PRIVACY POLICY

1. Introduction

The Clink Museum respects your privacy and is committed to protecting your personal data.  We are similarly committed to being transparent about how that data is collected and used and to meet our data protection obligations.

This privacy notice was last updated on 25th May 2018 and reflects the changes to data protection law in the UK due to GDPR which came into force on 25 May 2018.  It sets out how the firm complies with GDPR and the legal basis under which we process your data in various instances.

2. Purpose of this Privacy Notice

The purpose of this privacy notice is to inform you about how The Clink Museum collects and processes your personal data when you use this website and/or interact with members of the firm; this includes any data you may provide to us when you apply for a role at the firm either via this website, via our applicant tracking system, or via other means such as by direct email.

To help you understand the meaning of some of the terms used in this privacy notice, we have provided a Glossary.

Please note that this website is not intended for children and we do not knowingly collect data relating to children.

3. Data Protection Governance at The Clink Museum

This privacy notice is issued on behalf of the The Clink Museum so when we mention “The Clink Museum”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant corporate entity in the The Clink Museum Ltd responsible for processing your data. The Clink Museum is responsible for this website and is the data controller for all data shared through it. Where other entities within the The Clink Museum Ltd are in control of your data that will be made clear at the point of collection or as soon as possible afterwards.

4. What we collect, how we use it, and supplementary privacy notices

We will only use your personal data when the law allows us to.  So that you are fully aware of how and why we are using your data, it is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you.

5. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, as listed below:

• 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; and
• right to withdraw consent

Further details of your rights can be found in the glossary at the end of this policy. The Information Commissioner’s website also provides more detail on the legal rights of individuals in relation to the processing of their personal data (www.ico.org.uk).  If you wish to exercise any of the rights set out above, or have any queries or concerns about our use of your data please contact our Data Protection Team using the details at section 3.

6.1. What we may need from you when you exercise your legal rights

When exercising your legal rights above, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that requests are made by the individual themselves and 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.

6.2. Fees and refusal to comply with requests

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

6.3. Time limit to respond

We will respond to all legitimate requests within one month. If your request is particularly complex or you have made a number of requests and it is likely to take us longer than a month to respond, we will notify you of that and keep you updated as to progress.

7. Your right to make a complaint

In addition to your legal rights set out above, you also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We are committed to protecting your personal data and would appreciate the opportunity to address any concerns or complaints you may have before you approach the ICO so that we can remedy them.  Any concerns or complaints should be raised with the Data Protection Team in the first instance.

8. Your duty to inform us of changes to your personal data

It is important that the personal data we hold about you is accurate and current.  Please keep us informed if your personal data changes during your relationship with us.

8. Data security and data breaches

We take data and information security seriously.  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; 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 security incident. We will notify you and any applicable regulator of a suspected breach where we are legally required or it is appropriate to do so.

10. Cookie and third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit. For details on how the The Clink Museum website uses cookies to improve user experience and functionality please read the Cookie Policy.

Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal third parties: Other companies in the Group acting as controllers or processors.

External third parties

• Service providers acting as processors based who provide IT and system administration services.
• Professional advisers and government bodies including lawyers, foreign associate, Intellectual Property Offices, law firms, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your legal rights

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.