Privacy Policy

  1. This privacy notice tells you what to expect us to do with your personal information.

    1. Who we are
    2. What is personal data?
    3. Contact details
    4. What information we collect, use, and why
    5. Lawful bases and data protection rights
    6. Where we get personal information from
    7. How long we keep information
    8. Who we share information with
    9. How to complain

  2. 1. Who we are

    This website is operated by Glass Castle Foundation. Glass Castle Foundation is referred to in this privacy notice (“Privacy Notice”) as “us” or “we” and you can contact us using the details set out in paragraph 3 below. In this Privacy Notice we describe the types of personal data which we collect and the uses which we make of it.

    For the purposes of applicable data protection laws, including the UK General Data Protection Regulation (“UK GDPR”), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (“Data Privacy Laws”), Glass Castle Foundation is the data controller. We are registered in England and Wales as a Charitable Incorporate Organisation (CIO) and registered charity number 1212538. Our registered office is at 145 Kensington Church Street, London, W8 7LP. You can contact us about any data protection matter using the details in paragraph 3 below.

  3. 2. What is personal data?

    Personal data includes all information held in electronic form or manually in a structured filing system relating to a living individual who can be directly or indirectly identified from that data (or from that data and other information in our possession) and includes personal contact information and images, such as from CCTV.

  4. 3. Contact details

    Telephone
    0207 7591056

    Email
    info@gc.foundation

  5. 4. What information we collect, use, and why

    As a charitable foundation committed to creating conditions for artists to experiment and thrive, Glass Castle’s activities include a wide range that involve data collection and processing. These include, but are not limited to, the following: 

    • Programming and producing exhibitions and events
    • Selling tickets for events via third party ticketing partners
    • Grant-making
    • Running residency facilities
    • Employment
    • Working in collaboration and partnership with range of organisations
    • Marketing and PR to support our mission
    • Fundraising

    We collect or use the following information to provide services and goods, including delivery and third party referrals:

    • Names and contact details
    • Gender
    • Pronoun preferences
    • Addresses
    • Date of birth
    • Emergency contact details
    • Next of kin details
    • Photographs or video recordings
    • Service use history
    • Right to work information
    • Health information (including medical conditions, test results, allergies, medical requirements and medical history)
    • Dietary information (including allergies and health conditions)
    • Information about care needs (including disabilities, home conditions, dietary requirements and general care provisions)
    • Information about work, home and living conditions
    • Information about support requirements
    • Information about lifestyle, interests or personal history
    • Criminal offence data 
    • Records of meetings and decisions
    • Information about income and financial needs for funding or personal budget support
    • Payment details (including card or bank information for transfers and direct debits)
    • Website user information (including user journeys and cookie tracking)
    • Information relating to compliments or complaints

    We collect or use the following information to receive donations or funding and organise fundraising activities:

    • Names and contact details
    • Addresses
    • Payment or banking details
    • Tax payer information (for Gift Aid purposes)

    We collect or use the following personal information for service updates or marketing purposes:

    • Names and contact details
    • Addresses
    • Marketing preferences
    • Recorded images, such as photos or videos
    • IP addresses
    • Website and app user journey information
    • Records of consent, where appropriate

    We collect or use the following personal information to comply with legal requirements:

    • Name
    • Contact information
    • Identification documents
    • Financial transaction information
    • Any other personal information required to comply with legal obligations
    • Health and safety information
    • Safeguarding information

    We collect or use the following personal information for recruitment purposes:

    • Contact details (eg. name, address, telephone number or personal email address)
    • Date of birth
    • National Insurance number
    • Copies of passports or other photo ID
    • Employment history (eg. job application, employment references or secondary employment)
    • Education history (eg. qualifications)
    • Right to work information
    • Details of any criminal convictions (eg. Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks)
    • Security clearance details (eg. basic checks and higher security clearance)

    We also collect or use the following special category information for recruitment purposes. This information is subject to additional protection due to its sensitive nature:

    • Racial or ethnic origin
    • Religious or philosophical beliefs
    • Health information
    • Sexual orientation information

    We collect or use the following personal information for dealing with queries, complaints or claims:

    • Names and contact details
    • Video recordings of public areas
    • Witness statements and contact details
    • Relevant information from previous investigations
    • Customer or client accounts and records
    • Financial transaction information
    • Information relating to health and safety (including incident investigation details and reports and accident book records)
    • Correspondence

  6. 5. Lawful bases and data protection rights

    Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

    Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

    If you make a request, we must respond to you without undue delay and in any event within one month.

    To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

    Our lawful bases for the collection and use of your data

    Our lawful bases for collecting or using personal information to provide services and goods, including delivery and third party referrals are:

    • Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
    • Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
    • Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
    • Legitimate interests: we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
      • Running our programmes: administering our grants and partnerships programme, the artist residency at Hatch Farm and our programme at Wapping Powerhouse, including assessing applications, arranging participation and keeping records of the support we provide.
      • Looking after the people we work with: keeping emergency contact details and information about access, care or dietary needs so we can support participants and keep them safe. Where this includes health or other sensitive information, we will also rely on an additional condition under data protection law, such as your explicit consent.
      • Making referrals: sharing information with partner organisations where this will help us support you.
      • Responding to you: answering enquiries, acting on feedback and handling compliments and complaints about our services.
      • Internal administration: keeping accurate records for accounting, audit and the day-to-day running of our organisation.
      • Running our website: administering and troubleshooting our site and keeping it safe and secure.

    We carefully assess the balance between our legitimate interests and your privacy rights before relying on them. For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above.

    For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.

    Our lawful bases for collecting or using personal information to receive donations or funding and organise fundraising activities are:

    • Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
    • Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
    • Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
    • Legitimate interests: we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
      • Processing your support: receiving and recording donations and keeping a record of your relationship with us.
      • Claiming Gift Aid: using your details to claim Gift Aid on eligible donations where you have made a Gift Aid declaration.
      • Thanking and updating supporters: acknowledging your support and letting you know how it is helping our work.
      • Managing funding relationships: administering agreements with arts organisations, charities, trusts, foundations and other organisations, including the reporting they require.
      • Organising fundraising activities: planning and running fundraising events and keeping records of who has taken part.

    We carefully assess the balance between our legitimate interests and your privacy rights before relying on them. For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above.

    Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

    • Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
    • Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
    • Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

    Legitimate interests: we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:

    • Keeping you informed: letting you know about changes to our services, programmes or policies.
    • Promoting our work: sending information about our programme, events and opportunities where you would reasonably expect to hear from us. We will only send marketing by email or text where you have given your consent, or where you are an existing supporter and have not opted out.
    • Professional and press contacts: contacting members of the press, professional networks and arts sector partners in their professional capacity, for example to send invitations to previews and events, press announcements, or updates about our programme and partnership opportunities.
    • Sharing our activities: using photographs and recordings from our events and programmes to promote our work. Where an individual is the focus of an image, we will ask for consent first.
    • Improving our website: understanding how people use our site so we can present content in the most effective way for you and your device.
    • Respecting your choices: keeping a record of your marketing preferences so we contact you only in ways you're happy with.

    We carefully assess the balance between our legitimate interests and your privacy rights before relying on them. For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above.

    Our lawful bases for collecting or using personal information to comply with legal requirements are:

    • Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
    • Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
    • Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

    Our lawful bases for collecting or using personal information for recruitment purposes are:

    • Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
    • Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
    • Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

    Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:

    • Consent: we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
    • Contract: we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
    • Legal obligation: we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
    • Legitimate interests: we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
      • Responding to queries and complaints: investigating and resolving concerns fairly, keeping a record of our correspondence and learning from feedback to improve what we do.
      • Keeping people and premises safe: using CCTV of public areas at our sites to protect visitors, artists, staff and property, and to help investigate incidents.
      • Investigating incidents and accidents: gathering witness statements, keeping accident book records and reviewing relevant information from previous investigations so we can understand what happened and prevent it happening again.
      • Handling claims: keeping records of accounts, transactions and correspondence so we can respond to, defend or settle legal claims.

    We carefully assess the balance between our legitimate interests and your privacy rights before relying on them. For more information on our use of legitimate interests as a lawful basis, you can contact us using the contact details set out above.

    • Vital interests: collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. This includes an urgent need for life sustaining food, water, clothing or shelter. All of your data protection rights may apply, except the right to object and the right to portability.

  7. 6. Where we get personal information from

    • Directly from you
    • Regulatory authorities
    • Charities or voluntary sector organisations
    • Schools, colleges, universities or other education organisations
    • CCTV footage or other recordings
    • Publicly available sources
    • Councils and other public sector organisations
    • Previous employers
    • Third parties: Arts organisations

  8. 7. How long we keep information

    We keep personal information only for as long as we reasonably need it to provide our services, run our programmes and manage our relationship with you, or for as long as we are legally required to keep it.

    Some records must be kept for a set period by law. For example, we keep financial records, including donation and Gift Aid records, for six years after the end of the financial year they relate to, as required by HMRC and charity law.

    When we no longer need your information, we securely delete or destroy it, or anonymise it so you can no longer be identified. If you would like more detail about how long we keep a particular type of information, please contact us using the details set out above.

  9. 8. Who we share information with

    Data processors

    Payroll services, London
    This data processor processes our payroll information.

    IT system support, London
    This data processor manages our IT systems.

    Finance support, London 
    This service partner supports our in-house Finance team with banking and payments.

    Others we share personal information with

    • Charities and voluntary organisations
    • Organisations we need to share information with for safeguarding reasons
    • Emergency services
    • Professional advisors
    • Local authorities or councils
    • Relevant regulatory authorities
    • External auditors or inspectors
    • Organisations we’re legally obliged to share personal information with
    • Publicly on our website, social media or other marketing and information media
    • Current employers
    • Previous employers
    • Suppliers and service providers
    • Third parties: Arts organisations we are partnering or collaborating with: we may share personal details to enable us to invite them to guest and press nights for events, and other legitimate interest marketing. 

  10. 9. How to complain

    If you have any concerns about our use of your personal information, you can make a data protection complaint to us:

    Email: info@gc.foundation

    If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. 

    The ICO’s address:

    ICO Head Office
    4th Floor, No.3 Circle Square
    5 Hawkshaw Street
    Manchester
    M1 7BL

    Helpline number: 0303 123 1113 
    Website: https://www.ico.org.uk/make-a-complaint