At the British Academy of Songwriters, Composers and Authors trading as The Ivors Academy, and at the BASCA Trust trading as The Ivors Academy Trust (“Ivors Academy”, “Ivors Academy Trust”,“we,” “us” or “our”) we are committed to protecting and respecting your privacy.
The Ivors Academy and Ivors Academy Trust
The following information applies to our use of your personal information. The Ivors Academy Trust was established by The Ivors Academy and is a charity registered in England and Wales (1080325).
By continuing to use the Site, or by otherwise providing us with your personal information, you acknowledge our collection, storage and use of your personal information as described below.
The Ivors Academy is the controller and responsible for your personal information.
Name of DPO: Graham Davies
Email address: firstname.lastname@example.org
Postal address: Data Protection Officer, The Ivors Academy, The Ministry, 79-81 Borough Road, London SE1 1DN
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.
Informing us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
The Site, and our other communications with you, may contain links to other online or mobile sites. We are not responsible and accept no liability for the privacy practice or content of such sites
1. What information do we collect about you?
The term “personal information” or “personal data” means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:
We do not typically seek to collect, and we ask that you do not provide us with, any Special Categories of Personal Data about you. This would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we seek to collect any information about criminal convictions and offences. To the extent that you voluntarily provide us with any Special Categories of Personal Data about you (or any criminal conviction or offence information about you) – for example, because you have chosen to include such information within your member profile in the Directory area of the Site, or because we have specifically asked you for such information for a particular purpose (e.g. a diversity research study or because you are applying for a grant from the Ivors Academy Trust or one of its projects such as the Writer Producer Fund) – then we process that data with your explicit permission, which you give to us by providing that information to be used for that purpose. You may withdraw that permission at any time by contacting us.
Where we need to collect personal information by law, or under the terms of a contract that we have with you and you fail to provide that information when requested, we may not be able to perform the contract that we have or are trying to enter into with you. If so, we shall notify you if this is the case at the time.
2.How do we collect your personal information?
We use different methods to collect information from and about you, including through:
3. How and why do we use your personal information?
We shall only use your personal information when the law allows us to do so. Most commonly, we shall use your personal information in the following circumstances:
Please refer to the Glossary below to find out more about the types of lawful basis that we shall rely on to process your personal information.
We do not generally rely on consent as a legal basis for processing your personal information other than, if you agree to receive such communications, in relation to the sending of third-party direct marketing communications to you via email, text message or post. You have the right to withdraw consent to such marketing at any time by contacting us.
Purposes for using your personal information
We have set out below, in a table format, a description of all the ways that we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground that we are relying on to process your personal information where more than one ground has been set out in the table below.
|Purpose||Lawful basis for processing (including basis of legitimate interest)|
|To enrol you as a member of The Ivors Academy member, to renew your membership of The Ivors Academy, and for our general record-keeping and administration to ensure that we deliver to you the benefits of your membership as set out in the Membership area of the Site (including allowing you to add and update your member profile within the Directory on the Site, and to use other Site functionality)||(a) Performance of a contract with you (for The Ivors Academy members)
(b)Necessary for our legitimate interests (to ensure that The Ivors Academy operates effectively for the benefit of all British music writers)
|To manage our relationship with you, including:
• delivering relevant Site content, newsletters, event invitations, industry updates and/or surveys to you and to measure or understand the effectiveness of any such communications we serve to you; and/or
• for The Ivors Academy members, contacting you to provide constitutional notices under the Articles (e.g. for annual general meetings), or in accordance with our statutory duties
|(a) Performance of a contract with you (for The Ivors Academy members)
(b) Necessary to comply with a legal obligation (statutory duty)
(c) Necessary for our legitimate interests (to keep our records updated, to promote The Ivors Academy’s services and our role in the industry, to study and develop how people use our services, and to expand our business and to inform our marketing strategy)
|To process and deliver the services and products you request from us (e.g. to provide you with tickets and admission to events, or providing legal or financial advice), including:
• managing payments, fees and charges;
• sharing your information with third parties whose assistance may be required to deliver such services to you; and/or
• collecting and recovering money owed to us
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To publicise and report on The Ivors Academy’s events and initiatives and the achievements of our members (including by publishing event reviews and photo/video galleries from our events on the Site)||Necessary for our legitimate interests (in pursuit of our objects to support British music writers (through various lobbying activities) and to celebrate excellence through our awards ceremonies and other events)|
|To conduct general research about the British music industry (e.g. to research and highlight equality and diversity issues) and to publish such research in aggregated form (from which no individuals can be identified)||(a) Necessary for our legitimate interests (in pursuit of our objects to support and protect British music writers and to encourage new professional music writers)
(b) Consent (to the extent only that such research involves any processing of Special Categories of Personal Data, and with that data having been specifically volunteered by each individual for the particular research purpose)
|To assist overseas CMOs in identifying British music writers for whom they may be holding distributable revenue and distributing that revenue to those writers||Necessary for our legitimate interests (in pursuit of our objects to support British music writers and protecting copyright across the world)|
|To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To use data analytics to improve the Site, products, marketing, customer relationships and experiences||Necessary for our legitimate interests (to define types of customers for our services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop our services, to expand our business and to benefit you by providing interesting information)|
We strive to provide you with choices regarding certain uses of personal information, particularly around communications, where relevant. Please contact us if you would like to discuss those.
Information from us about our services and products
We may use your Identity, Contact, Profile, Technical, Usage, and Communications Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products and offers it may be relevant for us to contact you about.
You may receive communications from us if you are an Ivors Academy member, or you have previously requested services or information from us, or if you provided us with your details and asked to receive such communications and, in each case, you have not opted out of receiving those communications.
We will never share your personal information with any third party outside The Ivors Academy or The Ivors Academy Trust for marketing purposes, unless you have given your express prior opt-in consent to do so.
If, at any time, you would like us to stop using your personal information or to correct any factual inaccuracies, just contact us by email or post. Be sure to state “Opt-out” in the subject line, and to include your full name, username (if any) and email address in the message.
Please note that, for The Ivors Academy members, if you opt out from receiving general communications from us, we may still continue to contact you for the purpose of providing constitutional notices to you that are required under the Articles, or otherwise in accordance with our statutory duties to our members.
Change of purpose
We shall only use your personal information for the purposes for which we collected the information, unless we reasonably consider that we need to use such information for another reason and that reason is compatible with the original purpose. If you would like to get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal information for an unrelated purpose, we shall notify you and explain the legal basis on which we intend to rely.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, if and to the extent that this is required or permitted by law.
We may share your personal information with the external parties set out below (“External Third Parties”) for the purposes set out in the table in section 4 above:
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
Please also be aware that the Site is available to users across the world and that any user of the Site can access personal information about you to the extent made available on the Site.
4. Do we transfer your personal information internationally?
As some of our External Third Parties are based outside the European Economic Area (EEA), their processing of your personal information will involve a transfer of information outside the EEA. Whenever we transfer your personal data out of the EEA, we strive to ensure that a similar degree of protection is afforded to such information by ensuring that at least one of the following safeguards is implemented:
For further details of such safeguards, please see the European Commission’s website.
Please contact us if you would like further information on the specific mechanism used by us when transferring your personal information to External Third Parties out of the EEA.
Please note that the Site is available to users across the world, and so personal information about you to the extent made available on the Site may be accessible outside the EEA when the Site is used by persons outside the EEA. When you provide your personal information to us to be used on the Site (for example, any information added by you to your profile in the Directory on the Site, or to a message forum on the Site), then you do so on the understanding that territories outside the EEA may provide a lower standard of protection for your personal information and so there may not be adequate safeguards in place to protect your information. To the extent that, in those circumstances, your personal information on the Site is accessed outside the EEA, that is done with your explicit permission which you give to us by providing that information for use on the Site. You may withdraw that permission at any time by contacting us.
5. How do we protect your personal information?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. How long do we hold your personal information for?
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected such information, including for the purposes of satisfying any legal, accounting or reporting requirements.
By law we have to keep basic information about individuals who purchase services or products from us (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your personal information: please see Request erasure below for further information.
In some circumstances we may retain records containing personal information where the retention and processing of that information is necessary for archiving in the public interest or historical research purposes. For example, some of our archives from the mid-Twentieth Century are currently archived at the British Museum. In those circumstances, we may use this information indefinitely without further notice to you. Where information is retained and/or processed for those purposes, we will take technological and organisational steps to safeguard your rights and interests so that any information retained or used is the minimum necessary for those archiving or research purposes.
7. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal information:
To find out more about these rights, please see section 10 below and the ICO’s website (www.ico.org.uk).
If you wish to exercise any of those rights, please contact us.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person that has no right to receive such information. 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 shall notify you and keep you updated.
Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product/content and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of a contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, which may include:
Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation to which we are subject.
YOUR LEGAL RIGHTS
In certain circumstances, you have the following legal rights in relation to your personal information:
This version was last modified on the date noted below, and historic versions can be obtained by contacting us.