The Cromwell Museum Trust is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information.
We ask anyone who gives us their information to ‘opt in’ for Marketing purposes or other communications. This is due to a change to the rules which govern how we can communicate with you and a new regulation on personal data (the General Data Protection Regulation) coming into force in May 2018. Therefore, we are introducing a new approach that relies on you giving us your consent about how we can contact you. This means you’ll have the choice as to whether you want to receive these messages and how you want to receive them (email, phone or post).
You can decide not to receive communications or change how we contact you at any time. If you wish to stop altogether send a simple e-mail entitled ‘unsubscribe’; to alter your preferred form of communication, please contact the Museum by email: email@example.com, writing to The Curator, The Cromwell Museum, Grammar School Walk, Huntingdon, PE29 3LF or telephoning 01480 410389 (9am – 5pm, Mon – Fri).
We will never sell your personal data, and will only ever share it with organisations we work with under very limited circumstances (e.g. names of volunteers where they are working on a joint project) and if its privacy and security are guaranteed.
Any questions you have in relation to this policy or how we use your personal data should be sent to firstname.lastname@example.org or addressed to The Curator, The Cromwell Museum, Grammar School Walk, Huntingdon, PE29 3LF.
2. ABOUT US
Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by The Cromwell Museum Trust (registered charity no. 1166233), which acts as the controller for the purposes of data protection law.
3. WHAT INFORMATION WE COLLECT
Personal data you provide
We collect data you provide to us. This includes information you give when volunteering, purchasing tickets for an event, making a donation, subscribing to our e-mail newsletter or communicating with us. For example:
- personal details (name, date of birth, email, address, telephone etc.) when you volunteer;
- financial information (payment information such as credit/debit card or direct debit details, and whether donations are gift-aided. Please see section 8 for more information on payment security)
Information created by your involvement with the Cromwell Museum
Your activities and involvement with us will result in personal data being collected. This could include details of how you’ve helped us by volunteering or which events you’ve attended.
If you decide to donate to us, then we will keep records of when and how much you give to a particular cause. These are stored digitally using a secured file limited to selected staff only.
Information we generate
We conduct research and analysis on the information we hold, which can in turn generate personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to interest you.
Section 7 (Research and profiling) contains more information about how we use information for targeted advertising.
Information from third parties
We may collect information from social media where you have given us permission to do so, or if you post on one of our social media pages.
Sensitive personal data
We do not collect or store sensitive personal data (such as information relating to health, beliefs, or political affiliation). However, there are some situations where this will occur (e.g. if you volunteer with us or if you have an accident whilst visiting us), which are part of a lawful requirement to collect information. If this does occur, we’ll take extra care to ensure your privacy rights are protected.
Accidents or incidents
If an accident or incident occurs on our property, at one of our events or involving one of our staff (including volunteers) then we’ll keep a record of this (which may include personal data and sensitive personal data), which are part of a lawful requirement to collect information.
Volunteers, Trustees and Staff
If you are a volunteer (whether for specifically for the Cromwell Museum, or if you are helping us for other reasons - for example you work for another organisation which is running an event with us) then we may collect extra information about you (e.g. references, DBS checks, details of emergency contacts, medical conditions etc.). This information will be retained for legal reasons, to protect us (including in the event of an insurance or legal claim) and for Safeguarding purposes in order to protect young people and vulnerable adults.
This additional information will be retained in the case of Trustees (for legal reasons and Charity Commission regulations) and staff (as part of our duty of care and to ensure we comply with employment and other legislation). This is stored in a secured office in a locked file.
The Museum holds records of donations, sales and loans of objects to our collections, going back to the establishment of the Museum’s collection in 1962. These contain contact details of donors or lenders (usually addresses and telephone numbers), are not publicly accessible and are kept
securely within the Museum’s collection store. These are maintained permanently for legal reasons to establish the rights, titles and copyrights over items in the collection or loaned to us.
4. HOW WE USE INFORMATION
We only ever use your personal data with your consent, or where it is necessary in order to:
- enter into, or perform, a contract with you;
- comply with a legal duty;
- protect your vital interests;
- for our own (or a third party’s) lawful interests, provided your rights don’t override these. In any event, we’ll only use your information for the purpose or purposes it was collected for.
We use personal data to communicate with people who have consented to this, to promote the Cromwell Museum and to help with fundraising. This includes keeping you up to date with our news, updates, campaigns and fundraising information. For further information on this please see Section 6 (Marketing).
We use personal data for administrative purposes (i.e. to carry out fundraising activities). This includes:
- receiving donations (e.g. direct debits or gift-aid instructions);
- maintaining databases of our volunteers, donors and those wanting to be kept in touch;
- fulfilling orders for goods or services (whether placed online, over the phone or in person);
- helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this on a suppression list).
Internal research and analysis
We may carry out research and analysis on our donors and volunteers, to determine the success of campaigns and appeals, better understand behaviour and responses and identify patterns and trends. This helps inform our approach towards campaigning and make the Museum a stronger and more effective organisation. Understanding you and what you care about also helps us provide a better experience (e.g. through more relevant communications).
5. DISCLOSING AND SHARING DATA
We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our partners, but these communications will always come from us.
Occasionally, where we partner with other organisations, we may also share information with them (for example, if you register to attend an event being jointly organised by us and another organisation). We’ll only share information when necessary and we’ll make sure to notify you first.
From 1 April 2018, the Cromwell Museum will ask its subscribers to “opt-in” for communications purposes. This includes all our marketing communications (the term marketing is broadly defined and, for instance, covers information about the Museum and its related activities).
This means you’ll have the choice as to whether you want to receive these messages and be able to select how you want to receive them (post, phone, or email).
You can decide not to receive communications or change how we contact you at any time. If you wish to do so please contact the Museum by email: email@example.com, writing to The Curator, The Cromwell Museum, Grammar School Walk, Huntingdon, PE29 3LF or telephoning 01480 410389 (9am – 5pm, Mon – Fri).
What does ‘marketing’ mean?
Marketing does not just mean offering things for sale, but also includes news and information about:
- our charity, and the work of the Museum;
- our role in educating the public about the life and times of Oliver Cromwell;
- volunteering opportunities;
- appeals and fundraising (including donations and also competitions, raffles etc.);
- our events and activities;
- products, services and offers (our own, and those of third parties which may interest you);
- leaving a legacy;
When you receive a communication, we may collect information about how you respond to or interact with that communication, and this may affect how we communicate with you in future.
As a charity, we rely on donations and support from others to continue our work. From time to time, we will contact subscribers with fundraising material and communications. This might be about an appeal or a fundraising event we’re running.
As with other marketing communications, we’ll only contact you specifically about fundraising if
you’ve opted into to receiving marketing from us (and you can, of course, unsubscribe at any time). Details of how to do so are in Section 1: Introduction.
7. RESEARCH AND PROFILING
This section explains how and why we use personal data to build profiles which enable us to understand our supporters, improve our relationship with them, and provide a better supporter experience, using legitimate interests under the relevant legislation.
Analysis and grouping
We may analyse our subscribers to determine common characteristics and preferences. We do this by assessing various types of information including behaviour (e.g. previous responses) or demographic information (e.g. age or location). By grouping people together on the basis of common characteristics, we can ensure that group is provided with communications, products, and information which is most important to them. This helps prevent your inbox from filling up, and also means we aren’t wasting resources sending information which isn’t relevant to you.
Profiling to help us understand our supporters
If, based on information that has been provided to us (such as geographical location, demographics, or previous donations), it appears an individual might be willing and able to provide more support to the Museum, we may contact them to see if they wish to do so. We collect information on preferences and interests (e.g. which events you have attended) so that we can send you information on similar events.
8. YOUNG PEOPLE
Photographs, pictures, stories and competitions
We want young people to get involved with the Museum, and may use photographs or quotes from young people on our website, social media or other publicity. However, if your child is under 18 then we’ll need permission from you as their parent or guardian for us to use their image, via a signed permission form. We take great care to protect and respect the rights of individuals in relation to their personal data, especially in the case of children. If your child is under 18, we’ll only use his or her personal data with your consent.
9. HOW WE PROTECT DATA
We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information. Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). We have a set of detailed data protection procedures which personnel are required to follow when handling personal data.
The Cromwell Museum complies with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council, and will never store card details. Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.
The Museum and our other venues may have CCTV and you may be recorded when you visit them. CCTV is there to help provide security and to protect both you and the Museum. CCTV will only be viewed when necessary (e.g. to detect or prevent crime) and footage is only stored temporarily for up to 28 days, under a password protected system with access by paid staff only. Unless it is flagged for review CCTV will be recorded over.
Where we store information
All of our data is stored securely at our office in Huntingdon, either electronically or in locked paper files. All the personal details are not shared beyond the EEA.
How long we store information
We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop storing
your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed).
We continually review what information we hold and delete what is no longer required. We never store payment card information. Information regarding the acquisition of objects into the Museum’s collections will be kept in perpetuity for legal reasons.
11. KEEPING YOU IN CONTROL
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:
- the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request);
- the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason, such as regarding the acquisition of an item to the Museum’s collections);
- the right to have inaccurate data rectified;
- the right to object to your data being used for marketing or profiling; and
- where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. If you would like further information on your rights or wish to exercise them, please contact the Museum by email: firstname.lastname@example.org, writing to The Curator, The Cromwell Museum, Grammar School Walk, Huntingdon, PE29 3LF.
You can complain to the Museum directly by contacting us using the details set out above. If you are not happy with our response, or you believe that your data protection or privacy rights have
been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk.
12. COOKIES AND LINKS TO OTHER SITES
Cookies and Web Analytics
Our website uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality. With regard to each of your visits to our website we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), events or exhibitions you viewed or searched for, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- We do use Google Analytics – a commonly used piece of software – to give us broad indications about our website usage. This does not give us any personal information relating to you and allows us simply to see how successful our website is and patterns of usage.
How we may use information collected about you:
- To improve our website to ensure that content is presented in the most effective manner for you and for your device, allow you to participate in any interactive features of our services when you choose to do so, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- To make suggestions and recommendations on our website (and by email and post if opted) to you about goods or services that may interest you or them, or to contact you if you have not checked out or to follow up on abandoned shopping baskets or to see if there was a problem with your use of the website.
Links to other sites