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 Independent Members appointed to of the Governing Body (Trustees) and external members appointed to the Academy’s Committees. This privacy notice should be read in conjunction with the privacy notice for donors and friends of the Academy, 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 understand 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 confident 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 varied 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 during the term of your appointment.

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, record and transfer different kinds of personal data about you which we have grouped together as follows:

Includes first name, maiden name, last name, username or similar identifier, marital status, title.

Includes passport or Driving Licence for the purpose of validating your identity as part of your initial appointment.

Includes family and social circumstances, education and biographical information, business and personal interests, attendance at Academy events.

Includes details of any transactions with the Academy, such as donations, and potential to support the Academy.

Includes CCTV footage captured in and around Academy premises and also photographs and video footage we commission or capture for the purposes of marketing, publicity and assessment/study.

We may also collect and use Special Category personal data including racial or ethnic origin, religious or philosophical beliefs, sexuality, physical and mental health data.

We collect personal data about you to fulfil our responsibilities as a registered charity, company registered with Companies House and higher education provider registered with the Office for Students, to assess your eligibility and continuing suitability as an independent member of the Governing Body (Trustee) or external member of Academy Committees, and to support a range of operational activities. We may also collect information about criminal convictions. Some of this data is collected to fulfil our reporting requirements to the Higher Education Statistics Agency. When collecting the data we will be transparent about the purpose for its collection and link it back to this privacy notice.

How is your personal data collected?

We use different methods to collect data from and about you:

  • Personal data and sensitive personal data/special category data is obtained directly from you, usually during the appointment process.
  • Annual declaration of interests for the Academy’s Register of Interests is obtained directly from you and may be cross referenced with data from other reputable sources such as the Charity Commission and Companies House.
  • We may collect data from other reputable sources such as the Charity Commission and Companies House, third party organisations such as recruitment consultants and other contacts known to the Academy.
  • We may seek references as part of our due diligence during the appointment process.
  • We may also collect data about you from media and social media.
  • Image data may be collected at any time during your term of appointment.

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:

a. Where we need to perform the contract we are about to enter into or have entered into with you.

b. 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.

c. Where we need to comply with a legal, regulatory or operational obligation.

d. When we use social media to broadcast messages and updates about events and news.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

When we collect and use special category data as part of statutory returns, this information is held securely within the Human Resources database.

Purposes for which we will use your personal data

We have set out below a description of the main ways we plan to use your personal data, and which legal basis/bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

1. To appoint you as an Independent Member of the Governing Body (Trustee) or external member of a Committee.

Type of data:

  • Identity
  • Contact
  • Contextual
  • Financial
  • Image
  • Special category

Lawful basis for processing:

  • Performance of a contract

Further information and retention period:

  • Retained in perpetuity as part of the Academy’s historic archive

2. Annual declaration of interests for the Academy’s Register of Interests.

Type of data:

  • Identity
  • Contextual

Lawful basis for processing:

  • Legal obligation/ Public task

Further information and retention period:

  • Duration of appointment

3. Security

Type of data:

  • Image/CCTV footage

Lawful basis for processing:

  • Public task

Further information and retention period:

  • 30 days unless retained as part of an internal investigation or legal process

4. To capture your image in video footage or photographs for the purpose of promoting the Academy.

Type of data:

  • Identity (video/ photographic image)

Lawful basis for processing:

  • Performance of a contract

Further information and retention period:

  • Video footage and/or photographs may be held in perpetuity as part of the Academy’s historic archive

Purposes for which we will share your personal data outside of the Academy

1. To meet our obligations for statutory reporting, for instance to the Charity Commission and Companies House.

Type of data:

  • Identity
  • Contact
  • Special Category

Lawful basis for processing:

  • Legal obligation

Further information and retention period:

  • In perpetuity

2. To meet our obligations to provide audited end of year financial statements.

Type of data:

  • Identity

Lawful basis for processing:

  • Legal obligation

Further information and retention period:

  • In perpetuity

3. To meet our obligations for statutory reporting to HESA and the Office for Students.

Type of data:

  • Identity
  • Contact
  • Special Category

Lawful basis for processing:

  • Legal obligation

Further information and retention period:

  • Duration of appointment

4. To meet the requirements of our service providers, such as internal and external auditors, bankers and insurers.

Type of data:

  • Identity
  • Contact
  • Special Category

Lawful basis for processing:

  • Legal obligation

Further information and retention period:

  • Duration of appointment

5. To meet our obligations in answering Freedom of Information requests.

Type of data:

  • Identity

Lawful basis for processing:

  • Legal obligation

Further information and retention period:

  • In perpetuity

6. Sending photographs to external organising for PR/marketing purposes or to third party organisations (eg production imagery).

Type of data:

  • Identity (video/ photographic image)

Lawful basis for processing:

  • Performance of a contract

Further information and retention period:

  • The period of the processing activity (sharing of data)

7. Maintaining relationships with donors/funding organisations/trusts.

Type of data:

  • Identity
  • Contact
  • Contextual
  • Financial

Lawful basis for processing:

  • Legitimate interest

Further information and retention period:

  • The period of the processing activity (sharing of data)

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 table in paragraph 8 above.

The Academy employs the services of third party photographers or videographers to shoot or record events. Please note that these individuals/organisations may hold the right to retain the images taken. Details on the organisations who may hold your images are available upon request.

  • Higher Education Sector organisations who require us to share your data, such as:
    • The Office for Students (OfS)
    • The Higher Education Statistics Agency (HESA)
  • Service providers such as internal and external auditors, bankers and insurers.

If you would like more details of organisations with whom we share your data, please contact dpo@ram.ac.uk

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 may transfer the personal data outside of the European Economic Area (EEA) in connection with:

  • Photographic images used in the Academy’s end of year financial statements, annual report, marketing and publicity materials.
  • Identity and contextual data used in connection with the activities of the American Society of the Royal Academy of Music (ASRAM).

Data security

We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, service providers 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 benchmark 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 and for the Academy’s archive.

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 the information in the table in paragraph 7 for information on retention periods.

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 access 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.

Glossary

Legal basis

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.

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.

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

Third parties

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based the UK who provide consultancy, banking, legal, insurance and accounting services.
  • Charity Commission, Companies House, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based the United Kingdom who require reporting of processing activities in certain circumstances.

Action you can take

If you wish to exercise any of the rights set out below, please contact us.

You have the right to:

Request access to your personal data (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.

Request correction of the personal data that we hold about you. 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.

Request erasure of your personal data. 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.

Object to processing of your personal data 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.

Request restriction of processing of your personal data. 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.

Request the transfer of your personal data to you or to a third party. 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.

Withdraw consent at any time 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.