Policies

The Paul Mellon Centre is aware of its obligations under the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. It is committed to processing your data securely and transparently and will only use it legally and responsibly. You can find our Data Protection and Records Management policies online.

This privacy notice explains how The Paul Mellon Centre (“we”, “our”, “us”) processes the personal data of individuals who attend our events; apply for one of our grants or fellowships; enter, or verify an entrant for, the Write on Art competition; receive communications from us via our mailing list (“you”, “your”); are involved in our various networks (ECRN, DRN, BAN); are engaged in our publications activities; or have participated in the Country House Project. It describes how we process your personal data in the circumstances described in this privacy notice where we are a data controller in respect of your personal data, including what information we collect from you, what we do with it and with whom it might be shared.

If you have any questions about how the Paul Mellon Centre manages personal information please contact us.

The Paul Mellon Centre for Studies in British Art is an educational charity. It has two complementary purposes: to contribute to the study and understanding of British art and architecture and to act as a research centre for scholars working in this field.

We are the controller of your data and registered with the ICO under Data Protection Registration Number: Z7433064.

The Paul Mellon Centre for Studies in British Art
16 Bedford Square
London
WC1B 3JA

Our primary website domain is as follows: paul-mellon-centre.ac.uk

We only collect information that is necessary to run the Centre, fulfil our obligations to you, and keep you informed about our activities.

The personal data we collect may include:

• your name and title;
• your email address;
• your date of birth;
• your gender;
• your school name and school year;
• your university, employer or affiliation;
• your research interests;
• your postal address;
• your phone number;
• your bank details (for payments related to grant and fellowship applications; events or royalty payments);
• biographical information (for authors; event speakers, members of decision-making bodies, etc.);
• your IP address;
• your passport details (for Yale in London students, Graduate Summer School, faculty & academics);
• your academic grades, personal interests etc. (for Yale in London students);
• your interest in the arts & art related initiatives;
• the events that you attend in connection with us;
• personal information contained within your grant or fellowship application;
• personal information contained with your access survey questionnaire (such as communication preferences; caring responsibilities etc.);
• still images, videos and audio recordings of your participation in PMC events, initiatives and projects;
• still images and video recordings of your entry to, and presence in, 15 and 16 Bedford Square;
• information, photographs and films about your house and the works of art in your possession; or
• information about the archives and library collections in your possession.

Under the GDPR, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs and political opinions. We only collect such information where there is a clear reason for doing so, such as in relation to accessibility, dietary requirements for events, or for the purposes of equal opportunities monitoring. Data collected for these purposes is collected with the explicit consent of the data subject or for the purpose of allowing us to fulfil our legal duty of care (for example when processing information concerning access or dietary requirements); or on grounds of substantial public interest (where diversity information is collected for equal opportunities monitoring).

Information you give us

We collect personal information when you

• sign up to receive copies of our e-news updates online or in-person;
• fill in a general interests survey or preferences survey
• enter, or verify an entrant for, the Write on Art, or British Art in Motion Film competitions;
• make an application for a fellowship or grant;
• apply for, enrol, or teach on our Yale in London or Graduate Summer School programmes;
• enquire about our events; fellowships; grants or services;
• sit on one of our decision-making bodies (Advisory Council, Publications Committee, Board of Governors; BAS Advisory Board etc.);
• participate in one of our academic network partnerships (e.g. British Art Network; Early Career Network etc.)
• engage with our Publications activities, including entering into a publishing contract with us
• participate in one of our events, initiatives, archive or research projects (such as the Country House Project);
• complete one of our audience survey forms;
• complete one of our access survey questionnaires;
• consult our online archives and library catalogues or engage with our collections more generally (including requesting copies; making enquiries; booking appointments or saving online searches);
• offer archives and library material to the Centre;
• visit the Paul Mellon Centre at 15 & 16 Bedford Square; or
• otherwise give us permission to photograph items (including works of art; drawings; sketchbooks etc.) in your possession.

We will only process your information if we have a legal basis for doing so under current data protection legislation, including:

Legitimate interests

We process your personal information because it is necessary for our legitimate interests. Our legitimate interests include pursuing our charitable objective to promote and support the study of British art and architecture of all periods, including through the promotion of specific projects and resources on site and online. This includes the use of personal data as part of historical research and archiving in the public interest, either as a compatible onward use for personal data collected in accordance with these legitimate interests, or a reason for processing in its own right. Our legitimate interests also includes safeguarding staff and visitors and ensuring compliance with health & safety legislation.

As part of achieving these charitable objects, we may – in line with any specific preferences notified to us – use your personal data for marketing and fundraising purposes (unless it is required or appropriate to gain your consent).

Performance of a contract

We will process your personal information because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract, for example:

• to administer an event booking;
• to process grant and fellowship applications and administer grants and arrange fellowships for successful applicants;
• to process Write on Art or British Art in Motion Film competition entries;
• to facilitate enrolment and participation in, and teaching on the Yale in London; Graduate Summer School or other Paul Mellon Centre programmes;
• to facilitate your engagement as a speaker, presenter or other contributor at one of our events;
• to facilitate your tenure on one of our decision making bodies (eg. sharing paperwork for meetings, etc.);
• to assess publication proposals and manage publishing contracts (e.g. facilitate payment of royalties, etc.);
• to facilitate membership of, and support events relating to, one of our academic networks (e.g. British Art, Early Career etc.);
• to facilitate your engagement in our Climate & Colonialism Project (e.g. Participating in the Reading Group etc.);
• to facilitate access to our Archives and Library collections;
• to assess and process offers of Archives & Library material; or
• where you have entered into a licensing agreement with us, or given permission for us to access and photograph your artworks or property, or you have in some other way chosen to participate in a project with us (e.g. as an owner or a photographer).

Consent

We also process your personal information where we have your specific consent to do so. For example, where you have agreed to receive marketing emails and email updates about our activities; or where you have agreed to complete one of our audience survey forms.

Where you have given consent to the processing of your data you may withdraw it at any time. See below “What rights do you have in relation to your personal information?”

With regard to Write on Art entrants and British Art Network participants, information about race, religious beliefs, gender and other ‘protected characteristics (as defined by the Equality Act 2010) will only be collected with your explicit consent.

Legal obligations

We also process your personal information for our compliance with our legal obligations. In this respect, we may use your personal data for the following:

• to meet our legal and regulatory obligations;
• in order to assist with investigations (including criminal investigations) carried out by competent authorities.

For these purposes we may provide your data to our auditors, the police and other competent authorities.

We will not sell your personal information to any third parties or external organisations but we may share some of your personal information with our service providers/external data processors, to carry out work on our behalf or to help us deliver a service to you.

Personal data shared with others in relation to events

In the case of events, we may share some of your personal information with institutions with whom we collaborate. For example:

• we will share delegate lists with events venues (where the event is not held at the Paul Mellon Centre);
• we will share personal information such as your name and email address with partner institutions and networks (where digital events are held in collaboration with named institutions and/or networks, who are administering the event via their digital software providers’
• we will share personal information such as your name; contact details; and financial and credit card information with Eventbrite, our ticketing service provider and Zoom, our digital events interface
• audio and visual recordings may be made freely available via the Centre's website or via YouTube.

Personal data shared with others in relation to grants and fellowships

In the case of grants and fellowships, your personal information will be shared as follows:

• all applications and the personal data contained within will be shared with Good Grants by Creative Force, our online grant and fellowship application software supplier;
• all applications and the personal data contained within will be shared with members of our Advisory Council;
• Rome Fellowship applications and the personal data contained within will be shared with representatives of the British School at Rome;
• Digital Project Grant applications and the personal data contained within will be shared with external expert advisors in the field;
• Andrew Wyld Research Support Grant applications and the personal data contained within will be shared with representatives of the Andrew Wyld Fund;
• Terra-PMC Fellowship applications and the personal data contained within will be shared with representatives of the Terra Foundation for American Art;
• Details of successful applicants may be made available on the Paul Mellon Centre’s website and other Paul Mellon Centre channels (Annual Report, electronic newsletter etc.);
• Anonymised data relating to successful applicants may be shared with 365Giving, a charity that helps organisations to publish open, standardised grants data, and made available on their website.

Personal data shared with others in relation to Write on Art

In the case of Write on Art, your personal information will be shared as follows:

• all competition entries and the personal data contained within will be shared with Creative Force, our online competition entry application software supplier.

Your personal information, excluding information about race and ethnic origin, will also be shared as follows:

• all competition entries and the personal data contained within will be shared with Art UK our competition partners;
• all competition entries and the personal data contained within will be shared with the Write on Art judging panel.

Personal data shared with others in relation to the Country House Project

In the case of the Country House Project, personal information about participants will be shared as follows:

• name; address; and information, photographs and film about the participant’s house and the works of art in their possession will be made freely available in the form of a published research project on the Centre’s website
• it may also be made available in other matter published produced by the Centre, such as our information leaflets, annual report our and social media channels

Personal data shared with others in relation to the Paul Mellon Centre’s Photographic Archive Digitisation Project

In the case of the Paul Mellon Centre’s Photographic Archive Digitisation Project, where we have any record of the owners’ wishes in respect of publishing the image and any details associated with the image, we have sought to reflect those when the resource is made available:

• in the form of a published research resource on an online platform operated by the Centre and viewable via https://photoarchive.paul-mellon-centre.ac.uk;
• in the form of a digital research platform facilitated by PHAROS an international consortium of Photographic Archives: http://pharosartresearch.org/;
• in the form of an aggregated digital archive catalogue facilitated by Archives Hub: https://archiveshub.jisc.ac.uk/.

This may or may not involve any personal data of any living individual, in accordance with the owner’s wishes recorded at the time.

Personal data shared with others in relation to the Paul Mellon Centre’s Archives and Library Collections

In the case of the Centre’s Archives & Library collections, your personal data may be shared with:

• our online catalogue system providers: Gallery Systems; Axiell and IS Oxford;
• other aggregated online catalogue providers (facilitated by initiatives such as Archive Hub & Library Hub Discover);
• our external legal and copyright advisers (e.g. Farrer & Co.);
• couriers and other services employed to transport archives & library material;
• external conservation and preservation services employed to work on the material.

Personal data shared with others in relation to the British Art Network [BAN]

In the case of the British Art Network, your personal information will be shared as follows:

• with Tate, who – alongside the Paul Mellon Centre - are the joint lead organisation for The British Art Network, and therefore Joint Controllers of personal data relating to the Network’s activities;
• to third parties providing services to the British Art Network and to regulatory authorities (including HMRC) and as required by law;
• services employed by the PMC to support network events (such as Eventbrite, our ticketing service provider, caterers, travel providers etc.);
• to third parties involved in facilitating externally hosted events and initiatives (eg. caterers; travel providers etc.).

Personal data shared with others in relation to the Doctoral Researchers and Early Career Researchers Networks [DRN & ECRN]

In the case of the DRN & ECRN, your personal information will be shared with:

• appointed network convenors;
• services employed by the PMC to support network events (such as Eventbrite, our ticketing service provider, caterers, travel providers etc.).

Personal data shared with others in relation to Publishing activities

In the case of publishing activities, your personal data may be shared, where relevant, with:

• Peer reviewers and members of the publications committee for the purposes of assessment and acquisition;
• Yale University Press (London and New Haven offices) in its capacity as our distributor – for the purposes of logging author contracts, applying for CIP data, and for matters relating to publicity, marketing and distribution, etc.;
• Yale University Press’ warehouses – for the purpose of supplying copies of books;
• Yale University Press’ warehouses – for the purpose of supplying copies of books;
• Freelancers involved with the editorial, design and production stages of a book project (e.g. Copy editor, proofreader, designer, indexer, etc.);
• Printers – for the purposes of arranging for the shipment of advance copies;
• the Centre’s bank – for the payment of royalties.

Personal data shared with others in relation to Yale in London and Graduate Summer School activities

In the case of Yale in London and Graduate Summer School, your personal information will may be shared as follows for the purposes of facilitating your participation in, or teaching on, the programme:

• Yale University faculty, academics, administrators and staff generally;
• UK Faculty and academics teaching your course;
• Venue and event organisers in relation to trips and tours;
• Agents, landlords and other housing representatives in respect of your accommodation;
• Administrators of memberships (e.g. external library services) to facilitate access to resources during the programme.

Personal data shared with others in relation to the Climate & Colonialism Project

In the case of the Climate & Colonialism Project, your personal information will be shared as follows for the purposes of facilitating your participation in the initiative:

• Individuals working on the project in a freelance capacity;
• Substack the publishing software used to host the project.

Personal data shared with others in relation to Decision-Making bodies

In the case of decision-making bodies (Advisory Council; Publications Committee; BAS Advisory Board etc.) your personal information may be shared as follows for the purposes of facilitating your tenure as a member:

• Board of Governors for legal and compliance purposes;
• The Centre’s banks (Lloyds and Barclays) for legal and compliance purposes.

Personal data managed by others in relation to mailing lists

• Personal data such as your name; email address; and marketing preferences will be provided to Mailchimp, our email distribution service provider.
• In each case our providers are not granted any rights to use or pass on your data for their own purposes, and agree to legally binding terms to ensure this.

Personal data processed on our behalf by others

We may also provide your personal data to other third parties who help us manage our systems and processes including:

• Capsule, our online contacts management software supplier;
• Zapier, an automation tool that integrates various databases operated by us;
• Google Analytics, Google Data Studio and Google Tag Manager, a suite of tools that collect and display quantitative data about user interactions with websites operated by us;
• Hootsuite, a social media management platform that monitors engagement with content published by us;
• Senate House Service, who host our IT provision;
• Them Digital, who support our IT provision;
• N-Able, who provide our IT backup services;
• WeTransfer, DropBox and other internet-based computer file transfer service;
• Preservica, our Digital Preservation software;
• Loftus Media, who produce our audio and visual event recordings;
• Gallery Systems, who host our online Photographic Archive;
• SwipedOn Visitor Management System, which is hosted by Amazon Web Services;
• SAGE, who host the Centre’s finance system;
• Lloyds and Barclays Bank, the Centre’s banks;
• CitySprint, the Centre’s courier service;
• Qualtrics, the company who provide our online audience survey software; or
• Zoom, or other video conferencing tools that we may use to facilitate remote meetings and events (if you are participating in one of our events or meetings using such platforms, additional relevant information will be provided to you including concerning security and, where applicable, recording).

In each case our providers are not granted any rights to use or pass on your data for their own purposes, and agree to legally binding terms to ensure this.

Where service providers are based outside of the EEA, transfers of personal data are based on:

• a decision by the European Commission that the third country, territory or one or more specific sectors in the third country, or an international organisation ensures an adequate level of protection;
• data sharing agreements that incorporate the International Data Transfer Agreements (or Standard Contractual Clauses until 21 March 2024)
• there exists another situation where the transfer is permitted by law (for example, where we have your explicit consent).

We will keep your information for as long as is necessary for the purposes set out in this privacy notice for as long as is required for legal purposes; our legitimate business and charitable purposes; and to fulfil our contractual obligations to you including, where necessary, after the termination of our relationship with you. The retention period will vary according to the nature of the purpose under which the information is held. For example:

• We retain personal information needed to send you our e-news for as long as you wish to subscribe to this service. You may unsubscribe any time;
• We retain personal information needed to manage your members of our academic networks (DRN, ECRN) for as long as you wish to remain a member. You may unsubscribe at any time by emailing the network convenors;
• We retain information needed to manage your participation in the Climate & Colonialism Project for as long as you wish to remain involved. You may unsubscribe at any time by emailing [email protected].
• We retain information concerning your registration to access our Archives & Library collections for six years. After this period you will be required to re-register;
• We retain information about grant and fellowship applicants; Yale in London participants & lecturers, Graduate Summer School participants and lecturers; Write on Art competition entrants (excluding information about race and ethnic origin); British Art in Motion Film competition entrants; British Art Network activities; Archives and Library donors; and Country House or Photographic Archive participants indefinitely for historical research purposes in our Institutional Archive;
• We retain publishing contracts (excluding bank details) and other relevant information indefinitely in our Institutional Archive for legal and archival purposes;
• We retain details of your tenure on one of decision-making bodies indefinitely in our Institutional Archive for legal and historical research purposes;
• We retain still image and video footage taken via CCTV for a maximum period of 60 days; and
• Where this has first been communicated to speakers and participants, we retain audio and visual recordings of our events and initiatives, together with the PMC Event Contributor Forms accompanying these recordings, indefinitely for historical research purposes in our Institutional Archive.
• We retain information provided by you through the general interests survey for marketing purposes.

Where you object to our retaining your data, please let us know at [email protected]. However, please be aware that specific rules will in some cases apply that allow the retention of personal data for archiving in the public interest and historical research, as well as permitting ongoing publication in the public interest in respect of artistic, literary or academic matters. We will however take reasonable steps to keep use of such data proportionate, and appropriately secure where necessary, to protect the rights and interests of all involved.

We follow strict security procedures in the storage and disclosure of information which you have given us to try to prevent:

• unauthorised access;
• improper use of disclosure;
• unauthorised modification;
• accidental loss, damage and destruction.

This privacy notice does not apply to third party websites you are directed to from our website. We encourage you to read the privacy statements on the other websites you visit.

You have certain rights in relation to your personal information. They are:

• The right to obtain confirmation that we are processing your personal information (see below our Subject Access Request process);
• The right to access your information (see below our Subject Access Request process);
• The right to have your personal information rectified if it is incomplete or inaccurate;
• The right to have your personal information removed or deleted in certain circumstances, for example when you have withdrawn consent to it being processed and we have no other basis for processing it;
• The right to restrict the processing of your personal information in certain circumstances;
• The right to object where we are processing your information on the basis of our legitimate interest;
• The right to object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on you;
• The right to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;
• Where you have provided your consent to the processing, the right to withdraw consent to the processing of your data (without affecting the lawfulness of processing based on consent before its withdrawal), including in relation to marketing communications; and

Please note that the above rights are not absolute, and requests may be refused where exceptions apply (including those listed above) .

If you are not satisfied with how we are processing your personal data, you have the right to make a complaint to the Information Commissioner (or another data protection supervisory authority in the EU, including the data protection regulator in the EU country where you are located).

For a more detailed explanation of these rights, please see the Information Commissioner’s guidance or try the ICO helpline on 0303 123 1113.

Approved by the Director on 8 October 2020.

This privacy notice is updated from time to time.

8 November 2018: Additions were made to incorporate data processing in relation to the Write On Art competition.

12 February 2019: Clarification to section about how we collect information.

27 March 2019: Additions were made to incorporate data processing in relation to individuals participating in, and being invited to, events.

12 July 2019: Additions were made to incorporate data processing in relation to individuals participating in The Country House Project.

30 June 2020: Additions were made to reflect data processing in relation to digital publication and archive projects at the Centre and remote provision of services in light of COVID-19.

8 October 2020: Additions were made to incorporate new activities connected to the British Art Network.

22 March 2021: Additions were made to incorporate new activities connected to the Centre’s Publishing Programme & the payment of royalties.

14 September 2021: Additions were made to incorporate activities concerned with the Centre’s Archives & Library collections; and the Centre’s revised Event Contributor arrangements.

5 November 2021: Additions were made to incorporate activities concerned with the Centre’s British Art in Motion Film competition.

16 December 2021: Additions were made to incorporate new initiatives concerned with the Centre’s Grant & Fellowship programme.

28 March 2022: Additions were made to incorporate the Yale in London programme and in relation to transfers outside the EEA.

25 April 2022: Additions were made to incorporate the Graduate Summer School.

23 November 2022: Additions were made to incorporate CCTV.

9 February 2023: Addiitons were made to incorporate the Climate & Colonialism Project.

13 February 2023: Additions were made to incorporate the general interests and preferences surveys.

25 October 2023: additions were made to incorporate audience surveys.

16 February 2024: additions were made to incorporate decision making bodies.

9 March 2024: additions were made to incorporate new IT back-up providers.

13 May 2024: additions were made to incorporate access survey questionnaires.

22 May 2024: additions were made to incorporate transfer of anonymised Grants & Fellowships data to 365Giving.

19 July 2024: additions were made to incorporate the new visitor sign in system.

If you have any queries about our privacy notice, or want to raise a concern about how we process the information we hold about you, please email [email protected], or write to the Data Protection Manager at:

The Paul Mellon Centre for Studies in British Art
16 Bedford Square
London
WC1B 3JA