2 Who we are
This Privacy Notice applies to all personal information processing activities carried on by the Jersey Eisteddfod (“the JE”). It also extends to employees and volunteers who act as data controllers on behalf of the JE. JE is the data controller of all personal information you provide during your relationship with us.
Our address for correspondence is Mrs Christine Hamon, General Administrator, 2 Florence House, Clos de Paradis, St. Helier, Jersey C.I. JE2 3SP.
JE is registered under the Data Protection (Jersey) Law 2018 (“the DP Law”). JE will process personal information in accordance with the provisions of the DP Law.
JE organises performing arts and creative arts events and festivals. Member of the public participate in JE events and festivals in a number of ways, including as volunteers or competitors, or they may attend our events as members of an audience or visitors to an exhibition.
3 The information we process
3.1 Personal data
We collect and process a range of information about you. We limit the collection and processing of information to information necessary to achieve one or more lawful purposes as identified herein. Depending on how you interact with us, personal information that we may collect and process may include:
· Name, residential address, contact details including telephone number and email address; signature;
· Information about your children, including name, gender, residential address, age and school;
· Information about other participants on whose behalf you provide data;
· Information about your involvement in the events and festivals, for example entries as a competitor or events you have attended or at which you have volunteered, the results of your entry, trophies and certificates you are awarded;
· If you participate as a competitor in any of our events, we may collect and process information about fees payable and paid, your payment information and details of any refunds.
· recordings of performances submitted for any online festival.
3.2 Special Category information
We may also collect special category information for specific and limited purposes where such information is necessary to assist or enable you or your children, or those on whose behalf you enter the festival, to participate in and enjoy our events. We will only process special category information where we have your specific consent or are otherwise lawfully permitted to do so, for example due to the legitimate interest of a competitor or volunteer who may otherwise be unable to participate. Examples of special category information that we may collect include:
· Physical or psychological health details and /or medical conditions;
· Learning difficulties;
· Any other personal characteristic that prevents or is detrimental to your ability to participate in our events.
· Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific purposes. Primarily this is to enable us to perform and record checks on our volunteers to ensure that we comply with our safe-guarding policies.
4 How we obtain information
Individuals provide us with personal information in the following ways:
· When they enter our festivals using our application forms or our online entry system;
· Throughout our relationship in various ways, including through correspondence, telephone calls and meetings;
· By attending and participating in our festivals in events where your attendance or the results of your participation are recorded.
If you provide information about any participant that is not your child or your legal charge, we shall assume that you are entitled to provide such information. We reserve the right to ask you to show evidence that you are so entitled before we agree to process that information.
5 Our basis for processing your personal data
5.1 Legitimate interests
Under the DP Law, we may process your information where it is in our legitimate interests to do so, namely in order to run an organisation providing cultural events to encourage participation and interest in the arts in Jersey. We only rely on legitimate interests to process data; we have considered whether or not those interests are overridden by the fundamental rights and freedoms of the individuals whose data is being processed and we have concluded that, on balance, processing is fair. This is because, in most circumstances, our legitimate interest to process your personal data aligns with your interest to be able to participate in and attend our festivals and events. In other words, being able to process your data is usually in both of our interests.
We continually seek to develop and improve as an organisation, adapting to the artistic preferences and interests of Jersey’s population, and to offer a broad and relevant range of opportunities to existing and new participants. To achieve this, we may need to process your information to enable us to send you relevant updates and information about events we offer. We may also use your information to assist us to monitor and review festivals and events we organise to assess the performance, relevance and utility and popularity of what we offer, undertake staff and volunteer training, analyse feedback and complaints and shortfalls in standards generally.
We are constantly reviewing the services that the Jersey Eisteddfod offers competitors to ensure that they meet their needs and those of their teachers and supporters and keep us up to date with current trends. We shall use the personal data that we hold to inform you of any changes or opportunities that might affect you or be of benefit to you.
You can always indicate you do not want to receive updates and information from us and such notice will override the legitimate interest and your information will be excluded from processing until you indicate your consent.
5.2 Other lawful bases for processing
Whilst we consider that our legitimate interest provides us with a lawful basis for processing most of your data, we may also rely on the following lawful bases to process data:
· Processing data to fulfil a contractual obligation: if you enter our festivals as a participant we have a contractual obligation to you, the fulfilment of which may involve us collecting and processing your personal information.
· Consent: we may process your personal information on the basis of the consent you give, for example to receive certain direct marketing communications or for your details to be passed to a third party, to process photographic images of you and to process special category information.
6 How long we keep your information
7 How we protect your personal information
7.1 We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. Our processes for security include organisational and physical security measures as well as protection of networks and information systems.
7.2 If you receive an unsolicited call that claims to be from JE which you do not recognise, do not continue but instead call back our general telephone number.
8 Disclosing or transferring information to 3rd parties
Personal information of an individual is confidential and we will only disclose that information where necessary, for example in the following situations:
8.1 with an individual’s consent or, if the individual is a minor, with the consent of the individual’s parent or guardian;
8.2 to third parties who are providing a service directly to JE, for example to the printer of our programmes and other festival publications;
8.3 where necessary, to persons acting as our agent for the provision of services, for example staff at venues we use for our events and Run My Festival (see below).
9 Transferring information overseas
Most of the information we hold on you will be used and stored in Jersey and in England. Where we transfer data to persons in jurisdictions that do not have equivalent data protection laws, we will put appropriate agreements in place to ensure that such data is held and processed in a manner that would satisfy data protection requirements in Jersey.
10 Use of Data Processor
JE uses Run My Festival Limited, which is based in England, as its principal data processor (the “Data Processor”). The Data Processor is responsible for the provision of our entry platform and for all operational support with regard to that system. The Data Processor may not make any decisions on day to day data management and accuracy, may not perform any data processing for its own purposes and shall only store and retain the personal data in accordance with the contractual arrangements established by JE as data controller. The Data Processor may not enter into any sub-contract arrangements without the prior knowledge and consent of JE.
Unless you have told us not to, we may send you information relating to our services that we think will be of interest and relevant to you. It is in our legitimate interest to process personal information to communicate with you regarding issues, developments and topics that may be of interest to you. If you change your mind and no longer wish to receive these communications, please exercise your right.
JE does not share information with third parties for their own marketing or other purposes without your permission.
12 Your rights
You have rights under the DP Law, which are summarised below together with the circumstances in which they arise. If you wish to exercise your rights or have any other queries about the use of your personal information then please contact our General Administrator at firstname.lastname@example.org
Under the DP Law, you have the following rights:
- Right of access to personal data - If you would like to access your personal data please send a written request to: The General Administrator, 2 Florence House, Clos de Paradis, St Helier, JE2 3SP or email@example.com . Please note that for your security we may need to verify the request and depending on the nature of the request we may need to collect more information as to your specific requirements.
- Right of rectification - You have a right to rectification of inaccurate personal information and to update incomplete personal information. If you believe something we hold is inaccurate please contact us so we can correct the information. We may require supporting information to ensure such changes are valid. We can provide more information if required.
- Right of erasure - You have a right to request that we delete your information but please note that this may impact on the services we can provide, such as processing your entries and not being able to send you any communications about the JE and its Festivals. We can provide more information if required.
- Right to restrict processing - You have a right to request us to restrict the processing of your personal information but please note that this may impact on the services we can provide.
- Right to objection - You have the right to object to us processing your personal information (and restrict processing, see above) unless we can demonstrate compelling and legitimate grounds for the processing which may override your own interests – for example where we use Run My Festival.
- Marketing - You have a right to object to direct marketing.
- Withdraw consent - You have a right to withdraw consent where we rely on your permission to process your personal information. Please note that this may impact on the services we can provide.
- Lodge complaints - You have a right to lodge a complaint. In the first instance we recommend you contact our General Administrator, who will investigate the matter. We would hope to be able to address your concerns but if you are not satisfied with our investigations and findings, you can contact the Jersey Office of the Information Commissioner, JOIC. For more information, please visit www.jerseyoic.org
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