1. 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.
This privacy notice (“Privacy Notice”) sets out how we will store and process data we collect from people applying for grants from the BRIT Trust or who are connected with the BRIT Trust’s activities. We may update this Privacy Notice at any time and without notifying you before we do so.
2. WHAT INFORMATION WILL BRIT TRUST COLLECT ABOUT ME?
The BRIT Trust website and its subpages are referred to in this Privacy 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 BRIT Trust:
Physical Address (if any)
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, 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.
In respect of your visit to the Site, we may collect your IP Address.
3. HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect data from the data subjects themselves when you they register on our Site or fill out an application form for a grant.
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.
4. WHY DO WE COLLECT YOUR PERSONAL DATA?
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.
5. HOW DO WE USE YOUR PERSONAL DATA?
We will only use your personal data as permitted by law.
We use the information we collect about you to process your grant applications and, if you agree, to email you about The BRIT Trust.
If you subscribe to any of our communications, you can opt out at any time by following a clearly displayed link in the email or contacting our Data Protection Manager (“DPM”) (see contact details in paragraph 13), in which case all reasonable efforts will be made to erase your data from our systems.
We will not share your information with any third parties for marketing purposes without your prior consent.
“Special categories of personal data”
“Special categories of personal data” require higher levels of protection. We may collect such data when you apply for a grant. 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.
What if I am a Site user aged 13 or under?
If you are aged 13 or under, you will need your parent/guardian's permission before you provide us with your personal information via the Site. As a user of this Site, you have privacy rights the same as adults, so get to know what they are. You can:
• ask us what personal information we hold about you
• ask us to correct or delete your personal information
• tell us to stop using your personal information
If you're 13 or older, you can do this yourself, but not always. Sometimes we'll be asking for your parent or guardian to do that.
If you're under 13 your parent or guardian probably has to do it for you.
Users aged under 13 without parental/guardian consent are not allowed to provide us with personal information. If we become aware that you are under 13 and are attempting to submit or have submitted personal information via the Site without your parent/guardian's permission, we will not accept such information and we will promptly remove such information from our records.
6. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
7. 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 Privacy Notice. 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.
What about disclosure to other third parties?
We may share your personal data with other third parties, for example to external legal or other professional advisers, or to otherwise comply with the law.
We do not envisage transferring your personal data outside the UK. If the position changes, we will let you know and also let you know of the safeguards we will be putting in place to keep your personal data secure.
8. 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, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Details of retention periods for different aspects of your personal data are available in our Records Management Policy which is available from the DPM. 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, regulatory, tax, accounting, or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. 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 keep us informed if your persona data changes during your relationship with us.
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, though we may need to verify the accuracy of the new data you provide to us.
• 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), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• 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. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you exercise any of the rights set out above, 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 a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10. 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.
The Site is published in the UK by The BRIT Trust. All personal information submitted by you to the Site will be processed in accordance with this Privacy Notice (and any local terms that apply on the Site) unless terms on the Site specify otherwise.
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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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.
12. CHANGES TO THIS PRIVACY NOTICE
We reserve the right, from time to time, and at our sole discretion, to change or update this Privacy Notice.
All changes to this Privacy Notice will be published on this page and on the applicable Site. Upon publication, each change will become effective, and you will be deemed to be aware of and bound by it. You should therefore review this Privacy Notice regularly to ensure that you are up-to-date with the current terms of the Privacy Notice.
13. CONTACTING BRIT TRUST ABOUT THIS PRIVACY NOTICE AND CANCELLATION OF REGISTRATION
The 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
Email: [email protected]
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.