Covid-19 Data Collection

How we use your information for contact tracing


To support NHS Test and Trace (which is part of the Department for Health and Social Care) in England, we have been mandated by law to collect and keep a limited record of staff, customers and visitors who come onto our premises for the purpose of contact tracing.

By maintaining records of staff, customers and visitors, and sharing these with NHS Test and Trace where requested, we can help to identify people who may have been exposed to the coronavirus.

To support this we do require you (and everyone visting with you) to either use the offical NHS COVID-19 app on arrival, or to complete a COVID-19 Contact Details form beforehand.

This privacy notice was last updated on 7th May 2021, 18:33.

Our legal details

Sadler’s Wells Trust Limited (“Sadler’s Wells”) is a company limited by guarantee incorporated in England and Wales (Company No 1488786) with registered offices at Sadler’s Wells, Rosebery Avenue, London, EC1R 4TN.

Sadler’s Wells Trust Limited is a charity registered with the Charity Commission for England and Wales (No 279884).

We are registered on the Information Commissioner’s Office Data Protection Register, and are the Data Controller for the personal data that we hold and process.

We sell tickets and merchandise through the websites sadlerswells.com and peacocktheatre.com, as well as selling and having performances at Sadler’s Wells and Lilian Baylis Studio at Rosebery Avenue, and The Peacock Theatre in Holborn. From time-to-time we may also host performances at other venues or temporary performance spaces.

If you have any further questions about this policy or any of our data processing activities please contact us, details are available on our feedback page.

The personal data we collect, process or use is treated securely and in accordance with this Privacy Policy, the General Data Protection Regulation EU 2016/679 (GDPR), and the Privacy and Electronic Communications Regulations 2003 (PECR), as amended.

1. How do we collect personal information for contact tracing?

 

If you are not able to use the offical NHS COVID-19 app on arrival you do have the option of completing a COVID-19 Contact Details form that will be emailed to you prior to your attendance.

We also collect contact data when you purchase a ticket from us (as outlined in our main Privacy Policy), this may also be passed on to NHS Test and Trace if requested by them.

2. What types of information do we collect for contact tracing?


For the purposes of contact tracing we record your name & contact details, and those of people attending with you, along with the name, date & time of the performance you are attending.

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These are the details that we collect for contact tracing:


Your name

  • Your first name, last name


Your contact details

  • Your phone number or email address


Details of people attending with you

  • Their first name, last name


Their contact details

  • Their phone number or email address

    3. What do we use this information for?


    Any data collected on a COVID-19 Contact Details form will only be used for the purpose of contact tracing, and only if requested by NHS Test and Trace. Information of this type will not be used for other purposes.

    For example, if another customer reported symptoms and subsequently tested positive, NHS Test and Trace can request the details for everyone that attended that performance.

    Data collected via other means (for example, during the purchasing process) will be used in line with our main Privacy Policy.

    4. What legal reason do we have for collecting this data?


    We have a legal obligation to collect data for the purposes of contact tracing on behalf of the NHS Test and Trace service.

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    The data we collect for the purposes of contract tracing is covered by the General Data Protection Regulations Article 6 (1) (c ) – a legal obligation to which we as a venue/establishment are subject to.

    The legal obligation to which we’re subject, means that we’re mandated by law, by a set of new regulations from the government, to co-operate with the NHS Test and Trace service, in order to help maintain a safe operating environment and to help fight any local outbreak of corona virus.

    Further details can be found at https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace.

    5. Who will contact tracing data be shared with?

    Companies your data may be shared with

    We use a third-party to host our COVID-19 Contact Details forms - they will only process any data entered under our instruction and will not use it for any other purpose.

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    Here are the companies that process data on our behalf, what they do
    for us, and the types of data they process:


    Hosting COVID19 Contact forms


    WordFly 1326 5th Avenue, Suite 800, Seattle, WA 98101, USA


    Data they process for us:
    • Your name(s), and those of people attending with you
    • Your phone number or email address, and those of people attending with you



    We will only share information with NHS Test and Trace if it is specifically requested by them, they would then be responsible for compliance with data protection legislation for that period of time.

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    NHS Test and Trace will not disclose this information to any third party unless required to do so by law (for example, as a result of receiving a court order).

    The NHS Test and Trace service as part of safeguarding your personal data, has in place technical, organisational and administrative security measures to protect your personal information that it receives from the venue/establishment, that it holds from loss, misuse, and unauthorised access, disclosure, alteration and destruction.



    Any data entered on one of our COVID-19 Contact Details forms will not be shared with any other organisations.

    Countries where data might be shared

    For financial and technical reasons the supplier we have chosen to host our COVID-19 Contact Details forms will transfer and process the data in datacentres that are outside the European Economic Area (EEA).

    We have taken steps to ensure suitable safeguards are in place to protect your personal information by selecting a supplier that has contract terms approved by the EU.

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    These are the suppliers that we use that are based outside the EEA, and the privacy safeguards we have in place to ensure that your data is processed on an equivalent basis to European law:


    Suppliers that use “model contracts” or “standard contractual clauses”

    The suppliers below process data on our behalf by using standard contractual clauses in their agreement with us that have been approved by the EU.


    WordFly Details in their Data Processing Addendum

    6. How long will contact tracing data be kept?


    We will retain any data submitted on one of our COVID-19 Contact Details forms for 21 days after the performance date registered on the form, to enable contact tracing to be carried out by NHS Test and Trace during that period.

    Any data that we collect during the purchasing of tickets will be kept in line with our main Privacy Policy.

    7. Your Rights


    You have several other rights under data protection regulations, a summary of these is available in our main Privacy Policy.

 

In line with government guidance, Sadler’s Wells continues to present performances to socially distanced audiences. Read more

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