Privacy Notice
Version: 1.0
Effective date: August 2026
Review date: August 2027
1. About this notice
Human Clay CIC is the controller of the personal information described in this notice. This notice
explains what information we collect, why we use it, who we may share it with, how long we
keep it and the rights available to you.
It applies to participants, audiences, artists, freelancers, collaborators, volunteers, partners,
suppliers, donors, people making enquiries, and people appearing in photographs, audio
recordings or films.
Human Clay CIC is a community interest company registered in England and Wales. Registered
office: April Cottage, Buckland in the Moor, Ashburton, Devon TQ13 7HN. Privacy contact: Anna
Kushnerova, Director, at humanclaycic@gmail.com.
2. Information we may collect
• Identity and contact details, such as your name, email address, telephone number and
organisation.
• Booking, attendance and participation information, including communications about an activity.
• Access, dietary, health or emergency information that you choose to provide and that is relevant
to safe participation.
• Professional, contractual and payment information relating to artists, freelancers, suppliers and
partners.
• Feedback, correspondence, complaints and records of concerns.
• Photographs, film, audio, interviews, artwork and contributor information where these form part
of a project or its documentation.
• Limited safeguarding information where a concern is raised or observed.
We aim to collect only information that is relevant and proportionate to the activity or
relationship.
3. How and why we use information
• To respond to enquiries and administer bookings, events, workshops and participation.
• To plan access arrangements and support safe, inclusive participation.
• To commission, contract with and pay artists, freelancers and suppliers.
• To communicate about current projects and, where permitted, relevant future opportunities.
• To document, produce, exhibit, publish or archive creative work where appropriate
arrangements have been agreed.
• To respond to complaints, safeguarding concerns, incidents, legal claims and insurance matters.
• To meet legal, regulatory, accounting, funding and contractual requirements.
4. Lawful bases
Depending on the purpose, we rely on one or more lawful bases under UK data-protection law:
• Contract: where information is needed to enter into or perform an agreement with you.
• Legal obligation: where we must keep or use information to comply with the law.
• Legitimate interests: where reasonably necessary to operate Human Clay, deliver and document
our work, maintain records, protect people and property, and handle concerns, after considering
your rights and interests.
• Consent: where we have asked for a clear, specific choice, including some communications or
uses of images and sensitive information. Consent may be withdrawn, although this may not
affect use that has already lawfully occurred.
• Vital interests: in a rare emergency where use is necessary to protect life.
Health information and other special-category information receive additional protection. Where
we use such information, we will identify an appropriate Article 9 condition, such as explicit
consent, vital interests, or the establishment, exercise or defence of legal claims, depending on
the circumstances. We will seek advice where the correct basis is unclear.
5. Photography, film and creative work
We will explain when photography, filming or audio recording is planned and how material is
intended to be used. Depending on the project, this may be governed by consent, a contributor
agreement, another contract, or legitimate interests. Project-specific information will take
precedence where it gives more detail.
Once material has been published, exhibited, distributed or incorporated into a completed
creative work, withdrawal or removal may be limited or impracticable. Any such limits will be
explained as clearly as possible before participation.
6. Sharing information
We share personal information only where necessary and appropriate. Recipients may include
delivery partners, venues, funders where reporting requires it, professional advisers, insurers,
payment and technology providers, contractors supporting our work, and public or statutory
authorities where required.
We do not sell personal information. We require service providers acting on our behalf to handle
information appropriately.
7. International use
Some projects, collaborators or service providers may be outside the UK. Where personal
information is transferred internationally, we will use an appropriate lawful safeguard or rely on
another permitted mechanism. Project-specific information will be provided where a transfer is
significant.
8. How long we keep information
We keep personal information only for as long as reasonably necessary for the purpose for which
it was collected, and to meet legal, accounting, funding, insurance, contractual or safeguarding
needs. Retention periods differ by record type and project. We periodically review information
and delete or anonymise it when it is no longer needed.
Published creative works and agreed archival material may be retained for longer as part of
Human Clay's artistic and organisational record, subject to the applicable agreement and legal
basis.
9. Security
We take proportionate technical and organisational steps to protect personal information from
unauthorised access, loss, misuse or disclosure. Access is limited to people who have a
legitimate need to use the information.
10. Your rights
Depending on the circumstances, you may have rights to access your information; correct
inaccurate information; request deletion or restriction; object to certain uses; receive certain
information in a portable format; and withdraw consent. These rights are not absolute and may
not apply in every case.
To exercise a right, contact us at humanclaycic@gmail.com. We may need to confirm your
identity before responding.
11. Concerns and complaints
Please contact Anna Kushnerova at humanclaycic@gmail.com if you have a question or concern
about how Human Clay uses your information. You may also complain to the Information
Commissioner's Office at ico.org.uk.
A concern involving immediate danger, abuse or neglect should be handled under Human Clay
CIC's Safeguarding Policy and Statement.
12. Review and related policies
We will review this notice annually and sooner if our activities or data practices change. It should
be read alongside Human Clay CIC's Safeguarding Policy and Statement, Equality, Diversity &
Inclusion Policy, Complaints Procedure and any project-specific consent, contributor or access
information.
Approved by: Human Clay CIC directors
Approval date: 01/08/2026
Contact: humanclaycic@gmail.com