What personal information do we collect about our Members?
We only collect information that is necessary to run the Gallery’s Membership programme, fulfil our obligations to you, and keep you informed about the Gallery and its activities.
The personal information we collect on you as a Member may include:
- your name, title and date of birth;
- your email address, phone number, postal address, billing address, delivery address;
- your named Joint Member;
- your current interests and preferences;
- feedback you may have submitted related to Gallery services and products;
- information about ticket purchases and event registrations/attendances;
- product selections and purchases of goods or services from the National Gallery Company Ltd.;
- donations you have made to the Gallery;
- your credit card or other payment information (we only store this for as long as we need to process payment);
- your contact preferences;
- your bank details for setting up a regular direct debit;
- your Gift Aid declaration;
- details of correspondence sent to you, or received from you;
- any other information provided by you to the National Gallery;
- 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 when searching for a Wi-Fi connection;
- images of you recorded on our CCTV cameras; and
- images captured on film or photography taken in the Gallery.
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’). We only collect such information in limited cases and where there is a clear reason for doing so, such as in relation to accessibility to Members' events, recording accidents, or dietary requirements for events.
How do we collect personal information about our Members?
Information you give us
We collect personal information that you provide to us including when you do one or more of the following:
- Sign up as a Member;
- Sign up to our Members’ email updates;
- Make a donation;
- Complete a visitor survey or enter a competition; and
- Provide feedback on products and services provided by the Gallery.
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;
- when you have contact with us as a visitor, customer, Member, or supporter of the National Gallery;
- information collected through use of CCTV in and around the Gallery; or
- 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 from third parties
We may also receive information about you from third parties, for example when you:
- enter a competition run on a partner website (and agree to the sharing of your information with us);
- follow the National Gallery’s social media channels, subject to your privacy settings on those channels; or
- make a purchase from the National Gallery Company Ltd.
How do we use information about our Members 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:
- Where we need to process your information to perform our Membership contract with you or in order to take steps at your request prior to the entering into of the contract, for example:
- To process payments;
- To fulfill orders for exhibition tickets or other events or services;
- To provide you with Membership benefits, which you are contractually entitled to receive;
- To send you your Membership card and pack; and
- To use your email address to enable you to book exhibition tickets and tickets for Members' events online.
- 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 Members' email updates in relation to the Gallery; and
- To send you limited information by post, including renewal reminders.
Where you have given consent to the processing of your data you may withdraw it at any time. See General privacy information for further details.
- Where processing your information is necessary for our legitimate interests, for example:
- To process donations;
- Where we combine information we hold about you to better understand your interests and preferences so that we can target communications we send to you (see below 'Membership communications');
- Where we conduct general quantitative research on National Gallery Membership;
- Where we collect and view images of our visitors (including Members) on CCTV footage for security purposes;
- Where we collect MAC addresses for the purposes of monitoring and analysing the usage of, and maintaining of, our free public Wi-Fi service and analysing (in an aggregated and anonymous format) visitor movements around the Gallery to improve our visitor experience; and
- 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 visiting the Gallery and we have to process your personal data in order to make sure you receive appropriate medical attention).
What other organisations do we share information about our Members with?
We will not sell your personal information to any third parties or external organisations.
Sharing your information with the National Gallery Company Ltd.
We share information with the National Gallery Company Ltd., which runs the shops in the Gallery and oversees the cafes and restaurants in the Gallery and the sale of audio guides in the Gallery. Complaints or feedback we receive about the shops, restaurants, and cafes may be shared with the Company and in the event of a security incident taking place in a shop, café, or restaurant, CCTV footage may be shared with the Company.
If you have agreed to be communicated with by email, we will share your information with the National Gallery Company Ltd. but you will not receive emails from the National Gallery Company Ltd. in relation to the shops or other services they provide 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 processes information enquiries (including requests to use the Gallery’s disabled parking space) received in the Gallery on our behalf; Securitas provides trained first-aiders in the Gallery who record details of any accidents within the Gallery if they are called to assist; Securitas sells Memberships and exhibition tickets on desks in the Gallery, and record on our behalf personal data of those making these purchases; Securitas processes comments and complaints submitted to the Gallery and responds to these on our behalf and in liaison with us.
- The National Gallery Company Ltd. which sells Memberships and tickets online on our behalf.
- Our email distribution service provider who sends out our marketing emails;
- Our mailing house who sends out our Membership welcome and renewal packs;
- Our ticketing service provider; and
- Our third-party Wi-Fi infrastructure provider who collects and processes MAC addresses and information regarding the 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 only for the purposes we specify, and ensure they have the appropriate controls in place to protect the security of your information.
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.
Communicating with Members
Members will be among the first to hear about Members' events, offers, news, and ways to support the National Gallery.
National Gallery Membership is administered almost exclusively through online channels. When you join as a Member, you will be asked for your email address, which will be used to send you confirmation of payment, a welcome email, direct debit notifications, and Members’ email updates and reminders, which may include our monthly newsletter, invitations to our Members’ events, what’s on round-ups, exhibition alerts, and surveys – providing information about our latest exhibitions, news, events, appeals, and offers available in the Gallery shops and restaurants.
You can unsubscribe from emails or change your email preferences at any time. Please see below changing your email preferences .
If you chose not to provide an email address (or you unsubscribe from receiving emails from us at any time) the only communications you will receive from us will be those very limited communications which we send by post, including the Membership card and pack (which form part of your Membership benefits) and a postal reminder about renewal.
We will only telephone you directly at the contact number you’ve provided when it is deemed the most appropriate channel to effectively resolve any issues or queries you may have with your Membership, or a Gift Membership you may have purchased.
Tailoring our emails and services
We are committed to communicating with you using an approach that is right for you. This means we carefully manage the communications we send you to make sure we are contacting you in the most relevant way.
In order to do this, we may combine the information we collect about you and analyse what we know about your interests, preferences, and interactions with our website(s) and marketing emails to create a profile so that we can contact you in the most appropriate way, and with the most relevant information. Example communications that use profiling in this manner include our Members' email updates, some newsletters, exhibition pre- and post-visit emails, abandon browse, abandon basket, recommendations, favourites, associated updates, and email reminders about renewing your Membership.
You do have the right to object to us combining and analysing information in this way. To make this easy for you, if you tell us that you don’t want to receive personalised emails we will treat this as an objection to the combining and analysing of your data and will stop dealing with your data in this way and sending you personalised emails.
Changing your email preferences
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 Members' email updates by clicking the ‘unsubscribe’ link at the end of our emails or via the email preference centre; or
- contacting us at Membership@ng-london.org.uk.
If you have indicated that you do not wish to be contacted by email, we will maintain a minimal amount of your personal information (for example, your name, email address, or postal address) on a suppression list to help us make sure that we do not continue to contact you by email.
When your Membership ends
When your Membership ends, you will be automatically opted out of Membership emails, including the Members’ newsletter and invitations to Members’ events.
However, you will continue to receive general National Gallery email updates (see What this means for our email subscribers) to let you know what is happening at the National Gallery, and give you an opportunity to renew your Membership. If you do not wish to hear from the National Gallery after your Membership expires, you can unsubscribe using the 'unsubscribe' link at the end of our emails, or via the email preference centre.
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, and to fulfil our contractual obligations to you and to comply with legal requirements, tax, and accounting rules.
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, accident or incident which may give rise to an insurance claim, which is captured on CCTV it may be retained longer.