We collect and use certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom), and the Data Protection Act 2018, which applies in the United Kingdom only, and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
|Outside Edge Theatre Company, we, us, our||Outside Edge Theatre Company (a company limited by guarantee with registered company number 03871591 and registered charity number 1080948);|
Registered at Brady Arts Centre, 192-196 Hanbury Street, London E1 5HU.
|Personal information||Any information relating to an identified or identifiable individual.|
|Special category personal information||Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership|
Genetic and biometric data
Data concerning substance use or recovery, health, sex life or sexual orientation
Information concerning any offences (including alleged offences), criminal proceedings, outcomes and sentences.
We aim to be clear when we collect your personal information and not to do anything you wouldn’t reasonably expect. The principles we apply in dealing with your personal information are:
- We never sell your personal information
- We won’t share your personal information externally except for marketing purposes with your express consent; or
- with specific processors legitimately acting on our behalf and with proper/appropriate safeguards in place; or
- if legally required
- We keep all personal information within Outside Edge Theatre Company-managed systems where access is carefully controlled
- We will only take and use your personal information where necessary and for a legitimate purpose
- We won’t warehouse your personal information and only retain it if it is necessary to do so.
- We will never send your personal information outside the EEA (the European Economic Area).
If you have any questions about how we process your personal information or if you wish to opt out of certain types of processing or communications, please contact us on the contact details set out below.
Why we use your personal information
We use (or ‘process’) your personal information when we have a proper reason for doing so, namely because it is necessary:
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party;
- to comply with our legal and regulatory obligations; or
- where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Where we use legitimate interests to process information, we have carried out a balancing exercise that considers our need to process your information against your privacy rights.
We may process your personal information for the performance of a contract where, for example, you purchase from us tickets; where you sign up for participatory arts activities; or where you enter into a business arrangement with us, for example, we commission you to write a script.
We may process your personal information because it is in our legitimate interests to do so, for example to inform you of other products, services or events related to Outside Edge Theatre Company, such as performances or participatory arts activities; to update you on Outside Edge Theatre Company news, e.g. via e-newsletters and occasional postal mailings; to provide information on fundraising campaigns, activities and appeals, including occasional general or tailored requests to consider giving financial support to Outside Edge Theatre Company, or to ask you to consider supporting Outside Edge Theatre Company by giving your time; to maintain and cultivate our relationships with you (particularly if you are an artist, service user, consultant, professional colleague, partner or potential supporter).
We may process your personal information to comply with our legal and regulatory obligations in conducting checks to identify our customers and verify their identities or in screening for financial and other sanctions or embargoes (e.g. potential donors).
We may also process your special category personal information where:
- it is necessary for medical purposes (e.g. in a medical emergency);
- it is necessary to protect your or another person’s vital interests;
- it is necessary for reporting purposes and used in an anonymised or aggregated form; or
- we have your explicit consent to do so.
For service users who attend our health-related participatory arts activities, we will collect and share personal information that is relevant to your care. We will meet our obligations to you under data protection legislation (including the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), and the Health and Social Care Act 2012.
- Providing your care
- Working with other agencies and partners involved in your care
- Telling you about Outside Edge Theatre Company services
- Updating, consolidating and improving the accuracy of our records
- Maintaining and improving our services
- Responding to your enquiries and complaints
- Managing your relationship with us
- Assisting regulatory authorities with their functions
- Crime detection, prevention and prosecution.
How we collect your personal information
We collect most of your personal information directly from you. You may give us information by filling in forms on Outside Edge Theatre Company’s website or by corresponding with us by telephone, email, face-to-face or otherwise. For instance, we gather information when people book for an event at Outside Edge Theatre Company or sign up to one of our mailing lists.
However, we may also collect information:
- from publicly accessible sources, e.g. Companies House or social media (e.g. LinkedIn, Facebook)
- from public sources for charities (in order to find information about those charities’ employees, trustees, etc. and to find information about donations and support)
- from public sources for individuals (collated lists that are publicly available)
- press sources (e.g. newspaper articles and databases), which may include media monitoring (e.g. Google alerts)
- directly from a third party, e.g.:
- customer due diligence providers
- sanctions screening providers
- credit reference agencies
- from a third party with your consent
- from cookies on our website
- via our IT systems, e.g.:
- access-controlled entry systems and reception logs;
- automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems.
- in photographs documenting an event or activity at Outside Edge Theatre Company where it would not be necessary, appropriate or practicable to obtain your specific consent (for example, we may seek specific consent for prominent or impactful uses, but typically not for group shots, background inclusion or internal use).
The information we get from other organisations may depend on your privacy settings or the responses you give to these websites. We recommend that you check these settings regularly.
As part of standard fundraising practice, if you are proposing to donate a significant gift to Outside Edge Theatre Company we will carry out due diligence research, including reviewing publicly available personal information, into whether your gifts have been accepted elsewhere and whether there is any substantiated negative press about you, including in relation to money laundering, which may negatively impact on Outside Edge Theatre Company’s reputation. This research is carried out in accordance with the Donor Charter and Public Fundraising Statement (set out at the end of this document) of Outside Edge Theatre Company’s Fundraising Policy.
What personal information we collect
We may collect and use the following personal information about you:
- your name and contact information, including email address and telephone number and (if applicable) company details
- Information to enable us to check and verify your identity, e.g. your date of birth
- your gender information, if you choose to give this to us
- location data, if you choose to give this to us
- your billing information, transaction and payment card information, including event payments, donations and Gift Aid declarations
- if you are a regular donor giving via direct debit, details of your direct debit instruction including your bank account details
- your previous participatory arts activity attendance and event booking history
- your contact history and purchase history
- information you make available on our social media accounts e.g. ‘likes’, posts and responses to our Facebook pages, Twitter and Instagram feeds and YouTube videos
- information to enable us to undertake credit or other financial checks on you
- Information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
- information provided by you for specific purposes (e.g. disability and dietary preferences for event management purposes)
- records of Outside Edge Theatre Company events you register for and attend
- records of communications and interactions we’ve had with you
- if you volunteer your time to Outside Edge Theatre Company, your volunteer activities
- information relating to your philanthropy and other giving, including donations to other organisations (which you may tell us about, or about which we may learn through the media)
- images of you when captured in photographs of our events in which you appear
We may use your personal information to send you updates in accordance with your preferences about our products and services, including exclusive offers, promotions or new products and services.
We send out emails about the following areas:
- Outside Edge Theatre Company full programme, news and offers
- learning and participation opportunities and appropriate related events
- ways in which you can support Outside Edge Theatre Company
You have the right to opt out of receiving promotional communications at any time by:
- using the ‘unsubscribe’ link in emails
- updating your contact preferences.
If you need further assistance you can also contact us at email@example.com.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and services in the future, or if there are changes in the law, regulation, or the structure of our business.
There are certain types of event-specific emails that you will always receive from us, regardless of your contact permissions. These include confirmation of booking, pre-visit information, post-visit information to gather feedback or notification if we need to change or cancel an event. These communications are sent to assist you with your booking and your visit, and are sent irrespective of any contact preferences you have supplied to us.
Disclosures of your personal information
Other than with your consent we only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they may only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We will not share your personal information with any other third party.
We only routinely share personal information with:
- Outside Edge Theatre Company employees, temps, volunteers and agents of Outside Edge Theatre Company;
- Third parties we use to help deliver our events, products and services to you, such as payment service providers, business associates and other professional advisers.
Information Requiring your Consent to Share
Sometimes, with your consent, we may need to share some information about you with other services that are involved in your care to better allow us to coordinate the treatment and care you receive. These services also have a legal obligation to keep any information that we may share with them confidential.
You may also wish to nominate one or more individuals who are close to you (e.g. partner, relative or friend), whom you wish to be involved in your care.
Should Outside Edge Theatre Company ever look to seek your consent to use your information, you have the right to withdraw that consent at any time. In a number of circumstances, we need to share confidential information without your consent. In these circumstances we will make every effort to discuss it fully with you first. The two main exceptions to the requirement to maintain confidentiality are:
- When there is concern that you are putting yourself or another person(s) at risk especially when this person is a child.
- When instructed by the courts, or in limited circumstances by the Police acting on the authority of the courts, to reveal information.
Outside Edge Theatre Company may need to use your information to carry out monitoring of services, to look at how services are performing and how services can be changed to improve the care provided to our clients. We will not use any identifiable information in these reports.
How long your personal information will be kept
We will keep your personal information while we are providing products and services to you or while it is in both our interests to maintain our relationship. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information, but in general we will contact you for consent to continue using your personal information after a period of 10 years after you have ceased to access or obtain our products and services.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
You have the following rights, which you can usually exercise free of charge:
|Access||The right to be provided with a copy of your personal information (the right of access)|
|Rectification||The right to require us to correct any mistakes in your personal information|
|To be forgotten||The right to require us to delete your personal information—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the information|
|Data portability||The right to receive the personal information you provided to us in a structured, commonly-used and machine-readable format and/or transmit that information to a third party—in certain situations|
|To object||The right to object:|
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us at firstname.lastname@example.org or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us — see below ‘How to contact us’; and
- let us have enough information to identify you (e.g. your full name, address and customer or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
Your information will be held and processed on Outside Edge Theatre Company systems or systems managed by suppliers on behalf of Outside Edge Theatre Company. All third parties we instruct to hold and otherwise process your information will be legitimately acting on our behalf and with proper and appropriate safeguards in place.
We maintain a customer relationship management (CRM) system to hold contact details and a record of your interactions with Outside Edge Theatre Company such as donations, queries, complaints and attendance at events. We aim to keep a single record for each individual.
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. Your special category information is only made available to members of staff who have a reason to work with it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and the UK regulator (the Information Commissioner’s Office (ICO)), of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
However, if we haven’t been able to do so, you also have the right to lodge a complaint with the ICO, who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 25 May 2023.
This policy may change from time to time so please check this page occasionally to ensure you’re happy with any changes.
How to contact us
Our contact details
Outside Edge Theatre Company, 192-196 Hanbury Street, London E1 5HU
Appendices to the Outside Edge Theatre Company Fundraising Policy
APPENDIX I – DONOR CHARTER
At Outside Edge Theatre Company, we rely on the generosity of our supporters to produce an extensive and diverse cultural programme, nurture artistic excellence and provide opportunities for people with creative potential. We welcome support from individuals, trusts and foundations and organisations and are dedicated to treating our donors with the highest level of care and respect.
- Acknowledge your gift swiftly, handle it responsibly and apply to the purpose for which we requested it;
- Respect your privacy and will only release details of you or your gift with your consent or if disclosure is required by law;
- Keep you informed about the specific project that you are supporting;
- Comply with all domestic and international legislation, including the GDPR and the Data Protection Act 2018 and adhere to the Fundraising Regulator’s Code of Fundraising Practice;
- Respond to any correspondence in a timely manner.
How your donation will be used:
- All donations, when undesignated, will be used for such purposes as Outside Edge Theatre Company judges appropriate in support of Outside Edge Theatre Company’s charitable objects;
- Where the gift is restricted, Outside Edge Theatre Company will apply the gift to the purpose originally intended.
In order to foster relationships with potential donors, we will invite people who we think might be interested in becoming donors to Outside Edge Theatre Company to a variety of special events. After attending an initial event, we will always ask you whether you would like to continue to be invited to Outside Edge Theatre Company and that you are being invited as a prospective donor. We will always respect your decision to opt out of further communications from us.
APPENDIX II – PUBLIC FUNDRAISING STATEMENT
At Outside Edge Theatre Company we aim to work with organisations and individuals who share our values and commitment to the arts. We will not accept donations where there is a risk of harm caused to Outside Edge Theatre Company by unethical sources of funding
All funding, sponsorship and partnership should comply with UK government and EU restrictions and exclusions.
Where a gift is deemed by the Trustees to be a significant risk to Outside Edge Theatre Company’s reputation or where potential harm is likely to be disproportionate to the benefit the charity will derive, the gift or sponsorship will be considered for rejection. The rejection of gifts is at the discretion of the board of Trustees.