Create Gloucestershire Privacy Statement

1. What is the legal basis for collecting personal data?

Data Protection legislation gives various reasons why a company could collect and process your data and only one is needed to enable Create Gloucestershire (Create Glos) to legally collect, store and manage your data. Create Glos uses the ICO lawful basis interactive guidance tool where necessary to determine legal basis.

The different legal basis are as follows:

Consent 

Create Glos can collect and process your data with your permission. An example of this is when you choose to sign up for our newsletter by filling in the subscription form.

Public Task

It is unlikely we would use this basis at Create Glos for processing personal data. This basis applies if we carry out a specific task in the public interest, or if we exercise official authority, which is laid down by law.  

Contractual obligations
We may need your personal data to comply with Create Glos’s contractual obligations. If, for example, we provide a service to you that has been paid for from public funding we collect personal details required as a result of accepting the funding and share them with our funder.

Legal obligation
Create Glos may be required to disclose your personal data by a court order or to comply with other legal requirements. We will endeavour to inform you of this requirement wherever possible, unless we are legally restricted from doing so. For example, we can pass on details of people involved in criminal activity to the police. If we have a safeguarding concern we may use Legal Compliance as a basis for sharing your data.

Vital Interest

It is unlikely we would use this basis at Create Glos for processing personal data. This lawful basis is very limited in its scope, and generally only applies to matters of life and death.

Legitimate interest
In specific situations, we require your data to pursue our Legitimate Interests in a way which might reasonably be expected as part of running our business or acting in your best interests (eg safeguarding or child protection issues) and which does not materially impact your rights, freedom or interests. For example, we may use your previous involvement in a project with us to send you details of other work we are doing in a similar field. 

We will use data from the information we hold to analyse the reach and impact of our work, and inform how we develop new programmes and projects.

2. What types of personal data do we collect and how do we use it?

➡PARTICIPANTS IN OUR PROJECTS & EVENTS

What do we collect? Contact details, application details in a variety of formats including forms, videos and audio files. Financial information, access requirements, photo permissions and feedback.

How do we use it? We collect contact details so we can contact you about the project or event that you’re interested in. We collect application details so we can process your application effectively. We collect financial information so that we can pay you where relevant. We collect access requirements so we can endeavour to remove barriers to participation. We collect photo permissions so we only collect and share images with consent. We collect feedback as part of our learning culture for improvement and learning.

➡CREATE GLOS COMMUNITY

What do we collect? We collect personal data from you when you register for newsletters or wish to contribute information to share with the Create Glos community. The data we collect from you is important to understand where our community is and what they are doing. It helps us understand who is engaging with CG. We do not share your personal information with third parties or send you Create Glos communication without your consent.

If you sign up for our newsletter:

We will collect your name and email address

How do we use it? We will send you our newsletter, which includes industry news, views and opportunities from Create Gloucestershire and it’s community.  We will also use this data to send information about your newsletter subscription. We will confirm that the information we hold is accurate and up to date by contacting you annually to review your information and ensure that you still want to hear from us.

If you wish to share your information publicly

You can choose what information you supply and how we share it on your behalf using the submit form for sharing opportunities and the community profile form to create a page on the Create Glos website in the community section.

We cannot guard against collection by third parties of the data published on this site.  You should be aware of the fact that publishing personally identifying information on the internet potentially puts you at risk of identity theft.  Please bear this in mind when adding content to the site. You can find more information about preventing identity theft on this website: https://www.getsafeonline.org/protecting-yourself/safeguarding-identity/.

What do we collect? We collect contact details, social media handles, a description of your practice/work/organisation, images and image credits.

How do we use it? We use the information you have supplied to create posts on the opportunities page on our website and we may also share this on our social media accounts. If you fill in our community profile form we will use the data you consent to share to create a page on the Create Glos website in the community section.

COMMUNITY PROFILE PAGE AMENDMENT OR REMOVAL

If you wish to amend or remove your profile from the Create Glos website you can do so at any time by emailing connect@creategloucestershire.co.uk    Your information will be deleted permanently within 1 week of making your request.  You are welcome to sign up again at a later date if you choose to.

Create Gloucestershire will remind you on an annual basis to review your profile page to ensure the information provided is accurate and up to date.  If you do not amend or confirm your profile during this annual review your page will be deleted.  You are welcome to request a new Profile page at a later date if you choose.

➡ LEGAL MEMBERS, BOARD DIRECTORS AND CONTRACTORS

What do we collect? We collect some or all of the following: Contact details, financial details, date of birth, declarations of interest, photographs, audio and video, access requirements and DBS records.

How do we use it? We collect contact details to contact you and to process applications for roles with Create Glos. We collect financial information so that we can pay you where relevant. We collect date of birth to meet our legal and contractual requirements as a company limited by guarantee. We collect declarations of interest in order to maintain the integrity and transparency of our governance. We collect access requirements so we can endeavour to remove barriers to participation. We request a DBS check to help us make safer recruitment decisions.

➡ SUPPLIERS, PARTNERS & CUSTOMERS

What do we collect? We collect contact and financial details.

How do we use it? For suppliers and customers we use this information to make or receive payments in relation to services we have requested or provided. In addition for partners we will use this information to form partnership agreements.

➡ EQUITY, DIVERSITY & INCLUSION MONITORING

Create Gloucestershire recognises that there are people whose background and experience is underrepresented in the creative industries, both in Gloucestershire and nationally. We believe that discrimination or exclusion based on individuals’ characteristics or circumstances represents a waste of talent and potential. We know that our work is strengthened and improved with greater diversity represented in all that we do and for this reason we collect statistical data to monitor the operation of our Equity, Diversity and Inclusion Strategy. It will be shared anonymously with our funding partners and other stakeholders so that they can monitor the impact of the resources they provide.

➡3RD PARTY SUPPLIERS AND PROCESSORS

Create Glos holds your details securely using tools that we have audited to ensure they meet our security standards. If you want to change the way in which we communicate with you or stop communications from us you can do so at any time by clicking the unsubscribe link on the newsletters or emailing connect@creategloucestershire.co.uk.

Dropbox and Google: As an organisation we use Dropbox and Google to store business information which may include personal data. For example, if you apply for a job or position with Create Gloucestershire we collect personal data from you using Google Forms to gather text and video or audio files.  The application details you send are processed using Google. You can see Google’s Privacy Policy here policies.google.com/privacy. You can see Dropbox’s Privacy Policy here https://www.dropbox.com/privacy.

Mailchimp: We use MailChimp to store email address and names in order to send Create Glos newsletters and to track interactions from those newsletters.  You can see MailChimp’s Privacy Policy here. mailchimp.com/legal/privacy/

Squarespace: We use Squarespace to host our website and to share information you have consented to be shared publicly. This could be on the community profile page or the opportunities page. You can view Squarespace’s Privacy Policy here. squarespace.com/privacy/

Ticket Tailor: we use Ticket Tailor as a platform for booking on to Create Gloucestershire’s events, labs or meetings. When you book we collect personal data from you in order to effectively manage the event and meet your access requirements. The information you give us is held on Ticket Tailor for this purpose only, and removed in line with our data retention and disposal policy. You can see Ticket tailor’s privacy policy here. https://www.tickettailor.com/privacy-policy

Zoom: We hold meetings and events in zoom and use the registration page to collect contact information solely for the purpose of holding the meeting. https://explore.zoom.us/en/gdpr/

Otter ai: We use Otter AI to transcribe virtual meetings so we can have a record of what was said. The conversations are always private, only accessible to us and the people we choose to share them with. Any information we hold is removed in line with our data retention and deletion timetable which details the disposal policy. You can read the otter ai privacy police here. https://otter.ai/privacy-security

Airtable: The Equal Opportunities monitoring form is hosted by Airtable. The information you contribute on the Equal Opportunities form is optional and is collated in an anonymised format via the Airtable platform. You can see Airtable’s Privacy Policy here. Privacy Policy - Airtable

Financial information: Financial information is processed by a number of providers.

Legal and accountancy: Legal and accountancy information is processed by three providers. Harwood Lane provides auditing and chartered accountancy services. You can see their Privacy Policy here https://www.harwoodlane.co.uk/privacy-statement-cookie-policy/. And information is shared with our Company Secretariat Burges Salmon, in order to fulfil our legal obligations as set out by Companies House. You can see their Privacy Policy here https://www.burges-salmon.com/privacy-policy. We also share information with Rupert Naylor, accountant.

Note on Contractors using Generative Artificial Intelligence:

The CG team uses Generative Artificial Intelligence (AI) in their work and are contractually restricted to using an approved list of AI systems. Approved AI systems are risk assessed by the Company Manager, with appropriate support from the team, assessing the benefits of using AI to CG delivery and operations and the risks posed to subjects. The decision of that review is stored as part of our systems audit and reviewed on an annual basis. 

3. External Links

www.creategloucestershire.co.uk contains links to other websites.  When you click on any of these links you are moving onto another site and their terms, conditions and policies will apply when you are visiting their pages.  These terms and conditions may differ from those of Create Glos.

4. Commercial disposal to third parties

Create Glos does not sell, rent or distribute any personally identifying data from our users to third parties for commercial purposes without your prior consent. 

The company works in partnership to deliver its projects.  As such it may help to share personal data with partner organisations.  In this case, you will be given the right to choose whether or not you wish your personal data to be shared with a partner and will be given detailed information about how your data will be protected within the partnership arrangements.  Data protection obligations and agreed data sharing protocols are also detailed within the Partnership Agreement between Create Gloucestershire any Project Partner. 

5. Data retention and disposal

Any personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose. We have a data retention and deletion timetable which details the disposal policy. You may instruct us to provide you with any personal data we hold about you (known as a Subject Access Request). This may be subject to the supply of appropriate evidence of your identity.

People can submit a Subject Access Request in order to find out all of the information Create Gloucestershire holds about them.  Create Gloucestershire will provide this information free of charge and within one month of receiving a Subject Access Request. 

If a Subject Access Request is particularly complex then the compliance period may be extended for up to two further months.  If this is the case, the individual concerned will be notified within one month with the reasons for extended time clearly explained. 

Where a Subject Access Request is excessive or without relevant purpose then Create Gloucestershire may choose to charge a reasonable fee to cover administrative costs.   

If a Subject Access Request is refused Create Gloucestershire will notify the individual within one month to explain the reasons clearly and remind them of their right to complain or take legal action.   

6.  Amending our Privacy Statement

We may update this statement from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.

If you have any questions about the Policy or would like to change your communication preferences contact us connect@creategloucestershire.co.uk

Privacy Statement updated December 2023