Who we are
The primary purpose of all Music Support’s services is to provide a safe non-judgemental and confidential service for anyone in the music industry to call on with their difficulties and receive support. We are also committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner.
We are a “data controller” for the purposes of the Data Protection Act 2018. This means that we are responsible for, and control the processing of, your personal information.
Our Data Protection Officers are Nicola Smith and Joanne Croxford.
For further information about our privacy practices, please contact our Data Protection Officers:
· Writing to 69 Caversham Road, London, NW5 2DR
· Calling 020 3648 6777
· Emailing firstname.lastname@example.org
Our use of Data
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
How we use your personal data will depend on which services you have requested to use. We will use your personal information in a number of ways depending on the purposes for which it has been collected, including for the following purposes:
· To provide you with the services or any information you have requested
· To update you about any changes to our services
· To communicate with you as set out in this policy below (including administrative communications as well as communications about our work, services, fundraising and events)
· To administer payments such as donations, including Gift Aid processing
· To display your profile or content on the website (if you have agreed to do so)
· To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
· To maintain our organisational records and ensure we have your most up-to-date details, including marketing preferences
· To help us improve our services, campaigns or information-offering, and improve your interactions with our website (including via cookies)
· To enable you to participate in interactive features on our website
· To enable you to participate in voluntary surveys or research
· To analyse your website behaviour
· To administer your volunteering or employment application
· To assist in your voluntary or fundraising work
· To deal with enquiries and/or complaints made by or about you
· To audit and/or administer our accounts
· To help us work with third parties to ensure that we send you targeted communications
· To contact you where you have been identified as a contact person for an organisation, such as a school
· To identify relevant networks and other suitable partners for Music Support.
We always want you to get the most out of our website, so if you do experience any issues with our online forms we may follow up with you to find out how our team can best support you with any problems experienced.
How we collect personal information
We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls. We collect personal information as volunteered by you in any registration forms and subscriptions.
We collect information from you in the following ways:
· When you interact with us directly – this could be via phone (including our helpline), email, post or in person.
· When you interact with us through partners or suppliers working on our behalf – this could be if you access a service via events/shows/a referral.
· When you interact with us through third parties – this could be if you provide a donation through fundraising sites such as JustGiving or Virgin Money and provide your consent for your personal information to be shared with us. Please note; these organisations will have their own privacy policies, and/or statements so please do ensure you check when providing your personal information to them.
· When you visit our website – we gather general information which might include which pages have been visited most often and which services or information is of most interest to visitors to the site.
We collect non-identifying information to help us to understand how supporters use our site, and to make improvements. This information consists of your IP address, your browser (e.g. Internet Explorer), when you visited and which pages you visited during your visit. We cannot use this information to find out anything at all about you and will not share any individual information unless required to do so by law.
What categories of personal information we collect
The types of personal information we collect depends on how we intend to use it.
We collect, store and use the following kinds of personal information:
· Identity data, including your name, date of birth (for example, if you make a donation or would like to volunteer).
· Contact data, including your email address, postal address, and phone number (for example, if you sign up to receive updates from us).
· Financial data, including bank or payment card details (for example, if you make a donation).
· Transaction data, including details of your giving.
· Technical data such as your IP address, when you browse our website.
· Marketing data such as your preferences for receiving communications from us.
· Any other information you provide us as above (see “How we collect personal information”).
· Where you are part of our ‘Care Delivery’ team, to have the required information needed to safely care for our clients.
We also collect and store data of those who contact us for support with mental health/addiction issues and the support we have offered.
For people we identify as having the potential to support Music Support in a greater capacity, we may collect job title(s), affiliated organisation(s), previous charity affiliations, education, career history and relevant interests.
Under the GDPR, we are required to ensure that any data is used only for the purpose for which it was requested and to make sure that the data is held securely. We only keep data as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, the collection of Gift Aid).
Sensitive Personal Information
You can of course decide if you want to remain anonymous, if you are happy to share your personal details with staff members/volunteers or if you would like us to share your story with the media or other parties as part of our work telling people’s personal stories about mental health and/or addiction issues.
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you contact us at Music Support through our Helpline, via email or in other more general communications, you may choose to provide details of a sensitive nature.
We will only use this information:
· For the purposes of dealing with your enquiry, training, and quality monitoring or evaluating the services we provide.
· We will not pass on your details to anyone else without your express permission except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others.
· Where you have given us your express consent or otherwise clearly indicated to us that you are happy for us to share your story, then we may publish it.
How we keep your data safe and who has access to it
We place great importance on the security of your personal information and always take appropriate precautions to protect it.
We ensure that there are security measures in place to protect your personal data. For example, we use encryption technology across our communication networks.
We only allow authorised personnel to have access to your information i.e. Music Support staff, volunteers or contractors and ensure that they are appropriately trained and, in most cases, have each signed an NDA.
Payment details (such as credit or debit cards) we receive through our website are passed securely to our payment processing providers who meet the required Payment Card Industry (PCI) Security Standards. We do not store your card details, when donations are made in this way.
Despite all of our precautions no data transmission over the internet can be guaranteed to be 100% secure.
We are committed to protecting the privacy of the young people that engage with us through our support services, whether that be via our website, via our helpline or at events. While we do not actively collect information from children (under-18s), we appreciate that our supporters are of all ages. Where appropriate, we will always ask for consent from a parent or guardian to collect information about children. All Music Support events will have clear rules on whether or not children can take part and the collection of data will be managed in accordance with each individual event, with appropriate safeguards in place.
We will communicate with you using the contact details you have provided for essential administrative purposes, such as to administer a donation or provide you with information regarding a fundraising event you have asked to take part in. You may change your communication preferences at any time. To do this please email email@example.com
We love to keep our supporters up to date with our fundraising, marketing and campaign activity.
If you have given us your consent to do so, we will contact you for marketing purposes by email and telephone calls. We may also send you communications by post, on the basis it is in our legitimate interests to do so, unless you ask us not to.
You can update your choices or stop us sending you these communications at any time by contacting firstname.lastname@example.org or by clicking the unsubscribe link at the bottom of the relevant email communication.
Developing Services and Research
We use data, including public feedback, to conduct research and for the further development of our services in order to provide you and others with a better experience, to spread awareness and to engage with the charities current campaigns. In some cases, we work with trusted third parties to perform this research, such as Survey Monkey, under controls that are designed to protect your privacy. We publish these insights, presented as aggregated data rather than personal data. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
We use others to help us provide our services (e.g., therapists, IT support and maintenance). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
Any information that could identify a particular user of our services is treated in the strictest confidence and will not be shared outside of Music Support without the prior consent of that individual. Music Support, however, has certain legal, professional and ethical obligations to report crime and protect the health and safety of the individual and/or others. Therefore, there may be certain situations where Music Support may need to break confidentiality and communicate concerns with external organisations due to our legal, professional and ethical obligations.
We would consider the need to share information about you with other agencies (such as Social Services or the Police) if you share something with us that makes us think;
· You or someone else is being hurt
· Your life or the life of someone else is in danger
· You have harmed someone else or you plan to harm someone else
· If you ask us to tell someone else that you are being hurt, you are in danger or you have hurt someone.
Legal basis for using your information
Data privacy law requires us to have one or more lawful grounds to process your personal information. The following grounds are relevant to our use of your information:
· Consent. In many cases we will seek consent to process your personal information, for example to send you marketing and fundraising emails, and text messages. Where we do rely on consent, you are entitled to withdraw it at any time.
· To protect your vital interests. For example, to ensure you get urgent medical assistance if needed when attending a Music Support event.
· Where we have a contractual relationship with you. Though the majority of our relationships are voluntary, if we enter into a contract with you we will process information to administer that contract.
· Legal obligations. We will sometimes pass on personal information to comply with legal obligations such as providing tax and gift aid information to HMRC.
· “Legitimate Interests”. Where it is appropriate we rely on the processing being in our legitimate interests, provided we are confident that such processing is not likely to override your own legitimate interests or rights and freedoms. For example, sending you marketing and fundraising post, provided this is done in an unobtrusive manner.
Music Support’s legitimate interests are ultimately in pursuit of our charitable objectives, including:
· Governance and operational management, such as statutory reporting and employee and volunteer administration and management
· Publicity and income generation, such as marketing and fundraising, events, and supporter analysis
· Administration, such as Gift Aid
· Financial management and control, such as processing donations.
Sharing your information
The personal information we collect about you will mainly be used by our staff (and volunteers) at Music Support so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
Music Support may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction and when there is a reason to do so we will only share your personal information with your consent.
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.
We may disclose your information if;
We are concerned that your mental health is poor; are in a current crisis and not in touch with mental health services
We are concerned that you could seriously hurt yourself or others
You are having suicidal thoughts and that you may act on those thoughts.
Who would you tell if you break confidentiality?
If Music Support decides that what you have said or written makes us think you or someone else may be at risk; we will always try and contact you to tell you that we will have to share what you have said with someone who can help. It will usually be Social Services we contact to share the information with unless we feel there is an emergency or that a crime has taken place and in that instance we would contact the Police.
How long we keep your information for
For some information we hold, there are legal requirements which determine how long we must keep it. For example, HMRC require us to retain details of Gift Aid for at least six years after the year in which the last donation was made.
Generally, we hold your personal information on our systems for as long as is necessary for the relevant activity, for example, in general we will only keep your contact information for as long as our interactions with you continue and for six years thereafter.
After such a period, within our database, we anonymise records so we can reference behavioural patterns in our data analytics, but the information is no longer personal to you.
We provide many choices about the collection, use and sharing of your data. Under the General Data Protection Regulation, you have the right to;
· be informed
· right of access
· right to rectification
· right to erasure
· right to restrict processing
· right to data portability
· right to object
· right not to be subject to automated decision-making including profiling.
You have the right to ask for a copy of any information which we hold about you, known as a subject access request. You also have the right to have any data removed or inaccuracies corrected. If you wish to make a subject access request, you will need to put your request to us in writing including proof of identity. We will have a month to comply with your request. Please note that we can refuse or charge for requests that are manifestly unfounded or excessive. Some of these rights only apply in certain circumstances and we may not be able to fulfil every request. If this happens then we will clearly explain the reasons why.
If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Data Protection Officers at Music Support; 69 Caversham Road, London, NW5 2DR, by email at email@example.com and by phone on 020 3648 6777. You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, https://ico.org.uk/.
Links to other websites
This policy may change from time to time. If we make any significant changes to this policy, we will publicise these changes clearly on our website or contact you directly with more information.
Please revisit this policy each time you consider giving your personal information to Music Support.