Privacy Policy
We are committed to protecting your personal information and being transparent about what information we hold about you.
Who we are and how to contact us
The London Philharmonic Choir (LPC) is a registered charity (number 1093455) and company limited by guarantee (number 4463793), funded by individual donors and concert engagements. For data protection purposes, LPC is the data controller.
Data protection contact: Honorary Secretary (Joy Lee), London Philharmonic Choir, 4th Floor, 89 Albert Embankment, London, SE1 7TP or secretary@lpc.org.uk. We do not have a statutory Data Protection Officer.
We handle personal information in line with the UK GDPR, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and the Data (Use and Access) Act 2025, as each is in force from time to time.
Who this policy covers
This policy applies to members and former members, prospective members and audition applicants, donors and supporters, volunteers, event participants and audience members, website visitors, suppliers and contractors, children and young people involved in outreach activities (and their parents or guardians), and safeguarding-related contacts.
What we collect and where we get it
We collect personal information directly from you (for example, when you audition, join, donate, volunteer, tour with us, or visit our website). We may also receive information from referees, audition panel members, existing Choir members, venues, DBS check providers, travel and visa processors, hotels, fundraising and payment platforms, safeguarding contacts, public registers and professional advisers.
Categories of information we hold include: contact details; voice type and musical background; audition and concert participation records; tour and travel data (passport and visa details, address, family details, travel history, seating and dietary preferences); health and medical information (see below); DBS and safeguarding records (see below); donation and Gift Aid records; photographs and recordings; website and cookie data; and correspondence.
Why we use your information and our lawful bases
The table below summarises our main processing purposes, the lawful basis under Article 6 UK GDPR, and the Article 9 or Schedule 1 condition where special category or criminal offence data is involved:
| Purpose | Lawful basis (Art 6) | Art 9 / Sch 1 condition (if applicable) |
| Membership administration, auditions, attendance | Contract (Art 6(1)(b)) | N/A |
| Tour/event arrangements including travel, visa, hotels | Contract (Art 6(1)(b)) | N/A |
| Health, medical and dietary information for tours/events/access | Consent (Art 6(1)(a)) | Explicit consent (Art 9(2)(a)) |
| DBS checks and safeguarding | Legal obligation (Art 6(1)(c)) or Legitimate interests (Art 6(1)(f)) | Sch 1 Pt 2 para 18 (safeguarding); Art 10 conditions apply |
| Donations, Gift Aid and financial processing | Contract (Art 6(1)(b)) / Legal obligation (Art 6(1)(c)) | N/A |
| Marketing and fundraising communications | Consent (Art 6(1)(a)) or Legitimate interests (Art 6(1)(f)) with soft opt-in | N/A |
| Photographs and publicity | Legitimate interests (Art 6(1)(f)) or Consent (Art 6(1)(a)) | N/A |
| Website operation, analytics and cookies | Legitimate interests (Art 6(1)(f)) / Consent for non-essential cookies | N/A |
| Legal/regulatory compliance, governance, complaints and claims | Legal obligation (Art 6(1)(c)) / Legitimate interests (Art 6(1)(f)) | Art 9(2)(f) if special category data relevant to a claim |
Where we rely on legitimate interests, we have assessed that our interests do not override your rights. You may ask us for details of these assessments. Where we rely on consent, you may withdraw it at any time (see below).
Who we share information with
We share personal information only where necessary, with: IT and hosting providers; payment and donation processors; travel agents, transport providers, hotels, venues and consulates (for tours); DBS providers; HMRC, the Charity Commission, Companies House and professional advisers; insurers; safeguarding authorities and law enforcement (where required by law); and marketing platforms (where used). We do not sell your personal information.
Health and medical information
We collect health, medical or dietary information (for example, for tours or access needs) only with your explicit consent, which is specific to the purpose, recorded in writing, separate from other consents, and withdrawable at any time. We delete this information at the end of the relevant purpose (e.g. end of tour) unless you ask us to retain it for future events. In a genuine medical emergency, we may share relevant information with emergency services under the vital interests condition (Article 9(2)(c)).
DBS checks and safeguarding
Where you work with children or vulnerable adults on behalf of LPC, we may ask you to undertake a DBS check. DBS and safeguarding data may include criminal offence data (Article 10 UK GDPR). We process it under Schedule 1, Part 2, paragraph 18 of the DPA 2018 (safeguarding of children and individuals at risk), maintain an appropriate policy document (held by the Honorary Secretary), restrict access to those with a safeguarding or governance need, do not routinely retain full certificates, and securely destroy records when no longer needed for safeguarding, legal or insurance purposes.
International transfers
The London Philharmonic Choir will not transfer an individual’s personal data to countries outside the UK, unless either:
(a) The UK has issued regulations confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the individual’s rights and freedoms; or
(b) The individual who owns the data has provided explicit consent to the proposed transfer after being informed of any potential risks.
Your rights
Under data protection law you have the right to: access your personal information; have it corrected or erased; restrict or object to processing; data portability (where processing is based on consent or contract and carried out by automated means); withdraw consent at any time (without affecting earlier lawful processing); and not be subject to solely automated decisions with legal or similarly significant effects. You also have the right to complain to the ICO (see section 11).
To exercise any right, email secretary@lpc.org.uk. We will respond within one month (or tell you if we need longer). There is usually no fee. You have an absolute right to object to direct marketing at any time.
How long we keep your information
We keep personal information only as long as needed for the purpose it was collected, or as required by law. Our standard retention bands are:
- Active relationship data (members, volunteers, donors): duration of relationship plus 6 years
- Tour and travel data: end of tour (unless legally required for visa purposes)
- Health/medical/dietary information: end of the specific purpose, then deleted
- DBS and safeguarding records: only as long as needed; reviewed at least every 3 years
- Financial, tax and Gift Aid records: 6 years after the relevant tax year
- Marketing preferences: until changed; suppression list retained indefinitely to honour opt-outs
- Website/cookie data: 13 months (analytics); session cookies expire on browser close
- Complaints, rights requests, governance, legal and insurance records: 6 years after resolution
- General correspondence: 3 years unless related to an ongoing matter
When information is no longer needed, we securely delete or anonymise it.
Data protection complaints
If you are unhappy about how we have handled your personal information, please contact us at secretary@lpc.org.uk. We will:
- acknowledge your complaint within 30 days;
- investigate it, keep you informed and tell you about the outcome without undue delay.
If you remain dissatisfied, you may complain to the Information Commissioner’s Office (ICO): ico.org.uk | 0303 123 1113 | Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. You do not have to complain to us first, but we appreciate the opportunity to resolve matters directly.
Marketing and fundraising
We send marketing communications only where we have your consent or, from 5 February 2026, where the PECR charitable purposes soft opt-in applies (contact details obtained directly from you on or after that date in connection with your support for LPC’s charitable purposes, with a clear opt-out offered at collection and in every message; not usable for third-party or bought-in lists). You may opt out at any time via the unsubscribe link in any message or by emailing us. We maintain a suppression list solely to honour opt-outs.
Cookies and website visitors
Our website uses strictly necessary cookies (which do not require consent) and, with your consent, analytics and embedded-content cookies. We will not set non-essential cookies until you give clear, positive consent. Where PECR allows a low-risk exception (including those introduced by the DUAA), we may rely on it.
Children and vulnerable adults
Where LPC works with children or young people, we collect only the minimum information needed, communicate primarily with parents or guardians, provide age-appropriate privacy information, and handle safeguarding disclosures in accordance with our safeguarding policy. Photographs of children are taken only with parental or guardian consent.
Automated decision-making
We do not currently make any decisions about you based solely on automated processing that have legal or similarly significant effects. If this changes, we will update this policy and inform you.
Keeping your information safe
We store personal information on secure, password-protected systems with access restricted to those who need it. We keep software up to date, train those who handle personal information, and review our security measures periodically. We collect only what we need and do not retain it longer than necessary.
Do you have to provide your information?
In most cases, providing your personal information is voluntary. However, some information is needed so that we can manage your membership, arrange tours, process Gift Aid or meet legal obligations. If you choose not to provide it, we will explain any implications (for example, we may be unable to include you in a concert or tour or be able to claim Gift Aid on your donation).
Changes to this policy
We may update this policy from time to time. Significant changes will be published on our website and, where practicable, communicated by email. The date at the top shows when it was last updated.
Contact
Honorary Secretary (Joy Lee), London Philharmonic Choir, 4th Floor, 89 Albert Embankment, London, SE1 7TP or secretary@lpc.org.uk