An outline of some of the principles and challenges of data sharing and signposts to guidance on the key issues
The Information Commissioner’s Office (ICO) is currently considering introducing new guidance which will affect our good practice information; changes relate specifically to sharing names and addresses gathered from online bookings between companies for mailing and other marketing purposes, under PECR (Privacy and Electronic Communications Regulations, dating from 2003). Please check for updates. Visit the ICO website here for more information on data protection guidelines.
Data, we are told these days, is the new oil. Consumer data – and that is the kind corporate business is excited about – is valuable because, if well used, it can drive real market understanding and customer relationships. Many cultural organisations are rich in data and have been using it with increasing sophistication to deepen and broaden audiences. Nevertheless, as well as “data-haves”, there are still plenty of “data-have-nots” says Anne Torreggiani.
Introduction to data sharing
In this introduction, we outline some of the principles and challenges, with the latest guidance by Roger Tomlinson on data protection for data sharing, plus suggestions for touring companies on data permissions and contracts and ideas for trying to develop their own audiences – culminating in six key principles towards better practice.
By collecting and sharing data, organisations can greatly increase the usefulness of their own information, while benefiting the whole sector with a valuable knowledge asset. By sharing data directly with collaborators, we can also maximise audience relationships. All this in turn has to be good for the public, whose needs we can then anticipate with much greater sensitivity.
Arts Council England now encourages funded organisations to maximise their data resources by exercising good practice in data sharing.
Why share data: purpose
Audience data is not inherently useful and only becomes so once it is put to a purpose and organised, analysed or processed to that end. We tend to think of data as information from a box office system, or increasingly from online or social media, but it includes any recorded information e.g. mailing lists, names in a CRM database, comments in a visitor’s book or emails/data collected through surveys.
There are 2 main purposes which data serves, and any plan to share data should be clearly geared to one or both:
a) to provide actionable insight about audiences and non-attenders
Sharing data enriches insight by creating context. This can help to highlight opportunities for growth or collaboration, form benchmarks and realistic plans, and make the case for what we do.
b) to enable communication directly with audiences or participants
Sharing data for communication enables different companies to build different audience relationships. This can help to increase engagement, offer the public a tailored service and make touring companies more resilient.
Data Protection, Data Ownership and Data Sharing
a) Sharing data for insight purposes
Provided that the data has been appropriately collected, the Data Protection Act allows ‘anonymised’ data to be used for research and analysis purposes. The data must not be reported or published in a form which would potentially enable the identification of individuals e.g. by including a full postcode.
b) Sharing data for communication purposes
Data protection legislation does however come into play if you wish to communicate directly with audiences, using “personal” data – or information to contact an individual directly (name, address, email etc).
Data Protection legislation is largely concerned with protecting named individuals and their right not to be identified or targeted unfairly or against their wishes. The law favours the customer’s decision about who should – and who should not – contact them. This creates a raft of cultural and legal challenges outlined below and explored through the downloadable guidance as part of this article.
Data protection legislation is not concerned with who owns processed data, only with how that data is used. Data control is then a matter of contractual agreement between 2 or more organisations. The organisation recording the data – or Data Controller – has legal obligations to the members of the public whose records they keep, which includes not sharing personal data with third parties without permission.
The challenges for data managers and venues
It is considered good practice for venues and visiting companies to work together to understand and reach their shared audiences, and venues should not unreasonably withhold data. Venues face a range of challenges to share data, however, and realistic plans need to take these into account. They include:
- Lack of knowledge or confidence in their legal responsibilities
- Costs and management issues of gaining permissions from audience members
- Lack of skills and resources to extract data and in the relevant format
- Ensuring data is “clean”
- Concerns that the data will be looked after properly by third parties
- Concerns about bombarding audience members with too many or inappropriate communications
Our guidance will help with some of these issues. Putting systems in place is not as complicated as people sometimes think. If you want to share personal data, it is a good idea to have a data sharing agreement or to include clauses in a contract that cover these issues. Audience Finder can support venues to supply data for insight.
The challenges for touring companies
Many touring companies rely on venues sharing data to give them some sense of who their audiences are and to provide the personal data that will enable them to build audience relationships. Sharing data regularly with venues brings its own challenges, however, and companies should consider other potentially more effective ways of accessing insight or managing audience relationships. See examples of data sharing case studies.
Evidence suggests that audiences tend to relate more closely to venues than companies, though not exclusively. In Audiences on Tour, we therefore recommend that companies prioritise sharing contact information with venues with which they have an ongoing and developmental relationship.
Where companies have enough resources to manage their own audience relationships, we also suggest that they build and manage their own mailing lists, through websites, social media and follow-up mailings with the help of venues.
The profile of a company’s audience also tends to match the profile of venues, varying from one to the other. Not all touring companies have in house skills and IT systems needed to carry out regular data analysis. For both of these reasons, it might be a red herring to go to the effort of collecting a lot of data from every venue. It is also very difficult for companies to build up big enough samples through audience surveys. It may be that using other sources of audience insight, like Audience Finder or other secondary research, might yield more useful insight than chasing data from many venues. There is more advice on audience insight for touring companies in the Toolkit.
The challenges for non-ticketed companies
Non-ticketed organisations can also share data usefully, by sharing the results of primary research with others. The Audience Finder survey is a standard framework enabling organisations to ask the same questions in the same way so that results are comparable; results are then shared and interpreted in meaningful clusters of similar organisations. Visitor Finder is the new museum specific version of Audience Finder offering small and medium sized museums access to insights that have only been available to the nationals or major partner museums. Even if you don’t use a common framework like this, you can still benefit by sharing the overarching results of your surveys with other organisations.
As organisations become more adept at understanding audience relationships in and through digital media, so the importance of sharing this insight grows. Digital affords an unprecedented opportunity for organisations, especially non-ticketed ones, to share knowledge and audiences, despite the challenges in doing so. Culture24’s Lets Get Real project has explored a number of the issues and have delivered workshops in understanding digital as part of Audience Finder with a downloadable set of resources available here.
Towards better practice
Six simple principles:
- Do collect and share data that is useful. Have a clear purpose, which can be achieved with the resources available.
- Do share, insight benefits all. Take a partnership or collaborative approach to sharing and interpreting audience intelligence.
- Do take care handling personal data. Remember: let the customer decide. Be aware of compliance and good practice whether you are the Data Controller or not, and note new advice on digital channels. Data protection does NOT affect the use of data for research purposes.
- Do ensure you have the right resources. Only share data that you have the right skills and resources to use.
- Do put a data sharing agreement in place. This should address concerns of both/ all parties and can be included as part of a contract.
- Do make the most of free Audience Finder resources. Audience Finder has been created to making data sharing easier and more effective.