Staff and Freelancers Privacy Policy
Staff and Freelancers Privacy Policy
About this policy
Here, at the City of Birmingham Symphony Orchestra, we take your privacy seriously. We promise to respect any personal data you share with us and keep it safe both during and after your employment.
This policy explains who we are, what information we collect, how and why we use it, how it is stored, which partners we work with, and your rights regarding any information you share with us.
We will use any personal information we collect about you in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act (DPA), and the Privacy and Electronic Communications Regulations (PECR). We aim to be clear when we handle your data, and not do anything you wouldn’t reasonably expect.
This privacy policy outlines how we process data for our:
- Staff (permanent, temporary, and casual)
- Freelancers
- Work experience
- Board of Trustees, Community Board, and Development Trust
Please read this information carefully, as by providing your data to us you acknowledge you have read this policy and understand we will process your data in accordance with its terms.
Who we are
The City of Birmingham Symphony Orchestra (CBSO) is a registered Arts Charity (number 506276) that processes data for purposes necessary to fulfil its aims and charitable objectives.
City of Birmingham Symphony Orchestra (ICO registration Z5724328) is the Data Controller for any personal information we process.
For this policy “CBSO,” “we, “us,” and “our” refer to the City of Birmingham Symphony Orchestra.
Contact us
Questions, comments, and requests about this Privacy Policy are welcomed.
Email us: mydata@cbso.co.uk
Write to us: City of Birmingham Symphony Orchestra, CBSO Centre, Berkley Street, Birmingham, B1 2LF
Data collection
Staff
We may collect or store the following information about you during and after our working relationship with you.
- Title, first name and last name
- Contact details including postal address, email address, and telephone number(s)
- First name, last name, email address, and contact telephone number(s) for emergency contact/next of kin
- Date of birth
- Nationality and place of birth
- Marital status
- Recruitment information (including copies of right to work documentation, references, and other information included in a CV or cover letter as part of theapplication/audition process)
- Offer letters, contracts of employment, written statements of terms and conditions
- Start date and, if different, the date of your continuous employment
- Employment records (including employment history, working hours, holidays, training records, professional memberships, and evidence of skills and qualifications)
- Education history
- Instrument details
- Passport information and visa status
- Job title, salary, annual leave, pension, and benefits information
- Leaving date and your reason for leaving
- Performance information
- Disciplinary and grievance information
- National Insurance Number
- Bank account details, payroll records, and tax status information
- Image and likeness (as captured on our CCTV cameras, and in photographs and videos we may use for promotional purposes)
- Any other information you provide to us by email, letter, telephone, social media, via our website, or in person
Sensitive Information
We collect health data such as access need, allergy information, or dietary requirements. We may also monitor and record health-related data, such as noise levels, to ensure a safe and healthy environment.
We collect Equality, Diversity, and Inclusion (EDI) data to help us understand how well we are fostering a diverse and inclusive workplace. This is important for identifying areas for improvement, ensuring fairness, and creating an environment where everyone feels valued. We also use anonymous, aggregated EDI data to report to our funders.
Some of the information we collect is considered "special category" data, which is more sensitive and requires higher levels of protection. We have strict safeguards in place to ensure this data is handled responsibly. We only process this type of information in limited circumstances, such as:
- With your explicit written consent.
- To meet legal obligations or exercise rights connected to employment.
- For equal opportunities monitoring in the public interest.
In rare cases, we may process this information in relation to legal claims, to protect vital interests if you are unable to give consent, or if you have already made the information public.
We collect the following types of data:
- Ethnicity
- Gender
- Gender identity
- Sex
- Sexual orientation
- Socio-economic background
- Trade Union membership
- Criminal Offence data
Data from third parties
We may also obtain or collect personal information about you from other third-party sources, for example:
- If we seek references for employment.
- If we engage an external photographer or videographer to capture events.
- Publicly available online information, such as information found in places such as Companies House, your biography on your work website, or information that has been
Freelancers
We may collect or store the following information about you when you supply goods/services to us, are recommended to us, or contact us with an enquiry.
- First name and last name
- Contact details including postal address, email address, and telephone number(s)
- First name, last name, email address, and contact telephone number(s) for emergency contact/next of kin
- Date of birth
- Nationality and place of birth
- Recruitment information (including copies of right to work documentation, references, and other information included in a CV or cover letter as part of the application/audition process)
- Contract information including fee
- Instrument details
- Passport information and visa status
- National Insurance Number
- Bank account details and tax status information
- Image and likeness (as captured on our CCTV cameras, and in photographs and videos we may use for promotional purposes)
- Any other information you provide to us by email, letter, telephone, social media, via our website, or in person
Sensitive information
We collect health data such as access need, allergy information, or dietary requirements. We may also monitor and record health-related data, such as noise levels, to ensure a safe and healthy environment.
We collect Equality, Diversity, and Inclusion (EDI) data to help us understand how well we are fostering a diverse and inclusive workplace. This is important for identifying areas for improvement, ensuring fairness, and creating an environment where everyone feels valued. We also use anonymous, aggregated EDI data to report to our funders.
Some of the information we collect is considered "special category" data, which is more sensitive and requires higher levels of protection. We have strict safeguards in place to ensure this data is handled responsibly. We only process this type of information in limited circumstances, such as:
- With your explicit written consent.
- To meet legal obligations or exercise rights connected to your contract with us.
- For equal opportunities monitoring in the public interest.
In rare cases, we may process this information in relation to legal claims, to protect vital interests if you are unable to give consent, or if you have already made the information public.
We collect the following types of data:
- Ethnicity
- Gender
- Gender identity
- Sex
- Sexual orientation
- Socio-economic background
- Trade Union membership
- Criminal Offence data
Data from third parties
We may also obtain or collect personal information about you from other third-party sources, for example:
- Recommendations from other organisations/clients.
- If we engage an external photographer or videographer to capture events.
- Publicly available online information, such as information found in places such as Companies House, your biography on your website, or information that has been published in articles/ newspapers.
Work Experience
We may collect or store the following information from you when you do work experience with us.
- Title, first name, and last name
- Contact details including postal address, email address, and telephone number(s)
- First name, last name, email address, and contact telephone number(s) for emergency contact/next of kin
- School/college name
- Date of birth
- Image and likeness as captured on our CCTV cameras and on audition videos
- Any other information you provide to us by email, letter, telephone, social media, via our website, or in person
Sensitive information
This includes health information (if supplied) such as access need, allergy, or dietary requirements, and any other information specific to the opportunity you are applying for. We may also ask you for information about your ethnicity and sexuality; if you prefer to opt out, you can.
Data from third parties
We may also obtain or collect personal information about you from other third-party sources, for example:
- Referees may provide information to us about your experience and competence.
Board of Trustees, Community Board, and Development Trust
We may collect or store the following information from you when you sit on one of our boards or trust.
- Title, first name and last name
- Contact details including home and work postal address, email address, and telephone number(s)
- Organisations associated with and other professional information
- First name, last name, email address, and contact telephone number(s) for emergency contact/next of kin
- Date of birth
- Start date and leaving date
- Image and likeness (as captured on our CCTV cameras, and in photographs and videos we may use for promotional purposes)
- Any other information you provide to us by email, letter, telephone, social media, via our website, or in person
Sensitive information
We collect Equality, Diversity, and Inclusion (EDI) data to help us understand how well we are fostering a diverse and inclusive workplace. This is important for identifying areas for improvement, ensuring fairness, and creating an environment where everyone feels valued. We also use anonymous, aggregated EDI data to report to our funders.
Some of the information we collect is considered "special category" data, which is more sensitive and requires higher levels of protection. We have strict safeguards in place to ensure this data is handled responsibly. We only process this type of information in limited circumstances, such as:
- With your explicit written consent.
- To meet legal obligations or exercise rights connected to your involvement with us.
- For equal opportunities monitoring in the public interest.
In rare cases, we may process this information in relation to legal claims, to protect vital interests if you are unable to give consent, or if you have already made the information public.
We collect the following types of data:
- Ethnicity
- Gender
- Gender identity
- Sex
- Sexual orientation
- Socio-economic background
- Trade Union membership
- Criminal Offence data
Data from third parties
We may also obtain or collect personal information about you from other third-party sources, for example:
- Recommendations from other organisations/clients.
- If we engage an external photographer or videographer to capture events.
- Publicly available online information, such as information found in places such as Companies House, your biography on your website, or information that has been published in articles/ newspapers.
Use of data
We will use your information for the purposes listed below under one of the following lawful bases:
- Performance of a contract between us and you
- Your consent (where we need it)
- To comply with a legal obligation
- Our legitimate interests (except where such interests are overridden by the interests, rights, or freedoms of the individual)
We use your data to:
Staff
We use the information we hold to:
Process your application and communicate with you about the selection and interview/audition process | Consent |
Seek references for employment | Legitimate interests |
Keep interview/audition notes for future reference | Legitimate interests |
Check you are legally entitled to work in the UK | Legal obligation |
Keep a record of your employment contract | Performance of a contract |
Share your name and job title/position on our website | Legitimate interests |
Ensure we cater for any specific needs you may have such as access need, or allergy/dietary requirements | Legitimate interests
|
Assess your fitness to work and keep a record of fit notes | Legal obligation |
Undertake health surveillance e.g. monitoring and recording noise levels | Legal obligation |
Make reasonable adjustments as needed | Legal obligation |
Pay you and deduct tax and National Insurance contributions | Performance of a contract |
Provide benefits to you such as annual leave, staff tickets, childcare vouchers, discounted gym, cycle to work etc. | Performance of a contract |
Enrol you in a pension arrangement in accordance with our statutory automatic enrolment duties | Legal obligation |
Communicate with Defined Benefit Pension Plan members and make future payments | Performance of a contract |
Liaise with the trustees or managers of a pension arrangement operated by your pension provider and any other provider of employee benefits | Performance of a contract |
Conduct staff appraisals, manage performance, and determine performance requirements | Performance of a contract |
Collect feedback on the performance of conductors/soloist to inform future concert planning/bookings | Legitimate interests |
Manage your sickness absence | Performance of a contract |
Process sickness self-certification forms | Legal obligation |
Manage family leave including adoption, maternity, and paternity | Legal obligation |
Make decisions about flexible working requests | Legitimate interests |
Manage other types of leave e.g., bereavement leave | Consent |
Gather evidence for possible grievance or disciplinary hearings or ‘whilstleblowing’ investigations. | Performance of a contract |
Manage training and development opportunities | Legitimate interests |
Manage incoming and outgoing post and deliveries on behalf of CBSO and its employees | Legitimate interests |
Record any statutory training received | Legal obligation |
Share shift opportunities | Legitimate interests |
Deal with legal disputes involving you including accidents at work and personal injury claims | Legal obligation |
Make arrangements for the termination of our working relationship | Legitimate interests |
Ensure compliance with policies, procedures, and laws | Legal obligation |
Prevent fraud | Legitimate interests |
Monitor your use of our information and communication systems to ensure compliance with our IT policies | Legitimate interests |
Monitor your use of our information and communication systems to ensure compliance with our IT policies | Legitimate interests |
Monitor your use of our information and communication systems to ensure compliance with our IT policies | Legitimate interests |
Conduct data analytics studies to review and better understand employee retention and attrition rates | Legitimate interests |
Invite current and former staff to future CSBO special events e.g., Anniversary Performance | Legitimate interests |
Maintain the security of property and individuals using CCTV footage | Legitimate interests
|
Monitor equal opportunities | Legal obligation |
Freelancers
We use the information we hold to:
Keep a record of our relationship with you | Legitimate interests |
Communicating with visiting artists, composers, and conductors about schedule arrangements | Legitimate interests |
Check you are legally entitled to work in the UK | Legal obligation |
Keep a record of your contract/services engaged | Performance of a contract |
Enable payment for services | Performance of a contract |
Collate relevant information to arrange and manage tours effectively | Performance of a contract |
Maintain a list of top-quality freelance players to replace members during vacancy, absence, or sickness | Legitimate interests |
Book musicians and choral staff to run rehearsals and take part in projects | Legitimate interests |
Deal with legal disputes involving you including accidents at work and personal injury claims | Legal obligation |
Undertake health surveillance e.g. monitoring and recording noise levels | Legal obligation |
Ensure we cater for any specific needs you may have such as access need, or allergy/dietary requirements | Legitimate interests
|
Ensure compliance with policies, procedures, and laws | Legal obligation |
Prevent fraud | Legitimate interests |
Maintain the security of property and individuals using CCTV footage | Legitimate interests
|
Monitor equal opportunities | Legal obligation |
Work Experience
We use the information we hold to:
Process your application and communicate with you about the selection and interview process | Consent |
Administering the work experience agreement we have entered with you | Consent |
Ensure we cater for any specific needs you may have such as access need, or allergy/dietary requirements | Legitimate interests
|
Ensure compliance with policies, procedures, and laws | Legal obligation |
Prevent fraud | Legitimate interests |
Maintain the security of property and individuals using CCTV footage | Legitimate interests
|
Monitor equal opportunities | Legal obligation |
Board of Trustees, Community Board, and Development Trust
We use the information we hold to:
Process your application and communicate with you about the selection and interview process | Consent |
Administer the involvement we have entered with you | Consent |
Document any conflict of interests | Legal obligation |
Facilitate, record, and share the outcomes of Board and Trust meetings | Legal obligation |
Maintain a record of current and former Board and Trust members | Consent |
Invite current and former Board/Trust members to CBSO events | Consent |
Keep members up to date with CBSO news | Consent |
Ensure we cater for any specific needs you may have such as access need, or allergy/dietary requirements | Legitimate interests
|
Share your name and job title/position on our website | Legitimate interests |
Ensure compliance with policies, procedures, and laws | Legal obligation |
Prevent fraud | Legitimate interests |
Maintain the security of property and individuals using CCTV footage | Legitimate interests
|
Monitor equal opportunities | Legal obligation |
Sharing your data with third parties
Unless you give us your consent, the personal information that you give us will only be shared with third parties where we are obliged or permitted by law to disclose it, we need to use the services of ‘data processors’ to fulfil your requirements, to support analysis and research for the CBSO or the Arts Sector, or for reporting to our funders.
As part of the services offered to you, the personal information you provide may be transferred to countries outside the European Economic Area (EEA). For example, this may happen if any of the computer servers used to host our ticketing system are in a country outside of the EEA. If the CBSO transfers your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Policy. For more details, please see Use of Data section above.
The ways in which we share data with third party organisations are listed below:
Staff
We may share your data with third party organisations as follows:
Third Party Processors providing services to the CBSO e.g., our HR system, payroll system etc. | Performance of a contract |
Funders such as Arts Council England for analysis and reporting purposes (anonymised data only) | Performance of a contract |
Agencies such as the British Association of Orchestras for analysis and research purposes (anonymised data only) | Legitimate interests |
Companies House, Charity Commission, our auditors and professional advisers, and other regulatory bodies | Legal obligation |
Social media | Legitimate interests |
Tour operators if you are a member of staff travelling abroad with the CBSO | Legitimate interests |
Freelancers
We may share your data with third party organisations as follows:
Third Party Processors providing services to the CBSO e.g., our HR system, payroll system etc. | Performance of a contract |
Chaperones and Workshop Leaders | Legitimate interests |
Birmingham City University and Royal Birmingham Conservatoire for partnership activities | Legitimate interests |
Tour operators if you are performing abroad with the CBSO | Legitimate interests |
Funders such as Arts Council England for analysis and reporting purposes (anonymised data only) | Performance of a contract |
Agencies such as the British Association of Orchestras for analysis and research purposes (anonymised data only) | Legitimate interests |
Companies House, Charity Commission, our auditors and professional advisers, and other regulatory bodies | Legal obligation |
Social media | Legitimate interests |
Appropriate organisations when recommending your services | Legitimate interests |
Work experience
We may share your data with third party organisations as follows:
Third Party Processors providing services to the CBSO e.g., our HR system etc. | Performance of a contract |
Companies House, Charity Commission, our auditors and professional advisers, and other regulatory bodies | Legal obligation |
Social media | Legitimate interests |
Appropriate organisations when recommending your services | Legitimate interests |
Board of Trustees, Community Board, and Development Trust
We may share your data with third party organisations as follows:
Third Party Processors providing services to the CBSO e.g., our HR system, email platform etc. | Performance of a contract |
External advisors as part of the recruitment and interview process | Legitimate interests |
Companies House, Charity Commission, our auditors and professional advisers, and other regulatory bodies | Legal obligation |
Social media | Legitimate interests |
Keeping your data secure
We take every precaution to protect your personal data, and we hold regular security reviews to ensure that the website is safe and secure for your protection.
Your data is processed in secure systems and digital environments. Only authorised and trained employees and approved contractors/developers are granted access to personally identifiable information. This will be from time to time, and only when they need to perform a specific job or task.
If we need to share personal data with a third party, we ensure that the appropriate data sharing agreements are in place.
How long we keep your data
We will keep your personal information only for as long as needed to meet the reasons we collected it, including any legal, accounting, or reporting obligations. Information about how long we keep different types of personal data is recorded in the CBSO Data Privacy and Protection Register, which you can access through HR. When deciding how long to keep your data, we look at things like the type and sensitivity of the information, the risk of it being used without permission, the reasons we need it, whether we can achieve those goals in another way, and any legal requirements we must follow.
Staff
We will store data in our HR system for the duration of your employment plus a maximum of seven years after your employment with the CBSO ends. At that point your data will be deleted, no longer processed, and you will cease to receive communications from us, unless there is an outstanding issue, claim or dispute requiring us to keep such information until resolution.
Freelancers
We will store data in our database and finance system(s) for as long as you continue to supply us with goods and/or services, or 6 years plus the current tax year, where the relationship is not ongoing. At that point your data will be deleted and no longer processed, unless there is an outstanding issue, claim or dispute requiring us to keep such information until resolution.
Work Experience
We will store data in our database and finance system(s) for up to a year after you completed your work experience. At that point your data will be deleted and no longer processed, unless there is an outstanding issue, claim or dispute requiring us to keep such information until resolution.
Board of Trustees, Community Board, and Development Trust
We will store data in our database for the duration of your membership plus ten years after your service ends. At that point your data will be deleted and no longer processed, unless there is an outstanding issue, claim or dispute requiring us to keep such information until resolution.
Giving you control
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Staff
Contact hr@cbso.co.uk.
Freelancers
Contact cbsofinance@cbso.co.uk or your regular CBSO contact.
Work Experience
Contact hr@cbso.co.uk or your regular CBSO contact.
Board of Trustees, Community Board, and Development Trust
Contact hr@cbso.co.uk or your regular CBSO contact.
Your individual rights
Under data protection law, you have rights including:
- Your right of access: you have the right to ask us for copies of your personal information.
- Your right to rectification: you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure: you have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing: you have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing: you have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability: you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- Your right related to automated decision-making including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Where you have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact hr@cbso.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to.
How to make a complaint
If you wish to make a complaint about how we are using your data, please email mydata@cbso.co.uk.
Where you take the view that your personal data is processed in a way that does not comply with the UK GDPR, you have a specific right to lodge a complaint with the Information Commissioner’s Office (ICO). They will then inform you of the progress and outcome of your complaint. You can contact the ICO at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Change to this policy
We may change or update this Staff and Freelancer Privacy Policy from time to time. Any significant changes will be communicated on our website or by contacting you directly.
Last updated 1 April 2025