This notice does not relate to personal data held about Approved Suppliers, Approved Grant Recipients or any other sole trader or organisation that we procure goods or services from. Nor does it relate to Employees or Trustees of Curious Minds. These are covered under separate privacy notices, which are available to view on request.
1. Who we areCurious Minds is a charity based in the North West of England, working across the region as well as nationally and internationally, to place creativity and culture at the heart of education and other services for children and young people.
As leaders of the Cultural Education Challenge in the North West region, our goals are:
- To promote access to the arts and culture for all children and young people
- To enable creative collaboration between the cultural and education sectors
- To work with schools, higher education institutions and cultural organisations to test and incubate innovative solutions to cultural and creative education.
Curious Minds is a registered charity (Charity No. 1130988) and a company limited by guarantee (Company No. 06775402). We are also registered with the Information Commissioner’s Office as a Data Controller. Our registered address is Curious Minds, 23-27 Guild Hall, Preston, PR1 1HR.
Curious Minds’ policy is to respect the privacy of individuals when processing their personal and private information, to comply with its statutory and other obligations regarding individual privacy, and to observe the guiding principles underlying these obligations.
This privacy notice sets out our data processing practices and your rights and options regarding the ways in which your personal information is used and collected. If you have any questions about this policy, you can email us at firstname.lastname@example.org or call +44(0)1772 827001.
2. Our privacy promiseWe promise to:
- Keep your data safe and private.
- Never to sell your data.
- To give you ways to manage marketing choices.
3. The data we collectWe collect and use a number of different types of data in pursuit of our charitable objectives. Some of this is personal data, such as names and email addresses, and some is statistical, such as website usage data. Data can come from a variety of sources:
a. When you give it to us directly
For example, if you submit personal information to us in the course of signing up to receive our email newsletters or register to attend an event, or personal information that you give to us when you apply to take part in a CPD training course, apply to work with us or otherwise communicate with us by email, phone or letter.
b. When we obtain it indirectly
For example, your personal information may be shared with us by third parties where we are acting on their behalf. For example, data provided to us in relation to our provision of support services for the Artsmark and Arts Award schemes.
c. When it is available publicly
Your personal information may be available to us from external publicly available sources. For example, when interacting with us via social media services (such as Facebook Pages and Groups, Twitter, LinkedIn) depending on your privacy settings, we may be able to see certain personal information from those accounts or services. We may also access information which has been published on your own or an employer’s website.
d. When you visit our website(s)
Curious Minds collects website browsing data using statistical tools such as Google Analytics, for evaluating and further developing our websites for digital audiences.. This information includes, but is not limited to:
- The date and time of your visit
- Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website, services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, and methods used to browse away from the page.
- Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
We currently don’t collect and use your personal information by using cookies on our website, although some embedded media (from third-party processors such as YouTube, Soundcoud or Mailchimp) may do so.
4. How we use personal data and whyData Protection law says that we are allowed to use personal data only when we have a valid reason for doing so. This includes sharing it outside Curious Minds. The law says that we must have one or more of the following reasons:
- To fulfil a contract with you.
- When we have a legal obligation.
- When you consent to it.
- When it is on our legitimate interest.
Legitimate interest is when we have a commercial reason to use your information – usually the pursuit of our charitable objectives. But, even then, this must not outweigh your own rights.
Our legal basis for processing information
Here is a list of the ways that we may use your personal information and the reasons we rely on for doing so.
|Purpose||Legal Basis||How we balance our legitimate interest against individual rights|
|Marketing: To inform and engage interested parties about our work and to further the cause of cultural education for all young people.|
|Email Marketing – Corporate recipients||Legitimate Interests||Recipients have a professional interest and might reasonably expect to hear from us. Recipients may ‘opt-out’ via unsubscribe or Manage preferences link.|
|Email Marketing – Private recipients||Consent||Consent collected is via ‘opt-in’ forms.|
|Postal Marketing – All recipients||Legitimate Interest||Recipients have a professional interest and might reasonably expect to hear from us. Recipients may ‘opt-out’ of postal marketing via contact details provided.|
|Telephone Marketing – Corporate contacts (rarely used)||Legitimate Interest||Recipients have a professional interest in our work and might reasonably expect to hear from us. Recipients may request not to be contacted by phone in future.|
|To publish the names, images, job titles and professional biographies of fellowship or advisory group members||Consent||Individuals are actively engaged in these initiatives and have provided their data. Consent is collected from participants and may be withdrawn in line with our take-down policy.|
|Promotional Images and film footage||Consent (young people) and Advisory (adults)||Participants are actively engaged in activities connected with our work. We will always notify participants when a photographer or filmmaker is present at a session or event. Written consent will always be obtained for young people under 18-years and we will respect the wishes of anyone who signals their desire not to have their image taken and will always ask for consent where photos are to be published alongside a name or other personal identifier. You may request removal of public images in line with our take-down policy.|
|Collection/analysis of statistical information about website usage and other marketing engagement metrics.||Legitimate Interest||To manage and improve how people engage with our public-facing channels.|
|Programme Management and Improvement: For the day-to-day administration of our business obligations and programmes of work.|
|Individual or small-group communication via email, post or telephone||Legitimate Interest||In order to efficiently and effectively manage our relationships with you and your business or employer, in line with your expectations as well as those of our trustees and funders. You may request not to be contacted.|
|CRM system data capture, storage and analysis– names and contact details, job title and employer details, engagement records||Legitimate Interest||We collect and store information about our engagements with customers, programme contacts and participants and other interested parties in to ensure the smooth operation of our business, effective planning and an efficient customer experience. You may request access to, rectification of or erasure of details we have stored on you.|
|Sharing information with cultural education partnership lead organisations||Legitimate Interest / Contractual Obligation||Pursuant to the furtherance of our charitable objectives and the obligations placed on us by funders, we occasionally share contact information for education and cultural organisations that may wish to engage in cultural education partnerships. You may request not to be contacted or to have your details erased.|
|Reporting participation / engagement and other programme related information with funders and contracted partners (including case study information)||Legitimate Interest / Contractual Obligation / Consent||Pursuant to the furtherance of our charitable objectives and the obligations placed on us by funding organisations, to inform the development or improvement of projects and to demonstrate the effectiveness of projects.|
|Managing events: In order to effectively manage the delivery of events, workshops and training.|
|Attendee registration, including name, job title and employer, address and phone number, email address, dietary requirements, access requirements||Contractual Obligation||The information you provide will be used to communicate with you about your attendance at the event and to follow-up on your experience post-event.|
|To publish your name, job title and employer organisation on delegate materials related to the event for which you are registered||Consent||You will be provided with an option to consent to this use of your data when signing-up. You may update our choice by logging into our event management software or by contacting us.|
- Your name and contact details (work or private, as provided) including job title and employer, postal address, telephone number, email address(es) and, where applicable, social media identity
- Your gender
- Personal descriptions and photographs
- Details of your qualifications/experience
- And/or any other personal information which we obtain as per section 3
Processing special categories of data The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example, information about your health, ethnicity and religious beliefs. In certain situations, Curious Minds may collect and/or use these special categories of data (for example, information on allergies, access or medical needs that are to your attendance at an event or meeting). We only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.
5. Who we share personal information withThe reports that we submit to our funders generally do not contain personal information, so it would be quite rare for us to share your information with third parties. However, there are certain circumstances where we may do so:
- In order to fulfil a legal obligation (such as in respect of safeguarding or fraud)
- In order to protect your vital interests (such as in a health emergency)
- Where we believe that doing so would be in your interest. For example, we may share your professional contact information with selected third parties (such as local public agencies or Arts Council England National Portfolio organisations) when recommending you for involvement in a local partnership or project. If we do share information in this way, we will only share data that is relevant to the partner programme and will ask partner organisations to confirm that they are compliant with the latest protection legislation.
In the course of conducting our business, we also make use of some third-party organisations to process data and/or deliver services on our behalf. These suppliers may include individual contractors as well as productivity software providers, digital or social media platforms and other marketing support software. Many of these providers are based in the European Economic Area (EEA) and are therefore subject to the same data protection legislation as Curious Minds. However, some organisations may store information outside EEA. Where we transfer data to third party processors, we ensure there is a contract in place which requires the protection of personal data to GDPR standards.
6. How we store informationGenerally, all personal data is securely stored electronically in our password protected CRM system or restricted access file server or other protected third party applications. Hard copies of information (such as consent forms), where retained, are stored in locked cabinets.
Our data retention policy varies depending on the type of information and purpose for which it is used. We have a legal obligation to retain financial records for six years and would argue that we have a legitimate interest to retain limited records related to our relationship with you indefinitely, for as long as they are relevant to our charitable objectives and provided reasonable steps are taken to ensure accuracy and you have not requested their removal. Some information, such as images of children, are retained for a shorter period, as defined and specified in the at the time of consent being obtained.
If you request to receive no further contact from us, we may keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.
7. If you choose not to give personal informationExcept where required by law or under the terms of a contract we have with you, you may choose to not to give us personal data (or to withdraw our permission to hold or process it). You should be aware that this may delay or prevent us from meeting our obligations or providing a service you have requested from us.
Where data collection is optional, we aim to make this clear at the point of collection.
8. Access to your information and complaintsYou have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the address given in section 1. We may make a small charge for this. We want to make sure that the personal information we hold about you is accurate and up to date. You can ask us to correct or remove information is you think it is inaccurate.
We encourage you to raise any concerns or complaints you have about the way we use your personal information by contacting us using the details provided in section 1 of this notice. You are further entitled to make a complaint to the Information Commissioner’s Office – www.ico.org.uk.