Privacy Policy

Introduction

We are Bradford Culture Company which was established to promote arts, culture, heritage and creativity in Bradford in the public interest and create a bid for Bradford’s bid for UK City of Culture 2025. It may also undertake other cultural activities at the discretion of its directors.

This privacy statement is intended to provide you with information about how we process your personal data in our interactions with you. If you have any concerns or outstanding questions after reviewing this statement, then we encourage you to contact us by emailing our Data Protection Officer at [email protected] or writing to:

Data Protection
c/o ProvePrivacy Ltd
73 Moor Close Road
Queensbury
Bradford
West Yorkshire
BD13 2EB

Bradford Culture Company is a Company Limited by Guarantee registered in England and Wales number 12330027, and a registered charity 1194599.

The data we process

We process personal data in several ways as part of developing and delivering the Bradford UK City of Culture 2025. This privacy statement outlines what data we collect, why we process it and how we treat it whilst we are holding it. Please review the section which details how we might interact with you.

If you fail to provide personal data: Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

You are an Attendee of one of our Events

Managing Enquiries

When you make an enquiry about attending one of our events, or if you attend one of our events then you are likely to provide us with personal data such as name and contact details to enable us to contact you or respond to any enquiry. You may do this via a form on our website or any similar method.

We normally retain this personal data for marketing purposes but only if you have provided us with your consent to do so and we will always respect your decision if you ask us to stop contacting you. We will not pass this information on to other third parties for marketing purposes unless you have asked us to do this separately.

We will process your enquiry on a customer relationship management system (CRM) and will process promotional campaigns through an email mailer system. We will keep a record of these communications with you, and we may track whether you receive or open emails so we can measure the effectiveness of our campaigns.

Event Attendance

If you are invited to an event then personal data such as your name and contact details will be processed on our ticketing system in order that we can provide you access to the event.

As part of managing ticketing we may process payments. We use the Ayden payment gateway to administer this service on our behalf. Ayden are a data controller in respect of the management of personal data associated with payments.

Media Usage

We will process personal data in the form of photographic, video and audio media in and around our events and will inform you of this through signs at the event or notices in event publications. Bradford UK City of Culture 2025 and any other wholly owned legal entity of Bradford UK City of Culture 2025 may use photographs, film, audio, or other images of the person named above to promote Bradford 2025’s legitimate charitable and commercial interests.

If you object to such processing then you should provide a clear opt-out, e.g. speak to the photographer, remove yourself from the photo areas, say no thank you if the photographer asks.

Data Retention

CRM and marketing information will be retained for up to 3 years after which point it will be deleted.

Press releases, photographic, video and audio media may also be processed and shared with West Yorkshire Archives as part of the historic archives in the public interest, once the Bradford 2025 City of Culture is complete, to learn about how this impacts your data protection rights, please review the section ‘Your Rights’ below.

Any records which need to be retained for longer than 3 years for statutory reasons (e.g. financial records) will be transferred to a temporary archive provider to ensure that our legal obligations can still be met.

You are a Volunteer supporting one or more of our events

Managing Enquiries

When you make an enquiry about Volunteering we will require personal data to enable us to manage the volunteering teams and the events which they support.

We may collect Volunteer information from you via a form on our website or through other opportunities such as face to face canvassing.

We may seek to process sensitive data about you, such as information about criminal records etc (DBS Checks) if your volunteering role might support vulnerable individuals. This is to ensure that we are meeting our legal safeguarding obligations.

We manage volunteering through a third party data processor volunteer management system, which enables you to register your interest for upcoming events and manage your participation.

Media Usage

We will process personal data in the form of photographic, video and audio media in and around our events and will inform you of this through signs at the event or notices in event publications. Bradford UK City of Culture 2025 and any other wholly owned legal entity of Bradford UK City of Culture 2025 may use photographs, film, audio, or other images of the person named above to promote Bradford 2025’s legitimate charitable and commercial interests.

If you object to such processing then you should provide a clear opt-out, e.g. speak to the photographer, remove yourself from the photo areas, say no thank you if the photographer asks.

Data Retention

Volunteering information will be retained by the Bradford Culture Company for up to 36 months. Once the Bradford UK City of Culture 2025 event calendar has completed the Bradford Culture Company will be dissolved and registration data for volunteers may be shared with a regional organisation to enable a volunteering workforce to be maintained for legacy events. Your personal data will not be shared for this purpose without your consent and information not shared will be deleted.

Press releases, photographic, video and audio media may also be processed and shared with West Yorkshire Archives as part of the historic archives once the Bradford 2025 City of Culture is complete, to learn about how this impacts your data protection rights, please review the section ‘Your Rights’ below.

You are a Participant contributing to one of our events

Engagement with Freelancers and Artists

When developing our programme of events we will engage with freelancers and artists and will process their name and contact information to liaise and define any agreement and to manage the event.

We may share some personal information with event organisers in order to enable them to manage the event.

Engagement with Groups of Participants

When developing our programme of events we will engage with participants in a number of ways, for schools, community organisations and other groups we will always engage with the educators or leaders rather than with the individuals who are likely to participate in an event. We will use personal data of these individuals to liaise and define our agreement with the organisations.

Once an agreement is in place we will process personal data in order to manage the event, this will include contact information, and might also include medical and emergency information in order to enable us to meet our safeguarding obligations to vulnerable people.

We might also need to share children’s personal information with local authorities in order to obtain child performance licences.

Media Usage

We will process personal data in the form of photographic, video and audio media in and around our events. As a participant in an event we will ask for your consent, or the consent of a guardian in the case of children. If you object to such processing then you should not provide your consent and we will put controls in place to ensure that your image is not used.

Data Retention

Press Releases, photographic, video and audio media may also be processed and shared with West Yorkshire Archives as part of the historic archives once the Bradford 2025 City of Culture is complete, to learn about how this impacts your data protection rights, please review the section ‘Your Rights’ below.

You are a Supplier or are involved in Event Operations

If you are associated with Bradford 2025 through our supply chain, we are likely to retain personal data of employees in your organisation with respect to managing any correspondence relating to the contract in place between our organisations. For example, we may hold email addresses or mobile phone numbers which we will use for contacting you.

We may share this data with a third party if this is required to manage our relationship. For example, if there is a dispute over payments of invoices then data may be shared with debt recovery organisations.

Data Retention

Personal data will be retained by Bradford 2025 City of Culture for up to 3 years after which it will be securely destroyed. Any records which need to be retained for longer than 3 years for statutory reasons (e.g. financial records) will be transferred to a temporary archive provider to ensure that our legal obligations can still be met.

You are a Survey Participant or have provided Feedback

You may consent to participate in any research that we undertake, we collect personal data which might include your name and contact information as well as your opinions, this may also include sensitive data such as racial origin. Survey data will be collected as a requirement of our funding and will be used to evidence that public funds are being spent effectively as well as for the purposes of researching the economic and social impact of the cultural and creative sector.

We will engage the services of qualified research partners who will undertake surveys on our behalf. Our objective is to always minimise the amount of personal data collected, so in most cases data will we anonymised before we receive it from our research partners.

We may share this information with the organisations commissioned to carry out research in order to conduct an independent analysis on behalf of Bradford 2025. The information shared will be anonymised and personal data will not be passed onto any other organisation.

All reporting produced from the survey data will be anonymised prior to being shared or published.

Subjects have the right to withdraw consent on any data provided at any time in the process.

Data Retention

Personal data will be retained by Bradford 2025 City of Culture for up to 3 years after which it will be securely destroyed.

You are a Sponsor or a Funder to the Bradford 2025 UK City of Culture

Funding from Businesses

When you make an enquiry about funding for Bradford 2025 UK City of Culture you are likely to provide us with some personal data to enable us to contact you. You may do this via our website or directly, by passing us your business card or any other similar method.

We may be introduced to you from a mutual contact or we may research public sources to obtain business contact details, which we go on to use to generate funding interest. As business to business communications these are outside of the scope of the Privacy in Electronic Communications Regulation (PECR) but are in scope of the Data Protection Act (2018), therefore we consider these communications to be in our legitimate interest, we will always offer you the opportunity to opt out of emails.

We will process your enquiry on a customer relationship management system (CRM) and will process promotional campaigns through an email mailer system. We will keep a record of these communications with you, and we may track whether you receive or open emails so we can measure the effectiveness of our campaigns. We normally retain this personal data for fund raising purposes as long as we believe that we retain a legitimate interest to continue towards dealing with you and we will always respect your decision if you ask us to stop contacting you.

Funding from Individuals

You will be able to provide one off donations via our website, where we will process personal information such as your name, contact details and financial transaction details. We will also offer you the opportunity to participate in the ‘Gift Aid’ scheme. For any gift aid contributions your personal data will be shared with HMRC in order for Bradford 2025 City of Culture to be able to recover the income tax on your behalf.

As part of managing contributions we may process payments. We use the Ayden payment gateway to administer this service on our behalf. Ayden are a data controller in respect of the management of personal data associated with payments.

Sponsorship

If you are associated with Bradford 2025 through our Sponsorship opportunities, we are likely to retain personal data of employees in your organisation with respect to managing any correspondence relating to the contract in place between our organisations. For example, we may hold email addresses or mobile phone numbers which we will use for contacting you.

Data Retention

Personal data will be retained by Bradford 2025 City of Culture for up to 3 years after which it will be securely destroyed. Any records which need to be retained for longer than 3 years for statutory reasons (e.g. financial records) will be transferred to a temporary archive provider to ensure that our legal obligations can still be met.

You are a Visitor to our website

There are several ways in which we might gather your personal information via our websites. You should review the ‘Our Use of Cookies’ section for details on how we use your personal data to track your usage of our website.

If you make an enquiry about attending an event via any of the forms on our website, then we will treat this information as outlined in the ‘Attendee’ section.

If you make an enquiry about volunteering to support our events via any of the forms on our website, then we will treat this information as outlined in the ‘Volunteer’ section.

If you make a funding donation via any of the forms on our website, then we will treat this information as outlined in the ‘Sponsor or Funder’ section.

Depending on your settings, or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you may give us permission to access information from those accounts or services.

You have applied for a role within Bradford Culture Company

If you have applied for a job role with Bradford Culture Company it is likely that you have provided us with personal information to support your application, typically a CV and contact details. We will use the information provided to review if you are suitable for an interview and we may also collect additional information from other sources such as your referees or from social media.

If you are successful in your application, we will provide you with an employee’s Privacy Statement which will detail how we treat the personal data of our employees. You will receive this as part of your offer notification.

Data Retention

If you are unsuccessful at any stage, then we may retain your personal information for up to an additional six months. We do this in order that we can meet our employment law obligations, but we may also use this information in our legitimate interest, to contact you again if we wish to revisit the application.

Sharing your data

If we are required by law, or requested by the police or a regulatory or government authority investigating potentially illegal activities, to provide information concerning your activities we shall do so. We may also disclose personal information to appropriate third parties to assist in anti-fraud checks and investigations.

Where necessary, we may share your personal data with:

  • HM Revenue & Customs, regulators and other authorities, and our professional advisers including lawyers, bankers, auditors and insurers within the EEA where it necessary for our legitimate interests in protecting our activities or where we have to comply with a legal obligation.
  • Our suppliers and sub-contractors, within or outside the EEA, where they require access to your personal data in order to fulfil our legitimate requirements or where we have your consent to share your details for the purposes of third-party marketing. Funders, key partners and evaluators for administration, assessment, monitoring and evaluation purposes, such as, City of Bradford Metropolitan District Council, Arts Council England and National Lottery Heritage Foundation.
  • Our education partners, primarily for their careers service to carry out student learner tracking and evaluating any impact of their engagement with us.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers working on our behalf (data processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Once the Bradford UK City of Culture 2025 event calendar has completed the Bradford Culture Company will be dissolved and certain data will be transferred to other parties. For example, personal data of historic interest will be transferred to West Yorkshire Archives, this is likely to include:

  • Photographic, video and audio
  • Minutes of significant meetings
  • Details of contracts with suppliers and sponsors

International Data Transfers

Bradford 2025 do not routinely transfer personal data outside of the UK or the EU.

If there are exceptional circumstances where your personal data needs to be processed outside of the EU, we will ensure that we have put in place recognised safeguards or that the transfer is subject to a recognised exception (as documented in UK and EU Data Protection Regulation).

Your rights

1. Right to be Informed

You have the right to be informed about the data that we process on your behalf. In most cases we will ensure that the Privacy Statement you are reading now is the means by which we inform you of our usage of your personal data, this will change from time to time and will always be dated in order that you know when this version came into effect.

There may be circumstances where you would not reasonably be expected to have had visibility of this statement when we obtain your data, such as when someone else provides us with it. In these circumstances we will inform you when we first communicate with you and at least within 30 days of receiving the data.

We will always endeavour to ensure that a Privacy Statement is available but there may be circumstances where we will not be able to provide you with a Privacy Statement, where we can’t identify you, for example where crowd photographs have been taken for our promotional or archiving purposes.

2. Right to Access

You have the right to access any personal data that we process on your behalf. If we do not hold any of your personal data, we will inform of this also.

We will provide this on request and we will also provide you with the purposes for which we process your data. If we have transferred your data to a ‘third country’, then we will inform you of the safeguards that we have put in place to ensure that it receives the same protections as you would expect.

We will provide you with a copy of any personal data free of charge, except in circumstances where additional copies of the same data is requested or where we deem your request to be excessive, where we may apply a reasonable fee to cover our administration costs.

3. Right to Rectification

It is our policy to ensure that any personal data that we hold remains accurate and up to date. If you believe that we are processing inaccurate personal data, you have the right to have this personal data corrected.

We may ask you to prove your identity to us prior to making any changes in order to confirm the integrity of the request.

4. Right to Erasure

You have the right to have your personal data removed from our systems. This right only applies where:

  • the personal data is no longer necessary for the purposes for which it was collected
  • we processed your personal data on the basis of your consent and you have withdrawn this
  • we are processing your personal data on the basis of legitimate interest and there are no legitimate grounds remaining for its continued use
  • the processing is deemed unlawful
  • the personal data must be erased to comply with a legal obligation
  • where the data applies to a child and their usage of ‘information society services’
5. Right to Restrict Processing

You have the right to ask us to restrict or cease the processing of your personal data. You may wish to use this right if you want to ask us to stop doing something, but not erase the data. This may be necessary for example if the data we are processing is incorrect, or you need us not to erase the data in order that you can retain it as evidence against legal claims etc.

6. Right to Data Portability

You have the right to ask us to transfer your personal data to another Data Controller where the processing is based upon a contract with you or with your consent and the data is processed by automated means.

7. Right to Object

You have the right to object to any processing which is bases upon our legitimate interests (or in the public interest).

8. Automated Decision Making

You have the right not to be subject to a decision based solely on automated means, for example in any automated scoring systems we might apply to learning.

Where you exercise this right, you have the right to have an individual to make this decision based upon the original facts and any other information that you might provide.

In the case of the above rights above numbered 2 through to 8, we will assess the request against any of our contractual or lawful obligations before responding. If we conclude that we must reject your request, we will provide you with a rationale. In all circumstances we will respond to a request within 30 days.

If you do not accept our decision, or if you have any other reason to be concerned about how we treat your personal data then you have the right to register a complaint regarding the use of your personal data to a supervisory authority at any time. The UK’s supervisory authority is the Information Commissioners Office details of which can be found at ico.org.uk.

In the case of the above rights above numbered 2, 3, 5 and 7 these rights may not apply when personal data is being archived for public interest reasons.

Our Use of Cookies

Cookies are simple ’text files’ which are downloaded onto your computer the first time that you visit a website and they can then be read by the website. Typically, they contain two pieces of information: a site name and unique user ID. Cookies are not programs and do not run anything on your computer.

Some cookies are sophisticated and might record things like your preferences for page layouts and colour schemes. They can also be used to store data for example for things like progress in a training course or information on what is in your ‘shopping cart’.

The possibilities are endless, and generally the role of cookies is beneficial, making your interaction with frequently-visited sites smoother – for no extra effort on your part.

By their nature cookies are recording behavioural data on your habits on websites and sharing this with the organisation, if you do not trust the organisation then you should be wary about the information being shared with them as they can influence what you see on the internet, for example through targeted advertising. As this can occur without warning we believe (and the law states) that you need to be aware when cookies are in use and provide your consent to their usage.

Cookies we use

Cookie: YSC
Domain: .youtube.com
Description: Youtube sets this cookie to track the views of embedded videos on Youtube pages.

Cookie: VISITOR_INFO1_LIVE
Domain: .youtube.com
Description: YouTube sets this cookie to measure bandwidth, determining whether the user gets the new or old player interface.
Cookie: VISITOR_PRIVACY_METADATA
Domain: .youtube.com
Description: YouTube sets this cookie to store the user’s cookie consent state for the current domain.
Cookie: hidecookiebanner
Description: Used by our cookie banner
Cookie: AWSALBTGCORS
Duration: Used by our online form tool, Typeform
Cookie: yt-remote-device-id
Domain: youtube.com
Description: YouTube sets this cookie to store the user’s video preferences using embedded YouTube videos.
Cookie: yt.innertube::requests
Domain: youtube.com
Description: YouTube sets this cookie to register a unique ID to store data on what videos from YouTube the user has seen.
Cookie: yt-remote-connected-devices
Domain: youtube.com
Description: YouTube sets this cookie to store the user’s video preferences using embedded YouTube videos.
Cookie: yt.innertube::nextId
Domain: youtube.com
Description: YouTube sets this cookie to register a unique ID to store data on what videos from YouTube the user has seen.
Cookie: AWSALBTG
Description: Used by our online form tool, Typeform

Contact us

Please contact us if you have any questions about this privacy statement or information we hold about you by emailing [email protected] or writing to:

Data Protection
c/o ProvePrivacy Ltd
73 Moor Close Road
Queensbury
Bradford
West Yorkshire
BD13 2EB