Croydon Council’s culture and library services provides various library events, culture and heritage. We understand that our audiences, library users and partners expect privacy in their transactions with us and for their information to be both secure and used only for the purposes for which it is provided.
We are committed to protecting your privacy when you use our services. This Privacy Notice explains how we use personal information about you and how we protect your privacy. Under the requirements of Data Protection Legislation including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018, this notice applies to any activity involving our use of your personal data, for example, collecting, storing, sharing, and destroying personal information. Please read it through carefully and if you have any queries contact: firstname.lastname@example.org
Where we collect information from
When you give data to us directly:
• Sign up to receive communications.
• Complete one of our surveys
• Participate in one of our events, workshops or classes.
• Apply for a position, paid or voluntary.
• Login to our public Wi-Fi
• Contact us on one of our online platforms such as (but not exclusively) Twitter, Facebook, Instagram, Trip Advisor, Google
• Contact us directly by telephone, electronically, post or in person with feedback about your experience.
• When you give your consent for filming and/or photography at one of our participatory workshops or events.
When you give data to us indirectly:
• Browse items on our website.
• Open and/or follow links and interact with emails and marketing you receive for London Borough of Culture and related cultural events in the Borough.
• Interact with us or mention us on social media sites.
What we collect and how it is used:
Information collected will be used to deliver services and communication. This includes the following Personal Data:
• your name;
• post code; and
• email address.
We may send out survey and collect information including the following Personal Data:
• your name
• date of birth
• email address and other contact details; and
The following Special Category data may be collected as part of surveys, this will be collected in an anonymised format and will not be linked to your personally identifiable information:
• sexual orientation.
We will only ever ask for data which is necessary for us to measure the impact of a programme. In most cases, this does not require the recording of name, date of birth, or address. How your data will be used will be made clear at the time of collection, and you will be provided with the option to refuse to provide information.
Lawful Basis of Processing
The Lawful basis of processing your data will normally be:
Article 6 (a) Consent as you have provided clear consent for the Council to process your personal data for a specific purpose;
Article 9 (a) Explicit Consent in respect of any Special Category Data; and/or
Article 6 (e) Public Task where the processing is necessary for the Council to perform a task in the public interest or in respect of its official functions, and the task or function has a clear basis in law, and the relevant Article 9, in respect of any Special Category Data where Article 6 (e) Public Task is engaged, and the processing of Special Category Data is necessary.
If we have used Consent as the Lawful basis to process your information, you have the right to remove the consent at any time. If you want to remove your consent, please contact Cultural Services service contact email@example.com and tell us which service you are using so we can deal with your request.
How your data is used
Based on your contact preferences we use your details to keep you up to date about forthcoming events. You can opt out at any time by updating your preferences or by contacting firstname.lastname@example.org
We sometimes use segmentation based on postcodes and your interactions with London Borough of Culture to assist us with sending your relevant information about news, offers and opportunities to support the London Borough of Culture.
Depending on your device’s privacy settings and those on other website and apps in use, we may aggregate information you give us directly or indirectly to target advertising and social media posts. For example, we may create a specific campaign to be shown on social media to people in the CR0 postcode sector aged between 25 and 40, or an advert to target specific people who have visited a particular page on our website.
How a website tracks you depends on the privacy settings on the device you are using and ay privacy settings you have set up with individual sites and apps. To find out more about this and what types of tracking we use and how you can opt out visit the Cookies Section
Reporting and analysis
We use the data that you give us directly and indirectly to report on audiences for This is Croydon – London Borough of Culture to improve your experience. This reporting is created from aggregated data and is not attributable to individuals.
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 and operating system. 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 to 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 normally linked to information that allows us to identify individuals. Alongside cookies we use tracking pixels which follow your activity after clicking a link from a third-party site. This does not allow us to personally identify you but may be used by the third party site. For more details on how and which cookies we use and how you adjust the settings on your device and specific apps please visit the Cookies section.
Surveys and promotions
We carry out promotions and surveys on a regular basis as part of these we may ask you to disclose personal information. Participation is entirely voluntary, and you have a choice whether to disclose Personal or Special Category Data. The data you supply is aggregated for reporting purposes and not attributed to individuals.
We use segmentation based on postcodes to report to funders and public bodies about audiences who attend or subscribe to This is Croydon – London Borough of Culture. The segmentation is applied by The Audience Agency and is created using data from Experian.
Who do we share your information with
Anonymised data will be shared with the Achates Philanthropy to analyse and evaluate the impact of our programmes:
• Contracted evaluation partners
• External programme funders
• Programme delivery partners
Our evaluation partner for the London Borough of Culture programme is Achates Philanthropy Limited, their Privacy Notice can be found here: https://www.achates.org.uk/contact/
The information shared with the orgainsation and Council service listed, will be used to inform Croydon Council’s understanding of its borough-wide cultural provision and engagement with culture, in the context of our year as London Borough of Culture 2023-24.
Where we have these arrangements there is always an agreement in place to make sure that the organisation complies with the law. We will often complete a data protection impact assessment (DPIA) before we share personal information to make sure we protect your privacy and comply with the law.
Sometimes we have a legal duty to share your personal information with other organisations:
• in order to find or stop a crime or fraud; or
• if there are serious risks to the public, our staff or to other professionals; or
• to protect those individuals who are thought to be at risk for example if they are frail, confused or cannot understand what is happening to them.
If this is the case we will make sure that we record what information we share and our reasons for doing so. We will let you know what we have done and why if we think it is safe to do so.
Where is your information stored
The majority of your personal information is stored on systems in the UK. There are however some occasions where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside the EU. The Council will ensure there is additional protection if your personal information leaves the UK and ensure there are robust clauses in the contractual arrangements with any third party who processes personal information outside the EU.
How long do we keep your personal information
We will not keep your personal information for longer than necessary and shall be relevant and not excessive in relation to the purpose or purposes for which it was collected. We will ask you to agree to opt in for marketing purposes every 24 months.
Where your information is held for a set period of time this will always be supported by a legal reason. These reasons are set out in our document retention policy. If you wish to see the retention schedule you can send your request to email@example.com.
You can ask us to delete information (the “right to be forgotten”)
You have the right to ask us to delete your personal information for example where your personal information is no longer needed for the reason why it was collected in the first place or where you have withdrawn your consent for us to use your personal information and there is no legal obligation for the Council to use it. Where your personal information has been shared with others legally, we will use reasonable endeavours to make sure the 3rd party also deletes your data where you request this.
Cookies – further information
Some independent information about cookies is available here:
• Information Commissioners Office (ICO) cookie advice
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us updating your preferences or by contacting firstname.lastname@example.org.
Email Sign Up
The information you are providing will be used only for the purpose for which you provide it. If you are selecting to receive our newsletter(s), you are providing your consent for us to process your personal data in this manner for this purpose. We will not add you to any other mailing lists unless you ask us to, and we will not pass your details on to third parties. Your personal data will be handled in accordance with our Privacy Statement.
Who to Contact
If you have any concerns regarding how you data has been processed in the first instance please contact email@example.com.
This applies to your personal information that is in both paper and electronic records. You can ask for your records by contacting the Information Management team at the Council at SAR@croydon.gov.uk.
We have a Data Protection Officer (DPO) who is responsible for informing and advising the Council on its data protection obligations and monitoring the Council’s internal compliance together with acting as a single point of contact for you and the ICO. If you wish to contact the Data Protection Officer, Billy Machekano, please email DPO@croydon.gov.uk or telephone on 0208 726 6000 and ask to speak with the Data Protection Officer.
Where can I get independent advice?
For independent advice about data protection you can contact the Information Commissioner’s Office at:
• Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5A or email firstname.lastname@example.org or call 0303 123 1113 or 01625 545 745