Chronicle Photography is a Photography business which provides photography services to its clients. Chronicle Photography will be a controller of your information when we are acting in the delivery of our Photography services to you. The personal data that we process to provide these services relates to its clients and other individuals as necessary, including staff. This policy sets out our commitment to ensuring that any personal data, including special category personal data, which we process, is carried out in compliance with data protection law. We are committed to ensuring that all the personal data that we process is done in accordance with data protection law and that good data protection practice is embedded in the culture of our staff and our organisation. This policy applies to all the personal data we process and is part of our approach to compliance with data protection law. All of our staff are expected to comply with this policy and failure to comply may lead to disciplinary action for misconduct, including dismissal. Our data protection policies and procedures are:
• privacy notices (website, clients, employees)
• data subject rights procedure
• data retention policy
• data protection impact assessment process
• record of processing activities
• personal data breach reporting process and a breach register
We will ensure that all staff who handle personal data on our behalf are aware of their responsibilities under this policy and other relevant data protection and information security policies, and that they are adequately trained and supervised. Breaching this policy may result in disciplinary action for misconduct, including dismissal. Obtaining (including accessing) or disclosing personal data in breach of our data protection policies may also be a criminal offence. The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff, for the purposes set out in this policy or for other purposes approved by you or as otherwise permitted by law. This may mean that your information is sent to computers out with the UK. We shall never sell or rent your personal information to third parties for their marketing purposes.
The Principles of Data Protection
We comply with the data protection principles set out below. When processing personal data, we ensure that:
- it is processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’)
- it is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (‘purpose limitation’)
- it is all adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’)
- it is all accurate and, where necessary, kept up to date and that reasonable steps will be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay as far as reasonably possible (‘accuracy’)
- it is kept in a form which permits identification of data subjects for as long as is necessary for the purposes for which the personal data are processed (‘storage limitation’)
- it is processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’)
We will facilitate a request from a data subject who wishes to exercise their rights under data protection law as appropriate, always communicating in a concise, transparent, intelligible and easily accessible form and without undue delay.
Our Processes and Procedures
- ensure that the legal basis for processing personal data is identified in advance and that all processing complies with the law
- not do anything with your data that you would not expect given the content of this policy and the fair processing or privacy notice
- ensure that appropriate privacy notices are in place advising staff and others how and why their data is being processed, and, in particular, advising data subjects of their rights
- only collect and process the personal data that it needs for purposes it has identified in advance
- ensure that, as far as possible, the personal data it holds is accurate, or a system is in place for ensuring that it is kept up to date as far as possible
- only hold onto your personal data for as long as it is needed, after which time will securely erase or delete the personal data (see our Data Retention Policy)
- ensure that appropriate security measures are in place to ensure that personal data can only be accessed by those who need to access it and that it is held and transferred securely
‘Data Protection Law’ includes the General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and all relevant EU and UK data protection legislation.
Your Rights as a Data Subject
Under data protection law you have rights in respect of the personal data about you that we hold and process. We have processes in place to ensure we can facilitate this.
For a list of your rights and more information please look at our policy document here: Data Protection Policy – May 2018 – SUBJECTS RIGHTS POLICY
Choosing Not To Share Your Information
We need to process your personal information to meet our contractual obligations – for our own legislative obligations – and in furtherance of the Photography services which we provide on your behalf in terms of our contract. If you fail to provide the data when requested, it may delay or prevent us fulfilling our obligations. This may mean we are unable to be your Photographer.
How We Process and Retain Your Data
We collect, store and process different types of personal information in the necessary course of our contractual obligations and the provision of Photography services to you. All our data is backed up daily to a server within the UK. We do not sell or rent your personal information to anyone.
We do not solely rely on automated decisions or processing of information for the purposes of fulfilling our legal obligations.
Who is responsible – Our Data Protection Administrator
If you have any concerns or wish to exercise any of your rights under the GDPR, then you can contact our Data Protection Administrator as follows:
Name: Darren Moore
Address: Chronicle Photography, 12 Copperwood Wynd, Hamilton, South Lanarkshire, ML3 0RP