What is this Privacy Policy for?
This privacy policy is for this website and served by Tunbridge Photography and governs the privacy of its users who choose to use it.
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy.
The Website
This website and its owners (Brian Tunbridge / Tunbridge Photography) take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies with all UK national laws and requirements for user privacy.
Use of Cookies
This website uses cookies to better the users’ experience while visiting the website. Where applicable, this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer/device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer/device.
Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server, to provide the users with a tailored experience within this website. Users are advised that if they wish to deny the use and saving of cookies from this website on to their computer’s hard drive, they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.
Data Protection – It really is important to me.
As you may imagine I hold a lot of personal and sensitive data on my clients. The security of that data is very important to me, and it should be to every supplier you use.
The Six General Principles for General Data Protection Regulations (GDPR)
1. Lawfulness, fairness and transparency – Personal data must be processed lawfully, fairly and in a transparent manner;
I won’t do anything with your data that I wouldn’t want to do to my own.
2. Purpose limitation – Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (with exceptions for public interest, scientific, historical or statistical purposes);
I will only ask for and collect data that I NEED to run my business. Anything else I am not bothered about.
3. Data minimisation – Personal data must be adequate, relevant and limited to what is needed;
I don’t ask you for information that I don’t need to help me do my job
4. Accuracy – Personal data must be accurate and, where necessary, kept up to date. Inaccurate personal data should be corrected or deleted;
I try to be accurate, but if you move house, change emails etc. then let me know. If you want to know what I hold, just ask. If you want me to remove it all (including photographs) or update/amend it – just ask.
5. Retention – Personal data should be kept in an identifiable format for no longer than is necessary (with exceptions for public interest, scientific, historical or statistical purposes);
I will only keep your data for as long as I need to. Being a wedding photographer, that may be longer than is usual due to the emotional nature of the wedding photographs. HMRC says about 7 years. However, I still get clients asking after 10 years for copies of wedding photographs.
6. Integrity and confidentiality – Personal data should be kept secure.
My business and your data are about as secure as I can reasonably make it.
How your data is protected
I use a multi-layered approach to security –
“Perimeter Security“ – All of our IT infrastructure is stored in a secure and alarmed location. The alarm is monitored 24/7 and where a key holder does not answer a call, the Police will be instructed to visit the site. Only two key holders exist.
“Network Security” – All of the IT is further secured using strong password protection, using a mixture of alphanumeric and symbols.
Photographs are stored online by a third party called Zenfolio. Zenfolio is GDPR compliant.
Portable hard drives for use off-site and on location will not have personal information stored on them, and where they do they will have password protected encryption at the drive level.
I ensure all my servers, routers, laptops, desktops, smartphones etc are kept up to date with the relevant security patches and updates by the manufacturer.
I have ensured as much as possible that all my third party suppliers who MAY hold personal data are also GDPR compliant, and where they are not I have taken steps to remove any possible data and found GDPR compliant companies.
I use only Apple Computer hardware with Apple Mac OSX operating systems. This is kept fully updated automatically. It is generally recognised that Mac OSX is inherently more secure than Microsoft Windows.
All applications running on all Apple Mac OSC computers are also kept updated on a weekly basis.
My website is also set up securely and uses the HTTPS security protocol. All information to and from the website is therefore transmitted securely and is encrypted.
“Privilege Based” – Only those who need to access your information will be able to access it. In 99.9999% of cases that is just one person – Brian Tunbridge. I use multiple alphanumeric passwords for access to all of my IT infrastructure. Where access is given to another person (I may be ill, away etc) then an audit is carried out to ensure that only the required information is accessed and the passwords are changed.
IP Addresses
GDPR classes IP address as personal information so I have to mention this.
Some of the cookies mentioned above will collect your IP address. The vast majority of this website’s users will use private Internet Service Providers (ISP) that also use something called Dynamic Host Configuration Protocol (DHCP). This means every time you log on to the internet you get a different IP address meaning I can’t track you personally. The IP addresses will point to your ISP, and they would not give me any details unless ordered to do so by a court order. Users of my website who log in using corporate internet link will have their IP address taken. Again, however, that IP address would point to the business NOT to the individual.
Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998.
Every effort has been made to ensure a safe and secure form to email submission process but advises users using such form to email processes that they do so at their own risk.
Your details are NEVER passed on to any third parties.
Processing & Storage of Data
Your personal information and any other data you give will be stored, securely, for a minimum of 36 months. After this time it will be automatically deleted / securely destroyed.
This does not apply to wedding photographs or other photographs kept online securely, nor does it apply to invoices/receipts etc. which need to be kept, legally, for a period of 6 years.
If you wish the photographs to be destroyed/deleted then I will do this also. It is YOUR responsibility to ensure you have backups.
I do not use any software to automatically process your biometric data – i.e. I don’t use facial recognition facilities that can be found in the major editing applications such as Adobe Lightroom.
Requesting Copies of Personal data
If you wish to request a copy or your personal data please contact me. There is no charge for this (unless I believe the request is manifestly unfounded or excessive and then you will be charged a fee commensurate with the time taken for me to process your request) and will get the information to you, in a form you can use, within 28 days.
Right to Erasure
If you wish for your personal data to be deleted permanently then please contact me.
You will need to provide me suitable and verified identification, such as –
· Copy of passport showing passport photograph page
· Copy of Drivers Licence
· Utility Bill showing home address that matches your driver’s license
· Date of event
I will NOT be able to delete data that is under 7 years old due to HMRC rules. For example, this will include contracts, invoices etc.
Please note deletion is permanent. Your photographs will be permanently deleted once you have proven your identification sufficiently. They will be deleted from all my archive hard drives, from my laptop/desktop IT systems, from my website and from the online gallery.
External Links
Although this website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text/banner/image links to other websites.)
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should, therefore, note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution with regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten lengthy URLs. Users are advised to take caution and good judgement before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URLs are published, many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Agreeing or Not Agreeing
The contact form on this website will have a checkbox for you to tick to show you have read, understood and agree to this Privacy Policy.
You are prevented from sending information to Tunbridge Photography unless that checkbox is ticked.
If you DO NOT AGREE, do not tick the box; however, you will not be able to contact Tunbridge Photography via the contact form. You can still do so using email, mobile or landline or via our Facebook Business Page.
Further Information
Your Personal Data:
What we need
Tunbridge Photography will be what’s known as the ‘Controller’ of the personal data you provide us. We only collect basic personal data about you which does not include any special types of information or location based information. This does, however, include name, address, email etc.
Why we need it
We need to know your basic personal data in order to provide you with notice writing and analysis services in line with this overall contract. We will not collect any personal data from you that we do not need in order to provide and oversee this service to you.
What we do with it
All the personal data we process is processed by our staff in the UK. No third parties have access to your personal data unless the law allows them to do so.
We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.
How long we keep it
We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
What are your rights?
If at any point you believe the information we process on you is incorrect, you can request to see this information and even have it corrected or deleted. If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).
Our Data Protection Officer is Brian Tunbridge and you can contact them at [email protected]