Tate Privacy Policy

Ivor Abrahams, ‘Privacy Plots V: Hedge and Street’ 1970
Ivor Abrahams
Privacy Plots V: Hedge and Street 1970
Tate
© Ivor Abrahams

Tate is dependent on the generosity and support of its many donors, supporters, employees, workers, volunteers and the general public. Paramount to maintaining and building on this is that Tate should conduct its business, at all times, in a manner which is fair and legal, and which earns the public trust enjoyed by the organisation.

Respecting your privacy and security is very important to us. Our Privacy Notice gives you detailed information on when and why we collect your personal information, how we use it and how we keep it secure. It also provides information about your privacy rights and how you may contact us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Who we are

The Board of Trustees of the Tate Gallery (‘Tate’) exists to promote the public’s enjoyment and understanding of British art from the sixteenth century to the present day and of international modern and contemporary art. Tate is an exempt charity under Schedule 3 of the Charities Act 2011 and an executive non-departmental public body sponsored by the Department for Digital, Culture, Media and Sport (DCMS).

Tate Enterprises Limited (company number 3173975) (‘TEL’) is a wholly owned subsidiary of Tate which trades on Tate’s behalf and exists to support Tate’s mission.

Under this policy, ‘we’, “us”, “our” and ‘Tate’ refers to both Tate and TEL.

Tate’s principal place of business is:

Tate

Millbank

London

SW1P 4RG

You can also contact us by phone +44 (0)20 7887 8888 or via the website: http://www.tate.org.uk/about-us/contact-us

If you have questions regarding this privacy notice, including any requests to exercise your legal rights, please contact our Data Protection Officer by email: dpo@tate.org.uk or by phone: +44 (0)20 7887 8888

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We only collect the information that’s necessary to carry out our business, provide the particular service you’ve requested and to keep you informed. There are occasions when you can choose not to give us certain information, but this for example, may limit the level of personalisation we offer e.g. you may not get to hear about an event you would have loved to have attended.

We may collect, use, store and transfer different kinds of personal data about you.
The type of information we collect depends on where and when it is gathered.

Identity Data includes prefix, first name, maiden name, last name, username or similar identifier, name of partner/spouse, marital status, title, date of birth, photograph and gender. For donations we also collect any other details provided by the donor for the purposes of crediting and stewarding them for their support (this may include names of children, associated trusts, etc.)
Contact Data includes billing address, delivery address, city or places of residence, email address and telephone numbers.
Financial Data includes bank account and payment card details. Please note, we will not hold payment information for any longer than it takes to process your transaction.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, purchases or orders made by you on the Tate Online Shop, your interests, preferences, previous interactions with Tate (particularly ticket purchases, event attendance and art loans), type of researcher, feedback and survey responses.
Technical Data includes internet protocol (IP) address and your login data. A public IP address is a unique number which allows a computer, group of computers or other internet connected device to browse the internet. The log file records the time and date of your visit, the pages that were requested, the referring website (if provided), your internet browser type and version, operating system and platform and other technology on the devices you use to access this website. This information is collected to help diagnose and manage the website, to audit the geographical make-up of users, and to establish how they have arrived at the website.
Cookies: for further information about Cookies and how Tate uses them, please see our Cookie page
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.

We will also collect information and personal data that you voluntarily give when you contact us with enquiries, complaints, comments or other feedback
Tate builds relationships with individuals and organisations who have compatible objectives and financial resources. For a small number of our audience, where we want to better understand people’s engagement with Tate and their potential interest in supporting us further we may collect additional information:

• Before contacting individuals we may seek additional information to better understand their engagement with Tate, as for example philanthropic support and current affiliations, link to existing Tate supporters, business network information and publicly available information relating to: residential location, source of wealth and assets, family (excluding information about children unless given personally by the individual concerned), employer/employment history, donations to other organisations (including political parties where they are made public by the individual) and hobbies and interests to create a profile of their interests and preferences. This helps us understand the background of the people who may choose to support us and helps us to make requests for gifts to those who may be able and willing to give. We may also use publicly sourced images to help identify individuals who attend our special events.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Third Party Organisations

Your information may be shared with us by independent organisations, either within the Tate group, (for example, our connected charities Tate Foundation, Tate Americas Foundation, Tate Canada Foundation), or organisations Tate is working with such as Art Fairs. These independent organisations will only do so when it is required to complete a contract and/or when you have indicated your consent. You should check their Privacy Notice when you provide your information to understand fully how they will process and safeguard your data.

We may combine information you have given to us with this additional information available from external sources. This will only be done when you give permission to the relevant third-party organisations to share the data they hold on you, or if the data is already publicly available.

Social Media

Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you may give us permission to access information from those accounts or services.

Data Hygiene

It is important that the personal data we hold about you is accurate and current.
From time to time we may screen our database against recognised data hygiene file such as National Change of Address file and cleanse our file or correct inaccurate data. We may also update inaccurate data if the information is available.

If you fail to provide personal data

Although it is not compulsory to provide all of the information listed below, should you choose not to, then we may not be able to provide you with the full range of services that we have to offer.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you.

Generally, we collect your information when you decide to interact with us. This could include purchasing tickets online, over the phone or in person or it could be where you sign up to receive emails from us. We also look at how our audience use our website, so that we can offer the best possible experience whether you are booking tickets or just trying to find out more about our latest shows.

Direct interactions

  1. When you create user accounts and log in to Tate Online Shop:

Your account allows you to do the following:

  • Buy tickets, gift certificates or memberships or packages of tickets
  • Join as a Member, Patron or Tate Collective member
  • Make a donation
  • Buy merchandise such as prints, books or homeware from our online shop
  • Buy magazine subscriptions
  1. When you comment or create user accounts and log in to the following website services:
  1. When you sign up to receive our email bulletin or respond to Tate emails
  1. When you visit our website: we use cookies to help make the experience of using our website better and to personalise the service you receive from us. Please see our Cookie page for further information. When you visit our website www.tate.org.uk, our web server automatically records your public internet protocol ('IP') address and also generates a log file.
  1. When you use your membership card(s).
  1. When you contact us by phone to book tickets make a booking in our restaurants.
  1. When you make purchases or book tickets in person in one of our galleries.
  1. When you contact us by post, e.g. application forms for members.
  1. When you sign in to use Wi-Fi on your visits.
  1. When you respond to one of our surveys.
  1. When you contact us to provide feedback or send us an email.
  1. When you enter a competition, promotion or survey.
  1. When you apply for a vacancy advertised on Working at Tate. Please read the Working at Tate privacy policy for further information on how your personal data will be used.
  1. When you join Tate’s Library and Archive as member.

Signing in using social networking credentials

If you sign in to our sites using a Facebook or Google sign in as a means of authentication, you grant permission to Facebook or Google to share your user details. This will include your name and email address (as well as date of birth, gender and location if signing in via Google) which will then be used to form a Tate Digital account.

Please be aware that this authentication also permits the sharing of other information you may have chosen to share according to your Facebook or Google account settings.

If you remove Tate or the Tate app from your Google or Facebook settings, then our access to your additional information will cease. For more information, visit:

If you sign in to our sites using a Twitter sign in as a means of authentication, we receive your Twitter username. For more information, visit Twitter’s Connecting or revoking third-party applications page.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES

We may receive personal data about you from various third parties and public sources as set out below:

  • We use a number of different sources to aid us in our fundraising activities, including newspaper websites and archives, housing market websites and the electoral roll as well as official websites of companies, charities and other arts organisations. In addition to general use of the internet we also make use of company, director and shareholder information from publicly available information providers.
  • From time to time, we may also get data about you from third parties – please see the ‘How we may use your information’ section for more details. This could include organisations within the Plus Tate network, international museums or galleries hosting our touring exhibitions and partners that we have run competitions with.
  • We use Google Analytics to collect information about how our visitors use and navigate this website. This information is pseudonymous and cannot be used to identify you personally. For more information, please see our Cookie page.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: to provide a service you have requested.

Purposes for which we will use your personal data

Where we need to provide a service or perform a contract we are about to enter into or have entered into with you, to:
• Fulfil ticket, merchandise, image licence, donation and membership requests.
• Process payments. Please note that we do not store any Credit Card or other payment information once the transaction has been completed.
• Provide you with assistance through our customer service team.
• Send you e-tickets and products you have ordered.
• Register you as user to access Library, Archive and Public Records items in the Reading Rooms.
• Contact you with important information relating to a booking or purchase, such as confirming your order, reminding you of an upcoming booking or letting you know about changes that may affect your visit.
• Train those who provide you with services and who manage the website.
• Send you membership benefits such as your welcome pack and cards, magazine and Guide by post, passcards, catalogues and member-only event invitations or bespoke communications.

Where we have your consent, to:
• Offer you a personalised experience, inform you of upcoming exhibitions or events, offers and news or contact you if we need to obtain or provide additional information.
• Create invitation lists for events, including private views and opening receptions.
• Credit donors in publications and in gallery.
• Email you about a specific topic you’ve requested to hear more on such as our Families programme.
• Share your details with other organisations, for example our Plus Tate partners. These organisations will contact you to let you know how they collected your data and to check that you’re still happy to hear from them. You will always be able to opt out of their communications by contacting them directly.
• Where adequate measures have been taken to anonymise your personal data and share it with third parties. The data will be provided in accordance with any consents you have previously given.

Where we need to comply with a legal or regulatory obligation:
• To undertake due diligence to detect and reduce fraud and credit risk.
• As outlined in Tate’s Donations Policy, to comply with our duty to assess that money given to Tate has been generated lawfully, and that accepting the support will not expose the organisation to unacceptable levels of reputational risk.
• To submit a claim to HM Revenue and Customs (HMRC) for Gift Aid.
• The use of CCTV recording equipment in and around our premises for monitoring and security purposes.
• To keep our database accurate and relevant, for example, using National Change of Address.

Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests, to:
• Learn about your interests and preferences so that we are able to personalise your experience and contact you with programme or product information that is relevant to you.
• Assess potential level of support and identify individuals who might be interested in particular projects. It is also used to in aggregate to inform an overall strategy for securing donations.
• Identify works of art which would complement the national collection but are outside existing budgets, with the aim of encouraging the owners of such works to donate them during their lifetime or upon their death. Works which are of interest because they could be key loans for temporary exhibitions are also identified.
• Brief Tate staff on existing relationships.
• Recognise those who have provided support and thank them.
• Provide the best possible customer services and to help us with internal administration.
• Use your pseudonymised details, to protect your personal data, to show you advertising on social media platforms as Facebook and Instagram or via other third-party advertising that may appear on other websites you use.
• Use booking and publicly available information to classify our audience into groups or segments. These segments help us to understand our audience better and ensure we’re sending relevant messages to each group.
• Analyse and continually improve the services we offer.
• Measure and understand how our audiences respond to a variety of marketing activity so we can ensure our activity is well targeted, relevant and effective.
• Contact you to ask you to participate in consumer research either via an online or telephone survey or in person. You are under no obligation to participate in research and, should you provide any further information, Tate will inform you how any further information will be used.
• Help us run the test version of our website that we use internally to pilot new features and ensure the smooth running of our web services.

As a public authority we may process your personal data where it is necessary for the performance of our public task.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us:

By email: dpo@tate.org.uk

By phone: +44 (0)20 7887 8888
By post: Data Protection Officer, Tate, Millbank, SW1P 3RG

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

INFORMATION DISCLOSURE

We will never sell, rent or exchange your details with any other organisation outside the Tate group and Tate’s connected charities (Tate Gallery, Tate Enterprises Limited, Tate Foundation, Tate Americas Foundation, Tate Canada Foundation).

We will ask for your consent to share personal information with third parties.

Some of our service providers may have access to your data in order to perform services on our behalf. We require all third parties to respect the security of your personal data and comply with UK data protection laws. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may have to share your personal data with the following parties for the purposes set out above.

  • Service providers who work on Tate’s behalf for the performance of any contract we enter into with them or you, for example payment processing companies (e.g. World Pay), our ticketing service provider, our mailing house, marketing agencies or platforms (e.g. Emarsys), database services, website hosting, or email delivery service (such as Campaign Monitor) or email partners (for example, Fishbowl).
  • Named third party organisations, for example Plus Tate partners if you ticked the relevant opt-in box when contacted. In these instances, we will supply your personal information to the specific organisation(s) only.
  • Other organisations such as competition organisers (e.g. Time Out) if you choose to take part in such activities that need administration by third parties and you choose to opt in for contact from those organisations.
  • Third party providers, for example MHM, who help us to segment and understand our audience by providing additional information so that we can send the most relevant and targeted communications possible.
  • Third party advertisers (such as Facebook or Google) to help us identify customers similar to our audience or to serve relevant adverts to you on third party websites. The information shared with these advertisers is pseudonymised to protect your personal data.
  • Professional advisers including lawyers, bankers and auditors.
  • Where required to do so (for example, if required to do so by the ‘know your donor’ principles under charity law or a court order), or regulators and other authorities who require reporting of processing activities in certain circumstances (such as HMRC), or when requested by the police (e.g. in the event of a security incident) or a regulatory or government authority investigating illegal activities.

Tate is not responsible for the privacy notices and practices of other websites and recommends that you check the notices of each website you visit and contact its owner or Data Protection Officer if you have any concerns or questions.

HOW WE PROTECT YOUR DATA

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed and will notify you and any applicable regulator of a breach where we are legally required to do so.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All external suppliers have signed data processing and confidentiality agreements with Tate. However, despite all our precautions, no data transmission over the internet is 100% secure. As a result, we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention to the fact that you do so at your own risk.

International Transfers

As part of the services offered to you through our website, the personal information you provide is transferred to countries outside the European Economic Area (EEA). By way of example, for technical reasons, we sometimes need to use the services of a supplier outside the EEA and transfer your personal data to countries outside the EEA that may not have the same level of data protection as countries within the EEA.
However, whenever we intend to do this, before any transfer takes place, we ensure a similar degree of protection to European data protection regulations is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

If you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact the Data Protection Officer using the contact details outlined in this notice.

Data Retention

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will not keep more information than we need.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. By way of example, if purchasing a ticket only, we will typically keep your data for up to ten years from the date of your last transaction. However, due to the nature of art ownership, particularly of high value pieces, data can be kept for several decades and can extend to after a person’s death.

For further information about how long we will keep your information, please contact the Data Protection Officer using the contact details outlined in this notice.

If you ask us to stop sending direct marketing communications to you, we will keep the minimum amount of information (e.g. name, address or email address) to ensure we adhere with such requests.

In some circumstances you can ask us to delete your data: see Request for erasure for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Request access to your personal data
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of your personal data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Every email we send to you will include details on how to change your communications preferences or unsubscribe from future communications. Please keep us informed if your personal data changes during your relationship with us.

Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data
You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

At any time you have the right to ask Tate to amend or stop how it uses your personal information including for marketing purposes. You can do this by signing in to the website and accessing your account details or if you don’t have an account or if you prefer to, you can contact us by phoning, emailing or writing using our contact details below.

Request restriction of processing your personal data
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request transfer of your personal data
You can request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Right to withdraw consent
Where we are relying on consent to process your personal data, you have the right to withdraw this at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

If you wish to exercise any of the rights set out above, you may contact our Data Protection Officer:
By email: dpo@tate.org.uk
By phone: +44 (0)20 7887 8888
By post: Data Protection Officer, Tate, Millbank, SW1P 3RG

For independent advice, you also have the right to lodge a complaint with the supervisory authority, The Information Commissioner’s Office:

The Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113 or 01625 545 745

https://ico.org.uk/

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

UPDATES OR CHANGES TO THE PRIVACY NOTICE AND FURTHER INFORMATION

This notice was updated on 23 May 2018. It may be updated to take into account changes at Tate or for example to reflect changes to regulation or legislation.

Updates to this notice will be posted on this page – you may therefore wish to check this page each time you submit personal information to Tate. We may also inform you of any changes where we hold an appropriate email address for you.

When your data is provided to us by another person (for example a recommendation) or a publicly accessible sources (such as Google) we will tell you where we obtained the information within a month of getting it.

Further information on data protection regulations and laws can be found here: