Privacy Policy

At The British Academy of Songwriters, Composers and Authors (“BASCA”, “we,” “us” or “our”) we are committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, process and look after any personal information that we collect:

  • about you when you use our website at BritishComposerAwards.com or any related online or mobile service owned or operated by us (“Site”);
  • about members of BASCA and how that information may be used in connection with your membership; or
  • about non-members of BASCA, to the extent that we collect or process any personal information about you.

Further details of how we use your information are set out in our Cookies Policy, which forms part of this Privacy Policy.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information.

This Privacy Policy is provided in a layered format, so you can click through to the specific areas set out below.

By continuing to use the Site, or by otherwise providing us with your personal information, you acknowledge our collection, storage and use of your personal information as described below.

Contents:

  1. Important information and who we are
  2. What information do we collect about you?
  3. How do we collect your personal information?
  4. How and why do we use your personal information?
  5. Will we disclose your personal information to third parties?
  6. Do we transfer your personal information internationally?
  7. How do we protect your personal information?
  8. How long do we hold your personal information for?
  9. Your legal rights
  10. Glossary
  11. Changes to this Privacy Policy

  1. Important information and who we are

BASCA is the controller and responsible for your personal information.

We have appointed a data protection officer (DPO) to oversee any queries about this Privacy Policy.  If you have any such queries, including any requests to exercise your legal rights in relation to your personal information, please contact the DPO using the following details:

Name of DPO:     Lucy Skerritt

Email address:    info@basca.org.uk

Postal address:  Data Protection Officer, BASCA, 2 Pancras Square, King’s Cross, London N1C 4AG, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Informing us of changes

It is important that the personal information we hold about you is accurate and current.  Please keep us informed if your personal information changes during your relationship with us.

Third-party links

The Site, and our other communications with you, may contain links to other online or mobile sites.  We are not responsible and accept no liability for the privacy practice or content of such sites.

  1. What information do we collect about you?

The term “personal information” or “personal data” means any information about an individual from which that person can be identified.  It does not include information where the identity has been removed (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:

  • Identity Information includes your first name, last name, title, professional name/pseudonym, date of birth, gender, nationality, social media usernames or similar identifiers and collecting society identifier (i.e. IPI / CAE number).
  • Contact Information includes your billing address, delivery address, email address, telephone number(s) and online presence URLs (e.g. website or social media pages).
  • Financial Information includes your payment card or bank account details.
  • Profile Information includes your user name and password (for BASCA members), any information that you provide specifically to be used on the Site (e.g. your profile in the Directory area of the Site, or information that you post to any message forum on the Site), any services that we have previously provided to you, and your interests, preferences, feedback and survey responses.
  • Transaction Information includes details about payments to and from you and other details of services or products that you have bought from us.
  • Technical Information includes your internet protocol (IP) address, your log-in data, 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 that you use to access the Site.
  • Usage Information includes information about how you use the Site.
  • Communications Information includes your preferences for receiving communications from us and (if relevant) third parties.

We may also collect, use and share Aggregated Information such as statistical or demographic data for any purpose.  Aggregated Information may be derived from your personal information, but is not considered personal data in law, as such information does not directly or indirectly reveal your identity.  For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific Site feature.  If, however, we combine or connect Aggregated Information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information, which will be used in accordance with this Privacy Policy.

We do not typically seek to collect, and we ask that you do not provide us with, any Special Categories of Personal Data about you.  This would include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.  Nor do we seek to collect any information about criminal convictions and offences.  To the extent that you voluntarily provide us with any Special Categories of Personal Data about you (or any criminal conviction or offence information about you) – for example, because you have chosen to include such information within your member profile in the Directory area of the Site, or because we have specifically asked you for such information for a particular purpose (e.g. a diversity research study) – then we process that data with your explicit permission, which you give to us by providing that information to be used for that purpose.  You may withdraw that permission at any time by contacting us.

Where we need to collect personal information by law, or under the terms of a contract that we have with you and you fail to provide that information when requested, we may not be able to perform the contract that we have or are trying to enter into with you.  If so, we shall notify you if this is the case at the time.

  1. How do we collect your personal information?

We use different methods to collect information from and about you, including through:

  • Direct interactions: You may give us your Identity, Contact, Financial, Profile, Transaction and Communications Information by filling in forms on our Site or by corresponding with us by email, by post, over the phone, in person or otherwise. This includes personal information that you provide if you:
    • join BASCA as a member (or renew your BASCA membership);
    • add or update your profile in the Directory area of the Site, or post to a message forum on the Site;
    • order any of our services or products (e.g. tickets for an event);
    • submit a contact form via the Site;
    • send an email to any of our contact email addresses;
    • phone us, or meet us in person;
    • send us any correspondence by post;
    • attend one our events (where you may speak to us directly and/or appear in any photographs taken at the event);
    • request that we add you to our email mailing lists (for our newsletters etc.);
    • become a member of the BASCA Board or a BASCA committee;
    • enter a competition, promotion or survey; and/or
    • give us some feedback.
  • Automated technologies or interactions: As you interact with the Site, we may automatically collect Technical Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.  We may also receive Technical Information about you if you visit other websites using our cookies. Please see our Cookies Policy for further details.
  • Third-party sources: We may receive personal information about you from various third-party sources as set out below:
    • Technical Information from:
  • analytics providers such as Google based outside the EU;
  • social networks such as Facebook and Twitter based inside and/or outside the EU; and
  • search information providers such as Google based inside and/or outside the EU.
    • Identity, Contact and Transaction Information from third-party providers of technical, payment, fulfilment and delivery services, or from our partners that we may work with for the purposes of delivering benefits and services to our members and putting on events.
    • Identity, Contact and Transaction Information from collective management organisations (CMOs) that we may work with to assist overseas CMOs in identifying British music writers for whom they may be holding distributable revenue (for example, in relation to private and educational copying levies that apply in that CMO’s territory) and distributing that revenue to those writers.

 

  1. How and why do we use your personal information?

We shall only use your personal information when the law allows us to do so.  Most commonly, we shall use your personal information in the following circumstances:

  • where we need to perform any contract that we are about to enter into or have entered into with you, such as your BASCA membership arrangement and the performance of BASCA’s Articles of Association (Articles), or contracts for the sale of services or products to you (e.g. tickets for events);
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights and freedoms do not override our (or such third party’s) interests; and/or
  • where we need to comply with a legal or regulatory obligation.

Please refer to the Glossary below to find out more about the types of lawful basis that we shall rely on to process your personal information.

We do not generally rely on consent as a legal basis for processing your personal information other than, if you agree to receive such communications, in relation to the sending of third-party direct marketing communications to you via email, text message or post.  You have the right to withdraw consent to such marketing at any time by contacting us.

Purposes for using your personal information

We have set out below, in a table format, a description of all the ways that we plan to use your personal information, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information.  Please contact us if you need details about the specific legal ground that we are relying on to process your personal information where more than one ground has been set out in the table below.

 

Purpose

 Lawful basis for processing (including basis of legitimate interest)

To enrol you as a BASCA member, to renew your BASCA membership, and for our general record-keeping and administration to ensure that we deliver to you the benefits of your BASCA membership as set out in the Membership Benefits page of the Site (including allowing you to add and update your member profile within the Directory on the Site, and to use other Site functionality) (a) Performance of a contract with you (for BASCA members) (b) Necessary for our legitimate interests (to ensure that BASCA operates effectively for the benefit of all British music writers)
To manage our relationship with you, including:
• notifying you about changes to the Site T&Cs, including this Privacy Policy;
• delivering relevant Site content, newsletters, event invitations, industry updates and/or surveys to you and to measure or understand the effectiveness of any such communications we serve to you; and/or
• for BASCA members, contacting you to provide constitutional notices under the Articles (e.g. for annual general meetings), or in accordance with our statutory duties
(a) Performance of a contract with you (for BASCA members)
(b) Necessary to comply with a legal obligation (statutory duty)
(c) Necessary for our legitimate interests (to keep our records updated, to promote BASCA’s services and our role in the industry, to study and develop how people use our services, and to expand our business and to inform our marketing strategy)
To process and deliver the services and products you request from us (e.g. to provide you with tickets and admission to events, or providing legal or financial advice), including:
• managing payments, fees and charges;
• sharing your information with third parties whose assistance may be required to deliver such services to you; and/or
• collecting and recovering money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To publicise and report on BASCA’s events and initiatives and the achievements of our members (including by publishing event reviews and photo/video galleries from our events on the Site) Necessary for our legitimate interests (in pursuit of our objects to support British music writers (through various lobbying activities) and to celebrate excellence through our awards ceremonies and other events)
To conduct general research about the British music industry (e.g. to research and highlight equality and diversity issues) and to publish such research in aggregated form (from which no individuals can be identified) (a) Necessary for our legitimate interests (in pursuit of our objects to support and protect British music writers and to encourage new professional music writers)
(b) Consent (to the extent only that such research involves any processing of Special Categories of Personal Data, and with that data having been specifically volunteered by each individual for the particular research purpose)
To assist overseas CMOs in identifying British music writers for whom they may be holding distributable revenue and distributing that revenue to those writers Necessary for our legitimate interests (in pursuit of our objects to support British music writers and protecting copyright across the world)
To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To use data analytics to improve the Site, products, marketing, customer relationships and experiences Necessary for our legitimate interests (to define types of customers for our services, to keep the Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Necessary for our legitimate interests (to develop our services, to expand our business and to benefit you by providing interesting information)

Marketing

We strive to provide you with choices regarding certain uses of personal information, particularly around communications, where relevant.   Please contact us if you would like to discuss those.

Information from us about our services and products

We may use your Identity, Contact, Profile, Technical, Usage, and Communications Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services, products and offers it may be relevant for us to contact you about.

You may receive communications from us if you are a BASCA member, or you have previously requested services or information from us, or if you provided us with your details and asked to receive such communications and, in each case, you have not opted out of receiving those communications.

Third-party marketing

We will never share your personal information with any third party outside BASCA for marketing purposes, unless you have given your express prior opt-in consent to do so.

Opting out

If, at any time, you would like us to stop using your personal information or to correct any factual inaccuracies, just contact us by email or post.  Be sure to state “Opt-out” in the subject line, and to include your full name, username (if any) and email address in the message.

Please note that, for BASCA members, if you opt out from receiving general communications from us, we may still continue to contact you for the purpose of providing constitutional notices to you that are required under the Articles, or otherwise in accordance with our statutory duties to our members.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly.  For more information about the cookies we use, please see our Cookies Policy.

Change of purpose

We shall only use your personal information for the purposes for which we collected the information, unless we reasonably consider that we need to use such information for another reason and that reason is compatible with the original purpose.  If you would like to get an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal information for an unrelated purpose, we shall notify you and explain the legal basis on which we intend to rely.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, if and to the extent that this is required or permitted by law.

  1. Will we disclose your personal information to third parties?

We may share your personal information with the external parties set out below (“External Third Parties”) for the purposes set out in the table in section 4 above:

  • Service providers (acting as processors) who provide IT and system administration services to us (such as email, telephone and payment processing services), including CiviCRM (server based in Germany) which hosts our database and which is administered by Veda NFP Consulting LTD (based in the UK).
  • Service providers and partners (acting as processors or co-controllers) who help us deliver benefits to our members (as set out in the Membership Benefits page on the Site) and our other services (such as legal or financial advisory services, our workshops and seminars, discounts on services and products for our members, digital magazine production services, and event ticketing, hosting and administration services).
  • Our professional advisers (acting as processors or joint controllers), including lawyers, bankers, accountants and insurers, who are based in the UK and provide their respective professional services to us.
  • HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers), which are based in the UK and may require reporting of processing activities in certain circumstances.
  • CMOs (in the UK and overseas) that we may work with to assist them in identifying British music writers for whom they may be holding revenue and distributing that revenue to those writers.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Please also be aware that the Site is available to users across the world and that any user of the Site can access personal information about you to the extent made available on the Site.

  1. Do we transfer your personal information internationally?

As some of our External Third Parties are based outside the European Economic Area (EEA), their processing of your personal information will involve a transfer of information outside the EEA.  Whenever we transfer your personal data out of the EEA, we strive to ensure that a similar degree of protection is afforded to such information by ensuring that at least one of the following safeguards is implemented:

  • transferring your personal information to a country, organisation or sector that has, at the time of transfer, been deemed to provide an adequate level of protection for personal information by the European Commission;
  • using specific forms of contract approved by the European Commission that give personal information the same protection it has within Europe; and/or
  • transferring information to a provider based in the US if such provider is part of the Privacy Shield, which requires it to provide similar protection to personal information shared between Europe and the US.

For further details of such safeguards, please see the European Commission’s website.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal information to External Third Parties out of the EEA.

Please note that the Site is available to users across the world, and so personal information about you to the extent made available on the Site may be accessible outside the EEA when the Site is used by persons outside the EEA.  When you provide your personal information to us to be used on the Site (for example, any information added by you to your profile in the Directory on the Site, or to a message forum on the Site), then you do so on the understanding that territories outside the EEA may provide a lower standard of protection for your personal information and so there may not be adequate safeguards in place to protect your information.   To the extent that, in those circumstances, your personal information on the Site is accessed outside the EEA, that is done with your explicit permission which you give to us by providing that information for use on the Site.  You may withdraw that permission at any time by contacting us.

  1. How do we protect your personal information?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. How long do we hold your personal information for?

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected such information, including for the purposes of satisfying any legal, accounting or reporting requirements.

By law we have to keep basic information about individuals who purchase services or products from us (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your personal information: please see Request erasure below for further information.

In some circumstances we may retain records containing personal information where the retention and processing of that information is necessary for archiving in the public interest or historical research purposes.  For example, some of our archives from the mid-Twentieth Century are currently archived at the British Museum.  In those circumstances, we may use this information indefinitely without further notice to you.   Where information is retained and/or processed for those purposes, we will take technological and organisational steps to safeguard your rights and interests so that any information retained or used is the minimum necessary for those archiving or research purposes.

  1. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal information:

  • right of access to your personal information;
  • right to rectification of your personal information;
  • right to erasure of your personal information;
  • right to restriction of processing of your personal information;
  • right to portability of your personal information;
  • right to object to processing of your personal information;
  • right not to be subject to automated decision-making (including profiling); and
  • right to withdraw consent to processing of your personal information.

To find out more about these rights, please see section 10 below and the ICO’s website (www.ico.org.uk).

If you wish to exercise any of those rights, please contact us.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we may refuse to comply with your request in those circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and to ensure your right to access your personal information (or to exercise any of your other rights).  This is a security measure to ensure that personal information is not disclosed to any person that has no right to receive such information.  We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we shall notify you and keep you updated.

  1. Glossary

LAWFUL BASIS

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product/content and the best and most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, which may include:

  • for BASCA members, the performance of our contract to provide you with the benefits of BASCA membership and for the performance of our Articles which also constitute a contract between you and us (our Articles can be viewed by clicking here); or
  • contracts for the provision of services or products to you (e.g. tickets for events or seminars) entered via the Site, email or otherwise.

Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

YOUR LEGAL RIGHTS

In certain circumstances, you have the following legal rights in relation to your personal information:

  • Right of access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information that we hold about you and to check that we are lawfully processing such data.
  • Right of rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, although we may need to verify the accuracy of the new information that you provide to us.
  • Right to erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for our continuing to process such information.  You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law.  Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
  • Right to restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you would like us to establish the accuracy of such information; (b) where our use of the information is unlawful, but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information, but we need to verify whether we have overriding legitimate grounds to use it.
  • Right to portability of your personal information to you or to a third party. If you so request, we shall provide you, or a third party that you have chosen, with a copy of your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Right to object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you believe that it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
  • Right not to be subject to automated decision-making (including profiling) where that would have a significant effect on you. We do not in fact engage in such activities, so this right will not, in practice, be relevant in the context of your use of the Site.
  • Right to withdraw consent at any time where we are relying on consent to process your personal information. This will not, however, affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services, products, or content to you. We shall inform you if that is the case at the time when you withdraw your consent.

  1. Changes to this Privacy Policy

We may at any time update or otherwise modify this Privacy Policy. We will notify you of any changes to our Privacy Policy by posting the modified Privacy Policy on the Site.

This version was last modified on the date noted below, and historic versions can be obtained by contacting us.

Privacy Policy updated: May 2018

You can download a PDF of our Privacy Policy here.

 

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