Privacy Policy for Polly Stock Photography & this website www.pollystock.co.uk 

Created: 24th May 2018
Last Modified: 20th September 2021
This privacy policy outlines how I (Polly Stock Photography) collect, store, process, disclose and keep your personal information/data safe.
Please do notify me if you think that any of the personal information that I hold about you needs to be updated or amended.

What data is being collected, How is it collected and Why?

To be able to do my job to my best ability and carry out my contractual obligations, I collect, store and process data about you.  This may include any or all of the following:

PERSONAL IDENTIFICATION DATA - collected via the contact form on my website, through email communications, from messages sent to me via social media platforms and messaging services, from notes take during phone calls between us.

Enquiry/Prospect Client Phase - any or all of the following will be collected 

• Your Name
• Company Name
• Email Address
• Phone Number

Booking/Client Phase - if you choose to book me for your photography requirement, I may also need to collect:

• Partner’s Name & Contact Details (if provided)
• Photographs of you/your property
• Postal address
• Date of Birth
• Further details about you and your booking will be collected via a questionnaire and stored on my studio management software
• Any other information that you choose to send to me
• Photographs of you or your property
• Your marketing preferences

NON-PERSONAL IDENTIFICATION DATA

Website Visitor Tracking

Technical data about your computer and your visits to this website (including IP address, geographical location, browser type and version, operating system, length of visit, page views and website navigation 

Cookies 

This site uses Cookies, which are small text files that are stored on a user’s computer or mobile device.  They are used for a variety of purposes, including personalising pages, remembering visitor preferences, analysing visitor behaviour, managing shopping carts and delivering targeted advertising.  Cookies are used to improve the online experience of almost every website, including our own.  Please see my cookie policy for more details.  You can vary your cookie settings or disable cookies on this site either in the Cookie settings, or by disabling cookies in your browser.  View http://www.aboutcookies.org/ for more guidance.  I use Google Analytics to analyse the use of this website, which  generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at: http://www.google.com/privacypolicy.html 

I use this information to carry out the services requested of me (Polly Stock Photography) in the most efficient manner and to provide you with the best service I can.  It is used to:

• Identify you over another individual
• Contact you regarding the work I am doing for you
• Deliver any products to you
• Keep a record of our discussions & your requirements/preferences
• Promote Polly Stock Photography in my portfolios and marketing - your consent will be sought first
• Monitor the use of, analyse and improve my website
• Manage my business
• Keep in touch with you.  I will only use your contact information to respond to enquiries or fulfill my contact with you.  If can subscribe or unsubscribe to my keep in touch emails.

Lawful grounds of processing data

Personal Identification Data 
Enquiry/Prospect Client Phase : Legitimate Interests
Booking/Client Phase : Contractual
Marketing/Post Client Phase : Legitimate Interests (to grow my business) 
Non-Personal (Technical) Identification Data : Legitimate Interests
I do not collect any sensitive data about you or carry out any automated decision making or any type of automated profiling.

Who will it be shared with?

I will never share or sell your personal information to any third parties for their own marketing purposes unless you give your express consent. 

THIRD PARTY & INTERNATIONAL DATA TRANSFERS

I may have to share your personal data with the parties set out below:

• Studio Management Software 
• Cloud Storage Software
• Cloud Editing Software
• Website hosts
• Email providers
• Backup Software
• Professional advisors, including lawyers, bankers, accountants, auditors and insurers
• Industry Media - your consent will be sought first
• Government bodies that require me to repost processing activities or otherwise disclose your personal data
• If you request them, your information will be passed on to Second or Assistant photographers required to carry out my contract with you

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law.  I only allow such third parties to process your personal data for specified purposes and in accordance with my instructions.

Information may be stored and processed in and transferred to countries outside of the European Economic Area (EEA).  I will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.  Such as:

• Transferring your data to countries that have been approved by the European Commision as providing an adequate level of protection for personal data
• Transferring your data to US-based provider that are part of the EU-US Privacy Shield (as they have adequate safeguards in place)  
• If the provider is outside of the EEA, I 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.

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

Photographs

Guests at weddings and family members at portrait sessions captured in portraits of group photos do so as part of the event and their rights are protected by me as detailed in this privacy policy, and are photographed within the parameters of GDPR legislation on the basis of ‘legitimate interests’.  The taking of photographs of wedding guests when viewed as a form of processing personal data is necessary for the legitimate interests of Polly Stock Photography as a business unless there is a good reason to protect a given individual’s personal data which overrides those legitimate interests.

Operating within the parameters of legitimate interest as laid out in GDPR legislation, the disproportionate effort involved in providing privacy policy information to all wedding guests at the event and the degree to which it would distract me from performing my job renders it infeasible to do.  Wedding clients are therefore requested in their contract to direct their guest to read this privacy policy in advance of the event and to advise them to contact me in advance with any concerns around the processing of their personal data, namely being photographed.

Security

• I have put security measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation.
• Passwords on computers, hard drives & mobile phone
• Hard copies of job folders kept in locked cupboard
• Https website 
• Cloud storage vetted to ensure compliance with relevant regulations on data privacy and security
• Any products sent to you by post will be sent via the First Class: Signed for service

How long will I keep the data?

I will keep your data for as long as is necessary to fulfil the purpose which which it was collected, which may be up to 7 years for the purpose of satisfying any legal, accounting or reporting requirements.   I aim to archive all images indefinitely, but remind you to create back-up copies yourself.

Your rights

GDPR give you new rights over how your personal information and how it is processed.  For more information see: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

• The right to be informed about the collection & use of your personal data
• The right to access your personal data that I hold
• The right to rectify your data.  Please do notify me if any of your data may change, eg. moving house or changing your name or marital status etc.
• The right to withdraw consent for the processing of your personal information - e.g. send emails to you.  You can unsubscribe at any time by emailing me at hello@pollystock.co.uk 
• The right to request that I erase any personal information that I hold about you  (although there is some information that I am obliged to keep for up to 7 years for legal and administrative purposes). 
• You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) - https://ico.org.uk/concerns/ although please do contact me in the first instance 

If you have any queries about my Privacy Policy, or would like to exercise any of your rights then please send me an email to hello@pollystock.co.uk asking for a data request or your specific requirement or query.    You will be required to provide me with adequate proof to verify your identity.