When we talk about The Centralian Players, we mean the voluntary association called The Centralian Players and registered at 29 Bellamy Close, Watford, Hertfordshire, WD17 4RN. The Centralian Players operates the www.centralianplayers.co.uk website. When you interact with us through our website (or otherwise, including through third party service, such as TicketSource and MailChimp), you may provide to us, or we may collect, certain information from which you are personally identifiable (which is referred to as personal data).
For the purposes of the data protection laws, we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and, more importantly, for keeping your data safe and only using it for legitimate purposes.
To support the efforts of NHS Test and Trace, the Department of Health and Social Care (“DHSC”) has asked certain businesses in certain circumstances to keep a temporary record of visitors and customers booking tickets to their venues for 21 days, and to supply such data to the NHS Test and Trace service where requested.
We inted to co-operate fully with the NHS Test and Trace service and may ask visitors to our performances, and customers booking tickets to any of our performances, to provide certain details for this purpose. By maintaining these records and sharing them with NHS Test and Trace where requested, we can together help to identify people who may have been exposed to Covid-19.
We will collect the minimum amount of personal data required in order to sensibly comply with government guidance, with reference to the point we collect such data (https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace). This may involve collection of the following:
The accuracy of the information provided will be the responsibility of the individual who provides it. We will not verify any individual’s identity for NHS Test and Trace purposes.
Note that we will not ask individuals to provide us with any health information (special category data under the GDPR) at any time. We will, however, remind individuals of the entry conditions to our performances (which may involve a self-assessment by the individual of their health, along with other factors) and highlight that if the individual is feeling unwell, displaying any symptoms of Covid-19 or believe they could be refused entry to the performance on the basis of their own self-assessment, then they should not attend the performance.
The data collected above for the NHS Test and Trace service will only be used for contact tracing and not for any other purpose.
We will pass the data collected to the NHS Test and Trace service, which is operated by the DHSC, where requested. We will not supply such day to any other third party.
We will keep the data collected for a period of 21 days, in line with the government’s guidance on this issue (https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace#how-records-should-be-maintained). Once this retention period has ended, we will securely delete the data.
Notwithstanding the above, the data collected for the NHS Test and Trace service may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you. Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.
We are required to demonstrate that we have a GDPR-specified lawful basis for processing this personal data collected for NHS Test and Trace. We have identified that this personal data is processed under the ‘legitimate interests’ basis, where the legitimate interest is facilitating contact tracing in respect of Covid-19 and the processing is necessary to achieve such interest given that the government has recommended these measures and we have procedures in place to protect the individual data providers’ interests, rights and freedoms.
If you require any further information regarding our collection of personal data in connection with the NHS Test and Trace service, then please email us at firstname.lastname@example.org
We have set out below the different types of personal data that you provide directly to us, or which we collect from you when we interact with you. We also wanted to let you know why we use this data and the different legal grounds which allow us to do so. You don’t have to give us any of this data but if you don’t, you may not be able to buy tickets and you are unlikely to receive our optimal overal customer experience. We respect that choice.
You may provide us with the following types of personal data when you directly interact with us (through our website, in person at our performances, or otherwise):
The table below sets out how we use your personal data and our lawful basis for doing so. In addition to these purposes, please note that we also anonymise and aggregate personal data (so that it does not personally identify you) and use if for testing our internal systems, carrying out research and general customer data analysis. Because this is not personally identifiable, we can use this for any purposes.
|Reasons why we use the data
|Legal grounds for using the data
|Register you as a The Centralian Players customer
|Contact, Profile, Social
|To perform our contract with you. Necessary for our legitimate interests (to make your purchase experience more user friendly)
|Enable you to purchase tickets and other products
|Contact, Social, Technical, Usage
|Process payments for tickets and other products
|Perform our contract with you
|Deliver your tickets and other products
|Send you service messages by email, including ticket receipts, show information and updates on your orders
|To perform our contract with you. Necessary to comply with a legal obligation.
|For internal administration and record keeping purposes
|To perform our contract with you. To comply with our legal obligations. Necessary for our legitimate interests (to effectively operate our business and perform our services)
|Providing customer support, including answering your questions which may involve contacting you by post, e-mail or phone
|To perform our contract with you. Necessary for our legitimate interestes (to ensure our customers are informed and satisfied with our services)
|To understand who is buying our tickets and other products
|Necessary for our legitimate interests (to develop our business and understand our customer base to inform our marketing strategy)
|To contact you about relevant performances and products from The Centralian Players
|We only do this if we have your consent
|Improve and personalise your user experience by delivering more relevant content and advertising while you browse our website, and to remember your preferences
|Contact, Profile, Social, Technical, Usage
|Necessary for our legitimate interests (to develop our business, improve our user experience and inform our marketing strategy)
|Administer our website, including website trouble-shooting, testing and analysis and to enable you to participate in interactive features of our website
|To perform our contract with you. Necessary for our legitimate interests (to ensure that our website is fully functional and operating in the most effective way for you)
|Enable you to participate in a competition or prize draw
|To perform our contract with you
|To give you the opportunity to provide feedback to The Centralian Players through reviews and surveys
|Contact, Profile, Technical, Usage
|Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from customers to improve our services)
|Verify your identity and detect fraud and security issues
|Necessary for our legitimate interests (to prevent and detect fraud, security incidents and criminal activity)
Importantly, we do not pass your personal data to any third parties for the purpose of third party marketing. If in the future we want to do this, we will only do so if you have consented.
However, we do need to share your data with the following third parties as an essential part of being able to provide our services to you (in accordance with the purposes set out above). In each case, we will only ever share the minimum amound of information required and ensure that the relevant third parties are subject to suitable obligations in respect of confidentiality and security:
In addition to the above, we may also need to share your personal data with third parties if we are legally obliged to do so.
We may send your data outside of the UK. Whenever we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us is you want further information on the specific mechanisms used by us when transferring your personal data out of the UK.
If you have said we can, we will send you marketing messages by email and/or post to keep you aware of what we are up to and tell you about future shows we think will be relevant to you, or other services and promotions. If you change your mind, you can opt-out of receiving marketing at any time either by contacting us or by using the opt-out function detailed in the communication. Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Please note that it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.
We do not currently pass your data onto any third parties for marketing purposes, unless you have explicitly asked us to do so. However, if we ever wish to do so in the future, we will always get your consent. You can then opt-out from any third party marketing at any time following the same process as above.
If you have given the appropriate consent, The Centralian Players targets banners and ads to you when you have left our website and are on other websites and apps. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like pixels, ad tags, and cookies, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience service.
The banners and ads you see will be based on information we hold about you, or your previous use of The Centralian Players (for example, tickets you forgot to buy last time you were on the relevant website, or from reading a synopsis of a new show) or simply from The Centralian Players banners or ads you have previously clicked on.
We implement industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorised access or use or loss of your data. We also make sure that when we are required to share your data with third parties, they are subject to suitable confidentiality and security standards.
Despite these measures, the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
We will store your data for as long as you have an active The Centralian Players account*, or as long as is needed to be able to provide the services to you and/or where you are still happy to hear from us about our latest news, products and services.
After this, we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax or other financial reasons (such as being able to deal with chargebacks), where we need to resolve any disputes with you, or where we need to enforce our terms and conditions).In such circumstances, we will only retain the amount of data strictly necessary for these reasons and otherwise, will remove your data from our systems.
*If you’ve not used your account for more than three years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we’ll close the account and delete or anonymise the personal data associated with it (unless the above applies).
You have certain rights under the GDPR which entitle you, in certain situations, to:
Please contact us if you would like to exercise your rights, which you can do for free. The only time we may be allowed to charge a reasonable fee is where your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Otherwise, we will always respond within one month (unless there is a legal reason to take longer).
We may also need to ask you to confirm your identity before we proceed with your request if it is not clear who is making the request.
If you are concerned about the way we are handling your personal data you may also contact the ICO (Information Commissioner’s Office). However, where possible, we would really appreciate the opportunity to help with your concern in the first instance.
We may change this policy from time to time, to reflect how we are handling your data and will upload these updates onto our websites. If we make significant changes, we will make sure these are notified to you by email or other suitable method so that you are able to review the changes before you continue to use our services.
If you would like to discuss anything in this policy, want to exercise your rights or have any issues with the way we are handling your data, please:
Last Updated: 29 January 2022