DATA PROTECTION POLICY
Vaticinate Pictures Ltd (VP) is a media and performance production company.
VP takes the privacy of its audience and users very seriously. This Data Protection Policy outlines how personal information is collected, used and treated by VP, in accordance with the Data Protection Act, 2018.
All freelancers employed by VP are required to read and adhere to this policy in their dealings with VP audience and users, for the duration their contract with VP.
All data collected and stored by VP remains within the company, and is not to be copied or removed.
Because we can use personal information in a number of different ways, we have split this policy into sections that cover each category. However, for all personal information we hold we undertake to:
Tell users about how their data is used, either at the time we collect it (if we collect it directly) or as soon as is practical afterwards (if we collect it from a third party).
Keep it securely and make it available only to those within the organisation who need to see it. Where we share data with other organisations, we will tell users first wherever possible (sometimes there may be legal reasons not to).
Where data is processed by other organisations on our behalf, make sure that the processing is clearly defined, secure and governed by a contract.
Respect users’ rights over personal data.
Inform users about major changes to this policy.
This policy is effective from 12th October 2023. It is reviewed annually.
TCP’s Data Protection Officer is Robert Williams, co-director, contact at rob@vaticinatepictures.com
USERS RIGHTS OVER THEIR INFORMATION
VP users have the right to:
Have a copy of the personal information VP holds about them.
Correct inaccurate information or have incomplete information completed.
Have their data erased (‘right to be forgotten or ‘right to erasure’) in certain circumstances.
Restrict the processing of their personal information in certain circumstances.
Data portability – have their information supplied in a commonly used format and transmitted to another organisation.
Object to the processing of their personal information.
Object to automated decision making or profiling.
Further information on these rights can be obtained from the Information Commissioner’s website at: https://ico.org.uk/
If users are unhappy about the response they receive from TCP, they can contact the Information Commissioner’s office by writing to the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or via their website at https://ico.org.uk/
Users information is stored on a company password protected laptop.
VP retains user data for specific projects with specified end dates and generally speaking, data will be kept until then. At the end of each project, we will contact users to ask they whether they would like their data deleted.
HOW WE USE DATA FOR DIRECT MARKETING
If users/audience sign up a VP event, we will ask for their email address.
We will use this personal information to inform them about forthcoming VP events, news and offers which may be of interest. We only do this with their direct consent, and they can withdraw it at any time.
Objecting to direct marketing
If users do not wish to receive any further marketing information from us they can:
Contact us direct at rob@vaticinatepictures.com giving their name, email address and if possible sending a copy of the last communication received (this will help us identify they).
We will need to retain a small amount of information about they (usually name and email address) to add to our ‘stop list’. When we send marketing mailings, we run the recipients against this list to ensure those who have objected are not contacted.
HOW WE USE INFORMATION FOR FUNDRAISING
How we collect their information for fundraising
When fundraising, VP may collect information in two ways:
Direct from users when they buy a ticket to a VP event, make a donation or enquiry
From publicly available sources, such as annual reports or newspaper articles to help us identify potential donors.
What information we collect
Name(s) and address, email, phone number(s) and other relevant contact details and preferences
Records of donations to VP
Information about our relationship with them, correspondence, meeting notes, attendance at events etc.
Occupation and professional activity, network(s) and interests where relevant to our needs.
Philanthropic interests and giving history if relevant and only where information is publicly available.
Financial information and potential giving capacity, only where information is publicly available.
How we use their information for fundraising
We use this information to:
Process their donation – (to fulfil the contract we have with them to ensure their donation is recorded, auditable and is used for the right project).
Contact them with further information about our fundraising actives, or about the progress of the project they have supported, if they have given us permission to do so (see Marketing section above).
Carry out targeted prospect research into potential donors who have an affinity with VP and/or our subject matter. Prospect research involves collating information on specified individuals, including their interests, suitability and likelihood to donate to VP. We only carry this out using publicly available sources or information that they have provided. This activity assists us in understanding the background of the people who support us and helps us to make appropriate requests to supporters who may have the interest and means to give. We may also use this information to contact they, if they have a business address.
We carry out the last two activities because we believe it is in our legitimate interests to do so. All of VP’s funding is self-generated and our project funding agreements often specifically require us to generate income through fundraising. A significant way of doing this is through prospect research. We balance this out by ensuring that the information we collect, and use is strictly limited to what is already widely known about that individual (see section on ‘What Information we collect’ above).
Although it is often not practical to inform users when we start to carry out this research, they will be provided with a copy of this Privacy Policy on first contact and can ask us to delete any information we hold about they and not contact them again.
How long we keep their information for fundraising
Donation information is kept for six years, for audit and accounting purposes. In the case of major donations (defined as a gift of over £500), we will keep details of their donation for longer, as part of VP’s historical record.
We keep information on potential donors for a maximum of two years if no further contact is intended in regard to future relevant projects. Where their information is no longer required, we will ensure it is disposed of securely.
They can ask for a copy of information about them held on our fundraising database and for it to be amended or deleted, by contacting the VP’s Data Protection Officer
HOW WE USE PERSONAL INFORMATION FOR ENQUIRIES
We may also collect information about users when they write to us with an enquiry. This information is only used to answer their enquiry.
We believe that using their information in these ways fulfils our function as an independent media production company – that is to provide access to information about our operation and activities.
HOW WE USE INFORMATION FOR MARKET RESEARCH
If users have given their consent, we may also contact them to participate in general market research activity regarding VP via telephone, email or face–to–face.
We may also use their personal information for market research purposes, to track activity on our website, to publish trends or to improve usefulness and content. Where we do use their data in this way, we will ensure that it is made anonymous, so they can’t be identified personally.
We do this because we believe it is in our legitimate interests to do so.
COOKIES
Cookies are usually set when users visit a particular page on the VP website, or if they take a particular action, such as filling in an online form.
The information we collect via cookies consists usually of things like IP addresses, sites visited, and actions taken. We don’t use them to identify users by name, or record things like email addresses or bank details
The VP website also contains third party cookies set by other organisations.
HOW TO UNSUBSCRIBE
They can unsubscribe from any or all of VP’s services at any time, just click on the relevant links on our website or in the emails we send they.
CONTACT DETAILS
If there are any questions or concerns about the way in which we handle their personal information, please email rob@vaticinatepictures.com
POLICY UPDATES
This policy was reviewed by VP on the 12th October 2023.