The London Irish Centre Privacy Policy

 

The London Irish Centre is committed to being transparent about how we use your data. This policy explains how we gather and process your personal information.

As a registered charity, The London Irish Centre needs to collect some data about our customers and clients in order to be able to operate.

When you interact with us we will collect data about you for a variety of reasons - for example, to provide a service to you (such as posting purchased tickets or assisting you with a benefit application), or to report to our sponsors and funders. 

Collecting data about your preferences ensures that any communication that you have agreed to receive from us is appropriate and enables us to market events and services and fundraise more effectively.

Some of the information we request from you is optional and you can decide not to give it to us - we will let you know this when we request it.  If you do decline to give us those details it may limit the personalisation or services that we are able to offer - e.g., you may not get to hear about an event or service that we think you would be interested in. 

We ensure that all of our activities that involve your personal data are carried out lawfully, fairly and in a transparent manner.

  1. How do we collect your personal information?

From you directly

We collect data directly from you when you:

  • Seek advice or assistance with welfare issues
  • Engage with our daycentre and wellbeing activities
  • Sign up to the Befriending service
  • Purchase tickets from us
  • Join one of our membership schemes
  • Make a donation
  • Sign up to our mailing lists
  • Apply for one of our work or volunteering opportunities
  • Raise a query or give us feedback

This may happen via our website, over the phone, by email or in person.

We also get data from you if you take part in any surveys we may send you so we can learn more about you and your interests – however responding to these is optional.

From your use of our services

When you use our services we record details of this and the outcome, for example we retain a record of the tickets you have purchased from us, or a record of the advice you have received from us, or any donations you've made, and any memberships you may have had.

When you visit our website or make a booking online we will also make a note of how you access our website (e.g. from a computer, or a mobile device), and what parts of our website you use, using "cookies" - our cookie policy has more information on this.

We collect data about your use of our services when you:

  • Visit our website (londonirishcentre.org)
  • Purchase tickets from us (via our website, over the phone, or in person)
  • Join one of our membership schemes (via our website, over the phone, or in person)
  • Make a donation (via our website, over the phone, or in person)
  • Sign up to our mailing lists
  • Attend an advice session
  • Attend a social group
  • Have a befriending session

From your interaction with us on social media

If you interact with us on social media (for example to make a comment or ask a question), we may record the details of this interaction, particularly if you give us your personal data in relation to a booking query. 

Depending on your settings or the Privacy Policies of social media platforms you may be giving third parties (like ourselves) permission to access information from those accounts or services.

Our access to information from social media platforms is governed by the preferences you have set and the platforms’ polices.

If you have any queries about their use of your data you should read their Privacy Policies:

We also collect and track anonymised data on our social media audiences to better understand the ‘groups’ of people who engage with us online. We use this to ensure we engage with audiences and groups of people who are new to us.

From third parties

We may be given information about you by third parties that you have given your information to; for example if you attend one of our external events, book through a ticket agent, or make a donation to us through a donation portal.

You should check the Privacy Policy of the third party to fully understand how they will use your data and how it will be shared with us.

These are the ways that a third party may give your data to us:

Our external events

If you attend any of our external events and book with the hosting venue they may ask if you are happy for your details to be passed on to us.

If they do send the data to us we will contact you within 30 days to let you know it’s been given to us.

Ticket agents

If you book a ticket to one of our events via a ticket agent they will pass on some of your details to us so we can process your order and identify you should you have a query.

We will not use these details for any marketing or fundraising communications unless we have your consent directly from you.

Fundraising sites

If you donate to us by using fundraising sites such as JustGiving or PayPal they may also pass on some of your details to us.

From “public sources”

We will sometimes use data from other publicly published sources and combine this with what we already know about you.

We will only do this in relation to our fundraising activity, and only in order to ensure that any fundraising approaches that we make are appropriate to what we believe is within your inclination and capacity to donate.

We will only contact you with a fundraising approach or with an invitation to an event if we have your clear consent to do so.

Our fundraising processes are consistent with the Fundraising Regulator's Code Of Fundraising Practice.

The sources that we may use will be publicly available and can usually be found through search engines like Google.

Examples of the types of information we may be able to obtain:

  • Your biography on your employer’s website
  • Information published in mainstream media
  • Publicly published donor lists from other charities/arts organisations
  • Information from sources like Companies House or The Charities Commission.

We may also obtain information about you from individuals working on our behalf such as our development board.

2. What types of information do we collect?

We aim to collect the smallest amount of data about you that we need in order to either provide a service to you, or to meet our charitable aims.  

The exact data that we collect will depend on how you engage with us as an organisation- for example, we will collect different data if you join our mailing list compared to purchasing a ticket or using our advice service.

Your name, contact details, and requirements

We will record on our systems your name(s) and how you would like to be addressed, and details of how we can contact you (e.g., address, email).  

We will also make a note of any information you give us if you have access needs.

Information collected for Community Services, Casework and Wellbeing clients

 

We collect the following information to provide a service for our clients and for reporting to funders:

 

  • Gender
  • National Insurance Number
  • Place of birth
  • Irish status
  • Sensory impairment
  • Disability status
  • Nationality
  • Citizenship
  • Ethnicity

 

Additional information collected for Casework and Wellbeing clients

 

For casework/wellbeing clients we also collect further information such as health details including GP and other services, income details, and an overview of all circumstances including housing and financial in order to provide a specialised service for our clients and for reporting to funders.

 

Transactional details 

When you purchase something from us these are the transaction details that we will use:

If paying by card

  • Your payment (credit/debit) card details
  • Your payment card billing address

If paying for a membership by Direct Debit

  • Bank account number and sort code
  • Bank name and branch details

For all purchases

  • Your Gift Aid preferences / declaration

Do note that we do not retain your full payment card details on our CRM systems.

Your interests/preferences 

Our systems retain the history of the events you have purchased tickets for, and the types of events you tend to purchase.

If you interact with us on social media, those platforms may give us details of your interests and preferences - you should check their Privacy Policies for details of what they share with us.

These are the interests and preferences that we may record:

When purchasing a ticket

  • Event name
  • Event venue (e.g., London Irish Centre or a venue on tour)
  • Event genre (e.g., music or comedy)

Social media

If you interact with us on social media, these are the items that may be given/visible to us:

  • Your social media handle/name/avatar
  • Details of other pages/accounts you have “liked” or “favorited”
  • Details of your preferences
  • Any other information that you have made public – which may include contact information

Your interactions with us 

We will retain any correspondence that we get from you, whether that's in the post or via electronic means such as email.

We may also make a note of any conversations we have with you, either in person or over the phone - in particular in relation to any queries or feedback.

If you give us consent to send you email for marketing or fund-raising purposes we will note if you open these emails, or click any links within them.  We do this in order to assess the effectiveness of our emails.

These are the types of interactions that we record on our systems:

When you use our website

  • The public IP address of the internet connection you are using to access our website (including geographic location)
  • The type of device you use to view our website (e.g., PC, mobile, its screen size, browser information, etc.)
  • Which pages you visit on our site (e.g., which event details or service you have looked at)
  • How much time you spend on each page and on our site in total

When purchasing a ticket

  • Event name
  • Event venue (e.g., London Irish Centre or a venue on tour)
  • Event genre (e.g., music or comedy)

When attending an event

  • Details of your registration/attendance

If you have given us your consent to send marketing or fundraising emails

  • Which emails you have received
  • If you opened the email, when, and on what type of device (e.g.: PC, mobile)
  • Which links (if any) in the email you click

Your connections to other people

If you participate in a workshop or event, we may give you the opportunity to give us details of who should be contacted on your behalf in the event of an emergency.

At your request, we will link your account on our systems with the account of other people living at the same address as you.

3. Special types of information

Some of the information that you give us, due to its nature, has more potential to cause harm if not handled correctly. 

Payment card information

We only collect payment card details for the purposes of processing a single transaction.  

We only have access to partial payment card details to enable us to respond to queries and track transactions.

If you use your payment card (credit or debit) to purchase something from us (either through our website, in person, or over the phone), we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard. You can find out more information about PCI DSS here.

"Special category" personal data

Data protection law recognises that certain categories of personal information are more sensitive. This is known as "special category" data and covers health information, race, religious beliefs and political opinions.

We do not routinely collect special category data unless there is a clear reason for doing so - such as health details when taking part in an activity as part of the Advice & Wellbeing strands or when submitting an application for our work opportunities.

This is the special category data that we might request:

Health data

If you participate in an event or activity where we need this information to ensure that we provide appropriate facilities or support (for example recording any health conditions if you participate in an activity), we will ask you for the relevant details – which you can decline to give us.

Diversity monitoring

We do send out surveys from time to time to assist us with our diversity monitoring, and we are often required to report on this as part of our funding. These surveys will request some special category data but supplying this is optional.

Any diversity monitoring is subsequently anonymised and not linked to individual customer records.

Any special category data we have about you we will only use if you have agreed to give it to us, and we’ll only use it for the purposes we told you about at the time we collected the data.

4. What do we use this information for?

We collect and use your data for a variety of reasons.

To provide a service to you

Some of the data we have about you we need in order to provide a service to you – such as when you purchase a ticket, attend an advice session or sign up to one of our mailing lists.

Services we provide, and the data we used to do so:

  1. Your email address
  • Used to uniquely identify you on our systems
  • Used as your username for logging in to our website
  • Used to send you emails:
    • Details of your purchases
    • Inform you of any changes or updates to the event you’ve booked for
    • Send you reminders about your upcoming booking
    • Send you a post-event email to give you information about the event you have seen, and to invite you to participate in a survey
  • If you start to make a booking but are unable to complete it we may send you an email to offer assistance

We will only use your email address for sending you marketing or fundraising emails if you have given us your consent

  1. Your preferred title/honorific
    (Mr/Miss/Mrs/Ms/Dr)

    Your first name, last name, and any middle names/initials

We use this information so we can correctly address you in any correspondence with you, or over the phone or in person.

  • Your postal address(es)
  • Used as your billing address for credit card purchases
  • Used for sending you tickets by post if you request this
  • Used to send you brochures if you have a membership
  • Used for correspondence about your purchases/account, if we are unable to contact you via other means

We will only use your postal address(es) for sending you marketing or fundraising details if you have given us your consent.

  1. Your phone number(s)
  • Used for correspondence about your purchases/account if we are unable to contact you via email, or if you have requested to be contacted by phone
  • Used to send you a text message in the event of a event having to be cancelled at the last minute

We will not use your phone number for marketing or fundraising purposes.

  1. Your payment card details
  • Used to process payments
  • Partial card details are stored for us to track transactions and respond to queries
  1. Your Gift Aid preferences / declaration

Used to claim Gift Aid if declared, and to record your declaration

  • Details of other accounts you are linked to (other people living at the same address)

Used for audience demographics, and to tailor the marketing information that we send you (if you have given us your consent to send marketing)

  • Your interests/preferences

Used so we can tailor the information we send to you (if you have given us your consent to send you marketing).

 

Some information we request is not compulsory (such as your mobile phone number), but if you do give it to us it enables us to offer further services (such as sending you a text message if an event has to be cancelled at the last minute).

If you do not wish to provide details which are compulsory (in particular your email address, which is used to uniquely identify you on our system) you will not be able to create an account for online ticket sales – but you can still purchase tickets over the phone by calling Reception on 020 7916 2222, or by visiting in person.

To communicate with you about our work

With your consent, we will use your contact details to let you know about upcoming events, activities or services that we think you might be interested in.

If you give us your consent to contact you with marketing information, this is the data that we will use:

  • Your email address
  • Your postal address
  • Your preferred title/honorific (Mr/Miss/Mrs/Ms/Dr)
  • Your first name, last name, and any middle names/initials
  • Details of other people living at the same address (if your accounts are linked)

We will also use what we know about you (your purchase history, home address location, etc.) to only send you information that we think you will be interested in – this is sometimes known as “audience segmentation”.

We do not do any type of marketing by phone or SMS/text message – if you give us your phone number it will not be used for this purpose.

To communicate with you about our fundraising activities and how you can support us

With your consent, we will use your contact details and what we know about you to contact you if we think that you might be willing and able to provide us charitable support.

If you give us your consent to contact you with fundraising information, this is the data that we will use:

  • Your email address
  • Your postal address
  • Your preferred title/honorific (Mr/Miss/Mrs/Ms/Dr)
  • Your first name, last name, and any middle names/initials
  • Details of other people living at the same address (if your accounts are linked)

We will also use what we know about you (your purchase history, home address location, etc.) to only send you information that we think you will be interested in – this is sometimes known as “audience segmentation”. We may also look at sources of publicly available data (as outlined previously) to gauge your likely ability and propensity to donate to charity.

We do not do any type of fundraising by phone or SMS/text message – if you give us your phone number it will not be used for this purpose.

To learn more about our clients and customers and their habits

We would like to know more about our clients and customers, to ensure that our work is reaching people who might be interested in it, and to gauge the effectiveness of our marketing and communications.

We also have obligations towards our funders to be able to describe the nature of our clients and customers.

As we are a charity we also have a need to raise our own funds, by appealing to people who we think have the inclination and capacity to donate to us.

  1. What legal reasons do we have for using your data?

For everything we do with your data (or the data we have about you) we need to have a legal reason.  Below are the legal justifications that we use.

Things we do for legal or contractual purposes

Some of the use of your data enables us to fulfil an obligation to you - for example if you ask us to post a ticket to you we will need your postal address.

Other things we do enable us to meet a legal requirement that we are under - for example, recording details of Gift Aid declarations for HMRC.

Things we will only do when we have your consent

Some of our activity we will only do if we have your clear consent - such as sending you marketing information or contacting you about our fundraising work.

Any consent you give us you can revoke at any time - either by calling Reception on +44 (0)20 7916 2222, or visiting us in person at the London Irish Centre or emailing [email protected]

In addition, any email that we send to you on the basis of your consent will have an "opt-out" link at the bottom, to enable you to change your preferences.

Things we do where we believe we have a justifiable reason (known as "legitimate interest")

Some of the usage of your data we do because we believe that we have a legitimate interest in doing so, that we believe doesn’t infringe your rights and freedoms.

Where we have made this decision we have outlined our interests and balanced them against your interests and rights, and reached a conclusion that our activity doesn’t inconvenience you too much.

As an example, we believe we have a legitimate interest in monitoring transactions in our systems to spot potential fraud, or monitoring who opens emails we send to track the effectiveness of our marketing emails.

You do have the right to object to any of this processing, see "Your rights" below.

  1. Who do we share your data with?

 

Companies your data may be shared with

We engage third-parties to assist us with some of our data processing – these companies will only use your data for things that we have instructed them to do on our behalf. 

We will also ask if you are happy for us to transfer your contact details to the company whose work you are seeing, to allow them to communicate with you directly.

We may also share your pseudonymised purchase history with the company whose work you are seeing, for their own research purposes. They may ask us to send you an email on their behalf to invite you to participate in a survey – if you take part in this survey they may be able to link your responses to the purchase histories we have given them.

We do not sell or trade your personal data to third parties for any purpose.

Here are the companies that process data on our behalf, what they do
for us, and the types of data they process:

Countries where data might be shared

For financial and technical reasons some of the suppliers we use will transfer and process the data we give them in datacentres that are outside the European Economic Area (EEA).

When we select a service supplier based outside the EEA we take steps to ensure suitable safeguards are in place to protect your personal information, such as the EU-US Privacy Shield Framework.

  1. How long will your data be kept?

Your data will be kept only for as long as needed for the purposes that it is used for.  Exactly how long will depend on what we are using the data for, and on your level of engagement with our services.

For example, if you sign up to our mailing list and we notice that you have not opened any emails from us for over a year, we will email you to ask if you would like to keep hearing from us.  If you do not respond, we will then stop sending you emails, but we will keep any account that you have on our systems open and available to you.

If you have an account on our systems for making purchases we will retain your details for 10 years after the most recent purchase, or one year if there are no purchases - unless you have also opted in to receive emails from us and we can see you are opening those emails.  We will contact you before closing your account to let you know.

Website analytics data

We use Google Analytics to provide us with statistics about how people use our website. The data that they provide us is not used to identify any particular visitor to our website.

Google will keep this data for us for a period of 26 months after the last activity.

Applications for work opportunities

We will retain personal data for 12 months, at which point it is deleted.

  1. Your Rights

As well as the right to be informed about the data we collect and what we use it for (which this Privacy Policy outlines), you also have several other rights under data protection regulations.

Right Of Access

You have a right to ask if we hold information about you, and if we do you have a right to request a copy of that data.

You have the right to obtain a copy of the data that we hold about you, as well the right to obtain from us confirmation if we have personal data about you.

If we do have data about you, you have the right to know:

  • The purposes we have used your data for
  • The categories of data concerned
  • Details of any recipients to whom your data has been (or will be) disclosed
  • Details about how long we will store your data (or what criteria we use to determine this)

Should you wish to exercise this right we request that you contact us and provide:

  • The email address on your account


and

  • The postcode of the address in your account
    or
  • The last four numbers of the phone number in your account

Additionally, please provide as much information as possible about the nature of your contact with us to help us locate your records.

We will respond to your request within one month, and we may need to request further details from you to validate your identity and request.

Do note that if we feel that the request is manifestly unfounded or excessive we reserve the right to decline your request – if we do this we will write to you to let you know.

Right of Rectification

You have a right to correct any information that we have about you that is incorrect. If you notify us that the data we hold about you is incorrect we will stop using it until we have verified its accuracy (also known as the “right of restriction”).

Right of Erasure

In certain circumstances, you have the right to request that we erase the information that we hold about you, unless we need to retain it for legal reasons (such as details of a Gift Aid declaration (including cancelled Gift Aid declarations)), technical reasons (if you have asked us not to contact you or process your data we will need to store your information on a suppression list to ensure that we comply with your wishes), or we have an outstanding obligation to you (you have booked tickets to an upcoming event).

Should you wish to exercise this right we request that you contact us and provide:

  • The email address on your account


and

  • The postcode of the address in your account
    or
  • The last four numbers of the phone number in your account

Additionally, please provide as much information as possible about the nature of your contact with us to help us locate your records.

We will respond to your request within one month, and we may need to request further details from you to validate your identity and request.

Do note that if we feel that the request is manifestly unfounded or excessive we reserve the right to decline your request – if we do this we will write to you to let you know.

Right to Withdraw Consent

If we ask for your consent to do something (like send you marketing emails), you have the right to revoke that consent at any time.

Right to Object & Restrict processing

You have the right to object (or prevent) any processing we do where we feel we have a justifiable reason.

Some of the things we do with your data we do because we believe that we have a legitimate interest in doing this and we believe that it doesn’t outweigh your rights and freedoms.

However you do have the right to object to our use of your data for this purpose. If you do object we will not process your data for this purpose while we are assessing your objection.

Right to lodge a complaint

In the first instance we would ask that you contact us first so we have an opportunity to put things right, but ultimately you have the right to lodge a formal complaint with the regulator.

If you are unhappy with how we deal with your personal information in the first instance we suggest that you contact us directly so we can investigate the matter by calling Reception on +44 (0)20 7916 2222, emailing [email protected] or by visiting in person.

If you wish to make a formal complaint to us we request that you do so in writing.

If you are subsequently unhappy with our response you can contact The Information Commissioner’s Office, via their online reporting system: https://ico.org.uk/concerns

Accuracy

We do request that any information that you give us is kept accurate and up to date.

You can amend your details in the following ways:

By contacting reception on +44 (0) 20 7916 2222

By emailing us at [email protected]

By visiting us in person at the London Irish Centre, 50-52 Camden Square, London, NW1 9XB

If you gave us your data in relation to an application for one of our work opportunities please email [email protected].

 

Updates to this policy

This policy is under regular review so may change at any time. We will notify you about significant changes by sending a notice to the primary email address you have provided to us, and/or by placing a prominent notice on our website(s).

By continuing to use our services you will be deemed to have seen and understood such changes.

The last major update to this policy was made on 22nd of April 2019.

Our legal details

The London Irish Centre is a company limited by guarantee (Company No 08221421 ) with a registered office at 50-52 Camden Square, London, NW1 9XB.

The London Irish Centre is also a charity registered with the Charity Commission for England and Wales (No 1149787).

We are registered on the Information Commissioner’s Office Data Protection Register, and are the Data Controller for the personal data that we hold and process.

We sell tickets through the website www.londonirishcentre.org. From time-to-time we may also host cultural events and social functions at other venues or temporary performance spaces.

If you have any further questions about this policy or any of our data processing activities please contact us.

The personal data we collect, process or use is treated securely and in accordance with this Privacy Policy, the General Data Protection Regulation EU 2016/679 (GDPR), and the Privacy and Electronic Communications Regulations 2003 (PECR), as amended.