Many touring companies and venues want to use the Impact & Insight Toolkit to understand the impact their work is having on audiences, and so we’ve prepared this guidance note to help you ensure that you operate legally and ethically, whilst also gaining maximum benefit from the insight you gather together.
Counting What Counts (CWC) has worked closely with Katy Raines from Indigo-Ltd in preparing these guidance notes, following a touring pilot project she ran with three opera companies and seven venues. It should be noted that neither CWC, nor Katy, are lawyers specialising in data protection. Therefore, these notes should be taken as advisory guidance to organisations, to be used alongside their own approach to data protection.
The process of undertaking evaluations typically happens as follows:
Personal data – names, addresses and contact details of named individuals.
Insight data – responses to evaluations which, in most cases, does not include any personal data.
In some cases, and where technology allows, some touring companies have an agreement with the venue that for their productions, customers will be asked an additional question as to whether their personal contact data can be shared with the visiting company in order to keep them informed of their activities.
NB. The sharing of this personal data, however, is NOT the same as sharing evaluation data (see point 4.4).
NB. Selection of the customers should not be contingent on the customer opting in to receive information about the visiting company as noted in 4.1.
4.3 An email is sent to the selected bookers, inviting them to participate in an evaluation of the event. Best practice would suggest that this email should include the following:
• Specific reference to the event they came to see, with the name of the touring company mentioned specifically.• An invitation to complete the survey, stressing that whilst participation is voluntary, the importance of receiving their feedback to the venue and touring company.• Reassurance that all responses are anonymous, and that the findings are only used by the venue, company and Arts Council England to understand how their work is being received by audiences, and to inform future planning.
4.4 Insight data is gathered in the Culture Counts platform. If it contains no personal data (e.g. 6-digit postcode, name, address) then it is not personal data, and the resulting analysis can therefore be shared without reference to GDPR. If the insight data does include such personal data, then the following considerations need to be made:
The purpose of collecting and sharing survey data for touring companies and venues should be discussed at contractual stage, and clearly understood by both parties.
There are huge benefits in the venue and visiting company ‘aligning’ their objectives for a piece of work or tour, so that both parties can ensure they get the greatest value out of the survey.
Being clear about this from the outset and ensuring this is encapsulated in the data sharing agreement, should have maximum benefits for both parties.
We may collect personal data from you when you buy a ticket, join or renew a membership, ask us to send you information, complete a survey, make a donation, pledge a legacy, attend an event, visit our premises, volunteer or participate in a project or group, supply goods/services to us, pay us for goods/services or apply for a job.
We will use your information for the purposes listed below under one of the following legal bases:
The ways in which we use your data are listed below:
To invite you to give feedback on our programmes and services via customer surveys in order to improve our offer and feedback to our funders.
The ways in which we share data with third party organisations are listed below:
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