Matthew Priestley Photography Data Protection Policy

Matthew Priestley Photography Data Protection Policy

Matthew Priestley Photography-GDPR

 

What is the GDPR?

 

The GDPR is the General Data Protection Regulation which replaced the Data Protection Act when it came into force on 25th May 2018. It’s purpose is to ensure that organisations have strict policies and practices in place for managing and handling personal data. In light of the changes in data protection regulation, we have conducted a full audit of our processes. 

 

At a glance

 

We do not store personal data about pupils, parents or staff that we are photographing. Exceptions and how we deal with them, are detailed below.

 

 

How does the GDPR affect school photography?

 

We do not collect any personal data of the students or staff who we are photographing. Each image is assigned a random and unique identifier.

 

During this process, at no time do we link an image to any personal data.

 

Any SIMS data shared by schools is securely deleted once used to generate pupil photo info sheets.

 

After the photographs have been taken, they are encrypted and sent to our laboratory OneVision Imaging LTD to collate and process all our school photography. Their privacy statement is included below.

 

We do not gather or store the details of any parent who orders from us.

 

Matthew Priestley Photography

Data Protection Policy

 

01/08/2022

Next review date 01/08/2023 (enforcement date 25/05/2018)
Within our booking terms and conditions, we agree to uphold this policy and protect any data supplied by a customer or controller (school). Any data transferred between controller (school) and processor (us) will be handled with security as the primary concern. Any companies acting as a processor on our behalf will be contractually obliged to do the same and copies of contracts/policies can be supplied before data is collected.
1. Introduction
This Policy sets out the obligations of Matthew Priestley Photography (“the Company”) regarding data protection and the rights of customers, students and schools (“data subjects”) in respect of their personal data under the General Data Protection Regulation (“the Regulation”).
The Regulation defines “personal data” as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets out the procedures that are to be followed when dealing with personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
2. The Data Protection Principles
This Policy aims to ensure compliance with the Regulation. The Regulation sets out the following principles with which any party handling personal data must comply. All personal data must be:
a) processed lawfully, fairly, and in a transparent manner in relation to the data subject;
b) collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
c) adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, is erased or rectified without delay;
e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the Regulation in order to safeguard the rights and freedoms of the data subject;
f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
3. Lawful, Fair, and Transparent Data Processing
The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:
a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which the controller is subject;
d) processing is necessary to protect the vital interests of the data subject or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
4. Processed for Specified, Explicit and Legitimate Purposes
4.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us) and data received from third parties (for example, customer details, minimal student information (names and unique identifier numbers), teacher information ).
4.2 The Company only processes personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.
5. Adequate, Relevant and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 4, above.
6. Accuracy of Data and Keeping Data Up To Date
The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
7. Timely Processing
The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.
8. Secure Processing
The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.
9. Accountability
9.1 The Company’s data protection officer is Matthew Priestley matt@mattpriestley.co.uk.
9.2 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
a) The name and details of the Company, its data protection officer, and any applicable third party data controllers;
b) The purposes for which the Company processes personal data;
c) Details of the categories of personal data collected, held, and processed by the Company; and the categories of data subject to which that personal data relates;
d) Details (and categories) of any third parties that will receive personal data from the Company;
e) Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
f) Details of how long personal data will be retained by the Company; and
g) Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
10. Privacy Impact Assessments
The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy Impact Assessments shall be overseen by the Company’s data protection officer and shall address the following areas of importance:
10.1 The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
10.2 Details of the legitimate interests being pursued by the Company;
10.3 An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
10.4 An assessment of the risks posed to individual data subjects; and
10.5 Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the Regulation.
11. The Rights of Data Subjects
The Regulation sets out the following rights applicable to data subjects:
a) The right to be informed;
b) The right of access;
c) The right to rectification;
d) The right to erasure (also known as the ‘right to be forgotten’);
e) The right to restrict processing;
f) The right to data portability;
g) The right to object;
h) Rights with respect to automated decision-making and profiling.
12. Keeping Data Subjects Informed
12.1 The Company shall ensure that the following information is provided to every data subject when personal data is collected:
a) Details of the Company including, but not limited to, the identity of Martyn Headley, its Data Protection Officer;
b) The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
c) Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
d) Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
e) Where the personal data is to be transferred to one or more third parties, details of those parties;
f) Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 24 of this Policy for further details concerning such third country data transfers);
g) Details of the length of time the personal data will be held by the Company (or, where there is no predetermined period, details of how that length of time will be determined);
h) Details of the data subject’s rights under the Regulation;
i) Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
j) Details of the data subject’s right to complain to the Information Commissioner’s Office (the ‘supervisory authority’ under the Regulation);
k) Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it;
l) Details of any automated decision-making that will take place using the personal data (including but not limited to profiling), including information on how decisions will be made, the significance of those decisions and any consequences.
12.2 The information set out above in Part 12.1 shall be provided to the data subject at the following applicable time:
12.2.1 Where the personal data is obtained from the data subject directly, at the time of collection;
12.2.2 Where the personal data is not obtained from the data subject directly (i.e. from another party):
a) If the personal data is used to communicate with the data subject, at the time of the first communication; or
b) If the personal data is to be disclosed to another party, before the personal data is disclosed; or
c) In any event, not more than one month after the time at which the Company obtains the personal data.
13. Data Subject Access
13.1 A data subject may make a subject access request (“SAR”) at any time to find out more about the personal data which the Company holds about them. The Company is normally required to respond to SARs within one month of receipt (this can be extended by up to two months in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
13.2 All subject access requests received must be forwarded to Martyn Headley, the Company’s data protection officer. Martyn@jhpschools.com.
13.3 The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
14. Rectification of Personal Data
14.1 If a data subject informs the Company that personal data held by the Company is inaccurate or incomplete, requesting that it be rectified, the personal data in question shall be rectified, and the data subject informed of that rectification, within one month of receipt the data subject’s notice (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
14.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification of that personal data.
15. Erasure of Personal Data
15.1 Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
a) It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning data subjects’ rights to object);
d) The personal data has been processed unlawfully;
e) The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
f) The personal data is being held and processed for the purpose of providing information society services to a child.
15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
15.3 In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
16. Restriction of Personal Data Processing
16.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
16.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
17. Data Portability
17.1 The Company processes personal data using automated means. Name data is associated with a QR code which is photographed and used to associate data with an image. With this combination of data we produce media for the school that can be batch uploaded to their database system. Customer details are processed securely online using PayPal and stripe no data is stored on our servers or premises.
17.2 Where data subjects have given their consent to the Company to process their personal data in such a manner or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the legal right under the Regulation to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers, e.g. other organisations).
17.3 To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following formats:
a) We can supply data in the form of an excel spreadsheet to the data controller which is the school.
17.4 Where technically feasible, if requested by a data subject, personal data shall be sent directly to another data controller.
17.5 All requests for copies of personal data shall be complied with within one month of the data subject’s request (this can be extended by up to two months in the case of complex requests in the case of complex or numerous requests, and in such cases the data subject shall be informed of the need for the extension).
18. Objections to Personal Data Processing
18.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
18.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
18.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
18.4 Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
19. Automated Decision-Making
19.1 In the event that the Company uses personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on data subjects, data subjects have the right to challenge to such decisions under the Regulation, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from the Company.
19.2 The right described in Part 19.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the Company and the data subject;
b) The decision is authorised by law; or
c) The data subject has given their explicit consent.
20. Profiling (JHP do not use data for profiling)
Where the Company uses personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data security).
21. Personal Data
The following personal data may be collected, held, and processed by the Company:
a) Children’s names and identifying numbers be it UPN or admission numbers, This data is used to enable schools to enter there student photos into the school database. After creation of the batch entry media this data is destroyed.;
b) Photos of students and teachers, This is collected with the sole intent of selling it to the subject and with permission from the school. This data is stored on secure servers with individual access granted for the customer for a period of up to 6 years this data is then transfered.;
c) After photo transfer, Photos are stored offline on a secure server with no access from the internet, these files are kept on their own with no associated data.;
22. Data Protection Measures
The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:
a) All emails containing personal data must be encrypted [using HTTPS encryption]; Where possible name data should be sent only by our secure uploader.
b) Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hard copies should be shredded, and electronic copies should be deleted securely using verified and reputable secure shredding service to dispose of images or data that is printed. Any data provided by customers or data controllers is destroyed as soon as it becomes unnecessary to completing a job for that data controller.
c) Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
d) Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
e) Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
f) Where Personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
g) Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient.
h) No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from the DPO who is Martyn Headley. If Martyn is not available access can only be granted by one of the directors;
i) All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
j) No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the DPO who is Martyn Headley. If Martyn is not available access can only be granted by one of the directors.;
k) Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
l) If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
m) No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise [without the formal written approval of the DPO who is Martyn Headley, If Martyn is not available access can only be granted by one of the directors. and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
n) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
o) All personal data stored electronically should be backed up Weekly with backups stored onsite.
p) All electronic copies of personal data should be stored securely using passwords and data encryption;
q) All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols [. All software used by the Company is designed to require such passwords];
r) Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
s) Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the DPO who is Martyn Headley, if Martyn is not available access can only be granted by one of the directors to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service.
23. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
a) All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
b) Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
c) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
d) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
e) Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
f) The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
g) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
h) All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
i) Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
24. Transferring Personal Data to a Country Outside the EEA
24.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
24.2 The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
a) The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
b) The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the Regulation); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
c) The transfer is made with the informed consent of the relevant data subject(s);
d) The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
e) The transfer is necessary for important public interest reasons;
f) The transfer is necessary for the conduct of legal claims;
g) The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
h) The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
25. Data Breach Notification
25.1 All personal data breaches must be reported immediately to the Company’s data protection officer.
25.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
25.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 25.2) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
25.4 Data breach notifications shall include the following information:
a) The categories and approximate number of data subjects concerned;
b) The categories and approximate number of personal data records concerned;
c) The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
d) The likely consequences of the breach;
e) Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
This Policy has been approved and authorised by:
Name: Matthew Priestley
Position: Director
Due for Review: 01/08/2023 would like to find out more and book our service

 

 

One  Vision Imaging Terms of Use and Privacy Policy

 

 

Pics4Schools Privacy Policy

This website is operated by One Vision Imaging Ltd (‘OVI’), Pics4Schools is a trading style of OVI.
This website (www.p4sadmin.com) is aimed at businesses and as such our Privacy Policy is for business customers.

OVI take the protection and security of your personal information very seriously and this policy sets out our responsibilities under The General Data Protection Regulation 2016 (‘GDPR’) and other applicable laws in England and Wales relating to the processing and security of personal information.

This policy explains to you how OVI uses and secures your personal information whilst you are using the www.p4sadmin.com website as well as your responsibilities in relation to the use of the Pics4Schools platform.

OVI is registered and located within the United Kingdom.

One Vision Imaging Ltd
Herald Way
Coventry
United Kingdom
CV3 2NY

Company Registration Number: 01832011

OVI’s Data Protection Officer is Derek Poulston, please contact Derek if you have any questions about how your personal information is used by OVI, dataprotection@pics4schools.com or 02476 233506.

OVI review our Privacy Policy on an annual basis, sooner if changes to regulation require or OVI changes the way it processes personal information.

This policy was last updated on 1st April 2022.

Use of Your Data

 

This section explains how OVI use your data.

Collection of Data

We use Cookies on our website to enable you to log in securely and stay logged in for the duration of your visit. We do not log or track your IP address or any other activity.

You have the right to object to marketing

You can object to receiving marketing from OVI, by clicking the unsubscribe link contained in the email you have received.

Purchasing Products

When you purchase products through www.p4sadmin.com in the form of additional orders or remakes, we will collect a name, address, email address and phone number for the purpose of processing your order. It is your responsibility to ensure you have permission to use the personal data you are providing to us for this purpose.

All personal data we collect is held electronically within our secure database in the United Kingdom. Some of this data may also appear on the despatch note which will be used to process your order in the laboratory and then included with your order.

Marketing and your Data

We may send you reminder emails and emails regarding the status of orders relating to your account, we have a business case for doing this and these emails are not for the purposes of marketing.

We may collect email addresses from users of www.pics4schools.com whom have given us permission to forward their name and email address specifically to you as a data processor for the purposes of marketing. You may not sell these details to any third parties. You must ensure these details are stored and maintained in a way which does not breach the GDPR act (2016). You must also ensure that any email communcations to such persons provides an unsubscribe link. If you are found to breach these regulations at any point, we reserve the right disable your account with immediate effect and report any such incident to the Information Commissioners Office. 

The above details (if provided to you) will only be accessible through this website www.p4sadmin.com via an encrypted connection and only when you are logged in.

Please be assured we do not sell your personal data to third party companies for marketing purposes.

Third Party Sharing and Why

One Vision Imaging (‘OVI’) may share your information with third party service partners, who are acting on behalf of OVI as our data processor, the details are below of whom OVI may share your personal information with and why:

Schools, Nurseries or Institutions

If you opt to allow delivery of orders ‘Back to School’, we will provide your contact details to the relevant organisation for the purpose of dealing with any queries relating to the distribution of orders. These details will appear on a packing slip inside the box.

Customers of www.pics4schools.com

Any customer, that logs in to see your images on www.pics4schools.com, will be provided with your contact email and phone number where specified for the purpose of dealing with queries regarding your images or orders relating to them.

JONDO UK, Ltd

We may outsource parts of our production at our discretion to Jondo UK, Ltd. If we do, we may share your contact details with them for the sole purpose of fulfilling orders.

Accuracy and Retention

This section explains how OVI maintains the accuracy of your data and how long we hold your data for – please see individual sections below for more details.

Data Accuracy

You can update your address details in your ‘Address Book’ by clicking on your username in the menu bar of this site wwww.p4sadmin.com. To update your website and email details as seen by customers of www.pics4schools.com, please visit the consumer site theming section of this website. To update your contact details in our accounts system please update your details in the ‘My Account’ section of www.onevisionimaging.com. We will ask you annually to ensure these details are correct and that you are happy for us to continue holding and processing your personal data.

If, in addition to the above, your details have changed and you believe we need to know about it, please contact us at dataprotection@pics4schools.com.

Data Retention

Where we have collected your personal data for marketing purposes we will retain your information until you inform us that you no longer wish to receive marketing communications from us.

We will also hold your data in our United Kingdom based databases for the minimum period legally required by HMRC in relation to the processing of financial transactions.

Images sent to us will be stored on our secure UK based servers for a period of up to 14 months, after which time they will be permanently deleted.

Data Security

Your details will be shared with customers of your images on a secure (encrypted) website https://www.pics4schools.com. They will be stored in a secure database on a secured server. The server is equipped with a software firewall and resides behind a state of the art hardware Firewall all of which is licensed and updated at regular intervals. The hardware is in a secure location within the UK, with access by authorised technical personnel only. The secure location is alarmed, secured and monitored 24 hours a day and is protected by a series of locked doors, shutters and security grilles.

GDPR and your Rights

This section explains your rights under GDPR – please see section below for more details.

OVI are processing your personal data, we do this for our Commercial Benefit and for the benefit of our customers.

As an individual, you may have certain rights under the GDPR regarding the use of your personal data, these are:

  • The right to object – you can object to OVI processing your personal data at any time. Email dataprotection@pics4schools.com to object.

  • The right to be forgotten – you can request that OVI remove your personal data from our systems.

  • The right to access your personal data – You have a right to know what personal data OVI hold on you and for what purpose we are processing your personal data. This is known as a Data Subject Access Request (DSAR). These requests must be made in writing by either email or letter with photographic identification to confirm your identity.

You can send these requests to dataprotection@pics4schools.com or by post to the address noted below. If OVI are unable to comply with your request, OVI will provide you with an explanation:

Derek Poulston
One Vision Imaging Ltd
Herald Way
Coventry
CV3 2NY

SIMS/School Data Extracts/Data Matrix Software

If you are required by a School or institution to provide an image of each pupil back to them, the Data Matrix software (sold seperately) can provide this function for you. You do not need to share pupils personal data with us to do this.

If you require pupils names on your proof cards, we will become your data processor and so you must:

  • Ensure you have permission to pass these details on to us

  • Provide us with a csv file detailing the pupils names, class, year and admission number

  • Zip the csv file and encrypt it with a password before sending to us

Once we receive the data we will use it to import the images to our system, tagging each image with the pupils details in our secure, UK based database. Once this process has been done the csv file will be destroyed.

The details will remain on our secure production system for up to 14 months (see the Accuracy and Retention section above for more information). 

How to Complain

This section explains how you can make a complaint.

We appreciate that at OVI we do not always get things right and it is regrettable for us as an organisation when we receive a complaint. We take all complaints seriously and can assure you we will do our best to deliver a satisfactory outcome. If you do wish to complain about how your personal information is used by OVI then please write to us at:

Derek Poulston
One Vision Imaging Ltd
Herald Way
Coventry
CV3 2NY

Alternatively, you can email us at dataprotection@pics4schools.com

OVI will investigate and respond within 10 working days, this allows us time to investigate your complaint thoroughly.


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