Kent School Photography – Privacy Policy
Introduction
This privacy policy covers the data processed within Kent School Photography, explains what personal information we collect, why we collect it, and how we use it.
Definitions
‘We’, ‘Us’ or ‘Our’ refers to Kent School Photography
‘You’ or ‘Your’ refers to you as an individual or establishment
Contents
1. Who collects your personal information
2. How we collect it
3. What personal information do we collect
4. How we use your personal information
5. What our legal basis is for processing your personal information
6. Where your data is stored
7. How we keep your data safe
8. How long do we keep your personal information
9. Who we share your personal information with
10. Cookies
11. How you can amend your preferences
12. Personal data breaches
13. Your rights
14. Changes to our privacy notice
15. Contacting us
1. Who collects your personal information
Kent School Photography Ltd (16913741), trading as: Kent School Photography
Postal: 1-2 Rhodium Point, Spindle Close, Folkestone, CT18 7TQ
Email address: data@kentschoolphotography.co.uk
Phone: 01227 507859
Information Commissioner’s Office (ICO) registration number: ZC077873
2. How we collect it
Kent School Photography collects your data through our websites, products, customer accounts, and is requested for contracted services
3. What personal information do we collect
We collect personal information about you (such as your name, address, school, job role, email address or telephone number) in a number of ways, including when you give this to us as part of becoming a customer, registering as a customer via our online shop, completing a website form, or making a sales or support enquiry.
When you subscribe to any of our marketing or communications, you indicate that you have a preference to receive these communications. We store your preferences and you have the option to change these at any time by following the ‘unsubscribe’ link at the bottom of emails or by contacting us.
The Performing Pictures app may collect additional personal data during video recordings. This may include a child’s voice, mannerisms, and references to their current or future school or nursery. If a recording contains information considered excessive or inappropriate, such as sensitive personal information or information relating to another identifiable individual, Kent School Photography will stop the recording, notify the relevant school or nursery, and permanently delete the recording.
As part of using our websites and Performing Pictures app, we may also store information about how you use our sites, for example the pages viewed, time spent on each page etc. in order to be able to take steps to improve your digital experience. These behaviours including IP addresses are captured within Google Analytics and via the app. You can read more in our cookie policy (www.kentschoolphotography.co.uk/cookie-policy/).
4. How we use your personal information
We may use your personal information following…
· General enquiry or feedback - where you may be contacted by us via telephone or email requesting information about products and services and we may use the data captured to help improve services or assist in finding a resolution to your enquiry
· Marketing subscription - where you would have signed up via a web form or other data capture point. This information will be processed in accordance to that stated at the point of capture. You can unsubscribe anytime or customise your preferences
· Customer account registration - where we may use your data to send important updates, deadlines, promotions, direct marketing and other useful information that will help you get the most out of the products and services available to you
· Product Purchase - where we may have obtained your data following the agreeing to the terms and conditions of sale. We may use this data to contact you about production updates, delivery updates, order errors, financial queries, and other useful information that will help you get the most out of our products and services
· Sales Enquiry - where you may have contacted us via telephone, email or other channels requesting information about products and services we have to offer, or we have contacted you and you have expressed an interest. You can unsubscribe anytime or customise your preferences
· Support Enquiry - where you may have contacted us via telephone or email
· We may use the data captured to help to resolve your enquiry and may contact you after for feedback to help improve the service offered.
· Your website - occasionally we may need to obtain your details from your company website or from a publicly available website, such as Edubase. We will only process data if a suitable legal basis has been established and will follow all GDPR policies at all times.
5. What is our legal basis for processing your personal information
We will only collect and use your personal information (described in section 4) in accordance with data protection and GDPR legislation. Our legal bases for processing your personal information are as follows:
1. Contractual – We may process personal data associated with a contract or product purchase. It is important for us to hold this data in order to ensure that we have records from a legal perspective to whom agreed to the terms and conditions and who to contact following issues.
2. Consent – Where necessary, we will only collect and process your personal information if you have given your consent for us to do so. For example, we will only send you certain marketing emails and process any sensitive information about you if we have your consent.
3. Legitimate Interests – We may use and process some of your personal information where there are legitimate interests for doing so, defined under European Privacy Legislation as a justification for processing your personal information.
You have a right to object to our use of your personal information for these legitimate interests. Please see section 11 - Your rights and how to contact us for how to do this.
6.Where your data is stored
We store data using various methods and they are:
1. Cloud based storage – within the EU
2. Physical hard drives
3. Hard copies
7. How we keep your data safe
Our cloud-based storage is password protected and requires 2-factor authentication to gain access. Computers and hard drives (internal and external) use 254-bit encryption and require a password to gain access. Passwords are kept confidential and are not stored on any device or hard copy.
Our premises is securely locked and all locks conform to BS 3621 and EN 12209.
8. How long do we keep your personal information
All personal data will be held in accordance with GDPR, and historical records will not be held without legitimate reason. Data is regularly cleared down within our system if it has not been used, updated or interacted with for 8 years. We hold information for this time as it is the time a child attends a UK primary school plus one additional year. This is so we can fulfil requests such as reprints or queries in all circumstances. We will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this privacy notice or until you request it be deleted.
Our Performing Pictures app does not store any personal information however there may be instances when subjects reveal personal data, e.g. saying their name in a video. The videos and photos are stored on a UK-based server and only Kent School Photography Ltd and the user will have access to this. We store this data on for a minimum of 20 years to ensure functionality however you can request that this is deleted providing that it is not a group image that also does not contain any personally identifiable data.
9. Who we share your personal information with
We will never sell your personal data to any third party, business, charity or individual. We may only transfer data if Kent School Photography Ltd changes ownership in which case, all individuals will be made aware of the change and provided with 30 days’ notice via email.
We share your data with our online shop provided by GotPhoto, Fotografen Online Service GmbH, Greifswalder Strasse 207, 10405 Berlin, Germany. This is to fulfil any contractual obligations and to process all product orders. All data shared is subject to all EU data laws and GDPR. A signed data processors agreement is in place between us and GotPhoto.
When products are shipped via a courier, we will share your name and address to fulfil our contractual obligation and only use courier companies that have all relevant GDPR policies in place. The list of current couriers are as follows:
· Royal Mail - https://www.royalmail.com/privacy-notice
· Parcelforce - https://www.parcelforce.com/privacy
· DPD - https://www.dpdlocal-online.co.uk/content/privacy-policy
· TNT - https://www.tnt.com/express/en_gb/site/privacy-policy.html
· DHL - https://www.dhl.com/gb-en/home/footer/privacy-notice.html
· FedEx - https://www.fedex.com/en-gb/privacy-policy.html
· UPS - https://www.ups.com/gb/en/support/shipping-support/legal-terms-conditions/privacy-notice.page
· Parcel2go - https://www.parcel2go.com/privacy-policy
We may share your information with the school or nursery that your child attends in order to verify identity. We may also share your details external parties providing there is a lawful basis to do so, e.g. child protection services.
10. Cookies
“Cookies” are text files that are stored on your computer that allow an analysis of your use of the website.
The information generated by the cookie about your use of this website is usually transferred to a server and stored there. However, due to the activation of IP anonymisation on some websites, your IP address is sometimes shortened in advance within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Depending on the service provider, such an IP address is stored truncated.
On behalf of Kent School Photography, the third party will use this information to analyse your use of the website, to compile reports on the activities of the website and to provide further services to the website operator related to the use of the website and the Internet.
You can prevent the storage of cookies by changing the corresponding setting in your browser software; however, we would point out that in this case you may not be able to use all the functions of this website to their full extent. Which third-party cookies are used? We use the following third-party cookies on our website:
Google Analytics (For more information, see: https://support.google.com/analytics/answer/6004245?hl=de)
Google Adwords (For more information, see: https://policies.google.com/privacy?hl=de)
New Relic Inc. (For more information, see: https://newrelic.com/termsandconditions/privacy)
gotphoto.co.uk (For more information, see: Fotografen Online Service GmbH) (https://www.fotograf.de/datenschutzhinweise/)
11. How you can amend your preferences
If you or your school has received a marketing communication and you would like to change your preference, please click on the ‘unsubscribe’ or ‘change preferences’ button located at the bottom of the email to change your preferences. Alternatively, reply with ‘unsubscribe’ in the subject. You can also email us with your request – data@kentschoolphotography.co.uk
12. Personal Data Breaches
In the unlikely event we suffer a data breach, we inform you within the timescales outlined by the Information Commissioners Office and maintain a register of all data breaches. The register shall at a minimum include the following:
i. A description of the nature of the data breach, including, if possible, the categories and the approximate number of affected data subjects and the categories and the approximate number of affected registrations of personal data.
ii. A description of the likely as well as actually occurred consequences of the data breach.
iii. A description of the measures that we have taken or propose to take to address the data breach, including, where appropriate, measures taken to mitigate its adverse effects.
13. Your rights
Under data protection legislation you have a number of rights in relation to your personal information. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. We will respond to you within 30 days after we have received this information or, where no such information is required, after we have received your request. This section explains what they are and how you can use them, if you wish.
13.1 Accessing your personal information
You have the right to request a copy of the personal information that we hold about you. This is known as a Subject Access Request.
If you wish to request a copy of your personal information, please email requests to data@kentschoolphotography.co.uk
13.2 Correcting and updating your personal information
The accuracy of your information is important to us. If you change any information we may hold on you, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by emailing data@kentschoolphotography.co.uk
13.3 Erasing your personal information or restricting its processing
You may ask for your personal information to be removed from our systems. Unless we are legally permitted or required to keep the data, we will comply with your request.
You may also ask us to restrict processing your personal information in the following situations:
· Where you believe it is unlawful for us to process the data
· You have objected to its use or you require us to keep it in connection with legal proceedings.
If you wish to exercise any of these rights please email your request to data@kentschoolphotography.co.uk.
13.4 Right to lodge a complaint
You have the right to complain to the Information Commissioners Office if you are concerned about the way we have processed your personal information. They can be contacted via:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
14. Changes to our Privacy Notice
This Privacy Notice may be updated from time to time, so you may wish to check it each time you submit personal information to us. If material changes are made to this Privacy Notice, for instance affecting how we would like to use your personal information, we will provide a more prominent notice via our website or email.
15. Contacting us
If you any questions or comments regarding the content of this Privacy Notice, please email us at data@kentschoolphotography.co.uk