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Living Paintings

The Living Paintings Trust Privacy Statement

THE LIVING PAINTINGS TRUST (LIVING PAINTINGS) PRIVACY POLICY

CONTENTS


  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.


  1. 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:


  1. QUESTIONS AND CHANGES

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

info@livingpaintings.org.uk

or addressed 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.


  1. ABOUT THE LIVING PAINTINGS TRUST (LIVING PAINTINGS)

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

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.


  1. 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.

What we collectWhat this includes
Contact detailsThis relates to your personal data and will include:

·         Library members: your name, age, address, postcode, telephone number and email address

·         Supporters and Funders: your name, address, postcode, telephone number and email address

Socio-demographic details

(Library members only)

This will include age, gender and ethnicity. )
Disability details

(Library members only)

 

This includes level of visual impairment and any other disability/health issues that you inform us you have.
Financial details (Committed Givers only)Such as bank account details provided by you for the purposes of regular donations. See Section 12 (see note)
Donation history

(Supporters and funders only)

This will include the date, amount and reason (if there is one) for the donation.  This may be as a result of attending an event, a committed giver who gives on a regular basis, a fundraising campaign, a one off donation and any gift aid received.
Website usage historyThis relates to the collection of data using cookies.
Data on event invitations and attendanceThis information will include the types of invitations you have been sent and accepted and the events you have supported.
Data on recorded preferencesThis relates to information gathered from email communications sent to you via Campaign Monitor or Mailchimp.  These applications report unsubscribes.  This information is used to update your personal preferences on our databases and ensure that we only contact you in when you wish us to do so on the subjects that you are interested in.

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:

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

Where the data is collected fromWhat data is collected
Data you provide to us·         Contact details

·         Socio-demographic detail

·         Details required for a tailored service

·         Disability details

·         Information regarding your experience of using our service

·       Financial details

Data we collect when you use our services

 

·         Library Service usage history

·         Donation history

·         Website usage history

·         Data on event invitations and attendance

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.

How we use

your personal information

Our reasons for using your personal informationOur legitimate interests

(where relevant)

Providing our services
We use your address to send library books which you have requested.  We may use your address for additional reasons such as those listed under email address and telephone number.·   This is necessary for us to perform our obligations under the agreement we have with youN/A
We use your email address and/or telephone number to follow up overdue resources, to respond to your enquiries, request your help e.g. with a survey and all other library admin which will include informing you about changes to the service we provide.·   This is necessary for us to perform our obligations under the agreement we have with youN/A
Supporting our operations
We use your email address to send information which you have agreed to receive about our events and fundraising initiatives·   Your consentN/A
We use your address and email address  to share occasional news and updates about our services·   Our legitimate interests·   Raising awareness of our services

·   Identifying future funding opportunities

We use stories and experiences shared by you to inspire others to join our free library service, support our funding applications to grant making trusts, as part of our campaign and marketing materials·   Your consentN/A
We analyse our library membership in order to identify trends in terms of common characteristics and geographical location·   Our legitimate interests·   Data analysis on anonymised  membership data and usage is used to support funding applications to grant making trusts
Improving our services
We analyse our library membership in order to identify trends in terms of common characteristics and geographical location·   Our legitimate interests·   Increasing our number of beneficiaries

·   Improving our services

·   Expand the number of library resources

When you use our website, we use cookie to gather analytical information.   This is analysed and the results are used to improve the service we provide·   Our legitimate interests·   Improve a website and social media so that we provide the best experience for our users

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:

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


  1. DATA FROM THIRD PARTIES

As a principal 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:


  1. 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:


  1. 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:

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 privacy intrusive manner that would not reasonably be expected by you. We will also inform you of this use as soon as is reasonably possible.


  1. 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.

Special CategoryHow your data is dealt with
DisabilityWe ask about level of visual impairment to monitor who we are reaching, and ensure that our service is reaching the people it is designed for (those with a visual impairment). It is also used to help ensure our service suits them depending on whether they are blind or partially sighted
EthnicityWe use only in an anonymised way to monitor who we are reaching and for funder requirements.
Date of birthWe use to help send age appropriate books and to monitor who we are reaching

OR


  1. 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.


  1. 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:

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:

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.


  1. 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.uk 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:

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


  1. 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.


  1. 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.


  1. 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:

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:

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.uk 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 (local rate) or 01625 545 745

Fax: 01625 524 510


  1. 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.

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