Pirates of the Carabina Statement
Updated May 2018
Pirates of the Carabina is committed to protecting your personal information and being transparent about the information we hold, whether you are a collaborator, audience member, job applicant, customer, website visitor, or a participant in our Learning programme.
The purpose of this policy is to provide a clear explanation about how Pirates of the Carabina collect, hold, process and store your information. It outlines the measures we have in place to keep it safe and secure, whether it is collected online, by phone, email, in person, by letter or through social media.
The following sections should answer any questions you have but if not, please do get in touch by post, telephone or email. Contact details are shown below.
It’s likely that we’ll need to update this Privacy Notice from time to time, and you are welcome to come back and check this at any time or contact us by any of the means shown below.
Contacting Pirates of the Carabina
For the purpose of the GDPR (General Data Protection Regulation, 2018), the Data Controller is Pirates of the Carabina Ltd., trading under the name of Pirates of the Carabina.
If you want to know what information we hold about you or if you have any other queries in relation to this Privacy Notice, our contact details are as follows:
Postal Address: Towntree Farm, Stapleton, Martock, TA12 6AP
FAO Shaena Brandel, Company Director.
Pirates of the Carabina collects, holds and processes personal data from our employees, collaborators, cast members, job applicants, workshop participants, volunteers and audience members.
When we say personal data or personal information, we mean the details that you may provide about yourself and any information which identifies you, such as your name, address, email address, telephone number, country of residence or any photographs.
We do hold some sensitive information when there is a clear reason for doing so, for example if you participate in our workshops, we may need to know about your health. For activities involving the use of harnesses and counterweighted aerial equipment, we may also request information regarding your height and weight. If you are a workshop participant, we will only keep medical or health information for up to six months after the event has passed.
Certain funders may require us to collect information about gender, ethnicity, religious beliefs or sexuality (‘special categories’), which we will collect anonymously from job applicants, people engaged to work with us, workshop participants and, where appropriate, audience members. We will keep this information securely in password-protected locations, accessible only to relevant staff members.
We only retain this information for as long as required to report on our work to our funders, before destroying / deleting it. While holding this information, we will also anonymise it wherever possible.
Collecting and Storing your Information
We may collect personal information about you when you ask about our activities, register and participate in workshops or events, volunteer for us, buy something from our shop, sign up for our newsletter, contact us online, by phone or in writing or collaborate with us on any of our productions or projects.
We will only process ‘special categories’ of personal data – such as information about your ethnicity, sexuality or religious beliefs – if and when we have your explicit written consent; for the purposes of research or statistical reporting, or where there is a legal obligation. In all other cases, personal data will remain anonymous.
Most of the personal information we hold is provided directly from the person themselves, but some data could be provided by third parties such as fellow collaborators, referees or workshop leaders.
We will occasionally share personal data with other organisations where it is of legitimate interest, such as sharing production contact lists with venues hosting our shows or attendee lists for venues hosting Pirates of the Carabina workshops.
Third party services may also collect information on our behalf such as Eventbrite (for administering events), Paypal for purchases made in our online shop or payments for workshops, and mailchimp for sending out newsletters.
These companies will also have their own privacy statements.
Pirates of the Carabina have social media accounts on Facebook, Instagram, Twitter, YouTube, Vimeo and Storify. Depending on your settings or the privacy policies for these sites, by connecting with us on any of these channels you might give us permission to access your information on those accounts or services.
When you visit our website, we may collect your IP Address, page visited, web browser, any search criteria entered, previous web page visited and other technical information. This information is used solely for web server monitoring and to deliver the best possible visitor experience.
When we interact with you we may also collect notes from our conversations with you, details of any complaints or comments you make. We might record your identity where the law requires it.
We will only ask for and use your personal data for the purpose stated when it is collected. If we believe your data is no longer needed for this purpose we will not process your data further.
In some cases, we will rely on legitimate interest for processing data of potential supporters, promoters and collaborators.
Additional information about images and audio-visual material:
On occasion, we take photographs and / or film workshop participants and audience members to document our productions and learning activities. We will only use these images / video materials for marketing and reporting purposes with your express permission, by way of detailed media release forms which will necessarily include personal data, such as your name and contact details. We will store these permissions alongside the images/film materials for as long as we store the images/film materials, or until you request they be deleted/destroyed. In the event that we wish to use these materials in ways for which we have not already requested consent (i.e. on new platforms), we will contact you in order to request permission.
How we use your information
We will only use your information for the following purposes:
- To provide you with information about our online content you have agreed to receive
- For marketing purposes where you have specifically consented to receiving marketing communications from us
- For recruitment purposes
- To produce marketing and promotional materials for forthcoming productions, workshops and events where you have given express permission for us to do so
- To produce and facilitate touring theatre productions and workshops with host venues and co-producers
- For fundraising purposes
- To process card payments and set up direct debits
- For internal record keeping
- To invite you to participate in surveys or research
- To develop aggregated data for analysis and reporting to funders
- To analyse and improve the activities and content offered
When we collect feedback from audience members at our shows or workshop participants about their experience, we will only use your words alongside your name in future promotional material or for reporting purposes if and when you have given us express permission.
Additional information for job applicants, employees and collaborators:
If you apply for a role with Pirates of the Carabina, we will hold the personal information you provide to process your application and we may undertake monitoring of recruitment statistics as required by employment and data protection law.
If we want to disclose information to a third party, for example where we want to take a reference up or obtain “disclosure” from the Disclosure and Barring Service, we will not do so without asking you beforehand unless the disclosure is required by law.
If you apply to work with us we’ll only hold your data for the purposes of that application. We won’t hold your personal information for any longer than is necessary for the purposes of that application, unless you give us permission to do so.
Where you have been engaged professionally on a project or performance, we will hold your health / medical information on record for up to one year after you provide it (as part of your contractual agreement), unless you request for it to be amended / redacted / destroyed or deleted. We will update medical and health information for those we work with on a regular basis, as part of the contacting process.
We take the security of your data seriously. All digital personal information has appropriate technical controls in place to protect your data; any sensitive information is kept encrypted or in password-protected locations.
Hard copies of personal information are stored in locked locations with access limited to relevant and appropriately trained staff only. Our network is protected and routinely monitored. We regularly undertake reviews of who has access to what information to ensure that access to personal information is restricted and appropriate.
Where we use external companies that may process data on our behalf, we will check that these companies comply with the law and our policy before working with them. We will only share your data where we have your explicit and informed consent, unless we are required to disclose your details to the police, regulatory bodies or legal advisors for a lawful basis.
Occasionally we need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), for example in production contact lists with venues hosting our shows or attendee lists for venues hosting Pirates of the Carabina workshops. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA, and we will treat the information under the guiding principles of this Privacy Notice.
Retention of your data
We regularly review the length of time we keep personal data, and will only keep your personal data for as long as is necessary for the purpose for which it was collected. At the end of that period, your data will be deleted completely, archived or anonymised.
If required to report on employees, attendees of workshops or productions for funding purposes, we will retain the information up to the point where we have submitted the relevant information to our funders before securely destroying or deleting the information.
Unsuccessful job applicants will have their data deleted after three months after the appointment has been made; unless they have specifically requested that we retain their details for longer. In this case, we will request specific consent to hold their personal data for up to two years following request being sought. Everyone has the right to request that their data be amended, deleted or destroyed at any point, by contacting us by any of the means listed above.
Pirates of the Carabina maintain a retention schedule to track personal information held by the company and to ensure that information that is no longer required for its original purpose is securely deleted in a timely manner.
Your Right to Access your Data
You have the right to request the information we hold about you at any time by submitting a written Data Subject Access Request. We will require proof of ID before releasing any information.
We will provide you with a description or copies of your information held by Pirates of the Carabina within 30 days, unless your request is particularly complex, in which case it may take up to 3 months.
Your Right to Correct Incorrect Information and Your Right to Be Forgotten
You have the right to keep your personal data accurate and up to date. If you have reason to believe that Pirates of the Carabina holds incorrect or out-of-date information about you, please make a written request by contacting firstname.lastname@example.org. We will send you a Data Subject Access Request form to complete, will respond within 30 days of receipt of a completed form regarding your request to access and/or amend that data.
You also have the right to be forgotten. If you would like your personal data held by Pirates of the Carabina to be erased, please make a written request by contacting email@example.com. We will respond within 30 days.
We will erase the data as requested under the following conditions:
- If it is no longer necessary for the purpose it was originally collected
- If you initially consented to us holding the information and have now withdrawn consent
- If the information was collected and retained on a legitimate interest basis which no longer applies
- If we need to comply with a legal obligation.
The right to be forgotten does not apply when the information needs to be retained to perform a task in the public interest, comply with a legal obligation, or to exercise the right of freedom of expression and information, or for the establishment, exercise or defence of legal claims. The right will also not apply in cases where processing is required for public health purposes in the public interest. Other reasons why a request to be forgotten may be denied is if it is manifestly unfounded or excessive or whether the request is repetitive in nature.
Your Right to Complain to the ICO
If a request is denied, we will inform you of this within 30 days and explain the reasons we are not taking action. We will also inform you of your right to make a complaint to the Information Commissioner’s Office (ICO), and your ability to seek to enforce the request through legal action.
Privacy Notice Review
We regularly review this Privacy Notice to ensure that it is up to date and fit for purpose. We will notify you about any significant changes to the way we treat personal information by sending a notice to the primary email address you have provided or by placing a prominent notice on our website.
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.