About

Policy

Privacy Notice

Introduction

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”); 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.

Who we are

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

What personal information do we collect about you?

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 postal address;
  • your phone number;
  • your bank details (for payments related to grant and fellowship applications or events);
  • your IP address;
  • the events that you attend in connection with us; personal information contained within your grant or fellowship application; 
  • still images, videos and audio recordings of your participation In PMC events, Initiatives and projects
  • information, photographs and films about your house and the works of art in your possession

Special categories of personal data

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 in limited cases and 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. 

How do we collect your personal information?

Information you give us

We collect personal information when you

  • sign up to receive copies of our newsletter and/or e-news updates online or in-person;
  • enter, or verify an entrant for, the Write on Art competition 
  • make an application for a fellowship or grant; 
  • enquire about our events; fellowships; grants or services
  • participate in one of our events, initiatives, archive or research projects (such as the Country House Project); or
  • otherwise give us permission to photograph items (including works of art; drawings; sketchbooks etc.) in your possession.

How do we use your information and what is our legal basis for processing it?

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.

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 competition entries; 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.

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, information about race and ethnic origin 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.

Do we share your information with other organisations?

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; contact details; and financial and credit card information with Eventbrite, our ticketing service provider;
  • 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 SurveyMonkeyApply by SurveyMonkey, 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. 

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 SuveyMonkey 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, Newsletter, 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 will seek 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 the Centre’s website
  • in the form of a digital research platform facilitated by PHAROS an international consortium of Photographic Archives: http://pharosartresearch.org/

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 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 the case of our tri-annual newsletter, your personal information will be provided to Cultureshock a creative media agency who manage the production process and AJ&T Mailing, our distribution company, who send out copies of our printed newsletter
  • 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; and
  • Senate House Services, who host and support our IT provision
  • Loftus Media, who produce our audio and visual event recordings
  • Gallery Systems, who host our online Photographic Archive
  • 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.

International transfers of data outside of the EEA

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

  • in the case of service providers based in the US, the service provider being a certified member of the EU-US Privacy Shield scheme;
  • 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;
  • standard data protection clauses in the form of template transfer clauses adopted by the European Commission have been entered into by us and the recipient of the data;
  • there exists another situation where the transfer is permitted by law (for example, where we have your explicit consent). 

How long do we keep your information?

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 copies of the newsletter for as long as you wish to subscribe to this service. You may unsubscribe any time.
  • We retain information about grant and fellowship applicants; Write on Art competition entrants (excluding information about race and ethnic origin) and Country House or Photographic Archive participants indefinitely for historical research purposes in our Institutional Archive.
  • Where this has first been communicated to speakers and participants, we retain audio and visual recordings of our events and initiatives indefinitely for historical research purposes in our Institutional Archive

Where you object to our retaining your data, please let us know at dataprotection@paul-mellon-centre.ac.uk. 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.

How do we keep your information secure?

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 

Links to other websites

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. 

What rights do you have in relation to your personal information?

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

  1. The right to obtain confirmation that we are processing your personal information (see below our Subject Access Request process);
  2. The right to access your information (see below our Subject Access Request process);
  3. The right to have your personal information rectified if it is incomplete or inaccurate;
  4. 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;
  5. The right to restrict the processing of your personal information in certain circumstances;
  6. The right to object where we are processing your information on the basis of our legitimate interest;
  7. 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;
  8. 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;
  9. 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.

Date of Approval

Approved by the Director of Studies on 30 June 2020

Updates 

This privacy notice is updated from time to time. The last update was made in 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. 

How to contact us

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 dataprotection@paul-mellon-centre.ac.uk, or write to the Data Protection Manager at:

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