This Privacy Policy is between you and Upswing Ltd
Registered address Rich Mix, 35-47 Bethnal Green Road, London E1 6LA
Charity number 1149245
Company number 7248211

This Privacy Policy was reviewed in January 2022.

This Privacy Policy explains:

• What personal data Upswing collects and why
• How Upswing use that information
• How individuals can access, update and delete their information

Upswing needs to gather and use certain information about individuals. These can include participants, audiences, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

Upswing will respect any personal data shared with us; we are committed to keeping personal data secure and managing it in accordance with our privacy policy (described below) and our legal responsibilities under privacy and data protection laws.

What personal information do we collect and process?
The General Data Protection Regulation (GDPR) says that we are required to have a lawful basis for processing your personal data and places emphasis on us being accountable for, and transparent about this. In most cases, our lawful basis for processing data will be Contract, Legal Obligation, Legitimate Interest or Consent as explained below:

Contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract

Legal Obligation: the processing is necessary for us to comply with the law (not including contractual obligations)

Legitimate Interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests

Consent: we have been given clear consent to process your personal data for a specific purpose (such as electronic marketing)

We collect information from you if:

• You completed an online or paper feedback form following one of our performances, participatory projects, workshops, talks or other events.
• If you attend one of the above, we may ask you to fill out a feedback form in order to find out what you thought, so that we can improve what we do. We may also ask where you have come from (such as postcode or country) so we can understand how far people travel to see us, and ask for monitoring information so we can record the make-up of our audiences.We use this information to improve our understanding of our audiences and potential supporters, and to target our communications more effectively. We may share this information with our funders, to help demonstrate the impact and reach of our work. This information is always anonymised and we do not share with them anything which identifies you.We will collect data so we can build a picture of how we can improve the delivery of our projects and to engage with the widest possible group of people. If you took part in a workshop, conversation or event, we will collect data so that we can promote these events better and discover who is interested in the sort of work we are doing and how we can continue to attract a diverse group of participants.
• You have signed up to attend one of our masterclasses or workshops.We will retain your name and contact details, plus any additional health information you share with us that is relevant to the activity.
• You signed up to our mailing list.We will record your name and email address when you sign up to our mailing list, and ask for your postcode or country so we can send content relevant to your area.With your consent, we will contact you to let you know about our upcoming events (including but not exclusive to performances, classes, workshops, sharings and talks), news of our plans and the progress we are making, and exclusive offers. You will also have the option to be contacted with specific masterclass updates.If you chose the option to receive information on how to support Upswing, we may contact you about donations and fundraising for Upswing only.Each time we contact you, we will offer you the opportunity to opt-out.
• You have used our website upswing.org.uk
  We log your Internet Protocol (IP) address, in order to receive and send information from and to you over the internet. Our website also uses cookies to understand how people use our website, inform our digital advertising and enable online transactions. If you have left a comment on our website, your email and IP addresses will have been stored in our website’s database, and we may have saved your comment for evaluation purposes.
• You have contacted us via email. Your email address may be stored in our company contact lists or database.
• You have interacted with us on social media, either directly or indirectly. From time to time we save anonymised social media feedback and conversations for evaluation purposes.
• You have told a venue where we perform or partner organisation co-presenting one of our projects that you are happy for them to pass on your contact information to us.
• You have donated money to us either via our website (with PayPal), cheque, cash, debit/credit card, or services in kind.When you make a donation we will keep a record of your contact details, the details of the gift (amount, date, purpose) and your Gift Aid status.
• There has been a transaction between yourself and Upswing via bank transfer, PayPal, cash, cheque, or debit/credit card.We will retain your name, and/or organisation and contact details, and we may keep a record of your bank or debit/credit card details, but only as long as necessary, and solely to process the transaction.You can view Paypal’s Privacy Policy here.
• You have been contracted by us to provide a service, or performed in one of our productions/projects.
• You have contacted us regarding auditions and/or have auditioned for us, submitted a job application or sent us your CV.If you apply or audition for a job with us, we may ask for additional information about you. This is so we can improve how we target future employees, understand where individuals are finding out about opportunities with us, and who the people are that are applying.If we have requested you provide us with contact information for referees, they will only be contacted if you have been offered a job with us. They will be deleted, along with your application, 1 year after the position is filled.

As a minimum, we will usually collect:

• Your name
• Your email address
• Your postcode

Where it is appropriate we may also ask for:

• Information relating to your health, for example if you are attending an event and we need to make sure we’ve made adjustments so you are able to freely attend
• Why you have decided to take part in one of our events, and / or what you felt about the experience
• Permission to contact you about future events or opportunities. We will only do this if you opt-in to receive this type of communication from us
• Personal information (including age, gender, ethnicity etc), so we can better understand our audiences, members, donors and potential supporters and ensure our work is reaching as many people in as many places as possible. This type of information we collect from you is saved anonymously and securely

The information we request from you enables us to ensure communications are relevant, and allows us to target our resources effectively.

Some of the information which we collect from you may constitute sensitive personal data. We will only ever use this in accordance with this policy and shall maintain necessary measures to protect this information and its confidentiality.

Participation and collecting children’s personal information

In our participation projects, we may collect information about the people taking part, including children and young people. This includes for example, their medical details, school / work information, details of prior artistic experience and details of any learning difficulties or special access requirements.

This information will be used by our project team in order to plan and deliver the very best artistic and educational experiences, to keep participants safe throughout their experience with us, and may be passed to emergency services for use should any emergency situation arise.

We will seek consent from a parent or guardian before collecting information about children.

Cookies

Cookies are very small text files stored on your computer and are used by most websites to help personalise your web experience. For further information on cookies, visit www.aboutcookies.org or www.allaboutcookies.org.

We will use the information we collect as a result of you accepting a cookie from our site, to track your use of our website and to compile reports on the use of the website overall by all visitors.

You can set up your browser not to accept cookies – the websites above tell you how to remove cookies from your browser. In a few cases, some features of our website may not function fully as a result.

How long do we store your data?

We will not retain personal data for longer than is necessary for the purpose it is required, and we’ll ensure it is securely deleted when no longer needed (see table below). We will review data to reduce the risk of it becoming inaccurate, out of date or irrelevant. Please let us know if you see any inaccuracy with the data that we are holding by emailing us at admin@upswing.org.uk.

Sharing your data

We do not sell or share personal details to third parties for the purposes of marketing.  But, if we run an event in partnership with another named organisation your details may need to be shared. We will be very clear what will happen to your data if we share it and we shall not disclose your personal information unless obliged to, or allowed to do so by law.

We may share information about you with analytics providers for the purposes of improving our website

Some people wish to share feedback with us about their experience of one of our projects. If we have the explicit and informed consent of the individuals, or their parent or guardian if they are under 18, this information may be made public by us at events, in materials promoting our work, or in documents such as annual company reports or project evaluation report .

How we keep your data safe and who has access

We ensure that there are appropriate technical controls in place to protect your personal details. The personal information that you provide will be held securely and will not be used for any other purpose than as provided for in this policy.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff.

We may need to disclose your details if required to the police, regulatory bodies, enforcement agencies or legal advisors. We will only ever share your data in other circumstances if we have your explicit and informed consent.

Some of our suppliers run their operations outside the European Economic Area (EEA). Specifically Dropbox, Mailchimp, Google and Paypal all have their servers in the US. Although they may not be subject to the same data protection laws as companies based in the UK, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law.

Type of Data	Information	Processing/Purpose	Retention	Legal Basis
Sign-up for Master-  classes and workshops	Name, email, postcode, age, height, weight	Used to setup and deliver classes, contact in case of issues, added to marketing list (under soft opt-in)	In perpetuity for insurance requirements. All other info 3 years.	Contract
Contract Information	Name, email, address, organisation	Used to: perform show, run workshop program, run event	6 years from end of contract	Contract
Marketing email list	Name, email, postcode, age, address, gender, organisation, preferences	Marketing, analysis, research and storage	3 years from last contact	Consent
Feedback (Audience & Participant)	Name, email, opinions in the form of feedback	Added to marketing email list (under soft opt-in), used for analysis, research, reporting, communication with funders and board and promotion of Upswing	3 years with contact details. After that anonymously	Consent
Pictures of our events	Photographs or recordings of individuals	E-Marketing, website, fundraising, communications with funders, Board and R&D	3 years from dissolution of the company	Consent
Donation information	Name, email, payment details, address	Processing donation, analysis and research, reporting to funders	6 years	Legal Obligation
Industry email list	Name, email, postcode, organisation, preferences	Used for marketing, networking, R&D, sales and operational purposes	6 years from last contact	Legitimate Interest
Applicant Information	Name, email, CV, cover letter	Used for assessment of candidates, analysis, monitoring	3 years from unsuccessful application	Legitimate Interest
Website and Google analytics data	internet protocol (IP) address, 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 people use to access our website	Research and understanding how people use upswing.org.uk	Detailed data 3 years from use and  then aggregated anonymously	Legitimate Interest

Under data protection and privacy legislation you have various rights.

You have a right to request a copy of the information that we hold about you. If you would like a copy of some or all of the information we hold about you, then contact us by phone, email, post or social media including a copy of proof of your identity (driving licence or passport) to Upswing, Rich Mix, 35-47 Bethnal Green Road, London, E1 6LA or admin@upswing.org.uk (with ‘subject access request’ in the subject line of the email

We want to make sure that the information we hold about you is accurate and up to date. You have the right to ask us to correct, complete or remove information you think is inaccurate or incomplete. In that case please send a copy of your ID (if we haven’t got it already) to us at admin@upswing.org.uk, with details of what amendments you propose and evidence that these are accurate – and ‘personal data rectification’ in the subject line of the email.

You have the right to withdraw your consent to receiving marketing communications. If you want to unsubscribe from any Upswing mailing list (provided by Mailchimp) you can do this by using the footer ‘unsubscribe link’ in any recent email. In the event that this is unsuccessful or you encounter issues, please email admin@upswing.org.uk

You may have the right to request information about you in a portable format. This applies only to data that you have provided us with, which we process in automated systems either with your consent or in able to fulfil our responsibilities under a contract with you.

Deletion

In certain circumstances you may have the right to ask us to delete information we hold about you, or suspend or restrict its processing or object to its processing. In these cases, please contact us at admin@upswing.org.uk explaining what you want us to do – and why.

Complaints

We will do everything we reasonably can to ensure that you are satisfied with the way we have responded to you about your personal data and privacy. So, please do tell us if you are not so we can rectify any outstanding issues. If you are still not satisfied, you have the right to complain to the Information Commissioner’s Office (ICO) – see https://ico.org.uk/concerns/handling/.

Changes to this policy

Our privacy policy is kept under annual review and we will place any updates on our website. If we make any significant changes in the way we treat your personal information we will make this clear by contacting you by email.