Privacy policy

How we respect privacy when we deal with personal information collected by our organisation.

This Privacy Policy applies to information we, Nucleo, collect about individuals who interact with our organisation. We are a registered charity, under the number 1169328. It explains what personal information we collect and how we use it. 
If you have any comments or questions about this notice, feel free to contact the Data Protection Lead at dpl@thenucleoproject.org.

1. How we COLLECT INFORMATION

We collect information about you in the following ways:

  • Information you give us. For example, when you post information on our social media or message boards, make a donation to us, register for an event or otherwise provide us with personal information. When you register, we’ll ask for personal information, like your name, email address, telephone number, date of birth and contact preferences.

  • Information we get from your use of our website and services. We collect information about our online content that you use and how you use it, like when you watch a video on YouTube, visit our websites or view and interact with our content. We, like all organisations, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer. Please see Section 7. Cookies and Usage Tracking for more detail.

  • Information from known third parties. We may also receive information about you from our third party partners with whom you choose to interact, for example websites such as JustGiving when making a donation. This can include information such as your name, postal or email address, phone number, your geographic location, credit/debit card details and whether you are a tax payer so that we can claim Gift Aid. To the extent that we have not done so already, we (or they) will notify you when we receive information about you from them and tell you how and why we intend to use that information.

  • Information available publicly. We may include information found in places such as Companies House, LinkedIn and information that has been published in articles/newspapers.

Wherever possible we use aggregated or anonymous information which does not identify individuals by name. See below How we use your information to understand our purposes for processing your personal information.

2. Personal data that we process

The information below explains some of the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed. 

Enquiring about our organisation and its work

Name, email, message.

Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.

Subscribing to email updates about our work

Name, email.

Consent – you have given your active consent.

Making a donation

Name, email, address, payment information.

Legitimate interests – this information is necessary for us to fulfill your intention of donating money and your expectation of receiving a confirmation message.

Registration as a student

Name, email, address, personal details, medical conditions.

Legitimate interests – this information is necessary for us to deliver our teaching programme effectively.

Visual material

Photographs and video of activities at Nucleo.

Consent – you have given your active consent.

Event attendance

Name, email, message.

Legitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.

Impact measurement

Internal (teacher and student) and external assessments.

Legitimate interests – it is necessary for us to monitor the impact that our programme has in order to improve our offering and report to donors.

Job applicants

If you apply to work at Nucleo, we will only use the information you give us to process your application or to monitor recruitment statistics on an unidentified basis. If we want to disclose information to someone outside Nucleo, for example, if we need a reference from your previous employer, we will tell you beforehand. The only exception is where the law obliges us to disclose information to a third party (such as the police) and we are not allowed to tell you.

If you are unsuccessful in your job application, we may hold your personal information after we’ve finished recruiting for the post you applied for, for up to 6 months to deal with any follow up queries or issues.

We keep statistical information about all applicants to develop our recruitment processes however no individual applicant would be identifiable from this information.

If you commence employment with Nucleo, your personal information will be processed in accordance with your employment contract and other applicable human resources policies we have from time to time.

Legitimate Interest – it is necessary for us to process your application and monitor recruitment statistics.

Website functionality

Website activity collected through cookies.

Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect, such as remembering the contents of your order before you have fully completed the process.

3. How we use your data

We will only use your data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table at the top of this policy.

For example, we may use your personal information to:

  • reply to enquiries you send to us;

  • handle donations or other transactions that you initiate;

  • measure the impact of our programme;

  • monitor and report on student progress to our donors;

  • for publicity and fundraising purposes (such as, for example, in grant proposal, informational leaflets and on the project website);

  • in public settings (including in print and online) as a representation of the work of the project, and/or for educational purposes, such as sharing with other students, musicians and teachers and with members of other orchestra or musical projects;

  • support student learning;

  • to keep children safe;

  • assess the quality of our services;

  • where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.

4. When we share your data

We will only pass your data to third parties in the following circumstances:

  • you have provided your explicit consent for us to pass data to a named third party;

  • we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or

  • we are required by law to share your data.

In addition, we will only pass data to third parties outside of the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation.

5. How long we keep your data

We take the principles of data minimisation and removal seriously and have internal policies in place to ensure that we only ever ask for the minimum amount of data for the associated purpose and delete that data promptly once it is no longer required. Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

6. Rights you have over your data

You have a range of rights over your data, which include the following:

  • Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails).

  • You have the right to ask for rectification and/or deletion of your information.

  • You have the right of access to your information.

  • You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.

A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/
If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us. Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

7. Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, eg remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website.
Where cookies are used to collect personal data, we list these purposes in section 1 above, along with other personal data that we collect. However, we also use some cookies that do not collect personal information but that do help us collect anonymous information about how people use our website. We use Google Analytics for this purpose.  Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google’s privacy policy is available at http://www.google.com/privacypolicy.html.

8. Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website. If a modification meaningfully reduces your rights, we’ll notify people whose personal data we hold and is affected.