Privacy policy
What personal information BNJC holds, why, who it is shared with and how to ask about it.
Part of Policies and safeguarding.
This policy explains how personal information is used at BNJC, 29-31 New Church Road, Hove BN3 4AD, by three organisations. Each is responsible, as the controller, for the information it needs for its part:
- Brighton & Hove Jewish Community (BNJC), registered charity 1195729: the community programme, events, membership, donations, the mailing list and this website.
- BNJC Trading Ltd: stays, payments made on this website for tickets and stays, and the Limmud prize draw.
- Novellino Brighton Ltd: Yofi, the restaurant and deli, including table bookings and orders.
The three share one customer record, so that each person has one record across events, stays and Yofi. They follow the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003.
What information is collected?
The personal information that we collect includes:
- name, title, date of birth and gender
- contact details including postal address, email, phone numbers and links to social media accounts
- transaction history. Card payments are taken by Stripe: card details go straight to Stripe and are never seen or stored by BNJC. Only the card type and last four digits are kept, to identify a payment.
- Bank details for direct debit instructions (fully encrypted in our CRM database)
- access requirements (for example if you require wheelchair access, audio description, BSL interpretation, or any other access requirement) and whether you have a disability defined by the Equality Act 2010.
- details of visits to our website, including the pages you visit. If you accept analytics cookies and later book, fill in a form, open a link in a BNJC email or sign in, the pages visited on that device are added to your record. See the cookie policy.
- CCTV images of you in and around the Hub, used only for safety and security
- photographs and videos taken at events and in public spaces, which may be used to promote BNJC (notices are shown when filming, and you can ask not to be included)
- other background personal information and sensitive data you provide to us (for example when you apply for a job, take part in an educational project, provide a reason for making a donation or correspond with us).
- we may also collect information about race, ethnicity and sexual orientation (you have the right to decline to provide us with this information)
How information is collected
We collect your information when:
- You contact us by phone or by email to book a stay, purchase event tickets, join as a member, make a donation, attend a free or fundraising event, make an enquiry, sign up to our mailing list, give us your access and/or dietary requirements, or to provide feedback.
- You email us with any information relevant to your booking, fundraising or conferencing event, including Access Requirement, Dietary requirements, Providing feedback
- You visit our websites: through your I.P address given to us by your browser and through Cookies
- You purchase tickets to our shows via a third party
- You reply to a survey we have sent and choose to supply your personal data.
- You communicate with us via social media
- You appear on footage via CCTV in our venues. We use CCTV recording equipment in and around our venues for monitoring and security purposes in line with CCTV guidelines and licensing.
- You appear on filming and photography in our public spaces. We will always display notices when filming or taking photographs and where possible give individuals the option to not be captured
We may collect any of this information from a person working on your behalf with your consent such as a personal assistant.
Third parties organisations
We may also obtain your data from third parties such as organisations with which we enter into a co-production.
You should check their privacy policy when you provide your information to understand fully how they will process and safeguard your data.
Social Media
We use social media to broadcast messages and updates to our community about events and news. On occasion we may reply to comments or questions you make to us on social media platforms. You may also see adverts from us on social media that are tailored to your interests.
Depending on your settings or the privacy policies for social media and messaging services like Facebook or Instagram, you might give us permission to access information from those accounts or services.
Publicly available information
For a small number of our audience where we want to better understand engagement with BNJC and potential interest in supporting us further, we may collect information such as job history, political preferences, and philanthropic activities from places such as Companies House and other business related resources, the internet or information that has been published in articles/newspapers.
How your data is kept secure
BNJC is committed to protecting the personal information you entrust to us. Your personal data will be held and processed on BNJCs systems or systems managed by suppliers on behalf of BNJC to hold a record of your interactions with BNJC. These interactions include ticket purchases, donations, memberships, queries, complaints, correspondence and attendance at special events.
BNJC also conducts regular data hygiene processes which keeps the personal data we hold clean, up-to-date, and free of duplication. We aim to keep a single record for each customer.
Access to personal information is strictly controlled and can only be accessed by staff who need it to do their job. Sensitive data is additionally controlled and only made available to those who have a reason to work with it.
Who your data is shared with
- We may need to disclose your details:
if we run an event in partnership with another named organisation so that they can help us run the event - In order to comply with any legal obligation to do so. This includes the police and other crime protection and detection agencies or regulatory bodies
to our legal advisors to assist with dispute resolution and contract queries
for the purposes of regulatory or inspection compliance, for example to the Charity Commission - To funding bodies, who may use anonymised personal information to analyse our community engagement activities, event ticket sales, stay bookings and self-generated funding to understand the impact of the investment made in BNJC
- Data processing services acting in an accordance with our instructions, and subject to confidentiality obligations
The main services that process personal information for BNJC are:
- Stripe: card payments for each of the three organisations. Each organisation takes its own payments; card details are not passed between them.
- SendGrid (Twilio): sending booking confirmations, reminders and other emails.
- Google Analytics: counting website visits, only if you accept analytics cookies.
- Meta (Facebook and Instagram): measuring BNJC adverts, only if you accept marketing cookies.
- Toast: Yofi table bookings.
- The company that hosts this website and its database.
Some of these companies process information outside the UK, for example in the United States. Where they do, the transfer is protected by UK adequacy regulations or by the International Data Transfer Agreement or Addendum approved under UK law.
We do not sell personal details to third parties for any purpose nor will we share your personal data with any other organisations or promoters unless we have your explicit consent to do so. These third party organisations will be named at the point of data collection and your provision of consent to receive information from them.
Why data is collected, how it is used and the basis for processing
We aim to be clear when we collect your data and not to do anything you wouldn’t reasonably expect. The main way we use your information is to provide the services you’ve requested. We may process your personal data because it is necessary for the performance of a contract, for example:
- Sending out a ticket to your address if you’ve made a ticket purchase
- Reminders, updates and feedback requests when you sign up to an event or make a donation
- To invite you to events as part of your membership benefits
- To send you information as part of your stay booking
- To process payments assist us with internal administration
- To enable recruitment and employment processes
- To provide the best possible customer service
We have legal obligation for building and venue security and so use CCTV recording equipment in and around our premises.
We may also process your data where we have a legitimate interest to do so for example:
- To Learn about your interests and preferences so that we can contact you with information that is relevant to you i.e. future events and community engagement opportunities.
- To help us target our marketing and development communications and adverts so that they’re more relevant to you and to give you an exceptional experience
- To better understand your reasons for donating to us.
- To carry out screening on potential donors and to conduct due diligence on major donors (please also see the section below on Research, Profiling and ‘Wealth Screening’)
- To analyse how you use our services (including our websites) to help us better understand our audiences and customer base and to improve our processes.
- We also use films, photographs and audio for promotional purposes on our websites, social media accounts and other formats where it would not be necessary, appropriate or practicable to obtain your specific consent.
- To participate in research and data analysis as required by our funders. This allows us to understand our audience in a local and national context and helps us to identify new audience opportunities.
- To enable us to fundraise effectively because we are a charity
We may also process your personal data (including sensitive personal data) where:
- it is necessary for medical purposes (for example, in a medical emergency)
- it is necessary to protect your or another person’s vital interests
- we have your consent to do so for example photography consent as part of creative learning and Music and Arts project participation including parental consent for all participants up to 18 years.
- we will ask for your consent to provide you with information about products and services and fundraising activities which may be of interest to you (apart from where it is appropriate for us to rely on our legitimate interests to do so).
If you have opted out of marketing communications, we may still get in touch with you. For example, as mentioned above we may email you to give you important information about the events you’ve booked or to tell you about any changes.
BNJC as a charity and how we respect our donors. BNJC relies on charitable support to maintain work in the community and to make this available to everyone.
You can receive information about supporting BNJC by contacting our Head of Marketing by email, over the phone or in person. We will tell you about our current campaigns that we think are most relevant to you and ways that you can make a real difference to our community programmes.
Research, profiling and ‘wealth screening’
Our donors tell us that tailored and relevant communication is a priority for them, and we constantly review this and listen to you to make sure we are getting this right.
We want to ensure our communications to our supporters are personal, relevant and timely and we want to give you an enhanced experience when you attend events by introducing you to artists or members of staff that we think you might enjoy meeting. To ensure that our communications are relevant to you and your interests and to assess your likely ability to make, and interest in making, donations to BNJC, we may use additional information such as geographical information and measures of affluence where available from external sources to assist us. This will be a combination of publicly-available information, for example drawn from company resources and news media, with what you have provided to us, such as past donations and career information. We may use the services of external screening/profiling companies, and publicly available data from social media sites like LinkedIn, Facebook and Instagram, depending on your privacy settings and/or interaction with us.
BNJC may hold personal data that has been created by us from other personal data that we already hold about you, either from internal or external research/profiling. This may be carried out by automated or manual processes and enables us to better understand you as our supporter and make appropriate requests for support. A list of publicly available sources of information used by BNJC for the purposes detailed is available on request.
If you do not wish BNJC to undertake this activity, please email info@bnjc.co.uk.
Please note however that before seeking or accepting major donations we are required to conduct a minimum level of due diligence, including reviewing publicly available personal data. Due diligence is conducted in accordance with BNJC’s gift acceptance policy.
How long information is kept
We consider our relationship with audiences, donors and other stakeholders to be life-long. This means that we will maintain a stakeholder record for you until such time as you tell us that you no longer wish us to keep in touch. In this instance BNJC will delete the majority of your personal data we hold (except where we have a legal obligation to retain information),and will maintain basic personal data to ensure that we do not inadvertently create a new record in the future.
Employee records are maintained for 6 years after leaving the organisation and job application information will be held for up to one year for unsuccessful applications
Some information may also be retained indefinitely for historical, statistical or research purposes.
Limmud prize draw
If you enter the Limmud Festival prize draw at bnjc.co.uk/limmud, BNJC Trading Ltd keeps your name and email address, the link to the social post you shared to enter (to check the entry; it is kept and deleted with the entry), whether you said you were 21 or over, how you found the draw (the link you came from), and, if you played the Bagel Toss, the level and score. These are held in your BNJC customer record. We use them to run the draw, contact winners and answer any question about it, because entering the draw is an agreement between you and BNJC. If you are drawn as a winner, your name and email address are passed to Limmud to check that you hold a Limmud Festival ticket, and, for the third prize, so Limmud can give you the prize. Winners’ first names may be announced. If you don’t win and didn’t ask for news, your details are deleted 3 months after the draw closes. Winners’ details are kept until 6 months after the prize deadline. If you pressed “Send me news and updates”, BNJC emails you about its work and events until you unsubscribe, and you can unsubscribe at any time.
Your rights
Under UK data protection law you have the following rights which can be exercised by contacting BNJC and submitting a subject access request:
- To obtain access to, and copies of, the personal data that we hold about you
- To require that we cease processing your personal data if the processing is causing you damage or distress
- To require us not to send you marketing communications
- To require us to correct the personal data we hold about you if it is incorrect
- To require us to erase your personal data
- To require us to restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal)
- To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller
- To object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you are unhappy with how your information has been handled, please contact BNJC first (below). You also have the right to complain to the Information Commissioner’s Office: ico.org.uk/make-a-complaint, 0303 123 1113.
Contact
Please contact us if you have any questions about our privacy policy or information we hold about you or would like to submit a subject access request:
Email us at info@bnjc.co.uk
Write to us at: Data Protection, BNJC, 29-31 New Church Road, Hove, BN3 4AD
