PURPOSE OF POLICY

We are committed to protecting your personal information and being transparent about what information we hold about you.

Using personal information allows us to develop a better understanding of our patrons and in turn to provide you with relevant and timely information about the work that we do - both on and off stage. As a charity, it also helps us to engage with our donors and supporters.

The purpose of this policy is to give you a clear explanation about how the Octagon Theatre Trust, Octagon Theatre Catering Services and Octagon Theatre Productions collect and use the information we collect from you directly and from third parties.

We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:

• What information we may collect about you
• How we may use that information
• In what situations we may disclose your details to third parties
• Our use of cookies to improve your use of our website
• Information about how we keep your personal information secure, how we maintain it for and your rights to be able to access it

If you have any queries about this policy, please contact the Data Protection Officer at the Octagon Theatre or email: info@octagonbolton.co.uk

WHO WE ARE

The Octagon Theatre is a charity and is funded by Arts Council England, Bolton Council and the Greater Manchester Combined Authority as well as various trusts, foundations, individual donors and corporate supporters. Our registered charity number in England and Wales is [248833] and we are also registered as a company in England and Wales under registration number [882226]. We also have two subsidiaries companies Octagon Theatre Catering Services Ltd [02095489] and Octagon Theatre Productions Ltd [09260244]

INFORMATION COLLECTION

We collect various types of information and in a number of ways:

INFORMATION YOU GIVE US

For example when you register on our website, buy tickets or gift vouchers, participate in one of our projects, become a regular giver or Corporate Member, or make a donation to support us, we’ll store personal information you give us such as your name, email address, postal address, telephone number and card details.

We will also store a record of your purchases, donations and your Gift Aid status, where applicable and as required by HMRC.

INFORMATION ABOUT YOUR INTERACTIONS WITH US

For example, when you visit our website, we collect information about how you interact with our content and ads. We will keep records of communications sent to you by the Octagon or received from you. When we send you a mailing we store a record of this, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on.

We may also capture your image in photography or in the video recording of a production or special event.

We also use CCTV recording equipment in and around our premises to safeguard our staff, customers, and visitors to the building. Images from the CCTV are securely held for 30 days and if there is an incident they may be shared with the police.

INFORMATION FROM THIRD PARTIES

We occasionally receive information about you from third parties. For example, we may use third party research companies to provide general information about you, compiled using publicly available data, or may receive recommendations from friends or business colleagues.

SENSITIVE PERSONAL DATA

Data Protection law recognises that certain categories of personal information are more sensitive such as health information, race, religious beliefs and political opinions. We do not usually collect this type of information about our patrons unless there is a clear reason for doing so. [As an example, we collect health information about participants in our programme of classes and courses.]

LEGAL BASIS

There are three bases under which we may process your data:

CONTRACT PURPOSES

When you make a purchase from us or make a donation to us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example we may need to contact you by email or telephone in the case of cancellation of a show, or in the case of problems with your payment.

LEGITIMATE BUSINESS INTERESTS

In certain situations we collect and process your personal data for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.

WITH YOUR EXPLICIT CONSENT

For any situations where the two bases above are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.

MARKETING COMMUNICATIONS

We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this we use data that we have stored about you, such as what events you have booked for in the past, as well as any preferences you may have told us about.

We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may object to receiving these at any time using the contact details at the end of this policy. In the case of email, we will give you an opportunity to opt out of receiving them during your first purchase or communication with us. If you do not opt out, we will provide you with an option to unsubscribe in every email that we subsequently send you, or you can alternatively use the contact details at the end of this policy.

We may also contact you about our work by telephone however we will always get explicit consent from you before doing this. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases (as above).

We use social media to broadcast messages and updates about events and news. On occasion we may reply to comments or questions you make to us on social media platforms. You may also see adverts from us on social media that are tailored to your interests. Depending on your settings or the privacy policies on social media and messaging services like Facebook, LinkedIn, Instagram, TikTok or Twitter, you might give third parties (like the Octagon) permission to access information from those accounts or services.

OTHER PROCESSING ACTIVITIES

In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:

• We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
• We may use your data provided to occasionally send invitations to take part in customer research. It’s always optional, and you don’t have to take part. We may then use the information gathered to help inform decision making and improve the way we communicate.
• Any sensitive data collected via customer research including gender, sexual orientation and age is always anonymous, and always optional, although it is something we’re regularly required to ask by funders to demonstrate that we are providing for a range of people.
• We may analyse data we hold about you in order to identify and prevent fraud.
• In order to improve our website we may analyse information about how you use it and the content and ads that you interact with.
• We may use your data to carry out research to understand your interest in supporting the Octagon as a charity, and to make you aware of opportunities to make a donation and support the theatre.
• We will use your information to administer our regular giving and supporter schemes and donor records, and to make sure that communications we send you about fundraising are appropriate. By better understanding your interests and preferences we can continually improve our service for you as a supporter.
• We analyse and combine personal information with other publicly available information to better understand the interests, influence and affluence of our supporters and donors, to identify potential supporters and to make appropriate requests for gifts. This may include newspaper websites and archives, housing market websites and the electoral roll as well as official websites of companies, charities and other cultural organisations to collect information about age, place of residence, occupation and professional activities, recreations and interests, professional and personal networks, personal wealth and support of other charities. We may also use information which is publicly available from officially registered information providers, such as:
  - Charity Commission with information on Charity Trustees
  - Trustfunding org a database providing information of grant-giving trusts and foundations
  - Companies House with information on company directors and officials
• We may also use publicly sourced images to help us in identifying individuals who attend networking or fundraising events.
• We have in the past used third party fundraising agencies to undertake standard wealth screening exercises using portions of our ticketing and supporter information, where we held consent to carry out data processing, to support our business activities and identify appropriate levels of potential support, and areas of interest. We no longer perform such use external service providers to carry out such exercises, but will continue to conduct research and fundraising activities in-house to promote the Octagon as a charity.

In all of the above cases we will always keep your rights and interests at the forefront to ensure they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out tasks above that are for your benefit.

THIRD PARTIES

There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:

To the subsidiaries described above when it is necessary for them to be able to provide you with products or services that you’ve requested.

To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.

We may share personal information with other organisations, particularly The Audience Agency, and MHM who use this to analyse ticket sales and survey results for national and regional research into patterns of Arts attendance in England. This assists with reporting to funders and strategic planning, helping us to make better business decisions. Your personal data is never used by them to contact you, nor passed or sold on to any other agencies or companies, and we have agreements in place to ensure this.

Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).

To specific named visiting companies whose performances you have attended. In these cases we will always ask for your explicit consent before doing so.

COOKIES

Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your basket) as well to provide website operators with information on how the site is being used.

We use cookies to keep track of your basket as well as to identify how the website is being used and what improvements we can make.

View our fully cookie policy here

YOUR DEBIT AND CREDIT CARD INFORMATION

If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS). You can find more information about this standard here.

We optionally allow you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.

MAINTAINING YOUR PERSONAL INFORMATION

We store your personal information indefinitely such that for any subsequent purchases you make we are able to link them back to a single unique record that we hold for you on our system.

If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging in to your account through our website. Alternatively please use the contact details at the end of this policy.

Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.

SECURITY OF YOUR PERSONAL INFORMATION

We will put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.

We will not transfer, process or store your data anywhere that is outside of the European Economic Area.

YOUR RIGHTS TO YOUR PERSONAL INFORMATION

You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected. Please use the contact details at the end of this policy if you would like to exercise this right.

CONTACT DETAILS AND FURTHER INFORMATION

Please get in touch with us if you have any questions about any aspect of this privacy policy, and in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.

Octagon Theatre
Howell Croft South
Bolton
BL1 1SB

info@octagonbolton.co.uk

Further information on data protection regulations and laws can also be found here:

• Data Protection
• Fundraising Regulator