The Living Paintings Trust Privacy Statement

THE LIVING PAINTINGS TRUST (LIVING PAINTINGS) PRIVACY POLICY

CONTENTS

• Opening statement
• What the privacy and cookie policy covers
• Questions and changes
• About The Living Paintings Trust known as Living Paintings
• What personal information we collect about you and how we use it
• Data from third parties
• Information Living Paintings shares with other organisations
• Information created by Living Paintings
• Special category or sensitive personal data
• Children
• Legal basis
• You are in control
• How we protect your personal data
• Storage
• Your rights
• Glossary of terms

1. OPENING STATEMENT

At Living Paintings we are committed to protecting your personal information and being transparent about what we do with it. The privacy and security of your personal information is extremely important to us.

This privacy policy explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.

2. WHAT THIS POLICY COVERS

We ensure as a minimum that we use your data in accordance with all applicable laws concerning the protection of personal data. This policy explains:

• What data Living Paintings may collect about you.
• How we will use that data.
• Whether we disclose your details to anyone else.
• How we manage your personal data – security, storage and retention.
• Your choices regarding the data you provide to us.
• How we use cookies to provide services to you or to improve your use of our website.

3. QUESTIONS AND CHANGES

Any questions you have in relation to this policy or how we use your personal information should be sent to:

• Email: info@livingpaintings.org

Write to: The Office Manager, Living Paintings, Unit 8 Kingsclere Park, Kingsclere, Newbury, RG20 4SW.

Please note that from time to time we may need to amend or update this policy, for example if there is a change in the way that we use personal information or because of updates to the law. You should periodically check this website to make sure that you have seen the most up to date version of this policy.

4. ABOUT THE LIVING PAINTINGS TRUST (LIVING PAINTINGS)

Your personal data will be collected and used by the following party

• Living Paintings, charity no. 1049103

Living Paintings is based at Unit 8 Kingsclere Park, Kingsclere, Newbury, Berkshire, RG20 4SW.

Our purpose is to relieve the social and educational isolation and exclusion that is experienced by blind and partially sighted people of all ages.  Our method is to make the visual images that colour and inform our lives accessible to them.  In order to achieve this we design, create and publish Touch to See books for children, young people and adults. These include raised tactile pictures accompanied by atmospheric, educational and entertaining audio guides. The audio guides, often narrated by famous people, help fingers explore the tactile images, tell the stories of the pictures and describe their features. In this way, the senses of touch and hearing combine to make up for the missing sense of sight. By including colour images of the topics in the tactile pictures, our books can be shared with sighted friends, family and classmates.

Our Touch to See books are provided completely free of charge from our postal library so all visually impaired people, no matter where they live or their financial circumstances, can borrow them and gain a feel for the visual world.

5. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

If we collect personal information about you, your data will be stored on our library and supporter databases and occasionally in hard copy.  It is used for administration, communication and marketing purposes.

5.1    What personal information we collect

The following table sets out the information we collect by category and the types of data related to each category.

5.2    Where we collect personal information from

Living Paintings collects personal data from you when you engage with us as a supporter and/or library member.  You will be asked to provide information when you:

• register as a library member with us;
• apply to become a volunteer;
• make a donation to us;
• engage with our social media or communication services; or
• provide us with personal information in any other way

The following table details what data is collected and where the data is collected from.

5.3    How we use your personal information

The following table details how we use your personal data and the reasons to support the use and storage of your data.

When you provide your personal information to Living Paintings, please ensure that it is accurate and up to date. This will allow us to contact you and deal with providing you with our tailor made free library service, managing your donations, answering questions or providing you with data about our work more effectively. Please get in touch if you would like to change the personal details that we hold about you by contacting our office at Living Paintings, Unit 8 Kingsclere Park, Kingsclere, Newbury, Berkshire REG20 4SW or by logging into your online library account.

5.4      When you use Living Paintings website

When you use our website we collect data about the services and features you use and how you use them, including how you interact with its content and any campaigns.

Our website uses cookies. Cookies are files which are sent to the computer or device through which you access this website, and they collect small amounts of data. They are used to store information such as your computer or device and your preferences so that our website doesn’t have to keep asking you for them.

For further details about this, see our Cookie Policy which is available via the website.

5.5      When you use social media

When you view information published by Living Paintings using social media hosted across various platforms, we will collect and receive information that provides aggregate data relating to items such as video views, demographics and location data. Sources of this data include:

• YouTube
• Instagram
• Facebook
• X (formally known as Twitter)
• LinkedIn
• Sound Cloud
• Google Analytics

Identifiable personal information about people who access these platforms may be collected in order to allow Living Paintings to reach and market new audiences.

6. DATA FROM THIRD PARTIES

As a principle we do not acquire any personal data from other organisations.  Likewise we would never share personal data we hold with other organisations without implicit prior consent. Any data we may collect about you is only collected if it is in the public domain or, where applicable, from legitimate sources on a lawful, fair and transparent basis in accordance with applicable data protection law.  For example:

• Your name, postal address, phone number, email address, for example from Just Giving which is our online service for making donations. This is only collected when it has been knowingly provided to us by you.

7. INFORMATION LIVING PAINTINGS SHARES WITH OTHER ORGANISATIONS

We may disclose information to third parties or individuals, when we are obliged to by law or a regulatory order, or when one or more of the following apply:

• If you have specifically agreed that we may share your personal information to those third parties or individuals for a particular purpose.
• When we use other companies (known as ‘data processors’) to provide services on our behalf who are only processing personal information in accordance with our instructions. For example, companies that provide: direct mailing or marketing services that send material to you by post.
• Processing credit/debit card payments. Living Paintings sometimes process donations by credit card. The credit card transactions are made via a Verifone terminal, using secure debit and credit card processing services that are provided by First Data in accordance with Payment Card Industry (PCI) standards. Following completion of the transaction, card details are held by the Charity for a period of 24 hours to ensure that payment was successful and are then destroyed.
• We may disclose aggregate statistics about our library membership demographics to prospective partners, other reputable third parties and for other lawful purposes – these statistics do not include any information that identifies individuals.
• We use companies that provide us with library and contact management systems who solely hold data and do not use it for any purpose.  We contract with these companies that your information is handled securely, protected and only stored for as long as necessary, just as if we were handling it ourselves.

8. INFORMATION CREATED BY LIVING PAINTINGS

We complete internal research and analysis of your personal data. We do this by:

8.1    Internal research

We complete research by analysing our library membership, so as to identify trends in terms of common characteristics and geographical location.

We analyse:

• anonymised data for trends and cost effectiveness
• data you have provided in order to tailor our communications to your needs/requirements

To achieve this, we analyse library membership data by grouping people together in terms of common characteristics in order to offer more relevant and tailored information, services and communications.

For supporters of our charity, we keep track of the amount, frequency and value of each person’s support in order to offer more relevant and tailored information, services and communications.

We may also research supporters who we believe can become significant financial supporters of work undertaken by Living Paintings. We make sure that the sources we use are reputable public databases such as Companies House, mainstream news outlets or other reliable media sources which are in the public domain.

We will make sure that we do not use data about individuals that is clearly intended to be private or collect information in a privately intrusive manner that would not reasonably be expected by you. We will also inform you of this use as soon as is reasonably possible.

9. SPECIAL CATEGORY OR SENSITIVE PERSONAL DATA

We do collect and store what’s known as ‘special category’ or ‘sensitive’ personal information about library members – this includes data relating to someone’s disability, ethnic origin and age.

The table below details how we deal with special category data.

In addition:

• There may also be occasions when you share a story about you or a third party’s experience of using Living Paintings resources and the positive impacts you have experienced. These may include sensitive personal information relevant to Living Paintings to be used in a campaign or related marketing. When your information is collected in this way we will either gain your permission or anonymise your story before sharing.  On occasions where we may wish to use your story for a specific campaign, we will tell you how your information will be used and obtain your explicit consent to use it in this way.

10. CHILDREN

Living Paintings will not knowingly contact anyone under the age of 18 to ask them for donations or other forms of financial contribution.  We will not knowingly send communications about campaigns to children aged 12 years or under.

We will never have direct contact with any young person without the permission of a parent/guardian/primary caregiver.

We would like to give young people the opportunity to be involved in areas of our work that affect their lives for example helping to develop a new service/product for young people.

11. LEGAL BASIS

Living Paintings relies on the following legal conditions that are described in the EU General Data Protection Regulation to use your personal information in the ways described in this privacy notice:

• Legal obligations: where we are under a legal obligation to process your personal data for a particular purpose. For example, obligations we have to hold information about donations or manage Gift Aid information in compliance with applicable tax laws. We may also sometimes need to process personal information for the purpose of us being able to establish or exercise our legal rights or to defend legal claims.
• Contract: Library membership constitutes a contract between the individual and the charity. There is a requirement to process their personal data to comply with our obligations under the contract.  This will include, using personal information to carry out the processing of library transactions, undertaking the management of overdue resources, keeping members up to date with new resources as they are added to the library listing and other library administration functions as and when they arise.
• Legitimate interest: where we have a legitimate interest. This is the legal basis that we rely on to send information and marketing by post, email or telephone when you take part in supporting and/or benefiting from Living Paintings by making a donation, or requesting information about our work, marketing, campaigns and events or other services.

We will also have a legitimate interest in being able to use and process personal information for internal administrative purposes, and when it is necessary to take measures to protect our IT network and data security or to protect ourselves (and our library members and supporters) from risks to our charity such as fraud, criminal conduct or reputational damage.

When processing your personal information based on a legitimate interest, we will make sure that it is exercised proportionately and is always balanced against the privacy rights and other legal rights you have as an individual.

11.1    Service provision, marketing, campaigning and fundraising

We provide marketing and fundraising communications to library members and supporters which includes news, information and data about:

• Living Paintings and the services we provide to blind and partially sighted children, young people and adults, related events and campaigns.
• Opportunities to volunteer, appeals and fundraising (including donations, competitions, raffles and similar promotional activities).
• Our events and activities.
• Leaving a legacy.
• Newsletters.

With regard to fundraising Living Paintings relies on donations and support from others to continue its work helping blind and partially sighted children and adults all over the UK. Being able to contact you for marketing and campaigning purposes is an important part of our fundraising activity and purpose.

We will not share your data with any other organisation, individual or company to allow them to use your personal information for marketing or campaigning purposes.

11.2    Anonymised data

We may aggregate and anonymise personal information so that it can no longer be linked to any particular person. This anonymised data can be used for a variety of purposes such as to identify trends or patterns within our existing library member base. This data helps inform our actions and improve our campaigns, services and materials.

12. YOU ARE IN CONTROL

You can change your personal information and preferences about how we contact you whenever you choose.

12.1    How to change or stop us contacting you by post, telephone, email or text message

You can change your contact preferences at any time by contacting our team at Living Paintings, Queen Isabelle House, Unit 8 Kingsclere Park, Kingsclere, Newbury, Berkshire REG20 4SW or by emailing info@livingpaintings.org or calling us on 01635 299771.

12.2    How to unsubscribe from Living Paintings email newsletters and other communications.

If you no longer wish to receive email communications from Living Paintings, please email us as follows:

• Library members please email LibraryUnsubscribe@livingpaintings.org
• All other individuals please email OthersUnsubscribe@livingpaintings.org

In addition, all email communications will contain the option to unsubscribe.

13. HOW WE PROTECT YOUR PERSONAL DATA

Living Paintings is totally committed to the importance of keeping your information safe. We employ a variety of physical, organisational and technical measures to ensure we do this, and prevent unauthorised access to, or use or disclosure of your personal information.

Electronic data and databases that contain library members and supporters personal data are stored on secure computer systems and we manage who has access to that data (using both physical and electronic means). We have a set of detailed data protection procedures and policies which staff including volunteers must follow when handling personal information.

All hard-copy records and data are managed securely in lockable and access-restricted storage.

13.1    Payment security

All electronic forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.

If you use a credit card to donate your debit/credit card details are entered into a secure Verifone terminal which is processed by First Data who comply with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council. We do not store any payment card information.

We cannot guarantee the security of your home computer or any information sent over the internet or any publicly accessible communications network and using any online communications services are at the user’s own risk.

14. STORAGE

Where we store personal information:

Living Paintings is based in the UK. Where data is shared with some organisations and companies that provide services to us we have put other legally appropriate safeguards and/or contracts in place to ensure that your data is adequately protected in accordance with EU privacy standards.

14.1    How long we store data

We will only use and store personal information for as long as it is required for the purposes it was collected for.

Personal information that we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it. Some personal information may be retained by us in archives for historical research purposes, although we will do this in a manner that complies with applicable data protection law.

We continually review what personal information and records we hold, and delete what is no longer required. We never store payment card data.

15. YOUR RIGHTS

As part of our commitment to you, we want to make sure that you are able to make your own choices about how we use your personal information. It is important to us that you understand your data protection rights, which are set out below.

15.1    Right of Access – data subject access request

You have certain rights of access in relation to your personal information. We will confirm whether or not we have your data and, if we do, provide a copy of the personal information we hold and other information about how we process your information within relevant timescales (usually a month for simple requests and timescales can be extended for complex requests).

15.2    Right to be Forgotten

You have the right to be forgotten means that you are entitled to have your personal information that we no longer need erased from our records.

15.3    Right to Rectification

You have the right to have inaccurate personal information amended.

15.4    Right to Restrict Processing

Where we process data based on consent, you have the right to ask us to stop using your information.

It is important to note that in order to provide a service to our library members it is essential that the charity collects certain personal data for the purpose of delivering and requesting returns of overdue resources. These are:

• Name
• Address (including postcode)
• Age
• Email address
• Telephone number

Alongside the provision of our free library service another of the core reasons for processing data is to enable the charity to undertake the submission of applications for funding to grant making Trusts and Foundations.  A requirement of every application is the ability to provide supporting data to underpin each request.  The data that we provide under these circumstances in always anonymised unless we have the prior agreement of the person/s to which it refers.  This will include:

• The number of blind and partially sighted people there are and who have benefitted from our services and perhaps their age, gender, regional location, disability and ethnicity.
• The impact that our service have/have had on our beneficiaries and how this has improved their lives

15.5    Right to Object

You have the right to object to your personal information being used for marketing or profiling.

15.6    Right to Data Portability

 You have the right (in certain circumstances) to have a copy of your personal information provided for reuse in another service.

15.7    How to exercise your rights

If you would like further details about your rights or would like to exercise them, please write to our office at:

info@livingpaintings.org or addressed to Living Paintings, Unit 8 Kingsclere Park, Kingsclere, Newbury, Berkshire REG20 4SW.

We reserve the right to ask for further information to verify your identity (or clarify the information that you are seeking) when we receive such a request.

If you are dissatisfied with the response from Living Paintings you can contact the UK Information Commissioner’s Office (ICO) as follows:

Information Commissioner’s Office
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF

Telephone: 0303 123 1113

You can also use their Data Protection and Personal Information Complaints Tool here.

16. GLOSSARY OF TERMS

Personal data
Any data that identifies you, or which can be identified as relating to you personally.

Data controller
Refers to The Living Paintings Trust (Living Paintings) in this document.

Approval and Review

Approved by: Board of Trustees

Date: 10 November 2023

Review Date:   November 2024