PRIVACY POLICY

Privacy Policy – The Civic Trowbridge
Including Longfield Community Centre

1. Introduction

The Civic Trowbridge needs to collect and use personal information so that we can:

• Keep you informed about our shows, events, and services
• Enable you to purchase and pay for tickets
• Allow you to hire our venues and use our facilities

For the purposes of this notice, references to “the venues” include Trowbridge Civic Centre and Longfield Community Centre.

When we collect, store, use, and delete personal data, we do so in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Notice applies specifically to data processing carried out by The Civic Trowbridge in relation to events, venue hire, and conferencing. It does not apply to other areas of Trowbridge Town Council’s data processing, including Active Trowbridge or Trowbridge Museum. Further information about how those services process personal data is available on their respective websites or via a member of the Civic team.

Trowbridge Town Council is the data controller for all personal data collected, stored, and processed in relation to events organised by the Civic team.

The Council is registered with the Information Commissioner’s Office (ICO) for the purposes of processing personal data.

2. When This Privacy Notice Applies

This notice explains how we process personal data when you:

• Use the Civic website
• Visit the venues
• Attend an event or conference
• Correspond with us by post, email (including marketing bulletins), or telephone
• Are captured in photographs or video footage taken for promotional purposes

3. How We Collect Your Personal Data

We collect personal data from you when you:

• Hire one of our venues
• Purchase tickets for events
• Contact us by email, telephone, or post
• Visit the venues where CCTV is in operation

4. Information We Collect and How We Use It

Depending on the nature of your interaction with us, we may collect, store, and use the following categories of personal data:

• Name
• Postal address
• Telephone number
• Email address
• Bank or payment details
• CCTV footage
• Photographs and video recordings
• Access requirements
• Anonymised technical data (including IP address and cookies)

Special Category Data

In limited circumstances, we may collect more sensitive personal data, such as information relating to health or disability. This will only occur where:

• You have informed us of access or seating requirements, or
• You are attending a Civic-organised event where dietary requirements are required for catering purposes

This information is processed only for the specific purpose for which it is provided and handled with appropriate safeguards.

Please refer to our Essential Companion Scheme Privacy Notice here.

5. Purpose and Lawful Basis for Processing

We will only use your personal data where the law allows us to and for the purpose for which it was collected. This includes processing personal data where:

• You hire a venue
• You purchase tickets online, or in person
• We need to notify you of changes to an event (e.g. start time, cancellation, cast changes, or updated terms and conditions)
• You have consented to receive marketing or promotional communications
• CCTV footage is used in accordance with our CCTV Policy
• We need to investigate complaints, legal claims, incidents, or health and safety matters
• Issuing a refund

Lawful Bases

Our lawful bases for processing personal data include:

1. Contract
   Where you enter into a contract with us by hiring a venue or purchasing a ticket.
2. Consent
   Where you have explicitly agreed to receive marketing and promotional communications. You may withdraw consent at any time.
3. Legitimate Interests
   We may process personal data where it is necessary for our legitimate business interests, provided these do not override your rights and freedoms. This may include:

• Preventing and detecting fraud
• Analysing use of the Civic website to improve content and usability
• Sending post-event or post-show surveys
• Gathering feedback to improve events, services, and facilities
• Analysing anonymised browsing behaviour using cookies
• Using photographs and video footage to promote our shows and events

6. Data Sharing and Transfers

The Civic uses third-party data processors to collect, process, and store personal data securely and in compliance with UK GDPR.

Our processors include:

• Brightside Marketing Solutions Ltd
• PayPal
• Google Analytics
• Tickera
• Rialtas
• Campaign Monitor (Marigold)

Each processor has its own privacy notice, which explains how they handle personal data.

We may also share information where required for the prevention or detection of crime, including with the police or other bodies with lawful authority.

Personal data may be shared internally with the Community Engagement & Governance Manager, for example in connection with complaints or the exercise of individual rights.

Safeguarding and Protection of Individuals at Risk

The Council may share personal information with the Police, local authorities, safeguarding partners, regulatory bodies, or other relevant agencies where it is necessary to protect a child, young person, vulnerable adult, or another individual at risk of harm, or where disclosure is otherwise required or permitted by law. Any such sharing will be undertaken in accordance with the UK GDPR, the Data Protection Act 2018, and the Council’s Safeguarding Policy.

Ticket Sales on Behalf of Hirers

Where the Civic sells tickets on behalf of a third-party hirer, Trowbridge Town Council remains the data controller unless and until personal data is transferred.

• Personal data will only be transferred with explicit consent
• Data shared is limited to name and email address
• Transfers are secure

Once transferred, the hirer becomes the data controller, and any requests relating to data rights or withdrawal of consent must be directed to them.

7. Retention of Personal Data

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, and reporting requirements.

Details of retention periods are set out in our Retention Policy and Schedule, available via our Information Governance page.

When determining retention periods, we consider:

• The amount, nature, and sensitivity of the data
• The risk of harm from unauthorised use or disclosure
• The purposes of processing
• Legal and regulatory requirements

In some circumstances, personal data may be anonymised and retained for statistical or analytical purposes.

8. Social Media

We use social media platforms to promote events and engage with audiences. Each platform operates as a separate data controller:

• Facebook (Meta)
• Instagram
• LinkedIn

Please refer to the relevant platform’s privacy notice for information on how your data is processed.

9. Your Rights

You have the right to ensure that the personal data we hold about you is accurate and up to date.

Your rights include the right to:

• Request access to your personal data (Subject Access Request)
• Request correction of inaccurate or incomplete data
• Request restriction on the destruction of records approaching the end of their retention period
• Request transfer of your personal data to another party

Requests relating to access, restriction, or transfer should be directed to the Community Engagement & Governance Manager. Requests to update contact details may be directed to the Civic team.

There is no fee for exercising your rights. However, a reasonable charge may be applied for multiple copies of the same information.

Where processing is based on consent, you have the right to withdraw that consent at any time. Once withdrawn, we will stop processing the data for that purpose unless another lawful basis applies.

10. Contact details

Community Engagement & Governance Manager
Trowbridge Town Council
St. Stephens Place
Trowbridge
BA14 8AH
informationgovernance@trowbridge.gov.uk
01225 765072

Data Protection Officer
One West
i-west@bathnes.gov.uk
01225 395959

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. However, they would normally expect you to have raised your complaint with us in the first instance.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk
0303 123 1113