Privacy

Our promise to you

Your trust is very important to Askonas Holt and we take data protection very seriously.

We promise that:

• Any data we collect will be stored in a secure environment; if data is stored by a third party (e.g. database provider) we will make sure that they have appropriate security measures in place
• We will never sell or pass on your data to a third party, unless:

• We have your consent to do so;
• We are required to for performance of a contract; or
• We are required to for legal reasons

• If we do share your data with a third party, it will be done so safely and securely
• We will use personal information only for the purposes for which it was originally collected


Contents


INTRODUCTION

What data do we process?

We process a range of data, including some which is sensitive, relating to the following:

• Artists and their associates
• Touring partners and their members
• Promoter and venue staff
• Business associates, consultants and suppliers
• Prospective, current and past employees
• Website visitors

How do we collect data?

• You volunteer the information, either by completing a form, signing up to a service, communicating with us via email/phone/post or in person, or using our services
• Your information is passed to us in good faith by an artist, business contact or associate
• The information is freely available on your business’ website
• Anonymous data collected by cookies on our website

Why do we process this data?

1. For the performance of a contract
2. To monitor and improve the services we offer
3. To provide personalised services to individual users
4. To provide a requested service and related information
5. To keep up-to-date records on those we work with

Our legal bases

Consent: you have given clear consent for us to process your personal data for a specific purpose
Contract: the processing is necessary for the performance of contract, or because we have been asked to take specific steps before entering into a contract
Legal obligation: the processing is necessary for us to comply with the law
Legitimate interests: where the processing is necessary for our own legitimate interests or the legitimate interests of a third party, so long as our use is fair, balanced, and doesn’t unduly impact your rights

Data retention

Unless specified differently below, data is kept indefinitely, and for as long as Askonas Holt continues to operate in its current form. As is required by law, we keep all financial and business records for a period of six years.

Deleting data

All deletion of data will be done in a timely and secure manner, whether electronic or hard copy. Hard copy data will be destroyed using a confidential waste service or a shredder. Under no circumstances will any personal or confidential data be disposed of in any other manner. Records of disposal will be maintained, recording the document disposed of, date and the individual responsible for authorising the disposal.

There will be some cases where it is essential for us to keep some of your personal information on file; for example, if you ask us to stop sending direct marketing communications to you, we will keep the minimum amount of information (e.g. name, address or email address) to ensure we adhere with such requests.

Your rights

Under GDPR, you have the following rights:

Information: the right to be informed about the collection and use of your personal data
Access: the right to ask for your personal information
Rectification: the right to correct your information
Erasure: the right to have your info deleted
Restriction of processing: the right to limit how your information is used
Data portability: the right to ask for your info to be transferred to other organisations
Objection: the right to stop your information being used
Profiling: the right not to be subject to automated decision-making including profiling, including the right to ask for a person to check a decision made by a computer
Complain: the right to lodge a complaint with a supervisory authority, such as the Information Commissioner’s Officer (ICO)

Full information about your rights, and contact details for the ICO (Information Commissioner’s Office) can be found here: https://ico.org.uk/for-the-public/


OUR WEBSITE

Cookies

As with most websites, we use cookies. Read all about the cookies we use, and how to change your cookie settings, in our COOKIE NOTICE.

Log files

We gather information including IP addresses, system configuration information, URLs of referring pages, errors, and locale and language preferences to store in log files on our server. This allows us to keep track of any errors on the site and to provide a better service. It does not enable us to identify individual users.

Newsletters & The Green Room

We send information about similar products and services to people and organisations with which we have done business, to provide them with relevant information. This includes email newsletters and our magazine, The Green Room.

We will never sell your data to a third party, and you are able to unsubscribe at any time using the ‘unsubscribe’ link in the footer of the email, or by contacting us. We keep a record of the emails we send you and may track whether emails are opened or engaged with, so we can make sure we are sending you the most relevant information.

If you received our newsletter prior to 25 May 2018, we will continue to send you updates, as we believe it to be in both our and your legitimate business interests to keep you informed. If you do not receive our newsletters but would like to, please email [email protected]

Newsletters are sent using Campaign Monitor. You can read their privacy policy here: https://www.campaignmonitor.com/policies/#privacy-policy

Computer servers outside EEA

As part of the services offered to you through our website, the information we collect on website users may be transferred to countries outside the European Economic Area (EEA). For example, if any of the computer servers used to host the website are located in a country outside of the EEA. Regardless of where the data is stored, we are committed to ensuring it is kept safe and secure.

Third-party websites & embedded content

We do provide links to other websites and embed content (e.g. videos) from external sources, however this notice relates only to the Askonas Holt site. We have no control over external websites and are not responsible for their content or privacy practices. Please read the terms of use and privacy policies for any third-party sites you visit via links from this site.

Terms & conditions of use

Please read our WEBSITE TERMS & CONDITIONS.


ARTISTS, TOURING PARTNERS & THEIR MEMBERS

In order to make the necessary arrangements for any engagement or project, and to fulfil the terms of contracts for artists and/or touring partners, we will hold and process data on all artists, touring partners, their members and associates, as provided by the artist or touring partner. We will pass data on to a third party only as is necessary to fulfil our contractual obligations.

In addition, we are required under UK company law to keep your basic personal data (name, address, contact details) for a minimum of six years from the end of the financial year following the date of each financial transaction.

All information is stored within a secure database (Overture) and made accessible only to those who need it. You can view Overture’s privacy policy here: https://bookingwithoverture.com/housekeeping/privacy


BUSINESS ASSOCIATES (e.g. PROMOTERS, VENUES & SUPPLIERS)

Collecting & storing information

We collect and store your information when you correspond with us by phone, e-mail, in person via business card, or otherwise (including but not limited to name, job title, email address, postal address) for the purpose of fulfilling contracts and serving the needs of our clients. All information is stored within a secure database (Overture) and made accessible only to those who need it. You can view Overture’s privacy policy here: https://bookingwithoverture.com/housekeeping/privacy

How we use your information

We use the information that you give us to:

• Carry out obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us
• Provide you with information about products and services we offer that are similar to those that you have already purchased or enquired about – this includes Newsletters & The Green Room
• Notify you about changes to our service or policies

Sharing your information

We will only share your information with third parties when absolutely necessary, including:

• Business associates, suppliers and sub-contractors for the performance of a contract
• When it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law


JOB APPLICANTS, CURRENT & PAST EMPLOYEES

Job applicants

By submitting your CV to Askonas Holt, you consent to us processing your personal data (including any sensitive information you may choose to provide such as ethnic origin, religious beliefs, criminal records and any medical conditions). Any information submitted to us is treated in complete confidence and in accordance with all legal obligations.

We will keep your CV for a period of six months, after which we will delete your personal data from our systems unless we believe in good faith that the law or other regulation requires us to preserve it.

Current employees

Askonas Holt will hold as much personal data on file as is necessary for the purposes of managing your Contract of Employment, to comply with our legal obligations and/or for both of our legitimate business interests. If the Company needs any personal data (including that which may be sensitive) that is not necessary for managing your Contract of Employment, our legal obligations, or for our legitimate business interests but is nonetheless reasonable to request, then explicit consent will be sought.

We will share your personal information with selected third parties only when necessary for your employment or benefits relating to it, or as required by law, including:

• Payroll
• HMRC
• HR systems
• Health care providers
• Life insurance providers
• Legal advisors
• Law enforcement
• Letting and mortgage companies
• Office building management

Past employees

We keep data from past employees – including information on personnel file – for a period of six years post-employment, except for:

• Training records, which are kept for current year plus two years
• Probation, appraisal and performance management, which are kept for current year plus five years
• Data relating to ex-employee claims, which are kept for two years after claim or six years post-employment, whichever is later

We will occasionally be required to pass some of your data to third parties, for example, when providing a reference to future employers, but will only ever share what is necessary.


CHANGES TO THESE TERMS

We regularly review and, where necessary, update our privacy information and terms and conditions. Such variations shall become effective immediately upon the posting on the website.

CONTACT US

If you would like to talk to us about privacy and data protection, please contact:

Paul Hale, Chief Financial Officer
[email protected]

Askonas Holt Ltd
15 Fetter Lane
London
EC4A 1BW

+44 (0)20 7400 1700

Askonas Holt Ltd is registered with the Information Commissioner’s Office https://ico.org.uk/ESDWebPages/Entry/Z7561758

This notice was last updated on 24 May 2018.

Askonas Holt Ltd is registered in England with registered no. 3385237. Askonas Holt Ltd is a member of the International Artist Managers’ Association.