Cumbernauld Theatre Trust Ltd is committed to adhering with the laws and regulations when it comes to the confidentiality of your personal data.
The General Data Protection Regulation (GDPR) is a European Union (EU) regulation that governs consumers’ private information, becoming effective in May 2018, it impacts the way businesses process and handle data. Any business collecting personal data from individuals, directly or indirectly, is acting as a Data Controller and therefore regulated to operate in a lawful and transparent manner. It is the Data Controller who is responsible for, and must be able to demonstrate, compliance with the principles of GDPR. On the other hand, a Data Processor is defined as a body which processes personal data on behalf of the Data Controller and under their authority. GDPR stipulates that to protect the confidentiality of individuals, both bodies must operate abiding with the below standards:
Please contact our Box Office on 01236 732 887 if you have any concerns over the way your data is treated. If we have not been able to satisfactorily resolve a problem regarding our handling of your personal information or for more information about your Data Protection rights, please visit the website of the Information Commissioner’s Office here.
In the unlikely event of a data breach – we will report the incident to ICO within 72 hours and will notify you and any applicable regulator of a breach where we are legally required to do so.
3. Who is Responsible for Processing Your Personal Data?
As a Data Controller we use business partners to provide services and process Personal Data in support of Cumbernauld Theatre Trust Ltd activities. To undertake our business activities we sometimes have to share your information with third parties such as our ticketing system provider (Spektrix) and our mailing house (Johnston Mailing House), which handles our direct postal communications with you. We only choose partners we trust and will only ever pass personal data to them if they have an agreement in place to act in accordance with our instructions in upholding GDPR principles.
4. What categories of Personal Data do we Process?
Cumbernauld Theatre Trust Ltd processes both online and offline data that may directly or indirectly identify you when you use our booking services or website. This data may include:
Offline data when you book tickets at our box office or via the telephone or book with one of our third party agents or suppliers.
Online data where you book via our website or that of our business partners, when you order gift vouchers, become a member or kindly donate to Cumbernauld Theatre Trust Ltd.
Examples of specific information Cumbernauld Theatre Trust Ltd collects includes:
5. How do we use Your Personal Data?
We use your personal information to respond to your requests, to deliver and improve our services, to process orders, to sell our services and to comply with applicable laws.
To fulfil obligations we have with you as a customer
When you book tickets for a show hosted by Cumbernauld Theatre Trust Ltd we will process Personal Data about you as a customer and as a consumer of our products and services. We do this to administer and engage in relevant transactions. These may include the creation of an account, recording the products and services ordered by you, our administration of bookings, support of our products and any requests you may make around them.
To deliver technical functionality to our website
We may process your Personal Data to analyse, improve, develop, and optimise the Cumbernauld Theatre Trust Ltd website.
To manage the security of our website and systems
We may collect Personal Data from our networks, systems, and services that are used to inform security and operations management to help keep our website, networks, and systems secure. We can also use this information to investigate or prevent cyber-attacks or to detect bots.
To provide services to you
There may be occasions where you need to contact you to inform you of events, cancellations or changes.
To comply with legal obligations, applicable laws, regulations and to operate our business
There are occasions where Cumbernauld Theatre Trust Ltd may need to process Personal Data to comply with a legal obligation, applicable law, or regulations. For example, we may need to defend a legal claim or respond to a request from a lawful authority. Cumbernauld Theatre Trust Ltd may also process Personal Data in the operation of our business where investigations may require access to your Personal Data.
6. What is our Lawful Basis for Processing your Personal Data
Cumbernauld Theatre Trust Ltd will only process your Personal Data if there is a legal reason to do so that is recognised under the GDPR and Applicable Law.
Cumbernauld Theatre Trust Ltd must have a lawful basis for the processing of your Personal Data. Our lawful basis for processing includes:
a) Legitimate Interest.
To communicate with you and to respond to your requests we rely upon a Legitimate Interest to process your Personal Data
We process your Personal Data for marketing and sales activities based upon Legitimate Interest
We also rely upon Legitimate Interest to analyse, develop, improve and optimise our website, products and services and to use your Personal Data to maintain and improve the security of our website, networks and systems
We sometimes rely upon your consent to process your Personal Data where this is indicated at the time your personal data is collected.
c) Performance of a Contract
When we engage in transactions with customers, suppliers, or business partners we need to process your Personal Data to either enter into or to meet our obligations under a contract.
d) To Comply with Applicable Laws and Regulations
There are certain legal obligations that must be met by companies such as Cumbernauld Theatre Trust Ltd. Where there is a need to comply with applicable laws and regulations, we may be legally obliged to share your Personal Data.
7. How Long do we Keep Your Personal Data?
Cumbernauld Theatre Trust Ltd retains information for the following retention periods
Contact information such as your email address or phone number that has been collected from online or offline activities will be retained for as long as we have an active relationship with you as a customer. We treat you as an active contact if you have interacted with Cumbernauld Theatre Trust Ltd or if you have updated your contact details and preferences in the past 18 months and you have not made a deletion or do not contact / opt out request.
Personal Data needed to retain your opt-out preferences is kept for a period of two years or longer if required by applicable laws.
Where there is a legal obligation to retain records for a legal or compliance purpose information will be kept for a longer period in line with statutory retention periods for the data in question.
8. How do we Share Your Personal Information?
Cumbernauld Theatre Trust Ltd shares information about you throughout its operations to the extent necessary to perform its business with you, its suppliers and business partners. All Cumbernauld Theatre Trust Ltd employees, suppliers and business partners are only authorised to access personal information to fulfil an applicable and specific purpose and to perform their job functions.
Sharing with Third Parties
Cumbernauld Theatre Trust Ltd acts a Data Controller when you use our Services. We share Personal Data with third parties when you interact with us for the following reasons or purposes:
A list of current third-party processors can be found here.
Third Parties/ Data Processors
Cumbernauld Theatre Trust Ltd will never share, sell, rent or trade your personal information with or to any third parties for marketing purposes without your prior consent however, some of our service providers may have access to your data in order to perform services on our behalf (such as payment processing).
We make sure anyone who provides a service for the Theatre enters into an agreement with us and meets our standards for data security. They will not use your data for anything other than the clearly defined purpose relating to the service or consultancy they are providing.
We will only share email address and usage data with our partners managing the specific area where use of this data will only be with regards to CTT. We will ensure that all contracts and agreements with third parties that may handle the company’s sensitive data, comply strictly with our instructions.
Cumbernauld Theatre Trust only shares data with our regional partners listed below and no other third parties.
When you create an account on our website, buy tickets, sign up to our newsletter, request marketing materials, give us feedback or make a donation, we will store the personal information you give to us such as your name, email address, postal address, telephone number and card details. We will also keep a record of your purchases and donations. We keep all data under strict safekeeping and confidentiality measures and only allow authorised Cumbernauld Theatre staff to access to personal information you provide.
Please read the Spektrix Privacy and Security Policy which provides further information about the technical and security measures we take in the Spektrix system to protect your customer data.
Dotdigital provides us with a leading email marketing platform, operated through our Box Office system, Spektrix. Under our contract with Spektrix, Dotdigital will deliver marketing emails only to those with prior consent. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails. You can also amend your options at any point by contacting our Box Office on 01236 732 887.
We also work with GoogleAnalytics to generate statistical information about our website use by means of a cookie, which is stored on the users’ computers. This information relating to our website is anonymous and stored securely by Google.
9. How is Personal Data Exported?
Cumbernauld Theatre Trust Ltd does not export your data outside of the European Union. Where there may be a need to export your data to a third country outside of the EU in the future we will only do so based upon your consent and that it is only transferred to a recipient that resides in a country that has adequate data protection measures, or a recognised international transfer mechanism is in place by law. Where this is not possible, we will ensure that adequate measures including risk assessments and contractual obligations such as EU Model clauses are used to protect your Personal Data.
10. How is Personal Data Secured
Cumbernauld Theatre Trust Ltd adheres to standards that assure the appropriate organisational, technical, and physical security measures are in place to protect your Personal Data against accidental, unlawful destruction or loss, damage alteration disclosure, access, or use.
11. What are Your Privacy Rights?
You have several choices in respect of the Personal Data we process about you:
You may opt out of or withdraw consent for any previously provided permission given to Cumbernauld Theatre Trust Ltd for processing your Personal Data.
You may ask us to delete all or some of the Personal Data we have about you. Where we are unable to delete this data, we will inform you of why we are unable to do so. Example reasons preventing this deletion include contractual or legal obligations.
You can ask us to change or update information about you in certain cases, such as if the information we have on you is inaccurate.
You can ask us to stop using some or all of the personal data that we hold about you, for example where we have no legal right to keep using it. You can also ask us to limit the use of your Personal Data if it is inaccurate or if you disagree with our legitimate interest justification for the use of your data.
You can ask for a copy of the information we hold about you. Where possible we will provide this in a machine-readable format. Where we are unable to do so, we will provide you with a reason why we cannot provide it in a machine-readable form.
How do I Contact Cumbernauld Theatre Trust Ltd if I want to Exercise my Rights?
If you would like to contact us to exercise your rights under data protection laws, please call our box office on 01236 732 887 where we will endeavour to assist you to your satisfaction.
13. Disputes or Filing a Complaint
If you are unhappy with the investigation or attempts to resolve your complaint, you have the right to complain to the Information Commissioners Office. Their contact details can be found here https://ico.org.uk/make-a-complaint/
14. Cumbernauld Theatre Trust Ltd Address
If you would prefer to write to us, our address is:
Cumbernauld Theatre Trust Ltd / Lanternhousearts.org
South Kildrum Ring Road
Telephone +44 (0) 1236 732 887