Privacy Policy

Who we are

About us Attracting over 100,000 people each year, Pitlochry Festival Theatre (PFT) is a unique, theatrical phenomenon in the heart of Perthshire.

As a charity we rely on our supporters, team members and many other people who become involved with us to be able to deliver this vision.

Our details Pitlochry Festival Theatre is a charitable company limited by guarantee Company number: SC029243

Scottish Charity number: SC013055

ICO registration number: ZA266352

Contacting us If you would like to make an enquiry about data protection, update the information we hold about you, request or opt out of receiving marketing communications from us or change the way we process your information, you can let us know in the following ways:

Email: boxoffice@PitlochryFestivalTheatre.com

Post: Supporter Care, Pitlochry Festival Theatre, Port-na-Craig, PH16 5DR.

Phone: 01796 484626

Online: Log in to your account online and update your contact details and preferences.

If you would like to make a request to access the information we hold about you (see ‘Your rights’ section at the end of this document). To raise a concern about how your personal information has been used; please write to us at:

Post: Supporter Care, Pitlochry Festival Theatre, Port-na-Craig, PH16 5DR

Emailboxoffice@PitlochryFestivalTheatre.com

You are entitled to raise a concern to the Information Commissioner’s Office (ICO) without first referring your concern to us. See here for more information

 

What information we collect about you

Personal information is collected directly from you when you interact with Pitlochry Festival Theatre, for example making a donation, purchasing a ticket or gift, sending or receiving an email, making an enquiry, visiting our websites, applying for a role to work or volunteer with us, participating in an event or when signing up to a campaign or for our newsletter. Information may be collected in person, over the phone, through our websites, social media or from something you’ve posted to us.

The information we hold will typically include some of, or all of; your name, postal and email addresses, your phone number, and may include information like your date of birth and your bank details if you are supporting us financially. We may also receive information about you from other sources (including public sources). This is explained in the ‘How we might use your information’ section below.

 

How we might use your information if you are a supporter who receives communications, including fundraising and marketing materials, or makes donations

We may use your information for administration purposes.

Processing your donation or purchase

When you make a donation or other payment to Pitlochry Festival Theatre, we will use your payment and contact details, payment amount, date and time of payment; to process that payment and take any follow-up administrative action needed (for example, sending a receipt).

If you choose to include Gift Aid with a donation to us, then we will also ask for your address and UK taxpayer status as this information is required by law. You can read more about how Gift Aid works here. This information is needed for us to fulfil our obligations under tax (sections 413 to 430 Income Tax Act 2007) and charity law. Information associated with Gift Aid declarations must be retained for 7 years. This information will be shared with HMRC for tax regulation purposes and may also be shared with the Scottish Fundraising Standards Panel and The Scottish Charity Regulator OSCR) in the event of an enquiry or investigation.

Responding to enquiries If you contact us with a question, comment, compliment or complaint then we will keep a record of this correspondence and any associated documents so that we have the information available in the event of a follow-up, dispute or investigation.

Notifying you of changes to policies If we make significant changes to our policies which may affect you, we will use your contact details to inform you of the changes.

Requesting information if you are attending our events

If you participate in an event that we have organised, we may ask you to provide information to make sure we can manage the event safely and efficiently. We may also ask you for details of any accessibility need which you may have, so that we ensure our event is inclusive, in line with the provisions of the Equality Act 2010.

If you participate in an event organised by an external party or make a donation through a processor like JustGiving, then your information may be passed to us by the processor. We would only use it for marketing purposes if you have given your consent for this.

We may use your information to invite you to become involved with us in new ways, raise funds and grow our supporter base.

Sharing marketing, fundraising and other communications with you

Marketing, fundraising and other communications that we might share with you include information about our activities and their impact, our news, events and fundraising appeals, and other ways you can become involved with us.

Where you have provided your postal address or telephone number we may send this information to you by post or by calling your telephone unless you have asked us not to. We may also email you this information or send by SMS if you have agreed for us to do so.

You can let us know at any time, if you’d prefer to change how we share this information with you or stop it altogether. Simply use the details we’ve provided in the ‘Contacting us’ section to let us know your preferences. If you receive our e-newsletters, you can also use the unsubscribe link in the emails we send.

We will keep your personal information for no longer than is necessary for the purposes for which it is processed (in accordance with our internal policies/retention policy). If you ask us not to contact you, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

Targeting our communications and researching our supporters

We have a duty to make sure that we’re spending your donations wisely, and that means doing some research and analysis to inform our decisions. We want to send the most effective messages that we can in the most efficient way possible. In order to work out who to contact, what to say and when to get in touch, we carry out the following activities:

Analysing how emails are opened and read – we sometimes track emails which we have sent to you to see which messages have the highest response rates and whether there are messages that resonate with particular groups of people. We do this by logging whether emails we send have been opened, deleted and interacted with (for example, by clicking on links within the emails). Although we only use this information to look at general patterns, it is still personal information because it is linked to your email address.

Segmentation – this is where we analyse information such as postcodes of supporters, and whether donations have been given regularly. This helps us to tailor appropriate communications to you, as well as improve your experience as a Pitlochry Festival Theatre supporter.

Analysing our supporter base to send different communications to people who might choose to give higher donations – we undertake in-house research and occasionally engage other organisations such as Experian and Factary to help us identify people who may be able to support us with a larger gift; using information you have given us and publicly available records such as the electoral roll, land records, ‘rich lists’, Who’s Who publications and Companies House records. We may also collect information on your interests, for example board memberships, hobbies, or articles about you in newspapers or magazines. We use this information to tailor our communication with you and invite potential supporters to meetings, groups and events which may be of interest to them.

Here are some examples of the sources we might use…

  • Public registers (e.g Electoral roll, Companies House, Land records,)
  • Articles about you in newspapers or magazines (e.g. ‘rich lists’, Who’s Who publications)
  • Subscription services (e.g. Directory of Social Change, opencharities.org, Trustfunding.org, New Trust List service)
  • Internet search engine results
  • Wikipedia
  • Open postings on social media sites such as LinkedIn, Twitter and Facebook
  • The Charity Commission website
  • Local Authority and government websites
  • Property sites (e.g. Rightmove)
  • Deaths and marriages registers (e.g. Mortascreen or  National Deceased Register)
  • Google maps
  • Company websites
  • Public blogs
  • Aggregator sites that collate info (e.g. 192.com, Duedil, Directory Enquiries)
  • Public records of other charities or organisations you might be affiliated with (e.g.if you are listed as patrons of the royal ballet)
  • Any websites you manage or about you
  • Family tree websites (e.g. ancestory.co.uk, Thepeerage.com)
  • Professional registers (e.g. NHS employees (doctors), Academics, Solicitors, Accountants, Chartered Surveyors, House of Lords Register of Interests, City of London Directory and Livery Companies Guide, Office of the Scottish Charity Register (OSCR), ACF (Association of Charitable Foundations), Smee & Ford)

Finding other people like you who might like to hear from us – We may use the email address you give us to help find more people like you, so that we can grow our supporter base through our online channels. We use third party services to do this which you are likely to be familiar with, including Google, Facebook and Twitter.

When might we add information to your record that you may not have given to us directly?

We may also add information or update your record with us, from publicly available sources. This may include your telephone number, address related information, information from death registers, age or the information mentioned in the section above ‘Targeting our communications and researching our supporters’. We use this information to tailor our communications with you and send you more appropriate information.

These activities form a vital part of keeping support for our work going. You can request more information on these activities, or change your preferences, by using the information in the ‘Contacting us’ section at the beginning of this document.

We may use your information to enforce and comply with the law

As with all charities, we ensure that our activities comply with the law. Therefore we may need to share or use your personal information if we are required to do so by law (for example; in response to a warrant or court order) and we may use information from other sources for the purposes of fraud prevention, for example to comply with money laundering regulations, or to protect people’s rights, property or safety.

If certain levels of donation are made, the Fundraising Regulator’s Code of Fundraising Practice requires us, and all charities in the UK, to perform checks. More details can be found at https://www.fundraisingregulator.org.uk/11-0-major-donors/

How we might use your information if you are applying for a role within Pitlochry Festival Theatre

Your CV, covering letter and application form for any position with Pitlochry Festival Theatre will be used during the recruitment process to short-list suitable candidates who will be invited to proceed to the interview stage, and to select the final candidate that the role will be offered to.

We sometimes use third-party job application platforms to publish and receive applications for roles at Pitlochry Festival Theatre. When you apply through these portals the organisation’s privacy information will be available to you. We only work alongside other organisations in this way if we are satisfied that they will keep your information safely and use it only in the same legal ways that we would.

During the recruitment process, we will perform some checks on your identity, your right to work in the UK, your eligibility to work with vulnerable people and your past employment references.

If your application is successful, this information will then form part of your personnel file.

We delete the personal information of unsuccessful applications two years after the application process ends in case there are follow-up queries about the process, or should further opportunities arise, unless a candidate requests that we keep their details for longer. Statistical information like ethnicity, sexuality and disability is kept to ensure that our recruitment processes are inclusive and not discriminatory, but this is completely anonymised.

If we are required by law to share your information, (for example; in response to a warrant or court order), we will do so.

How we might use your information if you have visited our websites

When you visit our website we may automatically collect technical information about your session including the Internet Protocol (IP) address that connects your device to the internet, the type of device you use, your browser, operating system, whether you made a purchase and from where you have arrived at our site. We do not link this information to anything that identifies individuals. This information enables us to analyse how the website is used, where improvements can be made and to report to funding and public bodies.

We use essential and non-essential cookies on our website. A cookie is a small text file of letters and numbers that gets put onto your computer when you visit a website. This allows the site to distinguish you from other users. Essential cookies are required to login or to purchase items from our website. Non-essential cookies are used to track how you use and interact with our website and for analytical purposes and to monitor the efficacy of digital advertising. Cookies are not linked to information that allows us to identify individuals.

Who Pitlochry Festival Theatre shares personal information with and why

We promise to make all reasonable efforts to keep your details secure and will only share them with suppliers or professional agents working on our behalf, for example of we use professional organisations who send out our fundraising or marketing materials, or telephone agencies making fundraising calls on our behalf.  Where we decide to work with such partners, we will carefully select these partners and will only share information with them if we are confident that they will protect it, and we have a contract in place with them that assures this.

We will never share your details with other organisations to use for their own purposes, other than where we are required to by law. Pitlochry Festival Theatre will not, under any circumstances, share with or sell your personal information to any third party for marketing purposes and you will not receive offers from other companies or organisations as a result of giving your details to us.

Certain third party organisations collect information on our behalf as well as for their own use. We may receive your personal details from other organisations for our marketing purposes where you have consented for this information to be shared, for example Just Giving and Virgin Money Giving. These organisations have their own data protection and privacy policies and we urge you to make yourself aware of these before signing up.

https://www.justgiving.com/info/privacy-policy-versions/privacy-policy-v20

https://uk.virginmoneygiving.com/giving/terms/privacy-policy.jsp

We may also use other companies to provide services and process your personal information on our behalf, including delivering postal mail, making telephone calls to our supporters, sending emails, sending SMS messages, processing credit card payments and analyse our supporter information as outlined above, to help us offer you communications that are most appropriate to you and your interests. In some cases, our suppliers may use software which analyses publicly available information (as outlined above) to build up a picture about you based on the factors set out in the ‘Targeting our communications and researching our supporters’ section.

Transfer of personal information outside of the EEA

Pitlochry Festival Theatre is aware that countries outside the European Economic Area have differing approaches to data privacy laws, and that enforcement may not be as robust as it is within Europe’s borders.

The transfer of your information is governed by EU model contract clauses which set out how the organisation outside the EEA is required to protect your privacy rights by adhering to European data protection standards.

We will only work with organisations who process personal information in the USA which have verified their data processing standards meet the EU-US Privacy Shield, which sets out clear safeguards and transparency responsibilities for US-based organisations processing personal information from EU citizens.

Information security

Pitlochry Festival Theatre takes the care of your information seriously and protects your personal information in a range of ways including secure servers, firewalls and SSL encryption. We follow payment card industry (PCI) security compliance requirements when processing credit card payments. We operate a policy of restricted, password controlled, access to any of your information which is stored on our systems.

Children and Vulnerable Adults’ information

We collect information for our Youth Theatre and other young participants, but otherwise do not actively collect information from children or Vulnerable Adults (under 18s). Where appropriate, we will always ask for consent from a parent, guardian, Power of Attorney or next of kin to collect information about children or vulnerable adults. We appreciate that our supporters are of all ages. All Pitlochry Festival Theatre events will have clear rules on whether or not children can take part, and the collection of information will be managed in accordance with each individual event, with appropriate safeguards in place.

Your rights

How to request copies all of the information we hold about you, otherwise known as a Subject Access Request You have the right to ask for a copy of all of the information related to you that we are processing.

You can request this by completing the ‘Contact us’ section on this website. 

How to ask us to amend or delete your information

If you information is incorrect, out of date or if there is no longer justification for us to hold it, you can ask for it to be updated, removed or blocked from our use.

How to request your information so that you can use it elsewhere

You can ask for a copy of any personal information that you have provided to us in the past. We will provide it in a clear and easy to follow format. Please note that if you ask for the material to be sent electronically but prefer not to use a secure file transfer, Pitlochry Festival Theatre cannot be held responsible for the security risk to your information as it travels across the Internet. 

Our legal bases for using your personal information 

The regulations provide six lawful bases under which we may process your data. Typically, there are three bases under which we will process your data:

Contract purposes

When you make a purchase from us or make a donation to us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example we may need to contact you by email or telephone in the case of cancellation of a show, or in the case of problems with your payment.

Legitimate business interests

In certain situations we collect and process your personal data for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.

With your explicit consent

For any situations where other bases are not appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.

When you register online, sign up to a newsletter or opt-in to our communications using any of our forms (eg. a donation form or online form) or in person, then you are giving us your consent to send you marketing communications and fundraising materials by the methods you have chosen (e.g. email or post). We will never send you marketing communications without your consent, and you can withdraw your consent at any time.

If you have provided us with your postal or telephone contact details, but haven’t specifically opted-in to receive our communications (for example, making a donation by post), then we will carry out an assessment of whether it would be fair and reasonable to use them to send marketing and fundraising information to you without your explicit consent (i.e. it is in the interests of our aims as a charity and will not cause undue prejudice to you). This is called a “legitimate interests assessment”. You can opt out of our marketing and fundraising communications at any time if you don’t want to receive them.

We will ensure we have a legal basis to use your personal information for the other purposes mentioned in this policy (usually with your consent, further to a legitimate interests assessment, or because the use of your data is necessary to comply with a legal obligation).”

You can find out more about your data protection rights on the Information Commissioner’s Office (ICO) website here.

You can find out more about data protection law here: Data Protection Act 1998 until the 25th May 2018 General Data Protection Regulation 2018 from 25th May 2018

This policy was last updated in May 2018. Version 1.6

Pitlochry Festival Theatre reserves the right to make alterations from time to time. Please check this website from time to time for the latest version.

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Cookie Policy

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns.

Our system will issue cookies to your computer when you log on to this website. Cookies make it easier for you to log on to and use this website during future visits. The website also uses cookies to provide website analytics data on our visitor’s use of the website. This is used to help us improve the navigation and accessibility of our website.

The website uses two cookies to bypass the password entry portion of the website for users already logged in to the website. If the website recognises that you have valid, non-expired cookies when trying to access an admin page of the website, you go directly to the administration interface. If you don’t have the cookies, or they’re expired, or in some other way invalid, the website will require you to log in again, in order to obtain new cookies.

These cookies contain “hashed” data, so you don’t have to worry about someone gleaning your username and password by reading the cookie data. A hash is the result of a specific mathematical formula applied to some input data (in this case your username and password, respectively). It’s very hard to reverse a hash (bordering on practical infeasibility with today’s computers). This means it is very difficult to take a hash and “unhash” it to find the original input data.