Approved 6th April 2021

Trajectory Theatre is committed to processing data in accordance with its responsibilities under the Data Protection Act 2018. We will ensure that all personal data shall be:

• Processed lawfully, fairly and in a transparent manner;
• Collected for specified, explicit and legitimate purposes, and not further processed in a manner that is incompatible with those purposes;
• Adequate, relevant and necessary;
• Accurate and up-to-date;
• Kept in a form that permits identification of data subjects for no longer than is necessary;
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised, or unlawful, processing and against accidental loss, destruction or damage.

General Provisions

• This policy applies to all personal data processed by Trajectory Theatre.
• The Executive shall take responsibility for the Trajectory Theatre’s ongoing compliance with this policy.
• This policy shall be reviewed at least annually.
• Trajectory Theatre is currently exempt from registration with the Information Commissioner’s Office, as an organisation that processes personal data but will review it’s exemption status, at least, annually and register if required.

Lawful, Fair and Transparent Processing 

• To ensure its processing of data is lawful, fair and transparent, Trajectory Theatre  shall maintain a Register of Systems (an exhaustive list of systems and contexts in which personal data is processed by the Organisation). 
• The Register of Systems shall be reviewed at least annually.
• Individuals have the right to access their personal data and any such requests, made to Trajectory Theatre, shall be dealt with in a timely manner.
• Any such requests can be made to The Executive by emailing connect@trajectorytheatre.com .

  

Lawful purposes

• All data processed by Trajectory Theatre must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (full ICO guidance). 
• Trajectory Theatre shall note the appropriate lawful basis in the Register of Systems.
• Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
• Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available, and systems should be in place to ensure such revocation is reflected accurately in the Trajectory’s systems.

Data minimisation

• Trajectory Theatre shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. 

Accuracy

• Trajectory Theatre shall take reasonable steps to ensure personal data is accurate.
• Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

• To ensure that personal data is kept for no longer than necessary, Trajectory Theatre shall put in place an archiving policy for each area, in which personal data is processed, and review this process, annually.
• The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

• Trajectory Theatre shall ensure that personal data is stored securely, using modern software that is kept-up-to-date.
• Access to personal data shall be limited to personnel who need it and appropriate security should be in place to avoid unauthorised sharing of information.
• When personal data is deleted this should be done safely, such that the data is irrecoverable.
• Appropriate back-up and disaster-recovery solutions shall be in place. 

Breach

In the event of a breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Trajectory Theatre shall promptly assess the risk to people’s rights and freedoms and, if appropriate, report this breach to the ICO (full ICO guidance).