PRIVACY POLICY

This privacy notice covers our main activities including our website galwad.cymru. We describe here the data we collect from you when you engage with us.

These are our reasons for collecting it, what we do with it and what your rights are.

WHO ARE WE?

We are Collective Cymru, a project led by The National Theatre of Wales, 30 Castle Arcade, Cardiff, CF10 1BW, company registration number 06693227.

You can call us on +44(0)29 2035 3070, or email us on admin@collective.cymru.

The National Theatre of Wales are the controller for the processing described in this privacy notice, and we are registered as a controller with the Information Commissioner’s Office (ICO) registration number Z187416X.

PURPOSE OF PROCESSING

We process your personal data for a variety of purposes as set out in the table below, which also shows our lawful basis under UK data protection legislation (UK GDPR) for doing so.

  • Managing your enquiries - Our legitimate interests in responding to and managing your enquiry

  • Managing your newsletter subscriptions - Our legitimate interests in ensuring that you only receive the newsletters you requested and that you no longer receive them should you unsubscribe

  • Other Direct marketing - Our legitimate interests in ensuring we appropriately manage, deliver or suppress direct marketing activity you have opted in to receive or opted out to decline to receive

  • Recruitment enquiries (including volunteers) - Taking the steps necessary to enter into a contract with you. We will provide further privacy information to you as the recruitment process progresses

Where we are relying on our legitimate interests you are free to object to that at any time. In the case of direct marketing activity (including newsletter subscriptions) we will ensure that we cease to market our services to you should you object to our legitimate interests.

DATA WE COLLECT

The table below gives information on the categories of personal data we process for each of the purposes shown above.

  • Managing your enquiries - Name, contact details, contact history and message content

  • Managing your newsletter subscriptions - Email address & name

  • Other Direct marketing - Name, contact details

  • Recruitment enquiries (including volunteers) - Name, contact details, basic employment or skills information required at this stage, role applied for

SPECIAL CATEGORY DATA

There are additional rules we must follow if we collect certain types of more sensitive data, known as Special Category Data. These include details of your ethnicity, beliefs, health and sexuality and in each case we must let you know what our additional lawful basis is for processing such data.

We do not routinely process any such special category data, however we may occasionally do so (for example when we manage an event you are attending we may ask for any dietary or access requirements which could include data relating to belief or health) and will always ensure we have a lawful basis (normally by asking for your explicit consent) and only retain the information for a very limited period of time.

We do have obligations to report on the diversity and inclusion of our project, however we will only request such information from you anonymously which means that it is not personal data.

HOW LONG DO WE KEEP YOUR DATA FOR?

Where we are relying on our legitimate interests to process your data then we will keep your personal data until you object to our legitimate interests and we agree with your objection, or until the following default periods have elapsed after our last contact with you.

We will retain your personal data by default for the following periods:

  • Managing your enquiries - 7 years

  • Managing your newsletter subscriptions - 7 years 

  • Other Direct marketing - 7 years 

  • Recruitment enquiries (including volunteers) - 7 years (if successful)

DO WE EVER SHARE PERSONAL DATA?

We will share your data if we receive a legitimate request from a law enforcement agency.

When you submit your personal data online your data is held by our partner who hosts our website.

If we are communicating with you via email or social media channels we will be sharing your personal data with those email and social media providers.

We also utilise external suppliers to provide a number of business support services. We always ensure that we have appropriate contracts in place to protect your rights when personal data are processed on our behalf by these third parties. There is further information regarding these suppliers in the “Where Do We Process Data?” section.

HOW DO WE KEEP YOUR DATA SECURE?

We take sensible steps to keep your data secure and ensure we can uphold your rights and meet our obligations under UK GDPR:

  • All data sent between your browser and our website are encrypted in transit,

  • Access to personal data is role based: only those members of staff with a legitimate need will have access,

  • Systems are password protected and multi-factor authentication is enabled where available,

  • We maintain appropriate records of processing activities which record any data processors we use and we ensure that appropriate contracts are in place to protect your rights, that the processors take appropriate security measures to safeguard your data, and that any international transfers are done correctly under UK GDPR,

  • Our employees are all subject to an obligation of confidentiality, and receive training on data protection matters,

  • We utilise appropriate technical and organisational measures to optimise the security of your personal data.

YOUR RIGHTS

You have a number of rights relating to the processing of your data, if you would like to use them or have any questions then please contact us.

We won’t charge you for doing any of the following, however we may make a charge in the case of frequent repeat or unfounded requests:

  • Awareness: You have the right to be fully informed about why and how we process your information. This privacy notice is intended to meet that requirement, but please do contact us if you have any questions,

  • Access: You have the right to a copy of the data we hold about you

  • Rectification: If you think some of the data we hold is wrong then you have the right to ask us to correct it,

  • Erasure: You have the right to ask us to delete the data we hold about you. Where we are holding the data to fulfil a contract with you or your organisation then we will need to retain the data in accordance with the data retention requirements shown above,

  • Restriction: You have the right to ask us to restrict the processing of personal data whilst we check its accuracy, if you think the processing is unlawful, if you believe we no longer need to process the data but you need us to store it due to pending legal claims, or when you object to our processing based upon our legitimate interests and we are assessing the validity of that,

  • Object: Where we are processing your personal data based upon our legitimate interests you have the right to object to that. If your objection is valid (for instance in the case of any direct marketing activity) then we will stop processing your personal data for that purpose,

  • Data portability: You can request a copy of your data in a digital format which you can then supply to another provider when we ae processing your personal data under the lawful basis of performing a contract with you or because we have your consent,

  • Automated decisions and profiling: You have the right, in certain circumstances, not to be subject to decisions based on automated processing (including profiling) if it has a significant or legal impact on you. This doesn’t apply if the processing is necessary to fulfil a contract with you, or if you have given us your consent to do so. We do not currently use any technology to make automated decisions about you.

COOKIES – HOW DO WE USE COOKIES ON OUR WEBSITE

We utilise cookies on our website. Some are required for our site to work, these are known as essential cookies, and we also use others for analytics and marketing purposes.

We will ask for your consent to use any cookies which aren’t essential, and we won’t deploy any non-essential cookies without your consent. You should be aware that whilst we use non-essential cookies to help us understand how our website is performing, the author of the cookies (Google) also uses the data obtained for their own purposes. To find out more about this please see Google’s privacy notices here: https: //policies.google.com/privacy

These are the non-essential cookies we use:

  • Google Tag Manager - Marketing and Analytics 

  • Google Analytics - Marketing and Analytics 

WHAT HAPPENS WHEN I FOLLOW LINKS TO OTHER SITES?

If you follow a link from our site to another site then you should read the privacy notice on the other site prior to providing your data to them.

WHERE DO WE PROCESS DATA?

We primarily process data in the UK however we use partners to help us deliver our services, some of these services will mean that your personal data are transferred outside of the UK

  • Google Workspace - USA & Google locations in other nations - Standard Contractual Clauses in place.

  • Website host - UK - N/A

  • Zoom - USA - Standard Contractual Clauses in place.

  • SmartSheets - USA - Standard Contractual Clauses in place.

  • DropBox - USA - Standard Contractual Clauses in place.

  • MailChimp - USA - Standard Contractual Clauses in place.

MAKING A COMPLAINT

Please contact us at the above address. You can also contact the Information Commissioner’s Office (ICO) on their helpline 0303 123 1113 or online at www.ico.org.uk. If you should contact the ICO they will normally ask you to contact us first.