Privacy Policy

Sunderland Culture Ltd (we, our or us) is an organisation created to bring together the cultural programmes of Sunderland City Council, University of Sunderland and Music, Arts and Culture (MAC) Trust (the Partner Organisations) into a single, independent, resilient delivery model and realise the ambition of a city brimming with creative potential. We are an Arts Council England National Portfolio Organisation.

Sunderland Culture Ltd is a Registered Charity, no 1184073. Company Limited by Guarantee in England and Wales No. 10098742. Registered Office National Glass Centre, Liberty Way, Sunderland, SR6 0GL. VAT Registration No 414220646.

Sunderland Culture works with the National Glass Centre, Northern Gallery for Contemporary Art, Sunderland Museum & Winter Gardens, Arts Centre Washington and Culture House Sunderland, and delivers programmes of cultural engagement and events across the whole city. It works across the city to ensure the power of great art, culture and creativity is harnessed for the benefit of Sunderland, its residents and visitors. Sunderland Culture’s mission is to improve life for everyone in Sunderland through culture.

In order to run the Sunderland Culture campaigns for the benefit of Sunderland, its residents, businesses and visitors, we liaise and engage with you, as:

• an employee, representative or agent of our Partner Organisations;
• a stakeholder or investor;
• a patron, advisor, sponsor or business partner;
• a member of an associated community group;
• a business contact in any other capacity (our Stakeholders).

We are committed to respecting your privacy and the security of your personal data. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. We are the Data Controller of any personal data we hold on you for our purposes, and when we share this data with any of our Partner Organisations, they will be a joint data controller.

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

On this page:

Changes to our privacy policy

Information we may collect from you

How is your personal data collected?

Purposes for which we will use your personal data

Images

Marketing & social media

Disclosure of your personal data

Data retention

Security

Third party link

Your rights

Personal data, or personal information, means any information about an individual from which that person can be identified.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes.

We may collect, use, store and transfer different kinds of personal data about you, depending on the nature of our relationship with you and the ways in which you engage with us, which are listed in Purposes for which we use your personal data.

• Identity Data: includes any information we gather to help us identify who you are, such as your first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data: includes your billing address, delivery address, email address and telephone/mobile numbers.
• Financial Data: data about the payments you make to us, including your bank account and payment card details.
• Transaction Data: includes details about payments to and from you (including donations and bursaries), ticket details for events and activities, and any other products and services you have purchased from us.
• Attendance Data: information related to which of our events and activities you attend or take part in.
• Event Data: if you take part in one of our events or activities, we will gather information about how you take part in that event to help us understand what you’ve done in the event and to help us work out what your needs are.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Skills and Experience Data: where you are a prospective employee, we will collect information about your skills, past jobs and experiences that are relevant to the job you are applying for.
• Correspondence Data: if you contact us by letter, email, through social media, or by phone, we may keep a record of that correspondence.
• Website Data: information collected when you visit our website, including your IP Address, traffic data and location data,
• Account Data: if you register an account on our website, we will collect your log in information (email and password), your search history, saved searches, alert preferences, purchase history, and any other personal data provided within your account.
• Survey Data: we may ask you to complete customer surveys that we use for research purposes. Whilst the completion of these is optional, your feedback helps us continually monitor our service and ensure you receive the best experience when dealing with us.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Website Data to calculate the percentage of users accessing a specific website feature.

We may collect certain Special Categories of Personal Data about you in certain circumstances. Special category data includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We will collect this where we need the information to provide reasonable adjustments for activities you participate in and for health and safety reasons. We will collect certain ethnicity data, information about sexual orientation, data concerning health and information revealing religious or philosophical beliefs for the purposes of equality of opportunity or treatment. This is sometimes needed to support work where it is made pursuant to government grants where it is a condition of that grant to provide such information. Although this will be provided by us to funders on an anonymous basis, we nevertheless need to process the data to anonymise it before transferring it. We do not collect any information about criminal convictions and offences other than where you are making an application for a role with us. In this case we may carry out DBS checks where your role may involve contact with vulnerable individuals or the role being advertised involves a position of trust. We may use special category personal data about you if you make that information manifestly public, for example if you are a representative of a political party and we invite you to an event in your official capacity or if you tell us about dietary needs or allergens in the context of a medical condition.

Where we need your data for the performance of our contract or a legal obligation, and you fail to provide it, it may mean we have to cancel that contract. We will notify you at the time of the information we need.

Below, we outline the lawful basis which we rely on to use your personal data. A number of bases are mentioned for processing personal data.

All personal data needs one of the “general” processing conditions. We have set out below a description of the ways in which we may use your personal data, and what our legal basis is for processing under the UK General Data Protection regulation (UK GDPR). We have also identified what our legitimate interests are where appropriate.

A Legitimate Interest is an interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

People over the age of 13

Children under the age of 13 and adults at risk

We have a legitimate business interest to use photos and videos of our events in marketing documents, communications, in annual reports and on our website or publicity documents.

If you attend an event where we may be taking photos or video, you will see signs notifying you of this. You can opt out of any photography/video at an event by letting a member of staff managing that event know you wish to be excluded.

If you are identifiable from any image or footage that we wish to use, we will take every reasonable step to ask for your consent to use this image. If we do not have your consent, we will not use an image which we believe identifies you, a child, or adult at risk in your care for use in any campaign posters, publications, or other publicly available documents.

We may however use images and videos from events on our social media. If we do use an image or video which you believe identifies you or a child or adult at risk in your care, and you would like us to take it down, please contact info@sunderlandculture.org.uk

We only keep your personal data as already indicated above, for as long as is necessary for the purposes which it is provided. We will contact you from time to time to make sure you want to stay on our marketing database. By law we have to keep basic information about our stakeholders for six years after they cease being stakeholders for tax purposes.

Where the information we have on you is not for marketing or purchase transitions, we retain personal data for such period as is necessary to fulfil the purpose for which the data was collected to meet legal, accounting or reporting purposes.

As we continue to update and revise our data protection procedures and practices we may update our retention policy. Please check back from time to time or contact us to see how long your data may be held on file.

In some circumstances, you can ask us to delete your data. For more information, see Right to request erasure of personal data.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, for historic, research or statistical purposes. In this case we may use this information indefinitely without further notice to you. Otherwise, we will securely delete or destroy data when it is no longer required.

We use cookies and related technologies (collectively referred to as “cookies”) to provide you with the services accessible through our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

Find out more in our Cookie Policy

You have various rights including rights to:

Request access to any personal data we hold about you: you have a right to access a copy of your own personal data, known as a “data subject access request”. We will acknowledge a request within 30 days of receipt as set out in the Data (Uses and Access) Act. We will investigate any requests without undue delay. The time it will take us to complete a request depends on the complexity and scale of the request.

We will request information from you to help us confirm your identity and ensure you have a right to access the personal data you have requested. This is a security measure to ensure that we do not disclose personal data to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request.

You will normally not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded or excessive (particularly where requests are repetitive). Alternatively, if your request is clearly unfounded or excessive we may refuse to comply with your request.

Request correction of any inaccurate personal data that we hold about you: this enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide.

Request erasure: this enables you to have your personal data erased where there is no good reason for us continuing to process it. The right relates only to personal data we hold at the time you make the request. There are also some important restrictions on this right and we may not always be able to comply with your request of erasure for legal reasons.

Object to processing: you have an absolute right to object to any processing of your personal data for direct marketing purposes. This includes any profiling of personal data related to direct marketing.

In other circumstances, you have a right to object but this may not be an absolute right. For example, you have a right to object to us processing your personal data on the basis of legitimate interests if you feel it impacts on your interests, fundamental rights and freedoms. However, we may demonstrate that we have compelling legitimate grounds to process your information which override your interests, rights and freedoms, or that the processing is required for the establishment, exercise or defence of legal claims.

Request restriction of processing: you can ask us to restrict our processing of your data in certain circumstances such as while we check that its accuracy, or that our processing is lawful.

Withdraw consent at any time: where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. However, this will not affect the lawfulness of any processing we may have undertaken based on your consent before it is withdrawn.

Complain: you have the right to complain if you feel we have processed your personal data in a way that is no complaint with the law. This can be, for example, because you’re not happy about how we handled a subject access request or a personal data breach or you have some other concern about the way we’ve processed your personal data.

You can complain to us either by:

• email addressed to Nick Malyan, Chief Executive of Sunderland Culture at info@sunderlandculture.org.uk
• phone at 0191 515 5555
• post addressed to:
  • Sunderland Culture Limited
    C/O National Glass Centre
    Liberty Way
    Sunderland
    SR6 0GL

We will respond to you to acknowledge your complaint within 30 days of receipt as set out in the Data (Use and Access) Act.

We will handle your complaint in accordance with our complaints procedure.

Once we receive your complaint we will investigate it. We will aim to do this as soon as possible. We will keep you informed of progress and let you know of any factors which will delay our response (such as if the request is particularly complex).

We will let you know the outcome of the complaint as soon as we have finished our investigation and made our conclusions. We will let you know what we’ve done to resolve your complaint and, where appropriate, any actions we’ve taken as a result. We will provide you with sufficient information to enable you to understand why we have come to the conclusion we have reached.

If you are unhappy with the results of the complaint, you can complain to the ICO on 0303 123 1113 or at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.