– Your Rights, Our Obligations
– What Information Will We Collect and How?
– How We Use Your Data
– Third Parties
– The Archive and its Contents
1. British Pathé is a private limited company (2222005) registered at 10 Orange Street, London, WC2H 7DQ, United Kingdom. Our main address and contact details can be found here.
Your Rights, Our Obligations
2. British Pathé makes every effort to comply with applicable UK and European Union privacy and data protection laws and regulations.
3. We acknowledge and respect the rights of our users, customers, partners, and employees.
4. We will always collect and use your data fairly and transparently.
5. You have the right to the erasure of any data we hold on you, to amend your data, to restrict the use of your data to certain activities, to prevent us from processing any of your data, to request copies of your data in a format of your choice, and to transfer your data to another company. All such actions can be requested by emailing firstname.lastname@example.org.
6. These rights may be limited for the purposes of historical research, education, journalism, artistic and literary endeavours, the fulfilment of legal obligations, and British Pathé’s legitimate commercial interests.
7. After exercising your rights, such as to be forgotten, we cannot warrant that your data will not be collected again at some point in the future when such data will have been collected by fair, transparent, and legal means.
8. In the exercising of these rights, we will require proof of identity to ensure that we only alter or share the information of the person requesting it.
9. We will take all reasonable steps to comply with any data requests.
10. We will take the appropriate steps to keep your data safe according to industry standards.
11. You may make a complaint to, or request more information from, email@example.com.
12. You also have the right to file a complaint with the Information Commissioner’s Office.
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What Information Will We Collect and How?
13. We will collect the information that you provide to us yourself upon registering for our services, signing up to our mailing lists, interacting with our social media channels, adding items to WorkSpaces or Baskets, purchasing items from us, posting comments on our sites, and when emailing or telephoning our staff.
14. Data we may collect in the above manner includes your name, username, address, telephone number, email address, payment information, employer, job role, gender, interests, site behaviour, and preferences. By providing this information to us, you consent to its collection, storage, and processing.
15. Via social media interaction, we may also collect information about your date of birth, your profile picture, and any other information you make publicly available for viewing on social media. By publishing such information, you consent to the viewing, collection, storage, and use of such data according to the terms and conditions of the social media platform.
16. We may actively collect data that has been made publicly-available. This includes information such as your name, email address and telephone number should that information be published on your company website or other publicly-available source. We will not monitor social media accounts of our employees.
17. Data we may collect from you automatically when you use our services include your Internet Protocol (IP) Address, the device and operating system you are using, your location, your browser, your language, what pages you visit and for how long, what you search for, and the referral links that brought you there. This information will not be associated with your name and we will not attempt to personally identify any user of our services through the analysis of such data. Since this information is not attributed to you individually, it cannot be provided to you upon request, amended, or deleted, as we will not be able to distinguish your information from that of another individual.
18. We may use tracking technologies and store cookies on your devices, to which you consent by using our services.
19. When you create an account with us, you will provide us with a password of your creation. This password will be stored in an encrypted form which is not visible to any British Pathé employee. We will not share your password with others.
20. If you provide us with information about other living individuals, please ensure that they have given their permission and that they accept the terms of this policy.
21. We will retain your information only as long as required by law, financial accounting, or the needs of running our business. All data which does not meet these requirements, or is deemed to be out-of-date or irrelevant, will be deleted at the earliest opportunity.
22. We will collect only the information that is required in order to comply with the law, to conduct proper financial accounting, and to successfully run our business.
23. We do not intentionally collect or store any personal data of minors. If you are under the age of 16, we request that you do not use or interact with our services without the consent of a parent or guardian.
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How We Use Your Data
24. For the purposes of monitoring and fulfilling licensing agreements and other contracts, it is necessary to store relevant information relating to our customers, suppliers, partners, and employees.
25. We may use your information to respond to emails you send in or communications you initiate.
26. We may use your information to send you marketing communications. All communications will include the opportunity for you to opt-out. British Pathé will adhere to the requirements set out in the Privacy and Electronic Communications Regulations 2003 and any other applicable laws and regulations.
27. We may use your data to personalise our services, including interest-based advertising and remarketing.
28. We may use your data to analyse our services with the aim of improving how we work.
29. We may use your information in the enforcing of contracts, terms of service, legal obligations, and copyright ownership.
30. When storing or handling financial data, British Pathé complies with the Payment Card Industry Data Security Standard and warrants that it holds relevant compliance certification. British Pathé will make every effort to ensure that such data is shared only with third parties who are themselves compliant with the Payment Card Industry Data Security Standard, and to only share such information for accounting or order fulfilment purposes.
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32. We will not sell personal data to third parties, or purchase data from them.
33. Where we require the services of a third party in order to fulfil our obligations under an agreement or contract (such as using an outside facility house to send you film items), or to monitor an agreement or contract, we may pass data to such parties. Where we act as a supplier, we may receive, process, and store data as required by our partner.
34. We may use third parties to analyse and improve our business on a consultancy basis. This may involve the sharing of personal data.
35. We will only share with third parties information that they require to carry out their tasks, and not information that is not required.
36. Third parties we share information with will not be permitted by contractual agreement to use the information for marketing purposes or to sell data to another party.
37. Certain third parties may be based outside of the United Kingdom or the European Union.
38. British Pathé will make every effort to ensure that data is shared only with third parties who are themselves compliant with European Union data protection regulations or have the necessary certification from the relevant regulatory authority.
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The Archive and its Contents
39. British Pathé owns and/or controls an archive of historic importance. The images and metadata which make up the collection contain personally-identifiable information, including special categories of information such as race, of people both living and dead.
40. The collection also contains images and the personal information of individuals who were minors at the time the images were taken or when the metadata was written.
41. Personal information contained in the archive includes: Names, sex or gender, town/city address, ages, descriptions, race or ethnicity, personal appearance, political affiliation, trade union membership, and sexual orientation. Much of this information is not explicitly stated in the database but can be inferred from the images or their context.
42. The original purpose of image recording and metadata collection was for journalistic and artistic purposes. Much of this material was originally made available to the public via cinema newsreels.
43. The consent of individuals featured in this material is either implied by their participation in filming and photography, or consent was not required by the standards of the time in which the images were taken and/or data was collected, or for the purposes for which these activities were carried out.
44. We must weigh the rights of individuals against the damage caused to the integrity of the collection by hiding or deleting such data. We deem it to be in the public interest to retain and publish such information for the purposes of historical and sociological research, education, and journalism, as well as artistic and literary endeavours.
45. We make our archive free-to-view online for the benefit of the public and researchers. Through licensing agreements, we provide material for use by the public sector, museums, educational institutions, news organisations, documentary producers, and others. The archive is therefore actively used in historical and sociological research, education, and journalism, as well as in artistic and literary endeavours.
46. As a commercial licensing company, it is in our legitimate interest to accurately describe the items that are being sold and/or licensed by publishing or providing images of individuals, and of relevant information about individuals featured within its collection, to prospective customers and to make use of such material for marketing purposes.
47. As the copyright holder and/or controller of this material, we reserve the right to license and provide images and metadata related to the images from the collection to any customer, in any country, as permitted by law.
48. Third party clearance remains the responsibility of the licensees of British Pathé’s content under the standard terms and conditions of our licence agreements.
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Policy last updated 18/06/2018 11:52