GDPR – Privacy Notice
Carmel Jane Photography is a photography firm based in Brentwood, United Kingdom (EU). As an organisation we provide photographic services to Commercial, Dance Studios, Schools, Sports Clubs and the General Public. Please see: www.carmeljane.co.uk
Data Protection Officer
Under the regulation, Carmel Jane Photography has an acting a Data Protection Officer and a Senior Data Controller who can be contacted on:
The data we will process on your behalf commercially include:
- Company name
- Company address
- Telephone number
- Email address
- Invoice address
With Schools, Dance Studios and Sports Clubs:
- School Year
- Club or Dance studio
- Individual Photos of each child
- Any class photo the child may have been in
- Student ID (if applicable)
- Parents Name
- Parents Email
- Parents Telephone
- Address (only if photos have been ordered and requested to mail by parent/guardian
Our Legal Basis for Processing your Personal Data
We will process your data securely under the following legal basis:
- We require a name, address, telephone number, email address for secure identification and correspondence during your purchase of photos
- Consent for photography to take place, would have been given by the parent to the school, club or dance studio prior to our involvement
- We require personal details to provide you with photography services and retain this securely to ensure nothing can inflict harm on any personal data we hold
- We require this data or in order to carry out the required photography and delivery service to you
- We require invoice details in order for us to charge the agreed price for the photography services you receive, and retain this data for Tax and HMRC legally.
Legitimate interests pursued by us or third parties we use, are as follows:
- Your contact details are not shared with third parties. These details are not shared furthermore, except merely held for security or legal reasons relating to the service being provided.
Special Categories of Personal Data
- We do not store ‘special’ personal data such as driving license, passport, or national insurance numbers.
- We may ask to ‘view’ an item of ‘special’ personal data if being asked to hand over sensitive data and we are required to identify an authorised recipient in order to prevent a data breach
Carmel Jane Photography will not pass on your data to third parties, except ‘GotPhoto’ who securely hold your photographs so you can view and purchase the items. This is done through a secure encrypted portal. We do not pass any other information without first obtaining your consent.
Carmel Jane Photography will process personal data for a maximum of 7 years to coincide with HMRC, Legal and Accounting records. The exception being special case data which, in the event of a client requesting for photographic data to be deleted for security reasons. Accounting data will still be held for 7 years.
Your Rights as a Data Subject
As a data subject, you will have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Carmel Jane Photography refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
In line with Subject Access Request Procedure and Subject Access Request Form, which we can provide.
In the event that you wish to make a complaint about how your personal data is being processed by Carmel Jane Photography (or its third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority which is the ICO (www.ico.org.uk).
You can report a concern directly with the ICO, if Carmel Jane Photography fails to handle your complaint in an appropriate manner: https://ico.org.uk/concerns/
Please send any initial complaints to: firstname.lastname@example.org
Specific Online Privacy Statement
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
How we use your information online
This privacy notice tells you how we, Carmel Jane Photography, will collect and use your personal data for from our secure contact form which will refer to this policy for consent that you allow us collect personal data, for example: name, Email and contact telephone. Your data will be processed for contact purposes only.
Why do Carmel Jane Photography need to collect and store personal data?
In order for us to provide you any level of service we need to collect personal data for correspondence purposes. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Carmel Jane Photography would contact you for additional consent, unless you have formerly ticked the consent option on our contact form.
Will Carmel Jane Photography share my personal data with anyone else?
We only pass your photographic data on to third-party service provider ‘GotPhoto’ who are contracted to Carmel Jane Photography to enable secure encrypted and password access to your Photo’s. No name or personal details are sent or stored. When they no longer need to store your data to fulfil this service, they will dispose of the details in line with Carmel Jane Photography procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Carmel Jane Photography use the personal data it collects about me?
Carmel Jane Photography will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Carmel Jane Photography is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Carmel Jane Photography at your request, can confirm what information we hold about you and how it is processed. If Carmel Jane Photography does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. This will always be a representative based in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Carmel Jane Photography or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or EU international organisation, this is done securely through encrypted means.
The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored?
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing. (We do none of these)
What forms of ID will I need to provide in order to access this?
Carmel Jane Photography accepts any of the following forms of ID when information on your personal data is requested:
- Driving licence
- Another form for ID which leaves no doubt of the data owner