Privacy Statement

 

The Academy of St Martin in the Fields is committed to protecting your privacy and being transparent about what personal information we hold about you.

Processing personal information allows us to develop a better understanding of our supporters and audiences, and to provide you with relevant information about the work that we do. As a charity, it also helps us to engage with potential donors.

The Academy commits to the key data protection principles under the General Data Protection Regulation, which requires that personal data shall be:

  • Processed lawfully, fairly and in a transparent manner in relation to individuals;
  • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • Accurate and, where necessary, kept up to date;
  • Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  • Processed in a manner that ensures appropriate security of the personal data

The purpose of this statement is to give you a clear explanation about how we uphold these principles in our data collection and processing. It was last updated on 16 May 2018.

 

Who we are

Academy of St Martin in the Fields is an operating name of Academy Concerts Society and is funded by individual donors, corporate supporters, trusts, foundations and public bodies.

Our registered charity number in England and Wales is 289294 and we are also registered as a company in England and Wales under registration number 1808488.

The American Friends of the Academy of St Martin in the Fields is an independent non-profit corporation with tax exempt status under section 501(c)(3) of the Internal Revenue Code. The Academy of St Martin in the Fields is registered with the Information Commissioner’s Office under registration reference ZA212121.

 

Why do we collect data?

We collect personal information from you in order to make your relationship with us as easy and enjoyable as possible. We need it to administrate our membership schemes; organise our Learning and Participation projects; fulfil your ticket orders; process your payments; and to notify you about updates and changes to our events.

If you have shown interest in the Academy by ordering tickets, becoming a Friend or Patron, making a donation or applying for one of our Learning and Participation projects, we may send you news and updates about our events, fundraising appeals and other activities that we believe will be of relevance to you. We may supply this information by post, email or phone, and we will always give you an opportunity to opt out of our communications.

We may analyse your personal information to create a profile of your interests and preferences so that we can ensure the relevance of our communications with you. We depend on philanthropic support, and if we feel that you may be in a position to make a donation to our charity then we may make use of additional information about you available from external, publicly-available sources. This helps us understand the background of those who support us and attend our events, and helps us to make appropriate requests for gifts to people who may be able and willing to give more than they already do.

We may also use aggregated anonymised data of our website users to inform future planning, report to funders, and improve our customers’ online experience and our marketing campaigns. You can find out more about this by reading our cookie policy.

 

How do we collect data?

Information you give us

We collect personal information from you when you book for an event, make a donation or join us as a Friend / Patron to allow us to carry out tasks that you have asked us to perform (e.g. take a monthly membership direct debit) and to provide the highest level of service when we interact with you.

The personal information we may collect includes:

  • Your name
  • Email address
  • Postal address
  • Telephone number(s)
  • Payment card details
  • Gift Aid declarations
  • Your bank account number, name and sort code (solely for processing direct debit payments)
  • Your connections to others on the Academy database (e.g. your partner/spouse, other family member, employer, or an organisation of which you are a board member or trustee)
  • Your dietary preferences (where relevant to your attendance at events)

Information about your interactions with us

To ensure that the communications that we send you are relevant and appropriate, we keep a history of your interactions with the Academy. For example, if we have sent you a mailing we keep a record of this, and we may keep a record of whether you have opened an email from us or clicked on any of the links within it.

The types of information that we store includes:

  • The history of our communications with you and your interaction with them
  • Your event attendance history
  • Your membership and donation history
  • Transaction particulars, including the method of payment

Information from publicly available sources

If you are a current or potential financial supporter of the Academy we may aggregate information listed above with research from publicly available sources in order to better assess whether it may be appropriate to approach you about potential philanthropic support and help us to communicate in a relevant way with you.

To do this we may analyse publicly available information relating to you and may store basic biographical information about you, a record of your philanthropic interests and gifts to other charities.

We collect and process personal information in this way for purposes in our legitimate interests as a charity. However we only do this if these legitimate organisational interests do not override the interests, rights and freedoms of the individual. You have the right to object to any of this processing at any time.

 

Your credit and debit card data

When you make a donation, membership payment or book for an event online via the Academy website all payment card details are submitted directly to Blackbaud Merchant Services, our payment provider, and encrypted. Blackbaud Merchant Services is audited annually under the Payment Card Industry Data Security Standards (PCI DSS). The Academy does not at any point see your card details nor hold them on file.

When you pay over the phone all payment card details are input directly into Blackbaud Merchant Services. We do not save your payment card details on our database and will ask for them anew each time you book, purchase or donate.

When you enter your payment card details onto a paper form – for example, a Friends Membership Form – the details are input directly into Blackbaud Merchant Services. The form is kept securely for our records but the card details on it are destroyed.

 

Learning and Participation data

Our Learning and Participation department collects information about its project participants, applicants and facilitators including, for example, educational attainment and details of any learning difficulties or special access requirements. This information will be used by our project team in order to plan and deliver the best artistic and educational experiences for you, to keep participants safe throughout their experience with us.

We will always seek your consent for the above at the time we collect your information, and, where we need to collect this information in respect of children or young people, we will ask parents or guardians to provide the information and consent to its use for the purposes described. It may be necessary to share this information (e.g. for child performance licensing), but that will not be done without your knowledge.

We may keep participants, applicants and facilitators’ contact details on record in order to contact them about future relevant opportunities. We will always give you an opportunity to opt out of these communications. We may store anonymised data about our participants and applicants to allow future analysis and reporting to funding bodies.

Sensitive data, including data on children and vulnerable adults, will only be collected if necessary for the delivery of the project, and not stored for longer than is absolutely necessary. This information is securely held and staff access to it is restricted.

 

Data of Academy staff, players and suppliers

If you have a business relationship with the Academy of St Martin in the Fields as a member of staff, orchestral player, or service supplier, please see our separate Privacy Statement for staff, players and suppliers which explains how we process your data.

 

Data from website cookies

A cookie is a small amount of data generated by a website and saved by your web browser. Its purpose is to allow a website to function as well as to provide website operators with information on how the site is being used. The Academy uses Google Analytics and Google Advertising cookies to compile aggregated, anonymous statistics about how visitors use our website and which pages they visit. Click here to view our full cookie policy.

 

Our legal bases for data processing

The three legal bases under which we may process your data are:

Contract purposes

When you book for an event or purchase membership you are entering into a contract with us, and we need to process and store your data in order to fulfil this contract. For example, we may need to contact you in the case of the cancellation of an event, to alert you to problems with your payment, or to deliver benefits associated with your membership. When you make a donation we may contact you to acknowledge your gift and to express our gratitude.

Legitimate organisational interests

In certain situations we collect and process your personal information for purposes that are in our legitimate interests as an organisation. However we only do this if using your personal information in this way does not override your individual interests, rights and freedoms. Situations in which we may use this basis include marketing and fundraising communications.

With your explicit consent

We will always ask for your explicit consent before processing your personal information in a specific situation for which the two bases above are not appropriate.

 

Marketing and fundraising communications

We aim to communicate with you about the work that we do in ways that you find relevant, appropriate, timely and respectful. To do this we use information that we have stored about you, such as events that you have booked for, donations you have made and your geographical location.

Email communications

You will receive our email communications – including information about our latest tours, concerts and announcements; products (such as CDs); special events; ticket offers; competitions; opportunities to support the Academy; and, occasionally, information from our partner organisations – if:

  • You have signed up to our mailing list via our website;
  • You entered a competition run by one of our partners, for example Classic FM, and explicitly consented receive Academy communications;
  • You have attended one of our past events at the Barbican or at Cadogan Hall and explicitly consented to receiving communications from the Academy as a third party;
  • You are a former member of the Academy Chorus;
  • You have made a donation, attended an Academy fundraising event, or joined one of our membership schemes and didn’t opt-out of receiving our emails when given the opportunity in the processing of the transaction. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you.

We use MailChimp to facilitate our email communications. Recipient lists, including email addresses, are stored on their secure server in the USA for the purpose of email distribution. MailChimp takes customer privacy and security very seriously, and participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are signed up to an additional data processing agreement with MailChimp in addition to their publicly posted Privacy Policy to ensure they uphold the high standards of data protection under GDPR.

Postal communications

We use our legitimate organisational interest as the legal basis for communications by post. In the case of postal mailings, you may object to receiving these at any time using the contact details provided with every postal mailing you receive and at the end of this privacy statement.

We do most Academy postal mailings in house, but we may also occasionally use a mailing house to send out large quantities of letters on our behalf. This is subject to contractual agreements which ensure security of your data and the mailing house’s compliance with the GDPR principles – more info can be found in the ‘third parties’ section below.

How to opt out of receiving our communications

If you wish to opt out, you may do so at any time via the unsubscribe links at the bottom of our MailChimp emails, by emailing info@asmf.org, calling us on 020 7702 1377 or writing to us at the address at the end of this privacy statement. More information can be found in the section ‘Your Rights’ below.

 

Third parties

We will never sell or pass on your details to a third party for their marketing or fundraising purposes, however there are some rare circumstances in which we may disclose your personal information to third parties, which are:

  • To suppliers and service providers who are carefully vetted and contracted by us to carry out services related to our communications with you, such as the distribution of letters.
  • To our subsidiary, the American Friends of the Academy of St Martin in the Fields, when it is necessary for them to be able to provide you with products or services you have requested.
  • To profiling agencies whose purpose is to aggregate it with other data to determine whether it would be appropriate to approach you for a financial gift to the Academy.
  • Where we are under a duty to disclose it in order to comply with a legal obligation, for example to government bodies or law enforcement agencies.

Suppliers of the services mentioned above are bound by the same data protection rules as the Academy of St Martin in the Fields and subject to contractual agreements which ensure compliance with the GDPR and the security of your information.

 

How long we keep your personal information

The personal data collected by the Academy is evaluated periodically to determine whether it is current and still needs to be held.

Sometimes we are required to retain data for a certain length for legal requirements, e.g. VAT regulations require appropriate financial records to be retained for six years, Gift Aid regulations require appropriate records to be retained for seven years.

If you have told us that you have left a gift to the Academy of St Martin in the Fields in your will we will consider your relationship with the organisation to be life-long and your data will be kept on file until such time as you inform us that the organisation is no longer named as a beneficiary of your estate. In this instance you can still choose not to hear from us if you prefer not to be contacted.

You may notify the Academy if you do not wish your data to be held.

 

Security of your personal information

We take all reasonable steps to protect your personal information. Data on our server is secured with domain authentication and user access controls are in place for folders. Backups of our data and the transmission of the backup is encrypted.

Prevention measures against unauthorised external access include firewall protection and dedicated remote access hardware. Symantec Endpoint Protection is in place to guard against virus and malware.

Access to the Raiser’s Edge database at the Academy is restricted to those members of staff required to maintain a relationship with you and is controlled through electronic password protection and user security profiles. Staff access to sensitive data, including data on children and vulnerable adults, is restricted.

When it is necessary to keep paper records of data (for example, keeping membership forms for Gift Aid purposes) they are kept in locked storage.

 

Your rights

You have the right to be informed about what personal information we hold about you, and request details of your personal data held by the Academy. To request all information held please contact the Chief Executive, Academy of St Martin in the Fields, The Griffin Building, 83 Clerkenwell Road, London EC1R 5AR. We will respond to you within 10 working days of the date in which you contact us.

You have the right to rectification of your data. We endeavour to keep your personal information accurate and up to date. If you become aware of errors or inaccuracies, please email info@asmf.org.

You have the right to object to us processing your personal data for any or all of the purposes set out in this Privacy Policy, and you may do so at any time. To exercise this right, please email info@asmf.org giving clear details of the processing activities and/or types of personal data to which your objection applies.

If you choose to exercise your right to be forgotten and specifically tell us that you no longer wish us to hold your details we will anonymise your record, removing all personal data. The orchestra has a right to keep records for a certain period, as described above, which may mean that even if you ask us to erase details we are legally obliged to keep them until after that period has passed.

 

How to complain

We take data protection seriously and hope that there will be no need for you to make a complaint. If you would like to lodge a complaint with us you can do so by contacting info@asmf.org outlining fully the reasons for your complaint. We will respond within 10 working days. If you are not satisfied with our explanation, you can escalate this complaint to the Information Commissioner’s Office.

 

Contact us

Please contact us if you have any questions about our privacy statement or information we hold about you. Email us at info@asmf.org or write to the Chief Executive, Academy of St Martin in the Fields, The Griffin Building, 83 Clerkenwell Road, London EC1R 5AR.