Privacy Notice

Universal Music UK Sound Foundation Privacy Notice

Introduction

Universal Music UK Sound Foundation and its trading subsidiary, MSFC Ltd (referred to together as “UMUKSF”) respect your privacy and are committed to protecting your personal data.

This privacy notice explains how UMUKSF collects and processes your personal data, and summarises your rights relating to your personal data.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This version was last updated on 6 January 2020. You can obtain previous versions by contacting us.

Who we are

Universal Music UK Sound Foundation (company number 05062390 and registered charity number 1104027) and its wholly owned trading subsidiary MSFC Ltd (company number 03287591) are the controllers in common of your personal data (collectively referred to as “UMUKSF”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your data rights, please contact our Chief Executive, Janie Orr, using the details set out below.

Contact details

Email address: umuksoundfoundation@umusic.com

Postal address:

Universal Music UK Sound Foundation

4 Pancras Square

London

N1C 4AG

Telephone number: 0203 932 6101

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data this includes first name, last name, title, date of birth or age, and gender.
• Contact Data includes addresses, email address and telephone numbers.
• Grant Data includes the information about your eligibility for a grant or bursary, your family, your financial circumstances and/or those of your family, the instruments you play, your education and musical attainment, and any other information supporting a grant or bursary application, how often you have applied, and the outcome of your grant or bursary application.
• Images Data includes photos that you provide to us or that we take at our events.
• Donation Data includes information about any donations that you make to us, such as the method of donation and any gift aid declaration you make.
• Technical Data includes data we collect when you use our website, such as your internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website, and information about your use of the website (such as the pages you visit, and the time you spend on them).
• Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Payment Data in some exceptional circumstances we pay grants directly to individuals, rather than paying the supplier of the relevant instrument. When we do this we may hold bank details for making the payment.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Grant Data to help us understand which parts of the country we receive the most applications from. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Some of the data we collect may be what is known as Special Category Personal Data, such as data about race or ethnicity, religious or philosophical beliefs, or health. We only collect Special Category Personal Data if you or your parent or referee or another person acting on your behalf choose to include it in the grant application or in correspondence with us.

If you do not provide data that we need

Where we need to collect personal data in order to administer a grant or bursary and you fail to provide that data when requested, we may not be able to make the grant or provide the bursary.

Where we are legally obliged to collect data (for instance, your address if you make a Gift Aid declaration) and you fail to provide it we may not be able to accept a donation or award a grant or bursary relating to the missing data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us data by submitting forms or corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for a grant;
• make a donation;
• subscribe to our newsletters or publications;
• request marketing to be sent to you; or
• give us feedback or let us know how you are getting on with your instrument.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
• Third parties. We may receive personal data about you from various third parties as set out below:
• Identity Data, Contact Data, Grant Data, and Special Category Data from:
  • anyone who includes you in a grant application;
  • your referee if your reference is provided separately from your application.
• Technical Data from analytics providers.

3. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where you have given your consent for us to do so.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use personal data

The table below describes the ways we use personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

In addition to the purposes explained above, we may also need to process Personal Data for the purpose of complying with the law or to take legal advice. Where we do so the basis for processing will generally be that it is necessary for our legitimate interests or for us to comply with legal obligations. If we need to process Special Category Personal Data for those purposes, the basis will usually depend on the specific circumstances.

Promoting our activities

We may send you promotional material about our charitable activities, or invite you to events we organise to promote our work.

We will only send promotional messages to your personal email address or by text if you have opted-in to receiving these from us.

We may send promotional messages by post or to a corporate email address unless you opt-out of receiving messages this way.

You can ask us to stop sending you promotional messages at any time by following the opt-out instructions on any marketing message sent to you or by contacting us at any time.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosures of your personal data

We never sell your data or allow other organisations to use it for their marketing or fundraising.

We may share personal data with the parties set out below for the following purposes:

• The suppliers and sub-contractors that provide services we use to carry out the activities explained in the table above, for example our IT infrastructure providers and professional advisors.
• Third parties that we are legally required to provide the data to, for example HM Revenue & Customs.
• Our regulators, to comply with their requirements (including voluntary requirements).
• Another charity, if we were to merge with that charity.

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 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.

Our website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.  When you leave our website we encourage you to read the privacy notice of every website you visit.

5. International transfers

We never transfer your personal data out of the EEA. However, we may use suppliers or sub-contractors that are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Countries outside the EEA do not all afford the same protection for personal data as countries within the EEA. However, whenever our use of a supplier or sub-contractor involves transferring your personal data out of the EEA, we ensure a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented:

• We use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield scheme which requires them to provide similar protection to personal data shared between the EEA and the US.
• Where neither of the safeguards above applies we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

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.

Normally we keep personal data for seven years after it is provided to us. We keep it for seven years, because this enables us to apply our policies on repeat grant applications, maintain our relationship with individual applicants during the period when they are typically in education, enable us to comply with legal requirements such as those relating to tax and financial records, and means that we have sufficient records to enable us to take legal advice if necessary during the normal limitation period for civil claims.

In some circumstances you can ask us to delete your data. Those circumstances are explained under the heading ‘Request erasure’ below.

In some circumstances we may 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.

8. Your legal rights

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 data 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 successfully 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 restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

9. Exercising your rights

To exercise your rights, please contact us using the contact details at the beginning of this privacy notice.

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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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 your personal data (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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.