Last Updated: 6 September 2018
Free Word is committed to protecting your personal information and being transparent about the information we hold about you.
Using personal information allows us to provide our customers – website and venue visitors, residents and associates – with a secure and welcoming venue and workplace, and relevant and timely information about the work that we do. It enables us to gain a better understanding of your interests and experiences with us, and therefore to develop and improve the events, facilities and services we provide.
Personal information also helps us to engage with potential donors and supporters, fulfil our responsibilities to our Trustees and funders, and to be an effective partner, collaborator, customer and employer.
The purpose of this policy
The purpose of this policy is to give you a clear explanation of how we collect and use the information we get from you directly and from third parties. This policy applies to our customers, visitors, donors and suppliers; we have separate notices available for others whose data we process, including job and programme applicants, employees, workers, consultants and Trustees.
We use your information in accordance with all applicable laws concerning the protection of personal information.
This policy explains:
- Who we are
- Types of information we may collect about you
- How we may collect and use that information
- When situations we may disclose your details to third parties
- How we keep your personal information secure, how we maintain it, and your rights to be able to access it
Free Word is the data controller for your personal data. If you have any queries about this policy, please contact the data lead at Free Word, Free Word Centre, 60 Farringdon Road, London EC1R 3GA or by email email@example.com
For our terms and conditions of sale and website use, please click here.
1. Who we are
Free Word is an arts venue based in Farringdon, London which programmes cultural events and performances for the general public, hires out event spaces and meeting rooms, and provides workspace for a number of resident and associate organisations who support and promote reading, writing and free expression all over the world.
We are a registered charity (number 1128059) and we are also a company limited by guarantee (06691251) registered in England and Wales. We receive regular funding from Arts Council England and from Norwegian free expression foundation Fritt Ord and are also supported by various trusts, foundations, individual donors and supporters
2. Types of information we may collect about you
Personal information means any information about an individual from which the person can be identified. It does not include data where the individuals cannot be identified ie anonymised data, which may be summarised as statistics (aggregated).
We only collect information that’s necessary to carry out our business or to deliver our charitable objectives.
We may collect, use, store and transfer different types of personal information about you which we have categorised below:
- Identity data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender
- Contact data includes addresses, email addresses and telephone numbers
- Payment method data includes bank account and payment card details
- Transaction data includes details about payments to and from you, and other details of products and services you have purchased from us or we have purchased from you
- Technical data includes internet protocol (IP) address, your login data, 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
- Profile data includes your username and password, purchases or orders or donations made by you, your interests, feedback and survey responses
- Usage data includes information about how you use our website, products and services
- Communications data includes your preferences in receiving marketing from us and our third parties and your preferred communication methods. This also includes us making a note of conversations we have had with you in person and /or communications you sent to us. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.
- Security data includes information on security passes issued to building residents and visitors and CCTV images of visitors
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 information 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 usage data to calculate the percentage of users accessing specific website content.
We don’t collect any Special Categories of Personal Data about you (this includes 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), except anonymously to use in aggregated data, and in the case of recording some health information related to accidents, incidents and near misses at our venue (see section 3 legal obligation). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information 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 a ticket). 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.
Users under 18
We understand that people aged under 18 may use our website. To request to see our safeguarding policy, please contact firstname.lastname@example.org
3. How we may collect and use the information
We collect information about you in a number of ways:
Information you give us
When you create an account on our website, buy tickets, sign up to our mailing list, request marketing materials, make an enquiry, give us feedback, make a donation, visit our venue or enter into a contract with us to supply services, we will store the personal information you give us such as your name, email address, postal address, telephone number, card or bank account details, interests and communications preferences. We will also keep a record of your purchases and donations. We may collect any of this information from a person working on your behalf with your consent, such as a personal assistant.
Information about your interactions with us
As you interact with us, we may automatically collect usage data about your use of our website, products and services, and technical data about your equipment, browsers and systems. We collect this data by using cookies and other similar technologies.
When we send you an email or postal mailing we store a record of this, and in the case of emails we may keep a record of which ones you have opened and which links you have clicked on.
Information from third parties
We sometimes receive information about you from third parties.
For example, we may use search engines such as Google and websites with databases such as Companies House and the Charity Commission to compile general information about you, for example your work history, trusteeships held by you, your political preferences and philanthropic activities, compiled used publicly available information.
Depending on your settings or the privacy policies for social media services like Facebook, Instagram or Twitter, you may give us permission to access information from those accounts or services, such as your behaviour on these services and across our site. The majority of this behaviour is anonymised.
There are four legal bases under which we use the information we have collected about you.
For contractual purposes
- Registering you as a new booker, processing your ticket booking, confirming the booking, and sending you practical information about the event before it takes place
- Responding to meeting room and event space hire enquiries, processing your hire booking, confirming the booking, and sending you practical information before and after the booking
- Processing your application to be an Associate, setting you up as an Associate, and providing the Associate service for you
- Engaging you as a supplier and using your services
For our legitimate organisational interests
We rely on our legitimate organisational interests:
- If you have booked for an event or hired a space at Free Word in the past, have provided us with your email address and have not opted out of email communications from us, to contact you after the event about your booking and your overall experience at Free Word (to develop and improve our services)
- If you have booked for an event or hired a space at Free Word in the past, have provided us with your email address and have not opted out of email communications from us, to contact you with information on upcoming events and activities or hire opportunities at Free Word (to market our similar events and activities to existing customers)
- To analyse hirer and audience booking patterns, behaviour and interests (to develop and improve our services including targeting our marketing effectively)
- To gather and send statistics to Trustees, funders and other key stakeholders (to fulfil our reporting requirements; statistics are usually anonymised)
- To research and build profiles of potential donors, using publicly available information (to develop our fundraising capacity in order to provide our services)
- To contact potential donors by post with information on how to support us or invitations to visit us (to develop our fundraising capacity in order to provide our services)
- To track which bookers actually attended an event (to fulfil our reporting requirements and develop and improve our services)
- To record the number of people in the building (to provide our services)
- To film or photograph event attendees (to market our events and develop and improve our services)
- If you are a member of staff for one of our Resident or Associate organisations, to send you information related to working in the building (to provide our services)
- To respond to an enquiry you have made, feedback you have given or a complaint you have raised (to provide, develop and improve our services)
- To maintain information on those who have used our services or suppliers we have engaged as a reference tool (to provide, develop and improve our services)
- To update you on changes to our policies and services (to develop and improve our services)
If you feel that our legitimate interests are not appropriate, you have the right to object to our processing of your data on this basis.
If attending an event at Free Word and you wish to object to being filmed or photographed, please notify member of Free Word staff.
Otherwise, please contact email@example.com to raise an objection.
With your explicit consent
- To send you information via email with news, events and Free Word offers, including information on partner events and links to blogs and articles related to these events
- Sending you information via email about ways to support Free Word
- Sharing your contact data with our Resident organisations
- Sharing your contact data with an events organiser in relation to a specific event
You may opt out of receiving our email marketing communications at any time and will be given the opportunity to do so whenever we email you.
Otherwise, please contact firstname.lastname@example.org if you wish to withdraw consent at any time to any of the above.
Where we have a legal obligation
- To record the number and location of people in the building, to ensure the safety and security of all building users. This includes recording CCTV images to comply with licensing requirements and to assist with crime prevention and detection
- To keep records of accidents, injuries and near misses, to comply with health and safety legislation
- To keep records of financial transactions
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 purpose which we believe is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at email@example.com
If we do need to use your personal data for a purpose unrelated to the reason we collected the data, we will let you know and explain the legal basis for the new processing.
4. When we may disclose your details to third parties
In certain situations, we may disclose your personal information to third parties: For example:
- To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software provider Spektrix, our room booking software provider Artifax, our direct debit service provider Smartdebit, Arts Council England’s selected audience data analyst The Audience Agency). In these cases we require that these third parties comply strictly with our instructions and with data protection laws, for example around security of personal data.
- Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
- To our Resident organisations or to specific named partners or visiting organisations whose events you have booked for. In these cases we will always ask for your explicit consent before doing so.
Free Word will never share, sell, rent or trade your personal information to any third parties for marketing purposes without your prior consent.
6. How we keep your personal information secure, how we maintain it, and your rights to be able to access it
We are committed to protecting the personal information you entrust to us. We adopt appropriate technologies and policies so that the information we have about you is protected from unauthorised access and improper use, eg your online account is encrypted and our own network is protected.
As part of the services offered to you through our website, the personal information you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of the computer servers used to host the website or data backed up in cloud services are located in a country outside of the EEA
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
- 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; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Despite all our precautions, no data transmission over the internet is 100% secure.
So, we cannot guarantee the security of any information which you disclose to us, and we therefore want to draw your attention to the fact that you do so at your own risk.
Maintaining your personal information
We will keep your information only for as long as is reasonably necessary for the purposes we collected if for, including for the purposes of satisfying any legal, accounting or reporting requirements.
We will not keep more information than we need. To decide the appropriate retention period for personal data, we consider
- the purposes for which we process your data and whether we could achieve these purposes in other ways
- the amount, nature and sensitivity of the data
- the potential risk of harm from unauthorised use or disclosure of the data
- legal requirements which may apply
In some situations we may anonymise your personal data, so that it can no longer be associated with you, and then keep it for research or statistical purposes – in which case we may use this information indefinitely without further notice to you.
Any objections you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
In some cases you can ask us to delete your data: please see below for further information.
Your rights to access your personal information
You should find it easy to access and amend the personal information that we hold on you, or request that we stop contacting you.
It’s your data and we want to make sure you feel in control of it; and of course you have rights under data protection laws in relation to your personal data.
These include the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Withdraw consent
You can see more about these rights at:
If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (ICO).
If you wish to exercise any of the rights set out above, please email us at email@example.com
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 or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive.
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.
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.
If you are a customer who has an online account with us, you can amend your personal details and email contact preferences at any time. Simply sign in on our website to access your account and amend your preferences here.
Or, if you prefer, you can contact us by phoning the reception desk on 020 7324 2570, emailing firstname.lastname@example.org , or writing to us at the address below.
Every email we send to an account holder will include details on how to change your communications preferences or unsubscribe from future communications.
Data Lead, Free Word, Free Word Centre, 60 Farringdon Road, London EC1R 3GA