The Royal Academy of Music respects your privacy and is committed to protecting your personal data
This privacy notice sets out how the Academy processes the personal data of supporters and friends of the Academy, alumni, ticket buyers, corporate contacts, prospective students and applicants. This privacy notice should be read in conjunction with any other privacy or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are aware how and why we are using your data. We want to be as transparent as possible in the way in which we use your information so that you can be comfortable in providing the information to us and be clear on why we need certain information.
Contact details
Royal Academy of Music
Marylebone Road
London
NW1 5HT
Data protection registration number: Z4819206
Data Protection Officer: dpo@ram.ac.uk
Changes to the privacy notice and your duty to inform us of changes
This privacy notice may be updated from time to time; where necessary and possible, we will notify you of any changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.
The data we collect 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).
We may collect, use, store and transfer different kinds of personal data about you. We have grouped these different kinds of personal data together as follows:
Includes first name, maiden name, last name, username, stage name or similar identifier, or relationship to other Academy friends and supporters.
Includes home address, correspondence address, business address, social media accounts, personal websites, email addresses, telephone numbers and contact preferences.
Includes alumni documentation, passports and photos
Includes briefing profiles, due diligence reports, financial asset information, wealth estimations, network connections and memberships.
Includes Academy interactions, Academy memories and case studies, family and social circumstances, education and biographical information (such as birth date and marital status), competitions and prizes, Academy supporter participation, interests and volunteering.
Includes event booking history, digital communication history such as website clicks and email opens, philanthropic history such as giving, fundraising requests and engagement, postal communication history and volunteering hours.
Includes bank account and/or payment card details and details of transactions with the Academy, such as concert ticket purchases, donations of gifts, actual giving history and potential future gifts and HMRC Gift Aid scheme status.
We process data from applicants for the purpose of managing the admissions process, assessing and confirming an applicant’s suitability for a programme of study and decide to whom to offer a place.
The legal bases for processing applicant data are as follows:
- On the grounds of contractual requirement or to take steps to enter into a contract with you e.g., to offer you a place on a programme of study at the Academy.
- Because it is necessary for the performance of a task carried out in the public interest (fair admissions).
- Because it is necessary for our or a third party’s legitimate interests.
- To allow us to comply with our legal obligations.
- To protect your or another person’s vital interests.
- To monitor equality and diversity.
- Because you have given us your consent or, in the case of special category data, your explicit consent.
We process your data for the following reasons:
- to operate admissions and selection processes;
- to form the basis of a student record, should you be offered a place of study at the Academy;
- to enable effective communication with you as an applicant;
- to review references as part of your application;
- to review video submissions as part of your application;
- to verify English language test scores and academic qualifications;
- to ensure effective general recruitment and admissions administration, including the analysis of applicant numbers and trends to improve our processes;
- to compile returns for reporting purposes;
- to provide evidence that the University has met UKVI requirements in relation to the Student Sponsor guidance;
- to assess eligibility for an audition fee waiver and transport contribution;
- to assess applicant financial support applications;
- to assess an applicant’s fee status;
- to assess relevant mitigating circumstances;
- to make appropriate reasonable adjustments to the audition process;
- to meet the audit requirements of funding providers.
We may share your data with:
- Other HE institutions in relation to the admissions process.
- Verification organisations (e.g. UK ENIC, CHESSIC etc.) for the purpose of verifying qualifications and English language tests.
- Flywire, for the purpose of making a deposit payment (if applicable).
- Higher Education Statistics Agency (HESA), for the purpose of data reporting.
- Third parties that process data on behalf of the Academy to support it in fulfilling its obligations and responsibilities to and relationship with you (e.g., software and system providers) including UCAS, Ellucian, Dot Digital, etc.
- Third parties who award financial scholarships.
We do not collect any special category data as part of our day-to-day operations aside from when considering mitigating circumstances in the admissions process in order to provide reasonable adjustments for audition or audition fee waivers.
We collect information about criminal convictions as part of gift acceptance Due Diligence process. When gathering the data we will be transparent about the purpose for its collection and link it back to this privacy notice.
We collect personal data to provide the highest quality alumni and supporter services. In the unlikely event where we need to collect personal data by law, or in order to provide educational services and the subject fails to provide that data when requested, we may not be able to provide access to our external facing services. In this case and if we are aware of it, we will contact you with a view to resolving the issue and continuing our relationship.
How we collect data
We use different methods to collect data from and about you:
Digital Systems, including website visits, payments and donations, data collection forms, event bookings, survey submissions, social media interactions, and email interactions.
Analogue Systems, including data collection forms, gift forms, received letters, phone calls and in-person visits to the Academy.
Third party/ Appending, including Royal Mail National Change of Address Register (NSOA), Fundraising Regulator – Fundraising Preference Service (FPS), referrals from supporters of the Academy, public domain website research, subscribed research and due diligence tools. We may also collect data from third party organisations involved in the services provided by the Academy that have obtained the information in the first instance, for example mailing houses completing data cleanse checks before mailing distribution.
Hosting, including Box Office services for cultural touring companies.
Sensitive personal data/ special category data, obtained directly from you, usually through direct relationships.
If we collect any personal information from a third party source we will inform you of the collection and our purpose of processing within 30 days.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- For our legitimate interests (or those of a third party) where your interests and fundamental rights do not override those interests.
- Where you have given consent for your information to be used based on preferences you have communicated with us.
- Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data. We rely on legitimate interest in the first instance for the purpose of using the personal data of friends, supporters, alumni, ticket buyers and prospective students. External parties are provided with regular opportunities to update both their contact preferences and the consent given under which the Academy is permitted to use their data.
We have set out below a description of the main ways we plan to use your personal data, and which legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
1. Marketing for concerts
Type of data:
- Identity
- Contact
- Contextual
Lawful basis for processing:
- Legitimate interest
- Consent
2. Direct marketing (campaigns/ appeals)
Type of data:
- Identity
- Contact
- Contextual
Lawful basis for processing:
- Legitimate interest
- Consent
3. Administration, e.g. contact about an event you’ve registered for or a gift you’ve made as part of our application process
Type of data:
- Identity
- Contact
- Contextual
Lawful basis for processing:
- Legitimate interest
- Contractual obligation
4. Screening in order to identify donors
Type of data:
- Identity
- Contact
- Contextual
Lawful basis for processing:
- Legitimate interest
5. Security
Type of data:
- Image/CCTV footage
Lawful basis for processing:
- Legitimate interest
6. To capture your image in video footage or photographs for the purpose of promoting the Academy
Type of data:
- Identity (photographic image)
Lawful basis for processing:
- Legitimate interest
- Consent
7. To operate admissions selection processes
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
Lawful basis for processing:
- Contractual obligation
- Legitimate interest
8. To form the basis of a student record, should you be offered a place to study at the Academy.
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
Lawful basis for processing:
- Contractual obligation
- Legitimate interest
9. To enable effective communication with you as an applicant
Type of data:
- Identity
- Contact
Lawful basis for processing:
- Contractual obligation
- Legitimate interest
10. To review references as part of your application
Type of data:
- Identity
Lawful basis for processing:
- Contractual obligation
- Legitimate interest
11. To review video submissions as part of your application
Type of data:
- Identity
Lawful basis for processing:
- Contractual obligation
- Legitimate interest
12. To verify English language test scores and academic qualifications
Type of data:
- Identity
Lawful basis for processing:
- Contractual obligation
- Legitimate interest
13. To provide evidence that the Academy has met UKVI requirements in relation to the Student Sponsor guidance
Type of data:
- Identity
- Contact
- Identity evidence
- Financial data
Lawful basis for processing:
- Contractual obligation
- Legal obligation
14. To assess eligibility for an audition fee waiver and transport contribution
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
- Special category
Lawful basis for processing:
- Public interest
- Legal obligation
15. To assess applicant financial support applications
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
Lawful basis for processing:
- Contractual obligation
- Legal obligation
- Public interest
16. To assess relevant mitigating circumstances
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
- Special category
Lawful basis for processing:
- Contractual obligation
- Legal obligation
- Public interest
17. To make appropriate reasonable adjustments to the audition process
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
- Special category
Lawful basis for processing:
- Contractual obligation
- Legal obligation
- Public interest
18. To meet the audit requirement of funding providers
Type of data:
- Identity
- Contact
- Identity evidence
- Financial
- Special category
Lawful basis for processing:
- Contractual obligation
- Legal obligation
- Public interest
19. To maintain an archive for historical record
Type of data:
- Basic studentship
Lawful basis for processing:
- Legitimate interest
1. To meet our obligations for the Graduate Outcomes Survey.
Type of data:
- Identity
- Contact
Lawful basis for processing:
- Legal obligation
Change of Purpose
We will only use your personal data 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 you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the sections above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We ensure there is a liability clause in all contracts with our third-party partners. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
We do not transfer the personal data of external persons, including applicants, outside the European Economic Area (EEA).
Where necessary service providers are based outside of the UK and EU, we may transfer limited data to approved contractors, under the conditions described above. Whenever any international transfers are made, we ensure we have the appropriate safeguards in place to protect your personal data.
Data Security
We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an authorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have benchmarks regarding the adequacy of our data systems and the supplier that are in place, and where applicable data privacy impact assessments have been conducted.
Data retention - how long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes.
Please refer to our Data Retention Policy for more information on the specific retention of your data.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You will not have to pay a fee to exercise your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
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 will notify you and keep you updated.
We aim to offer supporters of the Academy a superior experience when they fund the future of music through our programmes. Donors and prospective donors can opt-out of communications from the Academy at any time. Alternatively, they have the option to opt-out through the Fundraising Regulator, using the Fundraising Preference Service. The Academy will be notified of this and we will update our systems accordingly.
Glossary
Legal 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 and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to 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: dpo@ram.ac.uk
Performance of contract means processing your data 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.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for a compliance with a legal or regulatory obligation that we are subject to.
External third parties
These are:
- Service providers acting as processors based in the EU who provide IT and system administration services (such as Unit 4/Ellucian, who manage our student records system(s)).
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Other external service providers.
Action you can take
If you wish to exercise any of the rights set out below, please contact us.
You have the right to:
Commonly known as a 'data subject access request'. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
This enables you to ask us to delete or remove personal data 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 data 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 data to comply with local law. 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.
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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Where we are relying on consent to process your personal data. However, this will not 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us to raise any concerns in the first instance.