PRIVACY POLICY
LIVE TOUR PROMOTIONS ARE COMMITTED TO PROTECTING YOUR PRIVACY. WE HAVE UPDATED OUR PRIVACY POLICY TO REFLECT UPCOMING CHANGES IN DATA PROTECTION LAW, AND TO BETTER EXPLAIN HOW AND WHY WE COLLECT YOUR PERSONAL INFORMATION.
GDPR Record of statement
For the: Live Tour Promotions ( CheeseFest, CheeseFest UK, Sausage& Cider Festival, Bark Life, Ibiza Orchestra Live, James Smith Live, ProseccoFest UK, The Big Nineties Festival & Other future associated brands )
Last updated: 25th May 2020
Approved by: Group Marketing Manager
Introduction
Live Tour Promotions Limited, (‘’ we”) is a Limited organisation whose registered address is Larch House, Parklands Business Park, Denmead, Hampshire, United Kingdom, PO7 6XP
. These addresses are securely locked and alarmed when not occupied.
Live Tour Promotions Limited needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored
to meet the company’s data protection standards — and to comply with the law.
Why this policy exists
This data protection policy ensures Live Tour Promotions Limited:
•Complies with data protection law and follow good practice
•Protects the rights of staff, customers and partners
•Is open about how it stores and processes individuals’ data
•Protects itself from the risks of a data breach
Data Protection Law
The Data Protection Act 1998 describes how organisations — including [Live Tour Promotions Limited]— must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Data Protection Act is underpinned by eight important principles. These say that personal data must:
1.Be processed fairly and lawfully
2.Be obtained only for specific, lawful purposes
3.Be adequate, relevant and not excessive
4.Be accurate and kept up to date
5.Not be held for any longer than necessary
6.Processed in accordance with the rights of data subjects
7.Be protected in appropriate ways
8.Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, Risks and Responsibilities
Policy Scope
This policy applies to:
• The head office of Live Tour Promotions Limited
• All branches of Live Tour Promotions Limited
• All Events associated with Live Tour Promotions Limited
• All staff and volunteers of Live Tour Promotions Limited
• All contractors, suppliers and other people working on behalf of Live Tour Promotions Limited
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the Data Protection Act 1998. This can include:
• Names of Individuals
• Postal Addresses
• Email Addresses
• Telephone Numbers
• Billing address
• Any other information relating to individuals
Data Protection Risks
This policy helps to protect Live Tour Promotions Limited from some very real data security risks, including:
• Breaches of confidentiality.
For instance, information being given out inappropriately.
• Failing to offer choice.
For instance, all individuals should be free to choose how the company uses data relating to them.
• Reputational damage.
For instance, the company could suffer if hackers successfully gained access to sensitive data.
Responsibilities
Everyone who works or is a potential contractor for or with Live Tour Promotions Limited has some responsibility for ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
However, these people have key areas of responsibility:
The Board of Directors is ultimately responsible for ensuring that Live Tour Promotions Limited meets its legal obligations.
The [Data Protection Officer], Elliottt Dalton, is responsible for:
• Keeping the board updated about data protection responsibilities, risks and issues.
• Reviewing all data protection procedures and related policies, in line with an agreed schedule.
• Arranging data protection training and advice for the people covered by this policy.
• Handling data protection questions from staff and anyone else covered by this policy.
• Dealing with requests from individuals to see the data Live Tour Promotions Limited holds about them (also called ‘subject access requests’).
• Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
• The [IT Manager], Elliott Dalton, is responsible for:
• •Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
• •Performing regular checks and scans to ensure security hardware and software is functioning properly.
• •Evaluating any third-party services, the company is considering using to store or process data. For instance, cloud computing services.
• The [Marketing Manager], Elliott Dalton, is responsible for:
• •Approving any data protection statements attached to communications such as emails and letters.
• •Addressing any data protection queries from journalists or media outlets like newspapers.
• •Where necessary, working with other staff to ensure marketing initiatives abide by data protection principles.
General staff guidelines
• The only people able to access data covered by this policy should be those who need it for their work.
• Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
• ED will provide training to all employees to help them understand their responsibilities when handling data.
• Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
• In particular, strong passwords must be used and they should never be shared.
• Personal data should not be disclosed to unauthorised people, either within the company or externally.
• Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
• Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT manager or data controller.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
· When not required, the paper or files should be kept in a locked drawer or filing cabinet.
· Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
· Data printouts should be shredded and disposed of securely when no longer required.
· When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
· Data should be protected by strong passwords that are changed regularly and never shared between employees.
· If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
· Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
· Servers containing personal data should be sited in a secure location, away from general office space.
· Data should be backed up frequently. Those backups should be tested
· regularly, in line with the company’s standard backup procedures.
· Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
· All servers and computers containing data should be protected by approved security software and a firewall.
Data Use
Personal data is of no value to Live Tour Promotions Limited unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area.
• Employees should not save copies of personal data to their own computers.
• Always access and update the central copy of any data.
Data Accuracy
The law requires Live Tour Promotions Limited to take reasonable steps to ensure data is kept accurate and up to date.
• The more important it is that the personal data is accurate, the greater the effort Live Tour Promotions Limited should put into ensuring its accuracy.
• It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• Live Tour Promotions Limited will make it easy for data subjects to update the information Live Tour Promotions Limited holds about them. For instance, via the company website.
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.
Subject Access Requests
All individuals who are the subject of personal data held by Live Tour Promotions Limited are entitled to:
• Ask what information the company holds about them and why.
• Ask how to gain access to it.
• Be informed how to keep it up to date.
• Be informed how the company is meeting its data protection obligations.
If an individual contact the company requesting this information, this is called a subject access request.
Subject access requests from individuals should be made by email, addressed to the data controller at info@livetourpromotions.co.uk The data controller can supply a standard request form, although individuals do not have to use this.
Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 14 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Providing Information
Live Tour Promotions Limited aims to ensure that individuals are aware that their data is being processed, and that they understand:
• How the data is being used
• How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
[This is available on request. A version of this statement is also available on the
company’s website.]
All of the above are data processors to Live Tour Promotions Limited as data controller. We have GDPR compliant processor contracts in place with all of the above named parties. All processors undertake to keep the data within the EEA or are compliant and certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
Policy Statement
1. Live Tour Promotions Limited intends to comply with GDPR or the same as subsequently enacted into UK domestic law at Brexit.
2. We will therefore:
1. Only process as much personal data as is necessary for the services we supply.
2. Only hold such data for so long as necessary for those purposes. In this connection we have decided that ten years following the last contact with an individual is usually an appropriate period to hold data covering the legal limitation period (six years) and a moderate margin. As in most cases this is only archived data, not sensitive, not dangerous and will not be used there seems little risk to data subjects.
3. Only process such data on grounds for lawful processing provided within GDPR Article 6.
4. Send or otherwise provide appropriate notices (GDPR Articles 13 and 14) to those whose personally identifiable information (“Personal Data”) is processed by us including our employees, and individuals or individuals within partners who supply us with goods or services. We will also send such notices to individuals within organisations to whom generic marketing communications (eg newsletters) are sent.
· Not engage in direct marketing to clients or prospects otherwise than in accordance with the relevant legislation and guidance from the ICO.
· Utilise appropriate organisational and technical measures to ensure that Personal Data processed by us is kept secure.
· Where we use third party data processors we will choose them carefully with a view to their data security and compliance with GDPR and have GDPR compliant contracts with them.
· Not transfer Personal Data (which includes giving third parties access to it within our IT system) to recipients located outside the European Economic Area and the UK without confirmation from our Data Protection Officer that such transfer is lawful.
· Update this document from time to time so that it remains an accurate record of our data processing activities and policies.
3. We conclude that where we hold and process such personal data for the purposes of direct marketing to those individuals’ employers we should, unless guidance from the ICO says otherwise, either:
1. obtain consent to that direct marketing from the individuals and send the notices required by Articles 13 and 14 to the individuals; or
2. Be satisfied that we have a legitimate interest in holding that Personal Data and using it for that purpose.
Our processing
1. Customers
Personal data collected:
Full Name, Email address, Telephone Number, Billing address,
Special categories of data collected:
None
Data origination:
Provided by individual
Storage location:
Mail Chimp, Fatsoma, Eventbrite, Squarespace, Google, Ticket Tailor, See Tickets, Festicket, Facebook, Ticket Tailor, Stripe
Identified data usage:
Event ticket sales history, Event Sign Up on Website, Website pixel tracking, cookie tracking
Third parties with access:
None
Retention period:
10 Years
2. Employees of suppliers, contractors and clients
Personal data collected:
Email Address, Full Name, Business Name, Postal Address, Role Title, Telephone, Signature and Bank Details
Special categories of data collected:
Just Develop iT
Data origination:
Provided by individual
Storage location:
Xero, Locked Filing Cabinet and Internal Server
Identified data usage:
Client invoices, supplier payments, marketing and communications, credit management and fraud prevention
Third parties with access:
Just Develop iT Book Keepers, (Accountants), Xero - Accounting Software
Retention period:
10 Years
4. Data Storage
Live Tour Promotions Limited stores and processes some of its data remotely:
· Cloud-based platform providers Google, Eventbrite, Fatsoma, Mail Chimp, Ticket Tailor, Festicket, See Tickets, Ticket Tailor, Stripe
· Hard Drive stored safely at outsourced location in locked and secure position.
All of the above are data processors to Live Tour Promotions Limited as data controller. We have GDPR compliant processor contracts in place with all of the above-named parties. All processors undertake to keep the data within the EEA or are compliant and certified under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks.
5. Organisational and technical measures
We use the following organisational and technical measures to ensure the confidentiality of personal data:
· Provisions that contractors who process data are required to consider the use of lockable filing cabinets, secure storage for archived files and the use of a shredder or confidential waste bin for hard copies of paperwork, file notes, incoming and outgoing letter correspondence containing personal data.
· For electronically held data employees who process data are required to consider using storage on the, work one drive or platforms approved by the Data Protection Officer, password protection on all files containing personal data, the use of the Live Tour Promotions Limited’s secure platforms for processing data, running up to date antivirus and malware systems, installation of adequate firewalls, the secure destruction or disposal of IT equipment.
· Email accounts are individually assigned and not shared with colleagues or third parties. Access to emails are only authorised for third parties for specific purposes by Senior Management Team members.
We hold GDPR compliant contracts with all data processors.