Privacy Policy

• respect the rights of each individual
• be open and transparent about the Personal Data it holds
• strive to observe the law in all collection and processing of subject data
• meet any subject access request in compliance with the law
• provide training and support to Amber Trust representatives who handle Personal Data in the course of their duties
• maintain an up-to-date ICO registration (which requires changes to the registration within 28 days of any adjustments)
• inform the ICO of breaches of the Acts (where required)
• include Data Protection guidance for all trustees and employees

The Amber Trust will only use data in ways relevant to carrying out its legitimate purposes and functions as a charity in a way that is not prejudicial to the interests of individuals. The Amber Trust will take due care in the collection and storage of any sensitive data. The Amber Trust representatives will do their utmost to keep all data accurate, timely and secure.

The Trust’s nominated Data Controller is its CEO. All Amber Trust representatives will be aware of the requirements of the DPA 2018 when they collect or handle data about an individual. Amber Trust representatives will not disclose data except where there is subject consent or legal requirement. Data sent to outside agencies will always be protected by a written contract. All collection and processing will be done in good faith. Paper records will be destroyed when no longer required.

• apply for an Amber Music Award (on behalf of children and young people) or to participate in The Amber Trust services
• when music tuition is provided through an Amber Music Award
• apply to volunteer or work as an employee or a Music Practitioner
• enquire about our activities, visit our website or donate to the charity
• sign up to receive our newsletter
• attend an Amber Trust event and provide us with information about you
• fundraise on our behalf
• post content to our social media sites
• contact us by email, online contact form, phone, SMS, social media or post

The Amber Trust may collect information in the following ways:

• when individuals provide information directly in making an application via the Amber Music Award Application Form, one of the Amber Music Services Family Registration Forms where parent/guardians provide the information required for the assessment of the project or Music Service Workshop forms, where teachers or professionals provide information required for the application of and assessment of the service.
• when individuals provide information directly as providers of music tuition/support through an Amber Music Award or The Amber Trust services
• when individuals provide information directly as a volunteer or as a Little Amber or AmberPlus or With Music in Mind or workshops practitioner.
• when individuals provide information directly, for example by providing details when they request information, make a donation or attend one of our events.
• when individuals provide information indirectly, for example when using other fundraising sites (e.g. GoFundMe) and provide their consent to be contacted by The Amber Trust for statutory purposes.
• when individuals connect with The Amber Trust on social media and messaging services, for example, Facebook, Twitter and Instagram. Depending on individuals’ settings or the privacy policies, individuals may provide permission to access information from the accounts or services.
• when individuals use The Amber Trust websites and information about the visit is recorded and stored (e.g. Google Analytics for website statistics tracking).
• when information about individuals is available from other public sources, The Amber Trust may collect personal details from the public domain, such as from company websites and news sites, to provide background information about an individual for The Amber Trust representatives in preparation for a meeting/event. This information will only be used for this purpose and not stored after the meeting/event unless consent has been provided by the individual.

Each information collection system will make individuals aware of this policy and include a statement to ensure they are aware of their right to ask not to be contacted for marketing and fundraising purposes.

In the instances outlined in the above justification of collection, The Amber Trust will only process personal information without consent when we are legally allowed to do so. This will only be where it is in the charity’s legitimate interests to do so and where we are confident that such processing is not likely to prejudice individuals’ legitimate interests or rights and freedoms.

In all other instances, The Amber Trust will process personal information on the basis of consent that has been given by individuals, who are entitled to withdraw that consent at any time such that we can no longer rely on it as a basis for continuing to process their personal information.

Little Amber, Amber Plus, With Music in Mind and Workshop – Application forms
The Amber Trust is committed to respecting and protecting your privacy. Once you choose to provide us with personal information, you can be assured that it will only be used by The Amber Trust, will be stored securely and we will never share your information unless legally required to do so.
Full details of The Amber Trust’s Privacy Policy can be found at www.ambertrust.org/privacy-policy
I agree that anonymised data pertaining to my child may be used to inform The Amber Trust’s planning and provision of Awards and services, and to help Amber Trust staff and trustees understand the range of musical interests and abilities within the population of children and young people across the UK.
We would also like to keep you posted with our news, activities and appeals by email, including our annual newsletters, AmberNotes. If you are happy to be contacted by email, please tick here

Little Amber, Amber Plus, With Music in Mind and Workshop – Practitioners and employee registration
The Amber Trust is committed to respecting and protecting your privacy. Once you choose to provide us with personal information, you can be assured that it will only be used by The Amber Trust, will be stored securely and we will never share your information unless legally required to do so.
Full details of The Amber Trust’s Privacy Policy can be found at www.ambertrust.org/privacy-policy
We would also like to keep you posted with our news, activities and appeals by email, including our annual newsletters, AmberNotes. If you are happy to be contacted by email, please tick here

Teacher/Therapist registration
The Amber Trust is committed to respecting and protecting your privacy. Once you choose to provide us with personal information, you can be assured that it will only be used by The Amber Trust, will be stored securely and we will never share your information unless legally required to do so.
Full details of The Amber Trust’s Privacy Policy can be found at www.ambertrust.org/privacy-policy
We would also like to keep you posted with our news, activities and appeals by email, including our annual newsletters, AmberNotes. If you are happy to be contacted by email, please tick here

Recruitment process for roles at The Amber Trust
Privacy Notice for job applicants (Appendix 1)

Newsletter sign up form on website or at events
By signing up to our newsletter, AmberNotes, you will be kept updated about The Amber Trust’s support of blind or partially sighted children across the UK, who have a talent or love for music, along with other relevant news that might be of interest about our events, appeals or activities. Your details will only be used by The Amber Trust and we will never share your information unless legally required to do so. You can unsubscribe at any time by emailing contact@ambertrust.org

Contact us form on the Amber Trust website
The Amber Trust is committed to respecting and protecting your privacy. Once you choose to provide us with personal information, you can be assured that it will only be used by The Amber Trust to enable us to respond to your enquiry, it will be stored securely and we will never share your information unless legally required to do so.
Full details of The Amber Trust’s Privacy Policy can be found at www.ambertrust.org/privacy-policy

Amber Trust leaflet
Your support helps blind or partially sighted children across the UK, who have a talent or love for music, and we’d love to keep you posted with our news, activities and appeals by email. If you are happy to be contacted by email, please let us know your email address below:

If you would rather not hear from The Amber Trust by email, we would like to thank and keep you updated by post but if you would prefer not to hear from us this way, please tick here

The Amber Trust will always store your personal details securely. We will use them to communicate with you in the way(s) that you have agreed to. We will only share your information if required to do so by law. For full details, please see the Privacy Policy at www.ambertrust.org/privacy-policy or contact us on 0300 323 9964 or contact@ambertrust.org.

Gift Aid form/envelope
Your support helps blind or partially sighted children across the UK, who have a talent or love for music, and we’d love to keep you posted with our news, activities and appeals by email. If you are happy to be contacted by email, please let us know your email address below:

If you would rather not hear from The Amber Trust by email, we would like to thank and keep you updated by post but if you would prefer not to hear from us this way, please tick here

The Amber Trust will always store your personal details securely. We will use them to communicate with you in the way(s) that you have agreed to. We will only share your information if required to do so by law. For full details, please see the Privacy Policy at www.ambertrust.org/privacy-policy or contact us on 0300 323 9964 or contact@ambertrust.org.

The Amber Trust backs up its Office 365 documents, in particular its SharePoint storage, using Hornet Security.

Hornet’s Privacy Policy is available at: https://www.hornetsecurity.com/en/privacy/

Bates Wells & Braithwaite London LLP

The Amber Trust engages Bates Wells & Braithwaite London LLP (BWB) as solicitors. BWB sets out its responsibilities for confidentiality and data protection in the terms of engagement.

BWB’s Privacy Policy is available at: www.bwbllp.com/privacy-policy

Benevity

The Amber Trust has received donations through Benevity, which facilitates online workplace giving and grant management for companies.

Benevity’s Privacy Policy is available at: www.benevity.com/privacy-policy

The Big Give

The Amber Trust is registered with The Big Give, which showcases our work to potential supporters and enables them to make online donations with match funding opportunities.

The Big Give’s Privacy Policy is available at: https://www.thebiggive.org.uk/s/privacy-policy

Border Office Supplies & Systems (BOSS)

The Amber Trust contracts with BOSS who provide software engineering support to manage the back-up process using the Altaro software.

BOSS’ Privacy Policy is available at: www.borderoffice.co.uk/privacy-policy/

Burgess Hodgson LLP

Burgess Hodgson LLP acts as accountants for The Amber Trust and carry out the annual audit and preparation of the accounts. Burgess Hodgson is registered to carry on audit work by the Institute of Chartered Accountants. Burgess Hodgson sets out its responsibilities for confidentiality and data protection in the terms of appointment letter.

Burgess Hodgson’s Privacy Policy is available at: www.burgesshodgson.co.uk/bh-privacy-policy

CAF Bank

The Amber Trust banks with CAF Bank, where all financial information is held securely.

CAF Bank’s Privacy Policy is available at: www.cafonline.org/navigation/footer/privacy

Easyfundraising

The Amber Trust has received donations through Easyfundraising, a charity reward shopping site through which retailers donate a percentage of the purchase price to the shopper’s selected charity.

Easyfundraising’s Privacy Policy is available at: www.easyfundraising.org.uk/privacy

Google Analytics

When someone visits www.ambertrust.org, we use Google Analytics as a third-party service to collect standard internet log information and details of behaviour patterns on the website. We do this to learn which pages are most and least visited, and this information is only processed in a way which does not identify visitors to our website.

Google Analytics’ Privacy Policy and information on safeguarding data is available at: https://support.google.com/analytics/answer/6004245

GoFundMe

GoFundMe enable supporters to set up fundraising pages and from which The Amber Trust can receive secure online payment of donations.  

GoFundMe’s  Privacy Policy is available at: https://www.gofundme.com/en-gb/c/privacy

Jessica Kingsley Publishers

Jessica Kingsley Publishers (JKP) has collaborated with The Amber Trust to publish resources that Amber uses in the provision of its music service, AmberPlus. The Amber Trust asks JKP to send the resources directly from their warehouse to specific institutions such as special schools which have requested them, using the contact information provided for this purpose.

Jessica Kingsley’s Privacy Policy is available at: https://uk.jkp.com/policies/privacy-policy

Insurance

The Amber Trust engages PIB Insurance Brokers to act as its insurance broker which acts as an insurance provider and risk management partner for The Amber Trust.

PIB Insurance Brokers is one of a growing family of organisations within the wider PIB Group of specialist insurance advisory businesses. Founded in 2015, PIB Group is backed by investment from The Carlyle Group.

PIB’s Privacy Policy is available at: https://www.pib-insurance.com/privacy-statement

ISM Trust

The ISM Trust is the Incorporated Society of Musicians’ (ISM) sister charity which was set up in 2014 to advance education, the arts and to promote health. The ISM Trust has collaborated with The Amber Trust to launch Amber’s new teaching resources through promotion to its membership and hosting online webinars.

ISM Group’s Privacy Policy is available at: https://www.ism.org/privacy_policy

MailChimp

We use a third-party provider, MailChimp, to send out our e-newsletters. We use statistics collected by Mailchimp about email opening and clicks to help us monitor and improve our e-newsletter.

MailChimp’s Privacy Policy is available at: https://mailchimp.com/legal/privacy

Max Interactive

maxinteractive.com was commissioned to develop The Amber Trust’s Sound Touch website.

Max Interactive Privacy Policy is available at: max-interactive.com/privacy/

Microsoft (Office 365)

The Amber Trust uses the Office 365 network for the processing and storage of documents and records by staff and volunteers. This network is secured with password protection and restricted access to personal information.

Microsoft’s Privacy Policy is available at: https://privacy.microsoft.com/en-GB

Paypal

The Amber Trust receives payments via PayPal for services including Print My Tickets and eBay for Charity. The PayPal Giving Fund is a registered charity (No. 1110538) which collects and distributes donations and Gift Aid.

Paypal’s Privacy Policy is available at: www.paypal.com/en/webapps/mpp/ua/privacy-full
Paypal Giving Fund’s Privacy Policy is available at: www.paypal.com/gb/givingfund/privacy

Print My Tickets

When someone books a ticket for an Amber Trust event online, we use www.printmytickets.co.uk to sell tickets for the events that we are responsible for organising. Payments are made via PayPal.

Print My Tickets’ Privacy Policy is available at: https://www.printmytickets.co.uk/privacy.asp

Salesforce

The Amber Trust database is a Salesforce based CRM, which securely holds the personal information of supporters of the charity; teachers, therapists and practitioners: and the children and families who receive support.

Salesforce UK’s Privacy Policy is available at: www.salesforce.com/uk/company/privacy

SiteGround

The Amber Trust uses SiteGround to host our websites.

The SiteGround Privacy Policy is available at: https://www.siteground.co.uk/privacy.htm

Social Media

The Amber Trust has a social media presence on Twitter (twitter.com/theambertrust), Facebook (www.facebook.com/theambertrust), Instagram (www.instagram.com/theambertrust/) and LinkedIn (www.linkedin.com/company/the-amber-trust). We use social media to raise awareness about The Amber Trust’s work and the impact of music in transforming the lives of visually impaired children, communicate with supporters and promote opportunities for children and families to apply for support.

Twitter’s Privacy Policy is available at: https://twitter.com/en/privacy
Facebook’s Privacy Policy is available at: www.facebook.com/privacy/explanation
Instagram’s Privacy Policy is available at: https://help.instagram.com/519522125107875
LinkedIn’s Privacy Policy is available at: www.linkedin.com/legal/privacy-policy

Taylor & Francis 

Taylor & Francis publish resources in relation to the With Music in Mind (WMiM) service.

Taylor & Francis Privacy Policy is available at: https://www.informa.com/privacy-policy/ 

Ticket Tailor 

When someone books a ticket for an Amber Trust event online, we use Tickettailor.com to sell tickets for the events that we are responsible for organising. Payments are made via PayPal.

Ticket Tailor’s Privacy Policy is available at: https://www.tickettailor.com/privacy-policy/

UK2

The Amber Trust uses UK2 to host our websites.

The UK2 Privacy Policy is available at: https://www.uk2.net/terms-and-conditions/privacy-policy/

University of Roehampton

The Amber Trust works with the University of Roehampton to support children and young people with visual impairments. Adam Ockelford, Professor of Music at the University of Roehampton is a trustee of The Amber Trust. Children and young people supported by The Amber Trust may also be involved in research studies conducted by Professor Adam Ockelford following university policies and procedures and with full consent from the parents/guardians.

The University of Roehampton’s Privacy Policy is available at: https://www.roehampton.ac.uk/site/privacy/

Vimeo

The Amber Trust has a channel on Vimeo (https://vimeo.com/user9123394) where video recordings featuring children and young people (with full consent from the parents/guardians and the young person if aged 13 years or older and has the capacity to consent) are available to showcase and raise awareness about The Amber Trust’s work.

Vimeo’s Privacy Policy is available at: https://vimeo.com/privacy

WordPress

The Amber Trust uses the WordPress content management system to manage and build our websites.

WordPress Privacy Policy is available at: automattic.com/privacy/

YouTube

The Amber Trust has a channel on YouTube (www.youtube.com/user/theambertrust) where video recordings featuring children and young people (with full consent from the parents/guardians and the young person if aged 13 years or older and has the capacity to consent) are available to showcase and raise awareness about The Amber Trust’s work.

YouTube’s Policies and Guidelines page is available at: https://www.youtube.com/intl/ALL_uk/howyoutubeworks/policies/community-guidelines/  and the Privacy link at the foot of the page of the Policies and Guidelines page links to the Google Privacy Policy which is available at  https://policies.google.com/privacy

Zapier, Inc

The Amber Trust uses the app Zapier, Inc which integrates its Google documents with Salesforce.

Zapier’s Privacy Policy is available at: https://zapier.com/privacy

Zing Digital Services LLP

Zing Digital Services was commissioned to design the Little Amber and Amber Plus sections of The Amber Trust website.

Zing Digital Services’ Privacy Policy is available at: https://www.zingcomms.co.uk/downloads/Zing_Privacy_Policy_2021.pdf

• • • • to provide individuals with the support or information they have requested
      • to fund music tuition through an Amber Music Award or The Amber Trust Services
      • to update individuals about any changes to the Amber Music Awards or The Amber Trust services
      • to administer donations, including Gift Aid processing
      • to support individuals’ fundraising activities
      • to maintain organisational records and ensure we have up-to-date marketing and communication preferences for individuals
      • to send newsletters or other information about The Amber Trust’s work
      • to invite individuals to participate in fundraising activities and attend events
      • to invite donations to support The Amber Trust’s work
      • to invite individuals to participate in surveys or research
      • to analyse and improve the operation of our websites
      • to analyse individuals’ use of our websites

The Amber Trust requires sensitive personal data (as defined by the DPA 2018) to assess each Amber Music Award or applications for The Amber Trust services. We will process any sensitive personal data only in relation to consideration of any application, including assessment to establish that the criteria for a Music Award or participation in The Amber Trust services are met.

As defined in the Photography, Video and Audio Recording Policy, the Amber Trust only stores and uses photographs, other images, video or audio recordings of children and young people with the consent of the parents/guardians and the young person if aged 13 years or older and has the capacity to consent. This consent is valid whilst the child or young person is a beneficiary of The Amber Trust and for up to two years afterwards.

The Amber Trust should conduct an annual review of photographs, other images, video or audio recordings and archive those where the consent is no longer valid. If the young person is now 18 years or older, new consent could be sought from them directly to continue to use the images and/or recordings. 

Archiving should involve storing images securely marked ‘do not use – consent no longer valid’. Images and recordings can be kept for historical purposes as long as they can’t be connected to personal information of individuals such as addresses and/or date of birth.

• • • • ensuring that there are appropriate technical controls in place to protect personal details on our websites and Office 365 network.
      • ensuring that only authorised personnel (i.e. selected The Amber Trust staff, volunteers or contractors) have access to your information, and that they are appropriately trained to manage personal information.
      • ensuring that donations and payments are processed securely

The Amber Trust database is a Salesforce based CRM which is linked to Office 365. A new contractor is being appointed to manage The Amber Trust IT support services and Andrew Duhig is contracted to manage all sections of The Amber Trust website (including Little Amber, AmberPlus and With Music in Mind and Amber Sound Touch). Max Mai is contracted to co-manage the Amber Sound Touch section of The Amber Trust website.

The Amber Trust database has restricted permissions to different sections on a ‘need to know’ basis. We undertake regular reviews of who has access to information that we hold to ensure that personal information is only accessible by appropriately trained representatives. Confidentiality agreements are signed by all those working with The Amber Trust, in both a paid and voluntary capacity.

Amber Music Award, Music Services Applications Forms , photographs, financial, including Gift Aid, and other information is being stored by financial year so that data can be identified and archived when it is no longer current. The Amber Trust’s database and information folders are backed up regularly and stored securely. Our Office 365 network is protected and routinely backed up by Hornet Security.

Should The Amber Trust suffer a data loss or breach, the individual identifying the breach will pass all relevant information to the nominated Data Controller (Chair of Trustees) who will record the incident information and assess if the loss/breach is significant enough to be reportable to the ICO. The UK GDPR requires that data losses/breaches are reported within 72 hours by the Data Controller and this will be strictly complied to by The Amber Trust.

The Amber Trust works in partnership with schools and music services. We only share personal data with partner schools and music services once the checks have been completed and a contract has been signed. The personal data will only be processed for the purposes of providing the Amber service agreed with the families and not for any other purpose.

The Amber Trust may legally be required to disclose personal information if required to do so by law. Such circumstances might include safeguarding, prevention and detection of crime, terrorism and legal proceedings. We will only ever share personal information in other circumstances if we have consent to do so. Such consent will be recorded and include the information to be shared and with whom. We will never sell personal information to third parties.

The Amber Trust has set a currency watershed of three years for holding data valid since last proactive contact confirming consent by the individual. After three years, the information will be either renewed by an individual or archived (unless it includes details of a Gift Aid donation, which will be kept for six years after the accounting year end that includes the last donation to which they relate).

The Amber Trust will maintain a list of signed photographic consents where individuals are identifiable, and the images are used for publicity or promotional purposes. Images captured for historical records will be exempt.

If an individual asks The Amber Trust to stop sending marketing and/or fundraising materials, we will keep a record of the individual’s contact details and appropriate information to enable us to comply with the request not to be contacted.

• • • 1. The right to be informed
      2. The right of access
      3. The right to rectification
      4. The right to erasure
      5. The right to restrict processing
      6. The right to data portability
      7. The right to object
      8. Rights in relation to automated decision making and profiling.

If an individual would like to exercise any of these rights, they should contact the nominated Data Controller (CEO) in writing at The Amber Trust, 64a Princes Way, London, SW19 6JF, by calling 0300 323 9964 or by emailing contact@ambertrust.org.

Any visitors to The Amber Trust websites who do not want their data used by Google Analytics can install the Google Analytics opt-out browser add-on.

A data subject (individual) or approved agent may make a request to have a copy of all information held on them by an organisation. On receipt of a Subject Access Request, it will be passed immediately to the nominated Data Controller (CEO). The Data Controller will then check the validity of the subject access request for authenticity and, once authenticated, will gather a response which will be sent to the subject.