Privacy Policy
Updated September 2023
1. Introduction
Our privacy policy is our commitment to you as our musicians, supporters, donors and stakeholders. It explains what personal information we collect and how we use it.
We will respect the privacy of everyone who interacts with our organisation and ensure that all data is collected and processed lawfully.
Once you have read this Privacy Policy, if you have any questions on how we protect your privacy or deal with your data please contact us.
2. Our Details
The National Youth Orchestra of Great Britain (The National Youth Orchestra / NYO) is known as the “data controller” of any personal information you provide. This means that we determine the purposes for and the way in which your personal data is used. We are a registered charity (No. 290598) and company limited by guarantee (No. 01858278).
We can be contacted at:
The National Youth Orchestra
10 Great Turnstile
London
WC1V 7JU
Tel: 020 7189 8100
Email hello@nyo.org.uk
3. How we collect information about you
When you decide to interact with us, we may collect information in a number of ways:
- When you apply to take part in NYO activities
- When you attend an NYO performance or event
- When you make a donation or pledge to NYO
- When you sign up for our newsletter
- When you visit our website or social media pages
- When you sign up to our portal musicians.nyo.org.uk
- When you get in touch with a general enquiry or request, give feedback or make a complaint.
From time to time, we may also receive data about you from third parties. This could include artistic venues where you have seen NYO perform, Music Education Hubs, schools and other music education organisations.
We also work with reputable organisations who maintain and update lists of people who have opted-in to receive marketing and fundraising information from organisations like NYO.We expect high standards of data protection from our partners and suppliers and when they share your personal information with us, we insist that they have your permission to do so. You should check any privacy policy provided to you where you give your data to a third party.
4. What personal information we collect
NYO collects different kinds of information depending on how, where and when it was gathered. When you register an account through our website, sign up for our newsletter, make a donation, RSVP to an event or otherwise initiate communication with us, we will collect information directly from you which may include your:
- full name and title, address, date of birth, telephone number, email address
- payment details and Gift Aid status (if you make a donation)
- IP address (see our separate Cookies Policy for further information on electronic tracking)
- access needs or dietary requirements
This data is collected so that we can accurately keep a record of your interaction with NYO, process your donation/membership/event ticket and communicate with you (or not) appropriately according to your wishes.
If you volunteer for us or apply for a job with us, we will collect information necessary for us to process these applications and assess your suitability (which may include things like employment status, qualifications and previous experience, as well as any unspent criminal convictions or pending court cases you may have).
If you apply to take part in NYO activities, we will collect a range of information relevant to the selection process and our statistical reporting. This may include:
information about your education and musical training
demographic information including financial background and protected characteristics such as ethnicity, sex, gender identity and disability
This is to help ensure we are targeting our charitable resources where they are most needed; we are required to report this data in an anonymised format to our funders.
As part of our application processes for NYO activities, we ask young people to provide contact details for their parents/guardians and for their school and instrumental teachers and Music Education Hub so that we can communicate with them about the young person’s involvement in NYO. We ask applicants to ensure that they have permission to share these details with us.
When a young person has been invited to take part in NYO activities, we collect medical, health and safeguarding information so that we can ensure their safety whilst in the care of NYO. Sensitive information is handled with great care, with access restricted to those directly involved in providing pastoral support to the young people.
5. How we use your information
We will use your personal information to:
- administer NYO activities;
- provide you with the information you asked for;
- administer your donation or support your fundraising, including processing Gift Aid;
- keep a record of your relationship with us;
- respond to or fulfil any requests, complaints or queries you make to us;
- understand how we can improve our services by conducting analysis and market research;
- manage our events;
- further our charitable objectives;
- register, administer and personalise online accounts when you sign up through our websites;
- send you correspondence and communicate with you;
- administer our websites and to troubleshoot, perform data analysis, research, generate statistics and surveys related to our technical systems;
- display content to you in a way appropriate to the device you are using (for example if you are viewing content on a mobile device or a computer);
- generate reports on our work, services and events;
- safeguard young people, our staff and volunteers;
- conduct due diligence and ethical screening;
- monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
- process your application for a job or volunteering position;
- audit and administer our accounts;
- meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
- carry out fraud prevention and money laundering checks;
- undertake credit risk reduction activities; and/or
- establish, defend or enforce legal claims.
6. How we use your information to tell you about our work
Our marketing and fundraising communications include information about NYO activities, events and campaigns, including requests for donations or other support. Occasionally, we may include information from partner organisations or organisations who support us in these communications.
For email communication, we operate an ‘opt-in only’ policy. This means that we will only send email marketing communications to those that have explicitly stated that they are happy for us to do so.
We also communicate with existing and potential supporters through the post. If you choose to respond to an appeal by donating to NYO, you will be given the opportunity to opt-out of any further contact. If you choose not to opt-out, we may contact you again with carefully-targeted information about NYO’s activities and opportunities to support or otherwise engage with the organisation. Direct Mail fundraising is a highly regulated field and NYO engages closely with guidance from the Fundraising Regulator, ICO and Institute of Fundraising to ensure that our activities are in line with the law and good fundraising practice.
You can change your mind about your preferences at any time by contacting us.
We may use information we hold about you, for example the record of your previous donations to and/or relationship with us, your location and demographics, as well as the type of activity you have been involved with, to tailor our communications with you about future activities. If you have opted in for email communication, we may use your pseudonymised details to show you advertising on social media platforms such as Facebook and Instagram or via other third party advertising that may appear on other websites you use. The information shared with these platforms is pseudonymised to protect your personal data.
If you’ve decided you don’t want to be contacted for marketing purposes, we may still need to contact you for administrative purposes. This may include where we are processing a donation you’ve made and any related Gift Aid, thanking you for a donation, or giving you information about your participation in our activities.
7. Building profiles of supporters
NYO’s work is only possible thanks to the generosity of our supporters – so it’s vital that our fundraising efforts are as effective as they can be. By developing a better understanding of our supporters through researching them using publicly available sources we can tailor and target our fundraising events and communications to those most likely to be interested in them. This allows us to be more efficient and cost-effective with our resources, and also reduces the risk of someone receiving information that they might find irrelevant or intrusive.
What information do we collect?
After taking a supporter’s communications preferences into account, we may use information we hold on them to research their potential to be a significant donor to NYO and collect additional details relating to their employment and any philanthropic activity.
Which information do we use?
We may use existing data from NYO’s own database and combine this with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of NYO. We only use reputable sources, where someone would expect their information may be read by the public. We avoid any data that we believe has not been lawfully or ethically obtained, and we do not use information sources which have not been broadcast or made public.
You are in control of your data and you’re free at any time to opt out of this activity. To find out more, please contact us.
8. Legal basis for processing
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.
Consent
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
Legal obligation
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a contract
We have a basis to use your personal information where we are entering into (or preparing to enter into) a contract with you or performing our obligations under that contract. Examples of this would be if you are signing up for a regular giving scheme, applying for or accepting a place on NYO activities, or applying to work/volunteer with us.
Vital interests
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance if there were to be a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
Legitimate interests
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
Some examples where we are relying on legitimate interests are:
- analysis and profiling of our supporters using personal information we already hold;
- updating your address using third party sources if you have moved house (please see the “Keeping your information up to date” section below for more on this).
- sending marketing and fundraising information to existing and potential supporters by post;
- use of personal information when we are monitoring use of our website for technical purposes;
- use of personal information to administer, review and keep an internal record of the people we work with, including supporters and participants in NYO activities;
- maintaining a database of professional contacts and suppliers (including potential suppliers).
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
9. How we keep your information safe
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details. We will do our best to protect your personal information. However, we cannot guarantee the security of your data before it reaches us, and any transmission is therefore at your own risk. Once we have received your information, we use strict procedures and security features to prevent unauthorised access).
Our CRM is Salesforce. This centralised, secure database ensures we can keep an accurate record of our interaction with individuals and their communication preferences. We use a number of associated Salesforce products and software integrations.
We use a range of other secure systems which may store and process personal data for specific purposes, including the management of projects, processing financial information and communicating with individuals.
Credit and Debit Card payments are processed by our secure payment processors Findock and Stripe. Direct Debits are processed by Findock and Smart Debit. Payment card and banking details are stored in an encrypted form within these systems.
Most of our data storage and transfer solutions are based in countries within the EEA; however some companies we work with may have servers based outside of the EEA. All data is stored and transferred in accordance with current Data Protection regulations through contract. Where data is sent outside of the EEA, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.
10. How long we keep your information for
We take into account various criteria when determining the appropriate retention period for personal data including:
- the purposes for which we process your personal data and how long we need to keep the data to achieve these purposes;
- how long personal data is likely to remain accurate and up-to-date;
- for how long the personal data might be relevant to possible future legal claims;
- any applicable legal, accounting, reporting or regulatory requirements which specify how long certain records must be kept.
We will keep data for only as long as it makes sense to do.
We retain basic information about participants in NYO activities indefinitely for statistical and archival purposes. Sensitive information about individual participants (including health and welfare information) is only retained whilst the individual is actively involved in NYO activities and for up to one year after their last interaction.
We keep data about supporters and donors under active review. If we haven’t heard from a supporter in two years, we may contact them to check if they still wish to receive information from NYO. If we do not hear back, we will no longer attempt to keep in contact.
To ensure that we do not contact individuals who have requested not to be contacted, it is important that we keep an adequate record of their request. This means that we cannot completely delete data from our systems. Instead, we will minimise the data that we hold (usually to name and last known address only).
Legally, we need to keep some records, especially relating to financial transactions and Gift Aid, for 7 years.
11. Sharing your information with others
We will never share your data with any third party for their own marketing or fundraising purposes.
We may need to share your information with a small number of trusted partners for the purposes outlined under “How we use your data”. Where we use third parties, we require them to adhere to appropriate controls to protect personal information. They will not be allowed to sell your data or compromise its security in any way.
12. Your rights
Under UK data protection law, you have rights over personal information that we hold about you. We’ve summarised these below:
Right to access your personal information
If you would like to see the personal data that we hold about you please contact us.
Right to have your inaccurate personal information corrected
If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and correct any inaccuracies immediately.
Right to restrict use of your personal information
Please let us know as soon as possible if:
- some information we hold on you isn’t right
- we’re not lawfully allowed to use it
- you need us to retain your information in order for you to establish, exercise or defend a legal claim; or
- you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.
Right to erasure of your personal information
If you would like us to delete some or all of your personal information, please let us know. If we are unable to delete your information, we will explain why this is the case.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object to the use of your personal information
If we are processing your personal information based on our legitimate interests or for archival/statistical purposes, you have a right to object to our use of your information.
If we are processing your personal information for direct marketing purposes, and you wish to object, we will stop processing your information for these purposes immediately.
If you want to exercise any of the above rights, please contact us.
We may be required to ask you for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
For more information on data protection, we recommend you consult the guidance published by the UK’s Information Commissioner’s Office (ICO).
13. Keeping your information up to date
We would really appreciate it if you can let us know if your contact details change.
We may use information from external sources such as the Post Office national Change of Address database and/or the public electoral roll to identify when we think you have changed address so that we can update our records and stay in touch. We only use sources where we are confident that you’ve been informed of how your information may be shared and used.
We do this so we can continue to contact you where you have chosen to receive marketing messages from us and contact you if we need to make you aware of changes to our terms or assist you with problems with donations.
This activity also prevents us from having duplicate records and out of date preferences, so that we don’t contact you when you’ve asked us not to.
We’re committed to putting you in control of your data and you’re free at any time to opt out from this activity. To find out more, please contact us.
14. Internal Privacy Policy
If you are a member of staff, volunteer, supplier or contractor and want to know more about how we store and process your data, please contact us for a copy of our Internal Privacy Policy.
15. Changes to this policy
We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on the NYO website or by contacting you directly.
16. Complaints
If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve. You can find out more and read our Complaints Policy on our website.
You also have the right to lodge a complaint about any use of your information with the Information Commissioner’s Office, the UK data protection regulator.