Privacy Policy

GDPR: OVERALL DATA PRIVACY NOTICE

SECTION A – Overall provisions and information

1. Who we are and what we do

Creative Land Trust is a “data controller”. This means that we are required under data protection legislation to notify you of how we will process your personal data. We are registered with the Information Commissioners’ Office, and our registration number is ZB113242.

Creative Land Trust exists to secure long term affordable workspace for artists and creatives. In some cases we need to hold some personal data to be able to achieve our aims. The way we do this is set out in a lot more detail below but some key principles will always apply;

  • We never pass your data onto third parties without your explicit consent.
  • We are committed to keeping your data safe.
  • We will always be upfront about how we use your data and are open to feedback about how we can do this better.

2. Scope of this privacy notice

This privacy notice is designed to provide information to our supporters, collaborators and partners (both current and future) about what data we may collect and how we use it. We have set out the overall principles in Section Athis section, and then the following sections deal with particular groups of people.

If you work or volunteer with us, a separate privacy notice will be given to you when you start your employment or volunteering.

3. What are our obligations to you in relation to how we process your personal data?

We are required by law to ensure that when processing any of your personal data that it is:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept in a form which permits you to be identified for only as long as necessary for the purposes we have told you about.
  • Kept securely.

4. What rights do you have in respect of how we use your personal data?

Subject to legal limitations you have the right to:

  • Request access to your data: You can ask us to provide a copy of the personal data we hold about you.
  • Request corrections to be made to your data: If you think that your personal data is incomplete, inaccurate you can ask us to correct it.
  • Request erasure of your data: If you consider there is no lawful basis for us to continue processing your data you can ask for that data to be deleted or removed.
  • Object to the processing of your data: If our lawful basis for processing your data relates to a legitimate business interest (or third party interest) you can raise an objection to that interest. You can also object to us using your information for direct marketing purposes.
  • Request that processing restrictions be put in place: If you believe that your information is being processed without a lawful reason or that the information is incorrect you can request that a freeze/restricting is placed on the processing of the information until your concerns are addressed.
  • Request a transfer of your personal data: You can ask us to transfer your personal data to a third party.

If you wish to exercise any of the above rights please contact via our email here.

5. How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact us through the email address linked here.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.

SECTION B – Supporters, Partners, Collaborators and Beneficiaries 

This section applies to our supporters and to any third parties who work with us, eg studio providers, developers, local councils, funders, and suppliers.

1. What personal data will we collect, use and store about you?

We may collect the following Data, which includes personal Data, from you:

  • First Name
  • Last Name
  • Job Title;
  • Company
  • Interests
  • Email Addresses
  • Telephone Numbers;
  • Address

2. How do we collect your personal data?

  • Email

If your email requires a response from one of our team members or expresses a specific interest in the organisation that may require future correspondence we may decide to hold your contact details in Creative Land Trust’s address book, managed using HubSpot. This is to allocate your query to the correct team member and better manage our response. In being added to this address book we assure you will not be spammed; however, you may contact the team at any time to be removed from our address book.

While corresponding with the Executive Team you may be asked if you would like to join our mailing list. If you agree to join our mailing list please see this section the next section.

Please note: If you email us we will keep your information secure when it reaches us, but we have no control over relay systems or other technology that your email provider may use. We may use spam filtering or other technology on incoming email. As a general rule, you should avoid putting personal information in unencrypted emails.

  • Mailing List

Mailing list subscribers come through our website forms or via email request. Mail list contacts will receive monthly updates. However, we may also contact select mail groups with information relating to their specific interest in the Creative Land Trust. For example, we may contact studio providers with details of upcoming tenders.

Our newsletter and mailing list are managed through the platform MailChimp, which allows you control over your mailing preferences and the option to unsubscribe.

  • Website Contact Form

If your contact form submission requires a response from one of our team members or expresses a specific interest in the organisation that may require future correspondence we may decide to hold your contact details in Creative Land Trust’s address book, managed using HubSpot. This is to allocate your query to the correct team member and better manage our response. In being added to this address book we assure you will not be spammed; however, you may contact the team at any time to be removed from our address book.

There will be an option to opt into the mailing list when using the contact form – if you opt-in please see the section above.

  • Legacy

By filling out our form to express an interest in Legacy Giving you have agreed to receive a free information pack from our partners, the National Free Wills Network. The only correspondence they will send is the welcome pack followed by the reminder letter 90 days later if the supporter hasn’t taken up the offer.

If you have signed up to our mailing list in the process of filling out the Legacy form please see our Mailing List section.

3. With whom do we share your personal data?

We share personal information in two circumstances only;

With your explicit consent, for example, if you express an interest in our legacy programme we will ask your permission before passing on your information to our partners

With data processing companies such as MailChimp and Hubspot – all of these instances are covered by data processing agreements and we check them to ensure conformity with GDPR and UK Data Protection law.

Our current data processors are;

  • MailChimp (for newsletter recipients)
  • HubSpot (to manager our address book and contacts)
  • Microsoft (provider of cloud solutions including documents and email)
  • Xero (provider of accounting software)
  • Kualo (data centre for our website, based in the UK)

We do not transfer your data out of the UK or the EEA, however, MailChimp, Xero, Hubspot and Microsoft operate internationally and may occasionally hold data outside the UK or EEA. At the date of writing this notice, all four companies have included the European Commission’s Standard Contractual Clauses (SCCs) in their data processing agreements to ensure that any personal data will be transferred in compliance with EU data-protection law (and by extension, current UK Data Protection law).

4. How do we keep your data safe?

In order to keep your data safe, we only use recognised third party systems that are compliant with both GDPR and accredited Information security standards (such as SOC2 or ISO27001)

All systems provide an audit trail and require named user logons and two factor authentication.

5. How long do we keep your data?

We only keep your personal data with your explicit consent.

If you are kind enough to have made a donation to us, we may need to hold certain information to comply with accounting and legal regulations for six years after your donation.

SECTION C – Applicants for job or volunteering opportunities

This section applies to anyone applying for a job, work experience or a voluntary position with us.

1. What personal data will we collect, use and store about you?

If you apply for a job at Creative Land Trust, we collect a range of information about you, including sensitive personal data. This includes:

  • Your name, address and contact details, including email address and telephone number.
  • Details of your qualifications, skills, experience and employment history.
  • Information about your performance in all aspects of assessment process, including job application; tests and interview.
  • Whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process.
  • Information about your work history including any gaps.
  • Information about your entitlement to work in the UK.
  • Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health, and religion or belief.

2. How do we collect your personal data?

Most of this information will be collected from you as part of the application process.

We may also collect personal data about you from third parties, such as references. We will seek information from third parties only once a job offer to you has been made and will inform you before we do so.

3. Why do we process this personal data?

We need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.

In some cases, we need to process data to ensure that we are complying with legal obligations. For example, we are required to check a successful applicant’s eligibility to work in the UK before employment starts.

We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.

We process health information if we need to make reasonable adjustments to the recruitment process for candidates who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.

Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes.

4. Whom do we share your personal data with?

We do not share your personal data with third parties other than data processors – see section B3 above for more information about who we use.

5. How do we keep your data safe?

In order to keep your data safe, we only use recognised third party systems that are compliant with both GDPR and accredited Information security standards (such as SOC2 or ISO27001)

All systems provide an audit trail and require named user logons and two factor authentication.

6. How long do we keep your data?

If your application for employment or a volunteering position is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

SECTION D – Website and Social Media Users 

1. Website

When you visit www.creativelandtrust.org we use a third party service, Google Analytics, to collect standard internet log information (IP addresses and web browsers) and details of visitor behaviour patterns. We do this to track interest on specific pages, see how the site is being used and look at how we can make improvements to the site. The information is only processed in a way that does not identify anyone.

We do not make, and do not allow Google to make, any attempts to find out the identities of those visiting our website.

2. Cookies

This Website may place and access certain Cookies on your computer. Creative Land Trust uses Cookies to improve your experience of using the Website. Creative Land Trust has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Creative Land Trust to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

This Website may place the following type of Cookies:

Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

3. Social Media

We monitor social media user activity and engagement through Hootsuite and the platforms themselves. This provides us with generalised data and does not offer data on individuals users.

However, if you message us via social media, even in so-called private messaging, we have no control over the privacy policy that is applied by the relevant channel. For that reason, please do not send personal data via social media – instead, let us know the general details of your message and we will contact you if appropriate.

Appendix –  Partners and Providers 

1. National Free Wills Network 

We work with The National Free Wills Network to support our Legacy Giving campaign. https://creativelandtrust.org/legacy-giving/. We will only pass on contact information to the NFWN if we have your explicit consent to do so, and only for the purposes of supplying you with information and support to create a free will. For more information about NFWN please go to https://www.nationalfreewills.net/