HOME (Greater Manchester Arts Centre Limited) is committed to handling and storing personal information in compliance with the terms of the General Data Protection Regulation (GDPR). This applies whether the information is obtained directly from individuals through the HOME website by completing web forms or by other means such as phone calls, e-mail, printed forms, or in person. It also applies to information obtained from publicly available sources.
In all instances HOME is the data controller.
Whose information do we collect?
We collect personal information about the following categories of people:
- Audience members
- Supporters – Friends, Patrons
- People hiring the building, or spaces within it
- Media and press
- Participants in engagement or talent development activities
- Other stakeholders
What information do we collect?
Depending on the nature of your relationship with HOME, we may collect some or all of the following information:
- Biographical – name, title, previous surname, date of birth or age, gender, ethnicity, faith, or information that indicates your socio-economic status
- Contact details – postal address, email address, phone number
- Current interests and preferences
- Access requirement
- Medical information
- Occupation and professional activities
- Record of donations or payments (payment for tickets and regular donations are managed through a third party – bank account details are retained only for the purposes of processing direct debits)
- Attendance at events
We will only collect this information when there is a legitimate reason for doing so.
How do we collect the information?
Information is collected under the following circumstances:
- Booking tickets/merchandise/gift vouchers/memberships online, in person or over the phone
- Subscribing to HOME mailing lists or other marketing communications
- Becoming a supporter of HOME
- Providing information via surveys about visitor experience
- Taking part in a competition on social media
- Through personal contact with a staff member or trustee
- From publicly available sources
- Enrolling on to or applying to an engagement or talent development programme
HOME’s restaurant is run by a separate company. Although their online table booking system appears on HOME’s website, data is not collected or retained by HOME.
When you provide contact details you will be asked if you would like to receive further information from HOME. You will also be offered the opportunity to opt-out every time we communicate with you. If you have an online account, you can also log in at any time and update your preferences.
Why do we collect the information?
We collect the information in order to:
- provide and manage services, such as attendance at free and charged events
- manage contact with, and provide information to, supporters
- communicate news about HOME
- communicate news about events at HOME
- issue invitations to HOME events
- administer donations, including Gift Aid
- understand who our audience is to improve our services, or to provide information to funders or visiting companies (we will only share information with visiting companies if you have given your consent to do so)
- Identify potential donors and sources of funding for, amongst other activities, learning and engagement, talent development, capital projects and our artistic programme
- Provide an appropriate environment, schedule, or level of support to participants in engagement or talent development activities
- Respond to emergency situations appropriately for participants in engagement or talent development activities and their families
- As part of NHS Track and trace programme, to help minimise the transmission of COVID-19 and support public health and safety
We use tools to assist us with providing targeted information to our stakeholders, such as art-form specific event communications. We may occasionally use profiling services provided by trusted third party organisations for the same purpose. We also gather information from publicly available third party resources, e.g. directories, charity registers, to assist us with identifying stakeholders who might be approached for financial support.
Under the terms of the GDPR the lawful bases for processing personal information are:
- we need it to fulfil a contract (e.g. ticket purchase);
- we need it to pursue our legitimate interests including by communicating with current and potential supporters; and/or,
- you have given your consent for us to do so.
Who collects the information?
Information is collected by, and on behalf of, HOME. It may be shared by departments within HOME in order for us to undertake a range of communications activities, both electronically, in print and through other channels.
Only where you explicitly consent for us to do so we will share your information with third parties which will usually be our funders of specific programmes.
How long do we hold the information?
Information is retained for as long as necessary for the purpose for which it is required, and in line with HOME’s Retention Schedule.
Any details gathered specifically for Test and Trace can be held for 21 days before being automatically removed. As the Data Processor we are responsible for removing this information after 21 days. Once this data has been transferred to the NHS the NHS becomes the Processor for this data.
We want to be sure that we have the most up-to-date information for you. If you discover that we have outdated information, such as address, e-mail address or change of name, please contact us via email@example.com. If you purchase tickets online for HOME you can update your information yourself by logging into your account or contacting our Box Office.
Where your information is stored
Your information is stored on secure, password protected databases and networks. Access to the information is given only to staff with the appropriate authorisation. Data is held mainly in the United Kingdom with some on servers within the European Union.
Track and Trace
To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, DHSC has provided guidance which recommends that we collect and keep a limited record of visitors’ details, for the purpose of contact tracing.
By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to coronavirus.
All visitors will be asked to supply the following details when booking tickets with HOME, however this will not be mandatory.
- Phone number
- Date of visit
All data held on behalf of Test and Trace will be held securely in line with HOME’s GDPR policy.
We will only share information with NHS Test and Trace if it is specifically requested by them. For example, if other customers at the venue subsequently tested positive, NHS Test and Trace can request the log of customer, visitor and staff details on a particular day. This information would be used solely for this purpose and handled in compliance with data protection legislation.
HOME operates CCTV camera surveillance throughout the building and on the perimeter of the premises. The system is in place for the purposes of reducing the threat of crime generally, protecting HOME’s premises and helping to ensure the safety of HOME’s staff and visitors. The images are stored securely and monitored in a controlled space. Images may be shared with Greater Manchester Police if required for the investigation of crime.
HOME uses photography and film at events to promote its activities, build new audiences and report to funders. These images may be used on our website, social media channels, in press releases and in written reports to funders. Any events being photographed will be clearly signposted to make the public aware. Public may request not to be photographed. We will seek parental consent to take photographs of children and young people under the age of 18.
You have the right to request copies of any of your data held by HOME. If you would like to request this, please e-mail datarequest@HOMEmcr.org.
If you no longer want us to use or process your data, you can opt out at any time via the unsubscribe link included in emails or contact the Data Protection team on dataprotection@HOMEmcr.org.
Contact and complaints
If you have any queries or complaints about this policy please contact
Data Protection, HOME, 2 Tony Wilson Place, Manchester M15 4FN or send an e-mail to dataprotection@HOMEmcr.org.
If you are dissatisfied with HOME’s response to your request for access to your data, or handling of your request to rectify or erase your data, you may contact the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Tel.: 0303 123 1113 https://ico.org.uk/concerns/
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