Privacy policy - The Courtauld Institute of Art

Privacy policy

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Privacy policy

Privacy policy

The Courtauld Institute of Art is committed to protecting your privacy. This statement applies to all information collected or submitted by The Courtauld Institute of Arts and is designed to provide you with details of how we collect and process your personal data in regards to the General Data Protection Regulation, (GDPR) and the UK Data Protection Bill 2017. The Courtauld Institute of Art is the data controller therefore responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

If you are not happy with any aspect of how we process your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Our registration number is Z6896909.

We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you. You can email us at DPO@courtauld.ac.uk or you can write to us: Data Protection Officer, The Courtauld Institute of Art, Somerset House, Strand, London WC2R 0RN, or call us on 020 3751 0536.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at DPO@courtauld.ac.uk indicating the changes required. All emails will be responded to within 24 hours and actioned in line with the regulations.

Sensitive Data

We only process sensitive data where it is necessary to do so in line with a legal lawful basis identified. For example, we may collect health information from some students / academic staff to ensure we protect you.  We do not process any sensitive data without your permission to do so. Sensitive data includes the following categories:

  • racial or ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • physical or mental health or condition
  • sex life or sexual orientation
  • genetic data
  • biometric data

HOW WE USE YOUR PERSONAL DATA  

 We will only use your personal data when legally permitted. The most common uses of your personal data include:

  • Supporting new students / academic staff through the lifecycle of their education.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

The Courtauld will ensure it always uses the correct legal lawful basis to process your personal information dependant on the process that is being carried out.

At least one of the conditions set out in Article 6 (1) must be met in the case of all processing of personal data except where a relevant exemption applies. These are:

  • Consent
  • Contract
  • Legal obligation
  • Vital interest
  • Public interest
  • Legitimate interest

Purposes for processing your personal data  

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at dpo@courtauld.ac.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

The below represents where personal data is processed, below which is a table that offers representable examples.

Development

o   Alumni

o   Donors

o   The Courtauld Friends

o   American Foundation for The Courtauld Institute of Art

o   Courtauld Alumni Association

 

 

 

Finance

o   General finance

o   Grant applications

o   Endowed and funded posts

o   Payroll (Courtauld and SCTE)

o   Student Payment data

o   Public Programmes bookings payments

o   Trade invoices

o   Expense Claims

o   Duchy House payments

o   Membership payments

o   Gift Aid

 

Gallery

o   Visitor bookings and Correspondence

o   Visitor Gift Aid forms

o   Press forms

o   Gallery Membership

o   Items on loan for Gallery display

 

Marketing

o   Undergraduate and postgraduate prospectus mailing

o   General enquiries

o   Newsletters

o   Comments cards

o   Audience research

o   Suppliers database

Libraries

o   Membership information

 

 

 

 

Recruitment and HR

o   Job applications and CV management

o   HR records

o   Right to Work Evidence

o   Maintaining Payroll information

o   Probation

o   Appraisals

o   Sickness

o   Occupational Health

o   Disciplinary

o   Maternity / paternity / parental leave

o   Student ambassadors

o   Temporary and contract staff

Public Programmes

o   Summer Universities

o   Schools Projects

o   Gallery Tours

o   Short Courses

o   Events

·       Research Forum

o   Events

o   Newsletters

·       Samuel Courtauld Trust Enterprises

o   Shop

o   Online Shop

o   Courtauld images (sale of Image rights)

o   SCTE Employees

 

·       Courtauld Security (3rd Party)

o   CCTV

o   Buildings Access Control

o   Security IDs

 

·       Student Services

o   All student registration and course data

o   Liaison with 3rd party colleges

o   VLE (Moodle) registration

o   Admission processing

o   Legally obliged statistical data collection

o   Timetabling

o   Student Loan liaison

o   US Loans

o   US Veterans association

o   TFL (Oyster Cards)

o   Confirmation of student qualifications

o   Accommodation

o   Scholarship management and allocation

 

·       Students’ Union

o   SU Events

o   SU Incidents

o   Expense reimbursements

 

·       Duchy House Summer guests

o   Summer guest rentals

o   Commercial lets

 

For specific questions please email dpo@courtauld.ac.uk

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing

 

To register you as a new student

 

(a) Identity

(b) Contact

(c) Health

 

(a)    Contract

(b)    Legal Obligation

(c)    Vital Interest

(d)    Legitimate Interest

To send you on-going information via email

 

(a) Identity

(b) Contact

 (c) Marketing and Communications

 

(a) Legitimate Interest

(b) Consent

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

 

To administer and protect our Institute and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests for running our Institute, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b) Necessary to comply with a legal obligation

 

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

 

To make suggestions and recommendations to you about services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

 

Necessary for our legitimate interests to develop our products/services and grow our business

 

 

Marketing communications 

 You will receive marketing communications from us if you have:

  • requested information from us; or
  • if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
  • in each case, you have not opted out of receiving that marketing. 

 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Any marketing done by The Courtauld will be done in line with the correct legal basis dependant on the actual marketing. At all times you will be offered the option to opt out. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of other reasons, for example student registration.

You can ask us or third parties to stop sending you marketing messages at any time by emailing us at marketing@courtauld.ac.uk at any time.

 DISCLOSURES OF YOUR PERSONAL DATA  

 We may have to share your personal data with the parties set out below for the purposes set out in the table above: 

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Regulatory bodies who require from us data. Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions and all processors are asked to provide evidence that they comply.

 INTERNATIONAL TRANSFERS  

We do not transfer your personal data outside the European Economic Area unless it is required of us or we have your consent to do so. Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria unless additional safeguards are put in place by us. The Courtauld will advise you should it require to transfer your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at marketing@courtauld.ac.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

DATA SECURITY   

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION    

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS  

 Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at dpo@courtauld.ac.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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