Hastings Lit Fest Ltd. GDPR Privacy Notice
What is the purpose of this document?
HASTINGS LITFEST is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).
HASTINGS LITFEST is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
This policy applies to visitors to the Festival website and social media pages, to entrants to competitions, people signed-up to LITFEST emails or other newsletters, people reserving or buying tickets for LITFEST events and people who submit feedback on events. This notice does not form part of any contract to provide services. We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
Data protection principles
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
The kind of information we hold about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). It is likely that the personal data we will collect about you will be limited to your name and contact details.
Personal contact details such as name, title, addresses, telephone numbers, and personal
Date of birth.
Information about your health or disabilities if relevant to your attendance at an event, in order to ensure appropriate adaptations are available.
How is your personal information collected?
We typically collect personal information about people seeking information about the LITFEST, through the competition entry and ticket booking processes, but may sometimes collect this information through enquiries to our web site.
How we will use information about you
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We will use information about your health, or disability status, to ensure your health and safety in the workplace and to assess our ability to meet your requirements when you attend any LitFest event.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest [or for official purposes].
Situations in which we will use your personal information
We need your personal data primarily to allow us to perform our contract with you and to enable us to comply with legal obligations.
In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. (For example, letting a venue manager know the name of the attendees of the LitFest at the events held there so they can contact them in the event of a short-notice programme change)
The situations in which we will process your personal information are listed below.
Establishing the profile of people attending events.
Establishing the profile of the level of satisfaction of people attending events.
Establishing the profile of people entering competitions
Administering the contract we have entered into with you.
Business management and planning, including accounting and auditing.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Hastings Lit Fest Ltd. may use personally identifiable information (email addresses and/or telephone numbers) to send users announcements about the Festival (e.g. changes to Venues, new events on the programme).
Hastings Lit Fest Ltd. may request users to supply personally identifiable information as part of a promotion, competition or survey. This information will be used to contact winners and administer the promotion and/or competition. Information gathered from surveys is used by Hastings Lit Fest Ltd. to continually improve and upgrade our service offering and website. Any personally identifiable information collected from surveys, promotions or competitions is not, however, passed on to any third parties.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as ensuring that you are admitted to events you have booked), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our attendees).
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
We will not transfer your personal information outside the EU.
Why might you share my personal information with third parties?
We may share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities involved in the Lit Fest (e.g. Venues, performers, partners)
How secure is my information with third-party service providers and other entities?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
Links to other sites
The Hastings Lit Fest Ltd’s website contains links to other sites. These sites are beyond Hastings Lit Fest Ltd.’s control and the user is subject to the individual privacy policies of these sites. Whilst Hastings Lit Fest Ltd. strives to protect personally identifiable information collected from users of the site, we cannot guarantee the security of private information disclosed online to linked sites.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Details of these measures are available upon request.
Unfortunately, no data transmission or stored information is 100% secure. Thus, whilst Hastings Lit Fest Ltd. strives to protect user’s information as far as possible, Hastings Lit Fest Ltd. cannot ensure or warrant the security of any information that the user transmits to us.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your rights in connection with personal information
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
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 which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact one of the Lit Fest Directors in writing.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact one of the Lit Fest Directors. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you have any questions about this privacy notice or how we handle your personal information, please contact Sam Davey (email@example.com) who is acting as the Data Protection Officer for Hastings Lit Fest.
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.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy notice, please contact Sam Davey (firstname.lastname@example.org) who is acting as the Data Protection Officer