Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, Julia Margaret Cameron Trust / JMC Trust / JMCT Trading / Dimbola Museum & Galleries / Freshwater Circle.
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Regulation.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and / or process any personal information about you electronically using the following lawful bases.
- We are registered with the ICO under the Data Protection Register, our registration number is: Z9953761.
- Lawful basis: Consent
The reason we use this basis: To send you newsletters, you need to sign up to our Mailing List via our website.
We process your information in the following ways: We will hold the data you provide on our Mailchimp database.
Data retention period: We will continue to process your information under this basis until you withdraw consent by clicking ‘unsubscribe’ at the bottom of any email we send you.
- Lawful basis: Legal obligation
The reason we use this basis: Gift Aid
We process your information in the following ways: We hold the data in an electronic database using Google Drive, which we also share with HMRC.
Data retention period: 6 years, in compliance with HMRC requirements.
- Lawful basis: Legitimate interests
The reason we use this basis: For our Museum Collection Database.
We process your information in the following ways: Storing your personal details in both paper and electronic formats.
Data retention period: We will store your data according to the type of donation.
Sharing your information: We will not share your information with third parties without your consent.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirement.
Transparent Privacy Explanations
We have provided some further explanations (see below) about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards and geographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (by clicking ‘unsubscribe’ at the bottom of any email from us) or manage your preferences / the information we hold about you at any time.
Our EMS provider is; Mailchimp. We hold the following information about you within our EMS system;
- Email address
- I.P address
- Geographic data
- Subscription time & date
- First and Last Name, if provided.
Resources & further information
- Overview of the GDPR – General Data Protection Regulation
- Data Protection Act 1998
- Privacy and Electronic Communications Regulations 2003
- The Guide to the PECR 2003