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Privacy Notice
25 May 2018

Literature Wales respects the privacy of every person who visits or registers with www.literaturewales.org (the “Website”) and is further committed to ensuring a safe online experience. Literature Wales also respects the privacy of every person who engages with the activity, opportunities and services (our “Services”) provided by Literature Wales.

1. Purpose of this Policy
This privacy notice (“Privacy Notice”) explains Literature Wales’ approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

This Privacy Notice will inform you of the nature of the personal data about you that is processed and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Website and our Services and/or to understand how your personal data may be processed as a result of providing the Services to others or as part of an application to work for Literature Wales. Please take a moment to read it.

Please note that this Privacy Notice only applies to the use of your personal data obtained by us, it does not apply to your personal data collected during your communications with third parties.

2. Who are we and what do we do?
The Website and our Services are operated by Literature Wales. Literature Wales is a Company Limited by Guarantee (Company no. 7779153) and a Charity (Charity no. 1146560) and whose registered office is at Literature Wales, Glyn Jones Centre, Wales Millennium Centre, Bute Place Cardiff Bay CF10 5AL.

Literature Wales includes the Tŷ Newydd Writing Centre which is located at Tŷ Newydd Writing Centre, Llanystumdwy, Cricieth, Gwynedd LL52 0LW.

3. How to contact us?
If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please contact us by:

E-mail: data@literaturewales.org
Telephone: 029 20472266

Post: Literature Wales
Glyn Jones Centre
Wales Millennium Centre
Cardiff CF10 5AL

4. What personal data do we collect and how do we use it?
Our primary goals in collecting personal data from you may be to:

• verify your identity;
• help us to deliver our Services;
• improve, develop and market new Services;
• carry out requests in relation to our Services;
• comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
• administer contracts and agreements;
• protect the rights, property or safety of us or third parties, including our other clients and users of the Website or our Services;
• provide support for the provision of our Services;
• recruitment purposes;
• other uses required or permitted by law.

To undertake these goals we may process the following personal data:

If you receive marketing material from Literature Wales:

• Name.
• Contact information.
• Demographic information such as postcode, preferences and interests.

If you are an applicant for a position at Literature Wales:

• Name and job title.
• Contact information including email address.
• Curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us.
• Other information relevant to potential recruitment.

If you are in receipt of our Services:

• Name and job title.
• Contact information including email address.
• Payment information.
• Other information relevant to provision of Services.
• Information that you provide to us as part of our providing the Services to you which depends on the nature of your agreement with Literature Wales.
• Relevant information as required by regulatory organisations, funders and other stakeholders.

The following is a non-exhaustive list which is reflective of the varied nature of the personal data processed as part of our business.

We may use your personal data for the following purposes:

i. Provision of services
We collect and maintain personal data that you submit to us to enable us to perform the Services.

Who do we share your personal data with for this purpose?
We may share personal data with a variety of the following categories of third parties as necessary when providing the Services:

 Activity partners for communications, the production of materials, or the provider of additional services required from time to time.
 Regulators, activity funders and stakeholders for the purposes of regulatory compliance, and activity reporting and evaluation.
 Media partners for the purposes of publicising activity

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

What is our legal basis?
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Services in the best way that we can. Individual contracts will be processed under the Contract Administration legal basis.

ii. Information and advice
Our Site uses various user interfaces to allow you to request information about our Services: these include printed and electronic enquiry forms and a telephone enquiry service. Contact information may be requested in each case, together with details of other personal data that is relevant to your Service enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal data with for this purpose?
We do not share personal data for this purpose.

What is our legal basis?
It is in our legitimate interest or a third party’s legitimate interest to use your personal data in such a way to ensure that we provide the very best service we can to you or others. Individual consent will also be established following contact for receipt of marketing material.

iii. Evaluation of our services
From time to time we will contact you to invite you to provide feedback about our Services in the form of online or postal communication(s). We use this information to help us improve the quality of service provided by our staff. We also use your feedback to monitor the quality of our Services.

Who do we share your personal data with for these purposes?
Literature Wales conducts in-house evaluation and we use a third party service provider to assist us with client surveys and feedback requests.

What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above. Feedback and evaluation requirements may also form part of a formal contract with Literature Wales and, in such cases, the legal basis will be Contract Administration.

iv. Business administration, and legal and regulatory compliance
We use your personal data for the following business administration and compliance purposes:

 to comply with our legal obligations;
 to enforce our legal rights;
 to comply with funder and regulator requirements.

Who do we share your personal data with for these purposes?
We will share your personal data with professional advisers such as lawyers and accountants, governmental and regulatory authorities, and funders.

What is our legal basis?
Where we use your personal data in connection with business transitions, payments, contracts, to enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. Data processing to administer contracts will derive from the Contract Administration legal basis. Legally mandated reporting will derive from the Legal Obligation legal basis.

v. Recruitment
We use your personal data for the following recruitment purposes:

 To assess your suitability for any position for which you may apply at Literature Wales.
 To review Literature Wales’ equal opportunity profile in accordance with applicable legislation.

Who do we share your personal data with for these purposes?
We do not share your personal data that you provide to us directly. You may have communicated with Literature Wales via a third party (e.g. recruitment consultancies). In these instances, your personal data will be shared with Literature Wales by the third party, and you should consult their privacy policy and/or terms.

What is our legal basis?
Where we use your personal data in connection with recruitment it will be in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent.

vi. Interaction Analysis
We analyse your contact details with other personal data that we observe about you from your interactions with our Site, our email communications to you and/or with our Services such as the Services you have viewed. Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal data from the computer hardware and software you use to access the Website, or from your mobile.

This includes the following:

 IP address to monitor Site traffic and volume;
 session ID to track usage statistics on our Site;
 information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.

Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our e-mail messages, we use a “click-through URL” linked to certain website administered by us or on our behalf.

Please see our Cookie Policy for more information.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of offers our registered users like to see. We also use this information for marketing purposes (see the marketing section below for further details).

Who do we share your personal data with for these purposes?
We share your personal data with a variety of third party service providers to assist us with client insight analytics.

What is our legal basis?
Where your personal data is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required.

Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other clients.

vii. Marketing communications
We carry out the following marketing activities using your personal data:

Electronic and postal marketing
We use information that we observe about you from your interactions with our Site, our email communications to you and/or with Services and/or your address details, to send you marketing communications electronically and/or by post.

Who do we share your personal data with for these purposes?
We do not share personal data for marketing purposes.

What is our legal basis?
Where your personal data is completely anonymised, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised information may be subject to other laws where your consent is required.

Where your personal data is not in an anonymous form, such as your email or postal address, using your personal data for marketing will be based on Individual Consent. Literature Wales will only send you marketing communications by email or post where you have consented to receive such marketing communications, or where we have a lawful right to do so.

How do we obtain your consent?
Where our use of your personal data requires your consent, you can provide such consent:
 at the time we collect your personal data; or
 by informing us by e-mail, post or phone using the contact details set out in this Privacy Notice.

5. Use of cookies
Our Site uses certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

You can access our Cookie Policy by visiting: http://www.literaturewales.org/cookies-policy/.

6. Third party contractors
Literature Wales may appoint sub-contractor data processors as required to deliver the Services, such as, without limitation, analytics tools and services, and providers of other services, who will process personal data on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal data appropriately and according to our legal and regulatory obligations.

7. Extra-EEA transfers
Literature Wales does not transfer data to countries outside the European Economic Area (EEA). If such transfers become necessary to meet regulatory, legal or business requirements, this Privacy Notice will be update to reflect this and Literature Wales will comply with legal and regulatory obligations in relation to the personal data including but without limitation having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data.

8. How long do we keep your personal data?
General personal data used to support marketing campaigns and communication will be retained for at least three years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulations.

Personal data processed as part of providing the Services will be retained for at least six years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulations (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations).

We may then destroy such files without further notice or liability.

If personal data is only useful for a short period e.g. for specific marketing campaigns we may delete it sooner than stated above, without further notice or liability.

9. Confidentiality and security of your personal data
We are committed to keeping the personal data provided to us secure and we will take reasonable precautions to protect personal data from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

 unauthorised access;
 improper use or disclosure;
 unauthorised modification; and
 unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are contractually obliged to respect the confidentiality of personal data.

You have the following rights in relation to the personal data we hold about you:

 Your right of access
If you ask us, we’ll confirm whether we’re processing your personal data and, if necessary, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

 Your right to rectification
If the personal data we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

 Your right to erasure
You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

 Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us. If you are entitled to restriction and if we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

 Your right to data portability
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal data you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

 Your right to object
You can ask us to stop processing your personal data, and we will do so, if we are processing your personal data for marketing.

 Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

 Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.

 Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at www.ico.org.uk or by calling their helpline on 0303 123 1113.

10. Collection of information by third-party websites
The Website contains links to other websites whose information practices may be different than ours. Visitors should consult the other websites’ privacy notices as Literature Wales has no control over information that is submitted to, or collected by, these third parties.

11. Changes to this Privacy Notice
To ensure that you are always aware of how we use your personal data we will update this Privacy Notice from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.