Website Privacy Policy

1. General

Southampton Cultural Development Trust is committed to protecting and respecting your privacy. 

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand how we use it, the conditions under which we may disclose it to others and how we keep it secure.

1.1. Who We Are

We are Southampton Cultural Development Trust, a registered charity (registration number 1139269).

Our charitable purpose is for the public benefit delivered through using arts and culture as key drivers for a cultural shift in Southampton; bringing people, organisations and ideas together to create the conditions and opportunities for our vision and shared ambitions of the city to be met.

For the purposes of data protection law, the Data Controller is Emalene Hickman who can be contacted by email at e.hickman@culturesouthampton.org.uk

1.2. How To Contact Us

If you have any questions regarding this Policy and our privacy practices you can contact us by email at hello@culturesouthampton.org.uk

We hope that we will be able to resolve any questions or concerns you have.

However, you may at any time raise your concern with the UK Information Commissioner.

1.3. Review Of This Policy

This policy is reviewed by the trustees of Southampton Cultural Development Trust from time to time to ensure it is kept up to date and in line with current legislation.

This policy was last reviewed in October 2018.

2. The Policy

2.1. Information We Collect

We will collect and process the following information about you:

  • Information you provide to us through contact with Southampton Cultural Development Trust. This may be via phone, email, the SCDT website, related social media (e.g. Facebook, Twitter) or any other method of contact or correspondence.
  • If you visit the Southampton Cultural Development Trust website we may automatically collect various technical information about your visit including, but not limited to, the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type & version, time zone setting, browser plug-in types & versions and operating system and platform.
  • Information from other publicly available sources.

2.2. How We Use The Information We Collect

Personal information collected through contact with us will be used by Southampton Cultural Development Trust to:

  • Manage the operation of the Southampton Cultural Development Trust in delivering its charitable objectives
  • Manage the delivery of key projects, including any associated activities 
  • Ensure that staff and other volunteers are kept as safe as possible
  • Notify you of future events to be hosted by Southampton Cultural Development Trust and its partners
  • Notify you of any other related events not hosted by Southampton Cultural Development Trust that may interest them (e.g. training opportunities)

Audio-visual information (photographs, videos, recordings, etc) of partners or volunteers will not be collected, stored or processed by Southampton Cultural Development Trust for any purposes unless specific prior consent has been obtained from the partner or volunteer concerned. Should specific consent be given Southampton Cultural Development Trust may use such images, videos and/or recordings for the following purposes:

  • Promoting future Southampton Cultural Development Trust events to the wider public using both physical (e.g. posters, newsletters) and electronic media (e.g. email, web sites, social media)
  • Including images of volunteers in the programme for any current events

Audio-visual and other information that volunteers post themselves on social media, including any social media platform hosted and/or managed by Southampton Cultural Development Trust, will be at the volunteer’s own risk. Although such information will not be used or processed further by Southampton Cultural Development Trust without specific consent, SCDT will not be held responsible for the further use of such information by others who have access to the social media platform concerned.

Technical information collected when you visit the Southampton Cultural Development Trust, website will be used for the sole purpose of improving the experience of your visit and ensuring that the information on our website is presented to you in the best possible way for the device that you are using to access it (e.g. phone, computer, tablet).

2.3. Who Has Access To Your Information

The database containing information collected from partners and/or volunteers through contact with Southampton Cultural Development Trust, including audio-visual information, is only available to the trustees and staff of the Southampton Cultural Development Trust charity.

Southampton Cultural Development Trust, will not:

  • Sell or rent partner or volunteer information to any third parties
  • Share partner or volunteer information with third parties for marketing purposes not related to Southampton Cultural Development Trust’s projects and hosted events

However, we may share limited information about partners and volunteers, including audio-visual information where specific consent has been given, with selected third parties specifically for the purposes of promoting future Southampton Cultural Development Trust’s projects and hosted events

If Southampton Cultural Development Trust is required to share personal information about partners or volunteers in order to comply with a legal obligation, or to protect the rights, property or safety of the charity and its partners and/or volunteers, then such information will be shared as necessary and/or required. This includes exchanging information with statutory bodies and others for the purposes of fraud protection, safeguarding and in the pursuit of any criminal investigation undertaken by the authorities.

In operating the Southampton Cultural Development Trust’s website it may become necessary to transfer any information we collect from you via our website to locations outside of the European Union for processing and storing. These countries may not have similar data protection laws to the UK. By providing your personal information to us, you agree to this transfer, storing and processing.

If you use our website while you are outside the European Union, you should be aware that any information you submit via the website may be transferred outside the European Union. 

We do our utmost to ensure that all reasonable steps are taken to make sure that your information is stored securely. However the sending of information via the internet is not totally secure and on occasion such information can be intercepted. Southampton Cultural Development Trust cannot guarantee the security of data that you choose to send us electronically and sending such information is entirely at your own risk.

2.4. How Long We Store Your Information

Southampton Cultural Development Trust will retain information about partners and volunteers for the duration of time that they remain partners and/or volunteers and for the period of two calendar years afterwards. The reason for this is that partners and/or volunteers often take a break from one or more projects due to other commitments, only to return for subsequent ones.

During such a break situation the partner and/or volunteer will be marked as inactive in the database and no further use (but see below) or processing of the partner’s or volunteer’s information will take place until either that person returns as an active partner or volunteer, or a period of two calendar years has elapsed whereupon that person’s information will be irrevocably deleted.

Where a partner or volunteer has been marked as inactive we may, from time-to-time, send that partner or volunteer information about future Southampton Cultural Development Trust events.

2.5. The Legal Basis For Storing and Processing Your Information

For personal information supplied through contact with Southampton Cultural Development Trust (excluding such information where its collection, storage and use is subject to specific consent) the legal basis for collection, storage and use of such information is the the legitimate need of Southampton Cultural Development Trust for the use of such information in managing its operation and delivering its charitable objectives in an enjoyable, safe and secure environment.

For personal information through contact with Southampton Cultural Development Trust subject to specific consent (e.g. audio-visual), then your specific consent is the legal basis for the collection, storage and processing of such information.

If we ask you to provide personal information for any other use (e.g. to comply with a legal requirement) we will:

  • Make it clear at the relevant time what the information will be used for and by whom
  • Ask for your specific consent to use the information
  • Advise you whether the provision of such information is mandatory or not
  • Advise you of the possible consequences if you do not provide the information

2.6. The Use Of Cookies

Cookies are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns but do not identify you as an individual. 

The use of cookies helps us to improve the Southampton Cultural Development Trust website and deliver a better and more personalised service. 

It is possible to switch off cookies by setting your browser preferences. However, turning cookies off may result in a loss of functionality when using our website.

2.7. Links To Other Web Sites

The Southampton Cultural Development Trust website may contain links to other websites run by other organisations.

This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. Southampton Cultural Development Trust is not responsible for the privacy policies and practices of other sites even if you access them using links from our website. 

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

3. Your Rights

Under the 2018 General Data Protection Regulations (GDPR) you have the following rights:

3.1. The Right To Be Informed

This means that you have the right to know what type of personal information we collect about you, how it is stored, how it is processed and what it is used for. This Privacy Policy contains explanations which cover these areas, but if you would like to know more than you can do so by contacting the Data Controller.

3.2. The Right of Access

You have the right to access the personal data Southampton Cultural Development Trust holds about you and processes according to this Privacy Policy. You can do this by submitting a Subject Access Request to the Data Controller who will provide you with a copy of your information within one month of your request. There will be no charge for such a request.

3.3. The Right To Rectification

You have the right to have any personal data we hold on you corrected if it is inaccurate or incomplete. We must also correct any such information that has been passed to third parties. You can do this by submitting a Correction Request to the Data Controller who will ensure that your information is updated and/or corrected within one month of your request. There will be no charge for such a request.

3.4. The Right to Erasure

This is also known as the ‘Right To Be Forgotten‘. You have the right to request the deletion or removal of personal data where there is no compelling reason for its continued processing. The right to erasure does not provide an absolute ‘right to be forgotten’. You have the right to have personal data erased and to prevent processing in specific circumstances:

  • Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
  • Where you have withdrawn consent (for that information where consent was the legal basis for collection, storage and processing)
  • Where you have objected to the processing and there is no overriding legitimate interest for continuing the processing
  • Where the personal data has been  unlawfully processed (i.e. otherwise in breach of the data protection law)
  • Where the personal data has to be erased in order to comply with a legal obligation
  • Where the personal data is processed in relation to the offer of information society services to a child
  • You can request erasure of your personal information by submitting an Erasure Request to the Data Controller who will ensure that your information is irrevocably deleted within one month of your request. There will be no charge for such a request.

3.5. The Right To Restrict Processing

You have the right to request that further processing and usage of your personal information is restricted in circumstances:

  • Where you have contested the accuracy of the personal information we hold on you
  • Where you have objected to the processing of your personal information as being either unlawful or not for the purposes it was originally collected for
  • When processing is unlawful and the individual opposes erasure and requests restriction instead
  • Where Southampton Cultural Development Trust no longer needs the personal information but you require it to establish, exercise or defend a legal claim

In the above circumstances we will continue to store your personal data but undertake no further processing or usage of it until such time as it is corrected or its accuracy verified, the legality of its processing has been established, or you no longer need the information to establish, exercise or defend a legal claim. 

You can request processing restrictions of your personal information by submitting an Processing Restriction Request to the Data Controller who will ensure that your information remains stored but unprocessed within one month of your request. There will be no charge for such a request.

3.6. The Right To Data Portability

The right to data portability allows you to obtain and reuse you personal information for your own purposes across different services. It allows you to move, copy or transfer personal information easily from one IT environment to another in a safe and secure way, without hindrance to usability.

You can request a machine readable copy of your personal information by submitting a Portability Request to the Data Controller who will send you by email a file containing your information in the CSV format (Comma Separated Variable – a data interchange format readable by most common IT applications and systems) within one month of your request. There will be no charge for such a request.

3.7. The Right To Object

You have the right to object to:

  • The processing of your personal information based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling)
  • The processing of your personal information for the purposes of direct marketing (including profiling)
  • The processing of your personal information for purposes of scientific/historical research and statistics

You can object to the processing of your personal information by submitting an Objection Request to the Data Controller who will ensure that your information remains stored but unprocessed immediately unless there are compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual and/or the processing is for the establishment, exercise or defence of legal claims. 

There will be no charge for such a request.

3.8. Rights in Relation To Automated Decision Making & Profiling

The General Data Protection Regulations provide safeguards for individuals against the risk that a potentially damaging decision is taken without human intervention. Individuals have the right not to be subject to a decision when:

  • It is based on automated processing
  • It produces a legal effect or a similarly significant effect on the individual 

However, Southampton Cultural Development Trust do not use any IT systems or applications that involve automated decision making without human intervention in any form. Remediation under this right is therefore not currently applicable.