Privacy
FRY Creative Consulting is committed to protecting your privacy and handling your personal data responsibly. This policy explains how we collect, use, and protect your information in accordance with the UK General Data Protection Regulation and the Data Protection Act 2018.
Who We Are
FRY Creative Consulting is an independent cultural evaluation and research company specialising in arts, culture and heritage. Our registered address is 198 Grange Road, Birmingham, B14 7RS.
We are a specialist cultural evaluation, research and insight firm working as a business-to-business consultancy.
FRY Creative Consulting is registered with the Information Commissioner's Office (ICO) as a Data Controller, registration number ZB917054.
Our Privacy Principles
To provide clear, honest information about how we use personal data
To use personal data appropriately and only when necessary
To process personal data only when clients have asked us to, or when we need to fulfil our contract
To protect personal data from harm and delete it when no longer needed
To ensure our staff understand their responsibilities
To respect your rights under UK data protection law
Information We Collect and Access
Contact and Business Information
We hold contact details of our clients on our systems in order to operate our business effectively. This includes contact details for members of staff involved in a project, and finance teams for invoicing. We also collect contact details for individuals who register to attend our events or join our research projects.
Research and Survey Data
When you participate in our cultural evaluation projects, we collect the information necessary to conduct meaningful research. Where necessary, we collect personally identifiable information (PII) as part of data collection strands for research, but participants are always notified of how this will be used and how they will be anonymised as part of the process.
Survey responses about your opinions and experiences of cultural activities and programmes may sometimes include PII, but sometimes won't, depending on how participants respond to questions. If PII is included, all efforts will be made to anonymise the participant where necessary.
For interviews and focus groups, we may record audio or create transcripts and discussion notes, but only with your consent. We sometimes collect demographic information like age, location and professional background when relevant to the evaluation. Any data such as cultural or ethnic background is only collected with your explicit consent and when necessary for evaluation purposes.
Data from Third Parties
We sometimes process personal data on behalf of our clients as part of our evaluation work. We only ever do this at the request of, or with the explicit permission of the client. In these cases we act as data processors, not data controllers. When processing third-party data, we establish a data sharing agreement with the client to ensure appropriate safeguards are in place. Where possible, we collaborate with clients to incorporate clauses into their participant consent processes that clearly inform participants about data sharing with us for evaluation purposes. We take care to ensure that any data is adequately protected and that it is deleted at the earliest opportunity after the need for processing has ceased.
Website and Communications
We keep a record of the emails we send and receive from clients in order to track progress of a project, or to keep a record of the work we have undertaken with them. Like most websites, we receive and store certain details whenever you use our website. We use cookies to help us make our site better, including gathering usage data via Google Analytics. We use social media to broadcast messages and updates about our work, but we never buy paid advertising on social media.
Other Potential Data for Cultural Evaluations
Depending on the project scope, we might also access or process: attendance records, participation logs from cultural programmes, or creative outputs shared for evaluation. The level of anonymisation of these materials varies according to the specific evaluation needs.
How We Use Your Data
The personal data we hold is used to perform the contract of work we have with our clients, to contact individuals about taking part in research, or to keep our contacts informed of opportunities to take part in future projects. This includes, but is not limited to, conducting surveys, interviews, and analysis for cultural programmes, creating reports with insights and recommendations for our clients, and undertaking follow-up research such as longitudinal studies where agreed.
We also use your information for quality assurance to ensure the accuracy of our evaluation methods, for business communications including project updates and billing, and to provide agreed incentives such as thank-you payments or vouchers for participation where applicable.
Legal Basis for Processing
We process your data based on several legal grounds. When you agree to participate in our research, we rely on your consent. When processing is necessary to deliver our evaluation services to clients, we rely on contractual necessity. We also process data based on legitimate interest for cultural research that benefits the sector, and to meet legal obligations when required by law or professional standards.
For any sensitive data, we always require your explicit consent before processing.
Sharing Your Data
We are committed to maintaining the confidentiality of your personal data. We will only share your information in the following circumstances:
With Clients: We share anonymised and aggregated findings with our clients in evaluation reports. This means reports contain overall trends and summaries, not individual responses. Individual responses are only shared with your explicit consent, and reports typically focus on patterns rather than personal details.
Third-Party Service Providers: We may share data with trusted third parties to help deliver our services, including cloud storage providers with UK-based servers, transcription services operating under strict confidentiality agreements, and survey and analysis platforms with appropriate safeguards. These providers are contractually bound to comply with strict data protection and confidentiality obligations, and they are only permitted to process your data for specified purposes and in accordance with our instructions. We ensure all such transfers are compliant with UK GDPR.
Legal Obligation: We may also disclose information when required by law, court order, or professional standards, or where there are genuine safeguarding concerns.
Keeping Your Data Safe
Your data is stored securely on encrypted servers within the UK. We use up-to-date technology to protect against loss, misuse, or unauthorised access, and we have robust technical and security measures in place.
We retain your personal data only for as long as necessary. Active project data is kept during the project and up to 3 months after completion. Anonymised evaluation data may be retained indefinitely for sector research as it no longer identifies individuals. Client communications are retained for 7 years for business records and website enquiries for 12 months unless an ongoing relationship is established. We regularly delete data that is no longer needed.
Your Rights
You have the right to:
Be informed about how your data is used
Access your personal data
Have inaccurate data corrected
Have your data erased
Restrict processing of your data
Data portability
Object to processing
Withdraw consent at any time
To exercise any of these rights, please contact Richard Hawley.
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you are unhappy with how we have handled your data.
Website and Cookies
When you visit our website, we may collect technical data for analytics and security purposes. We use cookies to ensure website security, understand website usage patterns, and provide anonymous statistics through Google Analytics. We are not responsible for the privacy policies of external websites linked from our site.
Changes to This Policy
We regularly review this policy to ensure it remains accurate and compliant. Any updates will be published on our website at frycreative.uk. For significant changes, we will also email you where we have your contact details.
Contact Us
Please contact Richard Hawley if you have any queries regarding how we process personal data.
Or write to us at: FRY Creative, 198 Grange Road, Birmingham B14 7RS.
Last updated: May 2025