Data & Privacy Policy
Ayton West Studio Data & Privacy Policy.
I understand the importance of your privacy and I totally respect the privacy of everyone that visits my website. It is very important for me that you know exactly how and why I collect, process and store your personal data. I will only collect, process and store your personal data in the ways that have been outlined here in my privacy policy, and in a manner that is consistent with my obligations and your rights under the law.
I have kept my privacy policy as short and straightforward as possible, so if there is anything that you don’t understand, or if you have any questions, please contact me using the contact form at the bottom of this page.
This Notice explains how EJA Purches T/A Ayton West Studio Photography complies with GDPR.
1. Identity and contact information
This Privacy Notice (“Notice”) is provided by EJA Purches trading as Ayton West Studio Photography (“me”, or “I”), of Harefield, Bont Dolgadfan, Llanbrynmair, SY19 7AT. It covers your rights in relation to the Data Protection Act 1998 (“DPA”), the General Data Protection Regulation (“GDPR”) and the Privacy and Electronic Communications Regulations (“PECR”).
EJA Purches T/A Ayton West Studio Photography is both the controller and processor of all personal data collected.
Date this Notice was created: 1st December 2018
Date this Notice was last modified: 1st December 2018
2. Compliance declaration
Both EJA Purches T/A Ayton West Studio Photography and this website, www.aytonwest.co.uk, comply with GDPR. The GDPR comes into effect on the 25th May 2018. This Notice is updated whenever changes are made to relevant data protection legislation.
3. Your rights under the GDPR
Under the GDPR, you have a number of different rights relating to your personal data and how it is processed. They are as follows:
Most of these Rights will apply to your personal data and how it is processed by EJA Purches T/A Ayton West Studio Photography, but some (such as the right to data portability and rights related to automated decision making including profiling) are not relevant to this business at the time of writing.
If you want to know more about your rights please visit the ICO Website directly.
4. The data I collect, how I use it and why
Cookies and website visitor tracking
This website uses cookies, most notably the ones relating to Google Analytics. The purpose of using these cookies is to better understand visitor demographics to this site so that future improvements can be made. By using this website I will assume that you are happy to accept all cookies.
Cookies are small text files that are placed on the hard drive of your computer or device to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymity tracking data to third party applications, in this case Google Analytics. As a rule, cookies will enhance your browsing experience. However, if you prefer not to receive cookies they can be disabled and removed from within the settings menu of your Internet browser. I suggest either consulting the help section of your browser.
Client contact information
I use personal data, provided directly and voluntarily to me by clients, for two purposes. The first is to carry out my contractual obligations. This means that it’s information that I need to do my job. This personal data includes (but is not limited to) names, addresses, email addresses, phone numbers and other information required for the job in hand. (This could include wedding guests for wedding photography, staff information for corporate portraits, etc.
The second purpose is for me to analyse and understand behavior of my clients to assist me in relation to sales and marketing exercises. For example, to better understand where you heard about me and whether or not you choose to book me. This is a legitimate interest and a reasonable expectation that most people would have about a business. All personal data that I collect is stored within a safe and secure, GDPR compliant, contact management systems including Mail Chimp and Google Docs. This is a cloud based system that allows me to keep track of upcoming jobs, emails and invoicing. For further information please view their privacy policies.
Email addresses for gallery login
To deliver images to clients, I make use of a galleries and proofing services. When clients share their galleries with friends and family, they will need to enter their email address to gain access with the email address acting as a login. This allows users to create favorite lists, leave comments and also share images effectively. For further information about how these services collects and processes personal data please view their privacy policies.
Mailing lists
I may make use of mailing lists to help market my business. Any new mailing lists created from this point, will be populated with personal data collected from you on the basis of explicit consent for this single purpose. The Mailing List client I use is Mail Chimp which is fully GDPR compliant.
More detailed information
If you want to contact me with questions about your personal data, wish to exercise any of your rights or ask me further detailed questions, please use the contact form at the bottom of this page.
5. Sharing information with third parties
Other than those third parties mentioned in this Notice and listed below, EJA Purches T/A Ayton West Studio Photography shall not pass your personal data to any other third parties.
Your personal data may, subject to my obligations to comply with data protection legislation, be shared with the following third parties:
Google Analytics demographics tracking software;
Second photographers/videographers who join me on shoots and need information to be able to do their job;
Having taken precautions to maintain the security of such personal data, I may in certain circumstances share personal data with the ICO, and other legal, regulatory and law enforcement bodies;
In anonymised form, I may share personal data with:
Any third party, in relation to the sale of some or all of my business, or its assets, or as part of any business restructuring or reorganisation. I will take steps with the aim of ensuring that your rights continue to be protected if your personal data is transferred in accordance with this clause; and
Data aggregators and platform providers as part of an analysis of user metrics or sales performance (including but not limited to Google and Facebook).
I may also share your personal data with third party media businesses for the purposes of marketing my offerings, improving my services, and running a profitable business. These third party businesses may include, wedding magazines/publications, wedding websites, social media sites, or other outlets, with the aim of raising public awareness of my business.
6. Security, storage and data retention
EJA Purches T/A Ayton West Studio Photography stores your personal data in the EEA and EJA Purches T/A Ayton West Studio Photography retains full details of your personal data for as long as it takes to complete your photography requirements. I will delete your personal data six years after completion of your photography requirements (I am obliged to keep a 6 year record of works carried out for my HMRC tax records), but you retain the right for your personal data to be deleted before this point which can be exercised by submitting a formal request for deletion via email.
7. Clients And Guests Captured In Photos
Under GDPR legislation, a photograph may in some instances constitute a form of personal data where they can be processed to allow “the unique identification or authentication of a natural person”. EJA Purches T/A Ayton West Studio Photography will never photograph an individual as a means of unique identification or authentication unless consensually contracted to do so. Guests at weddings appear in photos taken by EJA Purches T/A Ayton West Studio Photography as a part of the visual recording of the event in photos. Guests captured in portraits or in group photos do so as part of the event and their rights are protected by EJA Purches T/A Ayton West Studio Photography as detailed in this privacy policy.
In terms of explicit GDPR compliance, Wedding clients and guests 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 EJA Purches T/A Ayton West Studio Photography as a photography 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 interests 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 guests 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.
8. Storage of images
All images taken by EJA Purches T/A Ayton West Studio Photography will be stored securely on encrypted hard drives within my password protected home office computer. Where cloud technology is used for storage backup, the provider will be vetted to ensure they comply with the relevant regulations on data privacy and data security. Below shows an up to date list of any cloud technology that I am currently using to store images.
9. Social Media Policy And Usage
I adopt a safe and responsible Social Media Policy. While I may have official profiles on social media platforms users are advised to verify the authenticity of such profiles before engaging with, or sharing information with such profiles. I will never ask for personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with me on social media.
10. Your consent
By using this site and/or engaging me on my Terms and Conditions, you agree to be bound by this Notice.
11. Your right to withdraw consent
You have the right to withdraw your consent to be bound by this Notice at any time. If you wish to do so, please use the contact form at the bottom of this page. You also have the right, as set out above, to withdraw your consent to me processing your personal data.
12. Your right to lodge a complaint
As well as the right to withdraw consent and exercise any of the above rights mentioned under ‘Your rights under the GDPR’, you also have the right to raise a complaint with a regulatory body. In the United Kingdom, this is the Information Commissioner’s Office (ICO). If you have concerns about the way your data is being processed by an organisation, you can find out more here.
Ayton West Studio operates as a commercial photographer and designer in Mid Wales and also provides photography tuition in Mid Wales, North Wales, South Wales, The Midlands, Hereford and Cheshire.
Website designed and built by Ayton West Studio ©2018 All rights reserved
Images copyright Joe Purches ©2018 all rights reserved www.aytonwest.com