The Audience Agency
Anne Torreggiani, Chief Executive of The Audience Agency, explains the motivation behind the guidance
"We were commissioned by Arts Council England to draft some guidance on data sharing, not just in in the light of their new requirement to share data, also the new advice from the ICO on how arts organisations should best comply with Data Protection and privacy legislation. The idea was to help save money on lots of organisations spending huge amounts on the same legal advice, while confidently forming the happy data-sharing relationships that ACE intend as the result of their new requirements.
The guidance sets out what the law says you can do and what you can’t as clearly and simply as possible, and it has been produced in consultation with and with advice from the Information Commissioners Office. We have also reviewed this guidance in the light of the application of GDPR from MAy 2018 onwards. Arts Council England have also developed a very clear definition of their requirements.
When it comes to finding practical solutions to sharing information within these frameworks, however, there is still a lot of room for interpretation. Organisations differ greatly in what they want and are able to share. After consulting with scores of venues and companies we realised there is no one-size-fits-all practical solution. So the guidance acknowledges both the pressing needs for visiting companies to access data, and challenges venues and data controllers have in properly making data accessible. We’ve made lots of suggestions as to how companies can share – but in the end, organisations have to agree what fair-sharing actually looks like in practice.
To that end, we’ve presented all the practical guidance in such a way that allows everyone to leave feedback. We’ve also proposed checklists to help organisations decide whether or not they’re following good practice themselves. Do please take part and give us your feedback. It will all be collated, sent to Arts Council England, and used to build up the Questions and Answers / Suggestions section on the site, a living resource for us all.
The Audience Agency understands that there are a wide range of views about sharing audience data. We are as sympathetic to visiting companies who rely on access to data to develop their audiences, as we are to venues who have to find ways of making that possible practically and legally.
We do NOT take the view that it is always practical, fair or justifiable for organisations to share personal data, nor that it is always in the interests of audiences. We think that each situation is different, and partner organisations need to agree a mutually beneficial approach.