What personal information do we collect about our donors, patrons, and potential supporters?
We collect personal information that is necessary to carry out our fundraising activities, process donations, and keep you informed about the Gallery and its projects.
The personal information we collect from you may include your:
- name, title, gender, and date of birth;
- email address, phone number, postal address;
- family and spouse/partner details, relationships to other National Gallery supporters, and/or Members and named Joint Members;
- current interests and preferences;
- event registrations/attendances;
- donations you have made to the Gallery;
- credit card or other payment information (we only store this for as long as we need to process payment);
- contact preferences;
- bank details (if setting up a regular direct debit);
- Gift Aid declaration;
- details of correspondence sent to you, or received from you;
- any other information provided by you to the National Gallery;
- images of you recorded on our CCTV cameras;
- images captured on film or photography taken in the Gallery; and
- MAC (Media Access Control) addresses of any device(s) you bring with you to the Gallery, whether or not you have connected to the Gallery’s free public Wi-Fi service. MAC addresses are identifiers which any Wi-Fi enabled device transmits whilst searching for a Wi-Fi connection.
We also, on occasion, collect additional information from public sources. (See below ‘Analysis and research of our supporters and potential supporters’.)
Special categories of personal data
Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions (‘special category data’) and personal data relating to criminal convictions and offences. We only collect such information about patrons, donors, and potential supporters in limited cases, and where there is a clear reason for doing so, such as accessibility or dietary requirements for events, or due diligence in respect of major donations.
In respect of certain special category data, we may collect information that is manifestly made public by you (for example, where you have published your political opinions/affiliations).
How do we collect your personal information as a donor, patron, or potential supporter?
Information you provide
We collect personal information that you may provide to us; the National Gallery Trust (NGT), a registered UK charity which exists to support the Gallery; or the American Friends of the National Gallery, London Inc. (AFNGL), a US not-for-profit organisation which exists to support and assist the Gallery, including when you:
- make a donation to any of us or complete a Gift Aid declaration;
- complete a patron joining or renewal form;
- respond to an invitation or attend an event at the Gallery; or
- are in correspondence or verbal conversation about a donation or Gallery-related project with a member of the Development department.
Information we get from your use of our website(s) and services
We collect information about the services you use and how you use them in a number of ways, including:
- When you view and interact with our emails, advertisements, and content;
- Information about contact you have with us as a supporter of the National Gallery;
- Information collected through use of CCTV in and around the Gallery; and
- Information collected via your MAC address when you visit the Gallery with a Wi-Fi enabled device (with Wi-Fi switched on and whether or not you have connected to the Gallery’s Wi-Fi service).
Information we collect from publicly available sources
In relation to some patrons, other donors, and potential supporters we may collect publicly available information about you to assist us with our activities [See below ‘Analysis and research of our supporters and potential supporters’].
How do we use your information as a donor, patron, or potential supporter, 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 UK data protection legislation including:
- Processing your 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 process payments;
- To provide you with patrons' benefits, which patrons are contractually entitled to receive; or
- In relation to donations, to credit you in whatever way we have agreed to do.
- Where we are required by law to process your information, for example:
- To make a Gift Aid claim.
- Where we have your consent to process your information, for example:
- Where you have agreed to receive email invitations in relation to Gallery events.
Where you have given consent to the processing of your data you may withdraw it at any time. See our General privacy information for further details.
- Where processing your information is necessary for our legitimate interests, for example:
- To process donations;
- When we carry out analysis and research of patrons, donors, or potential supporters to gain a better understanding of our existing and potential supporters. This enables us to raise funds for our charitable purposes more effectively and efficiently, and allows us to approach supporters in a targeted and informed way about projects or activities they may be interested in supporting. See below ‘Analysis and research of our supporters and potential supporters’;
- When we carry out due diligence in advance of soliciting or accepting major donations in order to make sure we do not accept gifts from sources which could harm the reputation of the Gallery;
- When we collect and view images of visitors to the Gallery (including at patrons or supporters events) on CCTV footage for security purposes;
- Where we collect MAC addresses for the purposes of monitoring and analysing the usage of and maintaining our free public Wi-Fi service, and also analysing (in an aggregated and anonymous format) visitor movements around the Gallery to improve our visitor experience; or
- Where (from time to time) we (or a third party) carry out any filming, including interviews or filming/photographing of talks or events in the Gallery. Where particular areas of the Gallery are going to be used for filming or photography, we will always flag this in advance with clear signage or otherwise make you aware of the filming in advance, so that you can avoid being filmed or photographed.
Where we are relying on this basis of processing you have the right to object to this. See our General privacy information for further details.
- As a public authority we may also process your personal data where it is necessary for performing our Public Task.
- We may process special category data (for example, health data) on the basis of additional grounds, including where it is necessary to protect an individual's vital interests (for example, where you have a life-threatening accident or illness while at a patrons’ or supporters’ event at the Gallery, and we have to process your personal data in order to ensure you receive appropriate medical attention.)
Analysis and research of our supporters and potential supporters
We use tools, including information segmentation and profiling, to help us build a picture of our supporters and potential supporters to target our resources more effectively, as well as to improve the level of service we provide (for example, by briefing staff about guests in advance of meetings, dinners, and other events at which supporters and potential supporters may be present).
When building a profile we may use gift history, geographic, demographic, and other information you have provided, in order to better understand your interests and preferences.
On occasion, we may collect publicly available information to create a profile of your interests, preferences, and level of potential donations, so we can contact you in the most appropriate way and with the most relevant information.
Sources of publicly available information include Companies House, 192.com (UK Electoral Roll and Directory Enquiries), and information that has been published in articles/newspapers (we use Factiva, a Global news database).
We also carry out due diligence in respect of major donations.
Click here to see our ethical fundraising policy.
Our communications with you as a donor, patron, or potential supporter
We are committed to communicating with donors, patrons, and potential supporters using an approach that is right for you. This means we carefully manage the communications we send you to ensure that we are contacting you in the most relevant way.
If you are an email subscriber see What this means for our email subscribers.
If you have agreed to receive email invitations to events from the Development team, you can change your email preferences at any time by:
- logging into our email preference centre using the email address to which our emails are sent and indicating which type of emails you want to receive from us, including personalised emails;
- indicating that you do not wish to receive our emails by clicking the ‘unsubscribe’ link at the end of our marketing emails or via the email preference centre; or
- contacting us at email@example.com.
If you have provided us with your postal address we may send you direct mail about our work or invitations to our events, unless you have told us that you don’t want to receive such information via this channel. You may change your direct mail preferences by contacting us at firstname.lastname@example.org
What other organisations do we share your information with?
We will not sell your personal information to any third parties or external organisations.
Sharing your information with the National Gallery Company Ltd.
If you have agreed to be communicated with by email, we will share your information with the National Gallery Company Ltd. which runs the shops in the Gallery, but you will not receive emails from the National Gallery Company Ltd. in relation to the shops unless you have expressly opted to do so through our email preference centre.
Sharing your information with our service providers/external data processors
We may share some of your personal information with our service providers/external data processors, to carry work out on our behalf. Examples of such service providers/data processors include:
- Securitas, which provides security and visitor services within the Gallery; we share CCTV footage and other information about security incidents in the Gallery with Securitas; Securitas provides trained first-aiders in the Gallery, who record details of any accidents within the Gallery if they are called to assist;
- Our email distribution service provider; and
- Our third-party Wi-Fi infrastructure provider collects and processes MAC addresses and information regarding usage of our Wi-Fi service on our behalf.
Any such companies are acting as our data processors and the contracts we enter into with them require them to comply with UK data protection laws; to process your information only for the purposes we specify, and to make sure they have the appropriate controls in place to protect the security of your information.
Sharing your information with our supporting charities
Donations from our patrons are paid, at the option of the donor, to either the National Gallery Trust (NGT), a registered UK charity which exists to support the Gallery, or the American Friends of the National Gallery, London Inc. (AFNGL), a US not-for-profit organisation which exists to support and assist the Gallery. Other donations for the support of the Gallery may also be paid, if the donor wishes, to either the NGT or AFNGL. Where necessary, the Gallery shares data of patrons (and other donors) with the NGT or the AFNGL, to enable those organisations to collect and process donations and deal with any associated tax issues in relation to those donations.
Sharing information with our travel agency
If you book onto a patrons' trip we may share information, which you provide to us (to enable us to facilitate the booking) with Heritage Travel or another agency, through whom your booking will be made.
Sharing CCTV footage and Wi-Fi usage data
CCTV footage and Wi-Fi usage data (including MAC addresses) may, in the event of a security incident, be shared with the police and/or local authorities where it is lawful and appropriate to do so, in accordance with our legitimate interests outlined above.
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, to fulfil our contractual obligations to you, and to comply with legal requirements, tax, and accounting rules for Gallery record-keeping purposes. The retention period will vary according to the nature of the purpose under which the information is held. For example:
- We retain Gift Aid declarations in accordance with HMRC guidance, which in the case of a one-off donation is generally six years from the end of the accounting period in which the donation is received; the period is longer in the case of a declaration which applies to a series of donations or if an HMRC query is received during the normal retention period; and
- we normally retain CCTV footage for 30 days, although in the event of a security incident or accident which may give rise to an insurance claim, which is captured on CCTV, it may be retained longer.