PRIVACY POLICY
PRIVACY POLICY
Embedded Files
PRIVACY POLICY (PUBLIC)
PLOT TWIST MUSIC CIC
Date: 12/2024
This privacy notice tells you what to expect us to do with your personal information.
Contact details
What information we collect, use, and why; lawful bases
How long we keep information
Data protection rights
Where we get personal information from
Who we share information with
Sharing information outside the UK
How to complain
1. Contact details
1. Contact details
Post: 119 Forrister Street, Stoke-On-Trent, Staffordshire, ST3 1SP, England
Email: plottwist.sot@gmail.com
2. What information we collect, use, and why; lawful bases for the collection and use of your data
2. What information we collect, use, and why; lawful bases for the collection and use of your data
2.1. Information to provide services and goods, including delivery:
We collect or use the following information:
Names and contact details
Addresses
Payment details (including card or bank information for transfers and direct debits)
Website user information (including user journeys and cookie tracking)
Cookies are collected and managed via third parties - we do not collect or use the data ourselves. Please refer to the cookie consent banners on our website and online store.
Our lawful bases for collecting or using personal information:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
2.2. Information for research or archiving purposes:
We collect or use the following information:
Names and contact details
Addresses
Location data
Our lawful bases for collecting or using personal information:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are: To allow us to keep a shortlist of potential bookings for upcoming events.
2.3. Information for dealing with queries, complaints or claims:
We collect or use the following information:
Names and contact details
Address
Video recordings of public areas
Audio recordings of public areas
Video recordings of private or staff only areas
Audio recordings of private or staff only areas
Relevant information from previous investigations
Information relating to health and safety
Correspondence
Our lawful bases for collecting or using personal information:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are: To allow us to undertake a fair and thorough investigation, allowing us to reach the correct conclusion and make improvements.
2.4. Information to create promotional material such as videos, photos, zines and performance recordings (including at events):
We collect or use the following information:
Names and contact details
Photographs or video recordings
Recorded images, such as photos or videos
Records of consent, where appropriate
Our lawful bases for collecting or using personal information:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability.
Our legitimate interests are: To allow us to create promotional material to further the Company's activities, in return benefiting our nominated community.
3. How long we keep information
3. How long we keep information
See Annexe 1 - How Long We Keep Information.
4. Data protection rights
4. Data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website here.
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
Your right to erasure - You have the right to ask us to delete your personal information.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
Your right to object to processing - You have the right to object to the processing of your personal data.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
5. Where we get personal information from
5. Where we get personal information from
Directly from you
CCTV footage or other recordings
Insurance companies
Publicly available sources
Suppliers and service providers
6. Who we share information with
6. Who we share information with
Others we share personal information with:
Insurance companies
Organisations we need to share information with for safeguarding reasons
Professional or legal advisors
Relevant regulatory authorities
External auditors or inspectors
Professional consultants
Organisations we’re legally obliged to share personal information with
Emergency services
Publicly on our website, social media or other marketing and information media
7. Sharing information outside the UK
7. Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name:
Category of recipient:
Cloud storage provider
Country the personal information is sent to:
Republic of Ireland
How the transfer complies with UK data
protection law:
The country or sector has a UK data bridge (also known as Adequacy Regulations)
8. How to complain
8. How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Annexe 1 - How Long We Keep Information
Annexe 1 - How Long We Keep Information
1. Information to provide services and goods, including delivery:
No.
Item
Retention Trigger
Retain For
Action
Retention Source
1.1
Email correspondence (general)
Creation / Receipt
1 year maximum
Delete / destroy
Business need
1.2
Social media direct messages (general)
Creation / Receipt
1 year maximum
Delete / destroy
Business need
1.3
Postal correspondence (general)
Creation / Receipt
1 year maximum
Delete / destroy
Business need
1.4
Email and social media direct messages (manually taking customer details directly for orders)
Creation / Receipt
Until the order is fulfilled
Delete / destroy
Business need
1.5
Point of sale orders (manually taking customer details directly for orders)
Creation / Receipt
Until the order is fulfilled
Delete / destroy
Business need
1.6
Payment details for the purpose of paying for goods and services
Receipt
Until the payment is processed
Delete / destroy
Business need
1.7
Receipts and invoices
Creation / Receipt
6 years after the end of the related accounting period
Delete / destroy
Business need, legal requirement
1.8
Contracts for service
Creation / Receipt
6 years after the end of the related accounting period
Delete / destroy
Business need, legal requirement
2. Information for research or archiving purposes:
No.
Item
Retention Trigger
Retain For
Action
Retention Source
2.1
Entries on the artist database
Creation
2 years maximum
Review. Delete if not required
Business need
2.2
Feedback
Receipt
2 years maximum
Review. Anonymise and keep, or delete / destroy
Business need
3. Information for dealing with queries, complaints or claims:
No.
Item
Retention Trigger
Retain For
Action
Retention Source
3.1
Accident records
Creation
3 years
Review. Archive, or delete / destroy if not required (any related to claims made should be kept for 7 years after the expiration of the related insurance policy)
Business need, legal requirement
3.2
Material and correspondence relating to complaints
Creation / Receipt
3 years after the closure / resolution of the complaint
Delete / destroy
Business need
3.3
Material and correspondence relating to claims
Creation / Receipt
7 years after the expiration of the related insurance policy
Delete / destroy
Business need, legal requirement
4. Information to create promotional material such as videos, photos, zines and performance recordings (including at events):
No.
Item
Retention Trigger
Retain For
Action
Retention Source
4.1
Video recordings
Creation / Receipt
Indefinite, or until the Company no longer requires the material
Delete / destroy when no longer required
Business need
4.2
Photographs
Creation / Receipt
Indefinite, or until the Company no longer requires the material
Delete / destroy when no longer required
Business need
4.3
Audio recordings
Creation / Receipt
Indefinite, or until the Company no longer requires the material
Delete / destroy when no longer required
Business need
4.4
Zine Content webforms
Receipt
Indefinite, or until the Company no longer requires the material
Delete / destroy when no longer required
Business need
5. General Company documents:
No.
Item
Retention Trigger
Retain For
Action
Retention Source
5.1
Minutes, resolutions, votes
Creation
10 years minimum
Review. Delete / destroy if not required
Business need, legal requirement
5.2
Accounting records
Creation / Receipt
6 years after the end of the related accounting period
Delete / destroy
Business need, legal requirement
5.3
Diversity monitoring forms (anonymous)
Receipt
6 years
Review. Delete / destroy if not required
Business need
5.4
Insurance documents and certificates
Receipt
7 years after the expiration of the policy
Delete / destroy
Business need, legal requirement
5.5
Details of Directors, People with Significant Control
Creation
6 years minimum
Review. Delete / destroy if not required
Business need, legal requirement
5.6
Banking correspondence, documents, applications, agreements, loans, mortgages
Creation / Receipt
6 years minimum
Review. Delete / destroy if not required
Business need, legal requirement
5.7
Records of promises for payments the Company makes should something go wrong and the company is at fault
Creation
6 years minimum
Review. Delete / destroy if not required
Business need, legal requirement
5.8
Cloud storage local backups (monthly)
Creation
1-2 months
Delete / destroy
Business need
6. Employee documents:
No.
Item
Retention Trigger
Retain For
Action
Retention Source
6.1
Employee records and documents, training records
Creation / Receipt
6 years from end of employment
Delete / destroy
Business need, legal requirement
6.2
Application and recruitment records
Creation / Receipt
1 year
Delete / destroy
Business need, legal requirement
6.3
Accident records
Creation
3 years
Review. Delete / destroy if not required (any related to claims made should be kept for 7 years after the expiration of the related insurance policy)
Business need, legal requirement
6.4
Maternity and paternity records
Creation / Receipt
3 years
Delete / destroy
Business need, legal requirement
6.5
Parental leave records
Creation / Receipt
5 years (from birth / adoption) or 18 years (if child receives disability allowance)
Delete / destroy
Business need, legal requirement
6.6
Pension benefits
Creation / Receipt
12 years from end of payable benefits
Delete / destroy
Business need, legal requirement
6.7
Redundancy records
Creation
6 years
Delete / destroy
Business need, legal requirement
6.8
Sickness absence records
Creation
6 years from end of employment
Delete / destroy
Business need, legal requirement
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