Privacy Policy

Privacy Notice

About Koestler Arts

Koestler Arts is an arts charity that encourages people in prisons and other criminal justice settings to access the benefits of participating in the arts.

Koestler Arts is the working name of the Koestler Trust (registered charity number 1105759).
Address: Koestler Arts Centre, 170 Du Cane Road, London, W12 0TX
Email: [email protected]
Telephone: +44 (0)20 8740 0333

Koestler Arts is registered with the Information Commissioner’s Office (ICO) under registration reference ZA163089.

We are committed to protecting your personal information and handling it lawfully, fairly and transparently. We process personal information in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations (PECR) and other applicable data protection legislation.

This Privacy Notice explains:

• What personal information we collect.
• How we use it.
• The lawful bases we rely on.
• Who we share it with.
• How long we keep it.
• Your rights in relation to your personal information.

What personal information do we collect?

The personal information we collect depends on how you interact with us.

We may collect information from:

• Koestler Awards entrants.
• Donors and supporters.
• Newsletter subscribers.
• Event attendees.
• Volunteers.
• Job applicants and employees.
• Artists and exhibitors.
• Website visitors.
• Suppliers and partners.

The information we collect may include:

• Name and contact details.
• Postal address.
• Email address.
• Telephone number.
• Date of birth.
• Prison number (where applicable).
• Payment and donation information.
• Records of communications with us.
• Information relating to participation in our programmes and activities.
• Information you provide in surveys, feedback forms and applications.

In some circumstances we may collect special category information such as ethnicity, religion or disability information where this is necessary for equality monitoring, reporting, service evaluation or employment purposes.

Providing special category information is usually optional and choosing not to provide it will not affect your ability to participate in our activities.

How do we use your information?

We use personal information to:

• Deliver our charitable activities and services.
• Administer the Koestler Awards.
• Process donations and purchases.
• Manage supporter relationships.
• Communicate with supporters, entrants and stakeholders.
• Send newsletters and marketing communications where permitted.
• Evaluate and improve our services.
• Monitor equality, diversity and inclusion.
• Produce statistical reports for funders and stakeholders.
• Meet legal, regulatory and financial obligations.
• Recruit, manage and support staff and volunteers.
• Protect our organisation, systems and users from fraud, abuse or security threats.

Our lawful bases for processing

We only process personal information where we have a lawful basis to do so.

Depending on the activity, we may rely on:

Contract

Where processing is necessary to:

• Administer Awards entries.
• Process sales and purchases.
• Manage donations and memberships.
• Fulfil agreements with volunteers, suppliers or staff.

Legal Obligation

Where we are required to:

• Maintain financial records.
• Process Gift Aid claims.
• Meet employment law obligations.
• Respond to lawful requests from regulators or public authorities.

Legitimate Interests

Where processing is necessary for our legitimate interests, provided these do not override your rights and freedoms. This includes:

• Managing relationships with supporters.
• Improving our services and activities.
• Evaluating the impact of our work.
• Conducting fundraising and prospect research.
• Maintaining organisational records.
• Responding to enquiries and complaints.

Consent

Where we ask for your consent, including:

• Email newsletters and marketing communications.
• Certain cookies and analytics technologies.
• Specific uses of special category information where consent is required.

You may withdraw consent at any time.

Special Category Information

Where we process special category information, we do so in accordance with Article 9 UK GDPR and Schedule 1 of the Data Protection Act 2018, including for equality monitoring, employment purposes, safeguarding, or where you have provided explicit consent.

Koestler Awards Entrants

To administer the Koestler Awards, we collect information including:

• Name.
• Date of birth.
• Prison number (where applicable).
• Establishment details.
• Current or future contact address.
• Details of submitted artwork.
• Sales and payment information.
• Preferences regarding exhibitions and communications.
• Supporting information submitted with entries.

We also collect optional demographic information such as gender, ethnicity, religion, disability status, care experience or armed forces background to help us understand who we are reaching and to support equality monitoring and reporting.

Entry forms are authorised by both the entrant and an authorised representative of the relevant establishment.

This information is used to:

• Process entries.
• Administer judging.
• Arrange exhibitions and sales.
• Issue certificates and awards.
• Make prize and sales payments.
• Evaluate participation and impact.
• Produce anonymised reports and statistics.

Access to entrant information is restricted to authorised personnel who require access for operational purposes.

Donors, Supporters and Patrons

If you donate to us, become a Patron, purchase goods from us or otherwise support our work, we may collect:

• Contact details.
• Donation history.
• Payment information.
• Gift Aid declarations.
• Communication preferences.

We use this information to:

• Process donations and purchases.
• Claim Gift Aid where applicable.
• Maintain financial records.
• Manage supporter relationships.
• Communicate with you about your support.

Where required by law, we will obtain your consent before sending electronic marketing communications.

Newsletters and Marketing Communications

If you subscribe to our newsletter, we will use your contact details to send information about:

• Our activities and programmes.
• Events and exhibitions.
• Volunteering opportunities.
• Fundraising campaigns.
• News and updates.

You may unsubscribe at any time by using the link provided in our emails or by contacting us directly.

We may use email analytics to understand engagement with our communications and improve future content.

Fundraising and Prospect Research

As a charity, we undertake fundraising activities to support our work.

We may carry out research using publicly available information to identify individuals, trusts, foundations and organisations who may have an interest in supporting Koestler Arts.

This may include information obtained from:

• Public registers.
• Company records.
• Charity and philanthropy databases.
• News publications.
• Publicly accessible websites.
• Professional networking platforms.

We conduct this activity under our legitimate interests and always seek to balance our fundraising needs against individuals’ privacy rights.

You have the right to object to this processing at any time.

Website, Cookies and Analytics

When you visit our website, we may automatically collect information about how you use it.

This may include:

• IP address.
• Browser type.
• Device information.
• Pages viewed.
• Referring websites.
• Time spent on pages.

We use cookies and similar technologies to:

• Ensure the website functions correctly.
• Remember your preferences.
• Measure website performance.
• Improve user experience.

Where required by law, we will ask for your consent before placing non-essential cookies on your device.

Further information can be found in our Cookie Policy.

We use analytics services to help us understand website usage and improve our services.

Social Media

We maintain accounts on various social media platforms.

If you interact with our social media content, those platforms may collect information about you in accordance with their own privacy notices.

We may use aggregated and anonymised analytics provided by social media platforms to understand audience engagement and improve our communications.

Who do we share personal information with?

We do not sell personal information.

We may share information where necessary with:

• Technology and software providers.
• Payment processors.
• Accounting providers.
• Exhibition partners.
• Couriers and logistics providers.
• Professional advisers.
• Auditors.
• Regulators and law enforcement agencies.
• Funding bodies where information is anonymised or aggregated.

Where third parties process information on our behalf, they are required to do so under appropriate contractual and security arrangements.

International Transfers

Some of our service providers may process personal information outside the United Kingdom.

Where this occurs, we ensure appropriate safeguards are in place, including:

• UK adequacy regulations.
• The UK International Data Transfer Agreement (IDTA).
• The UK Addendum to the EU Standard Contractual Clauses.
• Other lawful transfer mechanisms recognised under UK data protection law.

How long do we keep information?

We retain personal information only for as long as necessary for the purposes for which it was collected and to meet legal, regulatory and operational requirements.

Examples include:

• Entry form hard copies: 12 months.
• Survey forms: 6 months before anonymisation.
• Unsuccessful job applications: 12 months.
• Employment records: 7 years after employment ceases.
• Judging forms: 6 months.
• Financial and Gift Aid records: at least 6 years.

We retain entrant records to administer the Koestler Awards, maintain a history of participation, and respond to future enquiries or requests relating to previous entries. These records are periodically reviewed to ensure continued retention remains necessary and proportionate.

Where records are retained for historical, research, archiving or administrative purposes, we will review them periodically to ensure continued retention remains justified.

How do we protect your information?

We use a range of technical and organisational measures to protect personal information, including:

• Access controls.
• Password protection.
• Encryption where appropriate.
• Secure storage systems.
• Staff training.
• Confidentiality obligations.
• Regular review of security arrangements.

Access to personal information is limited to those who need it to perform their role.

Your rights

Under UK data protection law, you have the right to:

• Be informed about how your personal information is used.
• Access your personal information.
• Request correction of inaccurate information.
• Request deletion of your information in certain circumstances.
• Request restriction of processing.
• Object to processing based on legitimate interests.
• Withdraw consent where processing relies on consent.
• Receive certain personal information in a portable format.
• Lodge a complaint with the Information Commissioner’s Office.

To exercise your rights, please contact us using the details below.

Complaints

If you have concerns about how we use your information, please contact us first so that we can try to resolve the matter.

You also have the right to complain to the Information Commissioner’s Office:
Website: www.ico.org.uk
Telephone: 0303 123 1113

Contact Us

If you have any questions about this Privacy Notice or wish to exercise your rights, please contact:

Mark Rogers, Data Protection Officer
Email: [email protected]
Telephone: +44 (0)20 8740 0333
Post: Koestler Arts Centre, 170 Du Cane Road, London, W12 0TX

This Privacy Notice is reviewed regularly and may be updated from time to time.