01. What is the purpose of this privacy notice and to whom does it apply?
British Record Industry Trust (company number 02372740) (registered charity number 1000413) (“BRIT Trust, “we” or “us”) is committed to protecting the privacy and security of your personal data. References to your “personal data” include any or all of your personal data, as the context requires, including “special categories of personal data”, which involves more sensitive information about you. This is most likely to include information about your racial, ethnic origin or your health. There are other categories of “special categories of personal data” which are less likely to be processed, but for a full definition, see Sections 10 & 11 of the Data Protection Act 2018.
The BRIT Trust is a “data controller”. This means that we are responsible for deciding how we hold and use personal data about you.
02. What information will BRIT Trust collect about me?
The BRIT Trust website and its subpages are referred to in this Notice as the “Site”.
We may collect the following information from you when you register on our Site or fill out an application form to benefit from the Trust:
Physical Address (if applicable)
If you apply for a Grant on behalf of your organisation we may collect information necessary to process your application, such as:
- Gender, name, email address, phone number, job title, and if applicable record of past criminal convictions, of you and the key directors, staff and/or Trustees of your organization.
- Recent relevant work, experience and achievements of your organisation
- If applicable, the particular group of people that your activity is targeted at. This may include, without being limited to, age group, ethnic group, gender group, sexual orientation, or group with a specific health condition.
03. How do we collect your personal data?
We collect data from third parties from the data subjects themselves.
Personal data may indirectly be shared with us by third parties when providing names or other personal information of applicant company directors and/or charity trustees and/or beneficiaries of donations. These may be provided by persons who have confirmed having the express consent of the data subjects in order to supply such information or when we have a legitimate interest to do so.
04. Why do we collect your information?
We collect data to (i) assess the eligibility of grant applications, (ii) keep you up to date with the progress of your application, (iii) request further information/clarification from you if this proves necessary and (iv) enable us to monitor the compliance & delivery of grant obligations and to promote the projects, charities, entities and initiatives supported by the BRIT Trust.
“Special categories” of personal data
“Special categories” of personal data require higher levels of protection. We may collect these data. We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in limited circumstances with your explicit consent, or in relation to personal data which are manifestly made public by the data subject.
05. Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so, before we start using it for that unrelated purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is permitted by law.
06. Sharing Data
The BRIT Trust will not provide your data to any third parties other than (i) the BPI (British Recorded Music Industry) Limited, whose employees provide essential management and administration services which enable the Trust to make donations and deliver against is Objects or (ii) in specific instances where you expressly consent for us to do so.
How secure is your information with third party service providers?
All our third party service providers are required to take appropriate security measures to protect your personal data in line with our policy. We do not allow our third party service providers to use your personal data for their own purposes unless they are data controllers in their own right in relation to your personal data. Where they operate as our “data processors” (i.e. they process your personal data on our behalf and acting only on our instructions), we only permit them to process your personal data for specified purposes and in accordance with our instructions.
07. How long will we retain your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
08. What are your rights and obligations as a data subject?
Your duty to inform us of changes:
It is important that the personal data we hold about you is accurate and current. Please let us know of any changes. We will update your records promptly upon being notified of such changes.
Your rights in connection with personal data:
Under certain circumstances, by law you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to another party.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact the DPM in writing.
No fee usually required:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances, as permitted by the Data Protection Act 2018.
What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
09. Using Our Site
The Site may contain links to other websites where information practices may be different to ours.
Visitors should consult the privacy policies of the websites they are taken to for further details, as we are not responsible for and have no control over information that is submitted to, or collected by, these third parties.
Our Site have security installed to ensure that any personal data entered onto the Site is protected against loss, misuse or alteration. However, due to the nature of the Internet, we can't guarantee the protection of your personal information and we can't be responsible for any outcomes resulting from a breach of security when the Site is used. We're confident in our security, and it is always a top priority to ensure we do not get any problems.
We have put in place measures to protect the security of your information. We secure the storage of your data on our servers, and restrict access to only those employees, agents, contractors and other third parties who have a business need to know. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
BRIT Trust is not obliged to appoint a statutory data protection officer, but has appointed a Data Protection Manager. For any queries, please contact:
Data Protection Manager, BRIT Trust, County Hall, Westminster Bridge Road, London, SE1 7JA
Telephone: +44 (0)20 7803 1300
The DPM is responsible for overseeing compliance with this privacy notice and for handling any data protection queries or issues involving the BRIT Trust and BPI and its subsidiaries. You should contact the DPM in the first instance about any issue involving data protection, whether it involves your data or anyone else’s.