641 (with The Charity Commission) and company number 08133744 (Companies House).

CMF’s registered address is: Church House, Cloth Fair, London EC1A 7JQ

Reason for this new policy

This new data handling and privacy policy is on the occasion of the direct application, effective on the 25th of May 2018, of the European Parliament Regulation (EU) 2016/679 and the Council of the 27th of April 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR).

The policy applies to the head office of CMF and any branches, and all staff and volunteers working with us in accordance with GDPR 2018. The Trustees and Board of Directors of CMF are ultimately responsible for ensuring that data is collected, stored and handled correctly.

We are in the process of checking and where necessary changing our internal systems and protocols in order to adapt to the new regulations and comply with the requirements established by the GDPR.

Managing Director – responsibilities

To draw up and regularly review the Data Protection and Privacy Policy and update as necessary.

To ensure CMF staff and volunteers are aware of the policy, and what it means to them in their working practice.

To ensure that all necessary steps are taken to ensure CMF complies with the new regulations in terms of collection, storage and confidentiality of data.

To deal with questions from staff and other individuals about their data, and with requests to see the data held about them.

What personal data we collect and the purposes for which we use it

Some examples of the type of information we may collect and hold about you are as follows:

  • your full name and your title, and an indication of the gender that you most closely identify with
  • birth date or a relevant age range
  • postal address
  • telephone number(s)
  • email address(es)
  • records of your correspondence with us on paper and email, social media, text message.
  • donation and gift aid details (if you donate to us)
  • dietary, accessibility, and mobility information
  • photographs and digital images and videos of individuals (usually attending CMF events)
  • your relationship with CMF for example music industry professional, CMF artist, applicant to CMF Artists Programme, audience member, friend, donor (financially or in-kind), mentor, workshop contributor, or other interested person.

But we may also occasionally collect, hold and process other personal data where it is appropriate and relevant, for example:

  • details of why and how you have decided to support/contact us and how you may have heard about us and the work that we do
  • details of how you would like to be involved and what you intend to do with any information we provide about CMF
  • personal data about you that will enable us to be more precise in how we approach you in future
  • for purely business and events-related reasons, so we can managing relationships with third party and partner organisations, as well as with suppliers and external service providers

We will only process sensitive personal data also known as special categories of data (e.g. in relation to your health), with your explicit consent, for reasons of substantial public interests or where necessary for the establishment, exercise or defence of legal claims.

How and why will we use this personal data

  • To provide you with the information, product or service you have requested from us, including such things as relevant music news, CMF updates, CMF artist news, concerts and events information and ticketing, other specific events that we run, merchandise, new CDs or videos being released, responding to your enquiries and requests.
  • To tell you about our work and our fundraising activities and specific campaigns.
  • To provide you with other information which we feel may interest you of broader interest, questionnaires or surveys, opportunities and requests for help or support, and details of any promotions and competitions we are running. We may also send you details of events we think you may be interested in attending

Also to:

  • administer all aspects of being a patron or mentor or judge or workshop leader of CMF
  • deal with any membership of friends schemes of CMF
  • deal with enquires about and process applications to CMF
  • keep a record of our relationship with you
  • improve how we communicate with you, how we fundraise, and how we operate more generally
  • keep in contact with you in the ways that you have requested or agreed to
  • personalise our services and communications to you (for example, to ensure that they take into account your age, location and previous involvement with CMF)
  • provide you with information about carefully selected third party events, products, campaigns and competitions especially involving CMF artists, patrons and other connected people, where we are permitted to do so
  • notify you about changes to our services
  • administer and process payments you make for products, services and charitable donations made
  • verify your identity where required to use some of our services and benefits
  • comply with applicable laws and regulations and requests from statutory agencies including for such purposes as health and safety; the detection and prevention of crime and safeguarding
  • carry out any obligations or provide you with any other services, functionality or content which you specifically request or agree to

 

Fundraising

Charitable giving is very important to CMF’s ability to achieve its mission.  We carry out a wide variety of marketing activities to seek individuals’ support for our work, ranging from appeals for small one-off donations, to large donations to support our core activities, to large fundraising initiatives for specific projects, such as building renovations.  We want to ensure that we are contacting you with tailored and appropriate communications, and ensure we direct our resources and fundraising activities as efficiently and effectively as we can.  We also want to communicate with you from time to time to thank you for your support and tell you what we have achieved with the help of your donation.

Since we were founded in 2012 CMF has relied on individual donations as well as trusts and foundations and businesses to support both our recurrent costs and for new projects. In order that our fundraising is appropriate, respectful, efficient and effective, we tailor our approaches to different people in different ways. We use information you have given us, sometimes together with data we collect from publicly available sources, to help us decide how best to do this.

For a small number of people, we may undertake research using publicly available information relating to philanthropic activities, wealth and capacity to give, to create a profile of interests and preferences.  This helps us understand the background of the people who we believe may be willing to attend events and enter into a dialogue with us to learn more about supporting our work and organisation.  Ultimately it helps us to ensure that proactive requests for gifts are directed to only those who we believe may be able and willing to give. This information is collected from public sources such as news articles, Companies House, the Charity Commission, Who’s Who as well as specialist charity research sources such as Trustfunding.org).

If we do collect such information about you, whether jointly or on our own, we will inform you in order to provide you with an opportunity to opt out of your data being used for these purposes. You can also opt out by emailing us on info@citymusicfoundation.org

 

We also have an obligation to ensure we are undertaking appropriate due diligence on potential donors, in accordance with guidelines set out by the Charity Commission and the Fundraising Regulator, and we may collect information from the public domain information for this purpose too.

 

What lawful bases do we rely on to use your personal data?

Through consent:

Where you will have provided your consent to us using your personal data for a specific purpose:

  • We will ask for your consent to use your personal data to send you emails.
  • You always have the right to withdraw your consent at any time.

For working or contractual relationships:

For example, if you apply to be a CMF artist, or support us as a patron, or help in our selection process, or with mentoring or with workshops or any other support of CMF’s core mission, if you purchase something from us (e.g. CDs), or join a membership scheme, or enter any other relationship with us, we will require your personal data to enable us to perform our agreement.

To comply with a legal obligation:

This would include where we have to retain certain records, for example, to manage health and safety, for the detection and prevention of crime, safeguarding obligations, to ensure we comply with marketing laws, for tax reasons (such as those related to gift aid donations) and undertaking due diligence before accepting certain donations or entering into certain relationships.

When it is within our legitimate interests:

Applicable law allows personal data to be collected and used if it is reasonably necessary for our legitimate interests or a third party’s legitimate interests (as long as the processing is fair, balanced and does not unduly impact individuals’ rights).  We will rely on this ground to process your personal data when it is not practical or appropriate to ask for your consent, and where we are confident that this will not impact your rights.

Our legitimate interests include raising funds for a wide range of activities to support our charitable objectives, ranging from recitals and concerts, other musical events, recording and filming, website development, dissemination of information on what we do, attracting applicants to the scheme, the selection process, education, mentoring, workshops, publications and many other activities. We also have a legitimate interest in publicity and income generation, campaigning and fundraising in order to support these objectives and undertaking due diligence to establish the provenance of donations that are made, or may be made, to us.

Where you have provided your details to us, we may contact you by post and phone for certain marketing and fundraising activities as set out above (but we will explain this to you at the point that we collect your details). You can opt out of this activity at any time by emailing us on info@citymusicfoundation.org

We will also rely on our legitimate interests for the proper administration of CMF, and to manage our operations (for example, maintaining appropriate records and databases, for the detection and prevention of crime and safeguarding all those who access our premises and facilities).

When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

How we collect personal data

When you give it to us directly

  • You may give us your personal data when you meet members of CMF staff or volunteers, or board members, or CMF Artists or alumni at CMF events or elsewhere.
  • You might give data in order to receive information from us when you purchase event tickets, or buy recordings, when you join a membership scheme, when you help us in delivering our charitable aims, when you donate to us, or respond to a survey or when you otherwise engage with us on our websites and digital products.
  • You may give us your data when you enquire about or apply for a place on the CMF Artists Programme.

When a third party provides us with your personal data

Your personal data may be shared with us by third parties in certain circumstances. This may include (but is not limited to) ticket agencies that may sell tickets to access CMF events, other musical organisations with whom CMF, or CMF artists, work, schools or hospitals or other institutions who work with us or our artists, mutual contacts who recommend you to us, our partners who may host and run events (or help to run and host events) with us, or who run competitions or prize draws jointly with us.  Where appropriate you should check any Privacy Policy of any third party when you provide your personal data to them in order to understand fully how they will process your personal data.

When you use our websites and digital products

We may collect personal data about you when you use our website www.citymusicfoundation.org and digital products. Whenever you input personal data into our website (for example, if you join a memberships scheme, or otherwise support us through our website we will collect the personal data that you give to us.

We may have links to other websites on our website.  This privacy policy does not cover external websites and we are not responsible for the privacy practices or content of those sites.  We encourage you to read the privacy policies of any external websites you visit.

Communications and marketing

We may contact you by post and telephone, and, where you have provided consent, by e-mail, to let you know about our events and activities (and we may also mention those of third parties, particularly where they are collaborating with us or sponsoring our events) that might be of particular interest to you; offers and promotions, or about the work of CMF more generally; and to request donations and provide you with information about and the opportunity to participate in our fundraising activities.  We provide the opportunity for you to opt-out from receiving our marketing communications every time we contact you.

In addition you can opt-out from receiving our marketing communications, or update your contact preferences at any time by emailing: info@citymusicfoundation.org

Data sharing

We do not sell your information under any circumstances.  We may from time to time share your personal data with third where we are embarking upon a joint musical venture or a joint fundraising project. However, we will only ever do this where you have given us permission to do so.

We may also, in certain circumstances, receive your details from charitable giving platforms such as Just Giving or CAF Donate, in accordance with a particular platform’s privacy policy. For example, where you donate to CMF through an online platform, they may then give us your address so that we can write to you and say thank you. Please do review any such policies before giving your data to these platforms, to ensure that you are happy for your data to be shared in this way.

We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies.

Unfortunately, the transmission of personal data via the internet is not completely secure.  Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to or via our websites and digital products; any transmission is at your own risk.

How we keep your personal data safe and who has access to it

We are committed to ensuring that there are appropriate controls in place to protect your personal data including protection from misuse and unauthorised access.  Data is stored on our network, and in cloud storage and Mailchimp and email servers, which are safeguarded. It is also stored in electronic files on hard drives and sometimes on paper.

Your information is only accessible by staff, volunteers and contractors who are bound by appropriate policies and procedures to protect your information

Your rights

  1. Rights to find out what data we hold on you
  2. Right to request removal of all information about me

Please note that you may only use/ benefit from some of the following rights in limited circumstances.  For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/  – or please contact us using the details below.

Right to restrict processing

In certain circumstances as outlined in the ICO guidance referred to above, you have a right to require us to stop processing your personal data in a particular way.

Right to erasure

You have the right to request that your personal data is erased from our records in certain circumstances.

Right of access

You have a right to ask for a copy of the personal data we hold about you.  If you want to access your personal data, please send a description of the personal data you want to see and proof of your identity by post to Managing Director, City Music Foundation, Church House, Cloth Fair, London EC1A 7JQ.

Right to rectification

We also want to make sure that your personal data is accurate and up to date.  Please let us know if your details change.  You may also ask us to correct or remove personal data which is inaccurate.

Right to object

You can also opt-out of receiving all or some of our marketing/ fundraising communications or request that we stop processing personal data about you for certain purposes at any time by contacting us using the details below.

Right to data portability

In certain circumstances you have a right to data portability which means we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format.

Complaints

If you are unhappy with the way in which we have handled your personal data please contact us using the details below.

You are also entitled to make a complaint to the Information Commissioner’s Office.  For further information see the Information Commissioner’s guidance here: https://ico.org.uk/for-the-public/personal-information

Data retention

We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected.  We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries.  In some cases, we are also obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep records of contractual or financial matters).

Whilst the specific time periods vary depending on the circumstances, in general we will not keep records that include personal data for more than 10 years after a particular matter or exchange has concluded.  In the event that you ask us to stop sending you marketing communications, we will retain certain details, such as your name and email address, but only to ensure that you are not contacted again.

Contact

For all enquiries in respect of this privacy policy, please contact Managing Director, City Music Foundation, Church House, Cloth Fair, London EC1A 7JQ.

 

 

Websites and digital products

In this policy “websites and digital products” refers to all CMF websites, including the primary CMF website found at www.citymusicfoundation.org , and all our digital products, such as email, applications and digital channels, including social media.

 

Changes to this privacy policy

We keep our privacy policy under regular review.  This privacy policy was last updated in May 2018.


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