Last updated on 23 September 2020
Purpose of policy
We are committed to protecting your personal information and being transparent about what information we hold about you. Using personal information allows us to develop a better understanding of our customers and in turn to provide you with relevant and timely information about the work that we do. As a charity, it also helps us to engage with potential donors and supporters. The purpose of this policy is to give you a clear explanation about how we collect and use the information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
- What information we may collect about you
- How we may use that information
- In what situations we may disclose your details to third parties
- Information about how we keep your personal information secure, how we maintain it for and your rights to be able to access it
If you have any queries about this policy, please contact the Data Protection Officer at Plymouth Arts Cinema or email: firstname.lastname@example.org
Who we are
Plymouth Arts Cinema is a trading name of Plymouth Arts Centre.
Plymouth Arts Centre is a charity and is funded by the British Film Institute, Plymouth City Council, as well as individual donors and supporters. Our registered charity number in England and Wales is 800664 and we are also registered as a company in England and Wales under registration number 02324916.
We collect various types of information and in a number of ways:
Information you give us
For example when you register on our website, buy tickets or make a donation, we’ll store personal information you give us such as your name, email address, postal address, telephone number and card details. We will also store a record of your purchases and donations. When you create a customer account with us, you are also given the opportunity to tell us more about yourself, for instance by providing your date of birth, but this is not compulsory.
Information about your interactions with us
For example, when you visit our website, we collect information about how you interact with our content. When we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.
Information from third parties
We occasionally receive information about you from third parties. For example, we may use third party research companies to provide general information about you, compiled using publicly available data.
Sensitive personal data
Data Protection law recognises that certain categories of personal information are more sensitive such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our customers unless there is a clear reason for doing so. As an example, we might collect health information about participants to a workshop.
We give our customers the option to provide information about their access requirements. This enables customers with limited mobility to book reserved seats online (wheelchair space, companion seat and front row seats). This information is stored on the customer account and can be reviewed at any time.
The customer survey we run annually collects information about health, race, and religious beliefs but it is an anonymous survey.
There are three bases under which we may process your data:
When you make a purchase from us or make a donation to us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example we may need to contact you by email or telephone in the case of cancellation of a show, or in the case of problems with your payment.
Legitimate business interests
In certain situations we collect and process your personal data for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
With your explicit consent
For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
Marketing and fundraising communications
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about. We use our legitimate organisational interest as the legal basis for communications by post and email.
During your first purchase with us, we give you an opportunity to opt in to receive our email newsletters. If you opt in, we provide you with an option to unsubscribe in every email that we subsequently send you.
If you are an existing customer, we have asked you to opt in to receive our email newsletters in the past. If you opted in, we have given you the option to unsubscribe in every subsequent email that we sent you, so unless you tell us otherwise, we’ll stay in touch with you to let you know about our future activities.
We will ask you for your consent to receive emails about Plymouth Arts Centre’s fundraising activities, whether you are a new or existing customer.
During your first purchase with us, we give you an opportunity to be added to our mailing list for marketing and fundraising communications by post. Please note that we only post our film guides to Members and regular cinema bookers.
If you are an existing customer, we have asked you for your consent to be contacted by post in the past, so we are using our legitimate interest to keep in touch with you and let you know about our future activities by post.
You can check what you opted in for and amend your contact preferences at any time by logging in to your customer account online, or in person by asking a member of staff at the Box Office. Alternatively you can use the contact details at the end of this policy.
If you become a Member of Plymouth Arts Cinema, this is how we will contact you during the course of your membership.
As part of your membership contract with us, we’ll send you the following emails:
- Welcome email the day after the membership is purchased or renewed
- Priority booking notifications
- Invitations to special events
- Notification that your membership is due for renewal.
- If your membership is set to auto-renew, you will also receive automated emails when your membership is due for renewal to let you know when we will attempt to take payment on your card, if you need to update your card details, and if the auto-renewal was successful.
Some contents in the emails will vary based on your marketing and fundraising contact preferences.
If you do not wish to receive email communications from us at all, you can click on the unsubscribe link at the bottom of each email.
Guide in the post
As a member, one of your benefits is receiving our bimonthly film guide in the post. But we will only send it to you if you have ticked “If you’d like to hear from Plymouth Arts Cinema by post” in your contact preferences.
The guide is the main thing we send in the post, and we will never share your details with third parties without your consent.
If you’ve also subscribed to Plymouth Arts Cinema’s email newsletters, you will receive our weekly what’s on e-flyer, targeted emails based on your past attendance, and exclusive offers.
Other processing activities
In addition to marketing and fundraising communications, we also process personal information in the following ways that are within our legitimate organisational interests:
We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
We may analyse data we hold about you in order to identify and prevent fraud.
In order to improve our website we may analyse information about how you use it and the content that you interact with.
We may use profiling techniques or third party wealth screening and insight companies to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you about potential philanthropic support. Such information is compiled using publicly available data about you.
We may use the data we hold about you for analytical purposes such as reporting on general audience attributes. This process uses anonymised data which cannot be personally identifiable.
In all of the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out tasks above that are for your benefit.
If you purchase a gift voucher online or at the Box Office, you will be given the option of sending a digital version of the gift voucher to the purchaser’s email address (you) or to the recipient’s email address (the person you are offering the gift voucher to). In both cases, we will only process the email address in order to send the gift voucher, on the Performance of a Contract legal basis. The email address will not be added to our marketing or fundraising mailing lists.
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
To HMRC when we submit a Gift Aid claim for your donations, if you completed a Gift Aid Declaration with us.
Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
To partner organisations whose work we have shown. In these cases we will always ask for your explicit consent before doing so.
NHS Test and Trace
Plymouth Arts Cinema is working with NHS Test and Trace as part of the country’s ongoing COVID-19 response. NHS Test and Trace is a contact tracing service run by the Department of Health and Social Care (DHSC).
What information will you collect and how?
We’ll collect the names and contact telephone numbers, and date of visit and arrival and departure time of all customers or visitors, or if it is a group of people, the name and number of one member of the group.
We’ll collect the information when you book a ticket (through our ticketing system).
Do I have to share this information?
Yes – since 18 September 2020, NHS Test & Trace is a compulsory scheme for visitors of hospitality venues including cinemas, and we are required by law to collect contact details for all people attending a film screening. Hospitality venues are required to refuse entry to those who refuse to participate.
If you do not wish to share your contact details with us, the alternative is to use the NHS COVID-19 app on your mobile phone and scan the official NHS QR code displayed on posters in our premises to check in our venue when you arrive on site.
For more information about hospitality venues requirements and the NHS COVID-19 app alternative, see: https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace
Why are you collecting and sharing this information?
We’re using your information on the legal basis that it is necessary for reasons of public interest in the area of public health.
Who do we share your information with?
Your information is shared with Department of Health and Social Care (who run NHS Test and Trace). This is only shared in the event that someone who has tested positive for COVID-19 has listed Plymouth Arts Cinema as a place they visited recently, or if Plymouth Arts Cinema is identified as potential location of a local outbreak of COVID-19.
How long do you keep my information for this purpose?
If the information is not being used for another reason by Plymouth Arts Cinema (such as facilitating ticket bookings where information will be kept longer), your data will be deleted after 21 days by Plymouth Arts Cinema.
Where your data is passed to NHS Test and Trace in the case of a suspected outbreak, your information will be kept for up to 8 years, as part of the standard contact-tracing retention period set out by Public Health England.
For more information on how your data is used by NHS Test and trace services see: https://www.gov.uk/government/publications/privacy-notice-for-maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace/privacy-notice-for-maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace
Data submitted through our website
When you make an online purchase with us for the first time, you will be given the option to register and create a customer account. For every subsequent online purchase with us, you will be asked to log in to your account. Customer account details are not stored on the website itself, instead they are stored on our booking system. We have checked and will regularly review that our booking system provider operates on a privacy and data protection policy compliant with the latest data protection regulations to ensure secure storage and processing of our customers data through this system.
You can sign up to receive our email newsletters by completing the sign up form on our website, at the bottom of the homepage. You will also be given the option to opt-in to receive our emails about fundraising activities. When you submit the form, a customer account will automatically be created by our booking system provider and will record the contact preferences you indicated in the form for receiving marketing emails and fundraising emails. Your details will be stored as described above. You will be able to log in to your customer account and review your contact preferences at any time. We will also provide you with an option to unsubscribe in every email that we subsequently send you.
You can send us queries about a specific event by using the contact form at the bottom of the event page. By submitting a contact form, you are soliciting a communication from us and we will reply to your query using the contact details you provided. When a contact form is submitted, we receive an email containing the query details on our general enquiries mailbox (email@example.com). The email might get forwarded internally to the staff member(s) most suited to reply to the query. The contact forms are stored on the password-protected end of our website and are only accessible by accredited members of staff. Both in the cases of the website and mailboxes, your details will only be stored as long as required to deal with your query.
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Your debit and credit card information
If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find more information about this standard here.
We optionally allow you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.
Maintaining your personal information
We store your personal information indefinitely such that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.
If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging in to your account through our website. Alternatively please use the contact details at the end of this policy.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
Security of your personal information
We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area.
Your rights to your personal information
You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. If you would like to exercise this right, please complete a Subject Access Request form, downloadable on our website here, and submit it to us using the contact details on the form. You do not have to use the form and may instead write to us using the contact details at the end of this policy.
Contact details and further information
C/O the Data Protection Officer
Plymouth Arts Cinema
Plymouth College of Art