Policies

1. Introduction

1.1 The School Photography Company is committed to safeguarding the privacy of our website visitors and service users.

1.2 This policy applies where we are acting as a data controller or data processor with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data to ensure that we comply with GDPR.

1.3 We use cookies on our website. In so far as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications. You can access the privacy controls by selecting “Edit Details” in the “My Profile” section of the website.

2. Credit

2.1 This document was created using a template from SEQ Legal.

3. How we use your personal data – To comply with Article 13, 14 and 6(1)(f) of the GDPR

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal basis of the processing.

3.2 We may process data about your use of our website and services (“usage data”). The usage data may include pattern of your service use and ordering. The source of the usage data is our analytics reporting system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

3.3 We may process your account data (“account data”). The account data may include your name, address, telephone number and email address. The source of the account data is what the customer provided on account creation. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.4 We may process your personal data that is provided in the course of the use of our services (“service data”). The service data may include your name, address, telephone number, email address, delivery information, image numbers and the name of the school of which images have been added to the customer account. The source of the service data is what the customer provided on account creation and by adding images to their account. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.5 We may process information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

3.6 We may process information contained in or relating to any communication that you send and/or provide us with (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering and selling relevant goods and/or services to you. The legal basis for this processing is consent.

3.8 We may process information that you provide to us for the purpose of email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is keeping the customer informed.

3.9 We may process information that you provide to us for the purpose of subscribing to our special offer emails (“marketing data”). The marketing data may be processed for the purposes of sending you special offer emails. The legal basis for this processing is consent.

3.10 We may process student data provided in the course of providing our services (“student data”). The student data may include the name, class/form and admission number of the student. The source of the student data is the school. The student data may be processed for the purposes of providing the services that school have requested. The legal basis for this processing is consent from the school with the agreement that they have the permissions to give this consent.

3.11 We may process photograph data created in the course of providing our services (“photograph data”). The photograph data may be processed to provide the service we have been contracted to complete. The legal basis for this processing is consent.

3.12 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.13 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others – To comply with Article 13(1)(e) and 14(1)(e) of the GDPR

4.1 Financial transactions relating to our website and services are handled by our payment services providers, Stripe and Paypal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.schoolphotographs.co.uk/policies and https://www.paypal.com/uk/legalhub/privacy-full.

4.2 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5. International transfers of your personal data – To comply with Article 13(1)(f), 46, 47 and 49 (1) of the GDPR

5.1 There are no circumstances in which your personal data will be transferred to countries outside the European Economic Area (EEA).

6. Retaining and deleting personal data – To comply with Article 5(1)(e) and 89(1) of the GDPR

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3 We will retain your personal data as follows:

(a) account, service and notification data will be retained for a maximum period of 5 years following the last date of account activity.

(b) transactional data will be retained for a maximum period of 7 years following order date.

(c) correspondence and enquiry data will be retained for a maximum period of 2 years following the original correspondence or enquiry date.

(d) school student data will be retained for a minimum period of 2 months and for a maximum period of 6 months following the received date.

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of usage data will be determined based on its remaining usefulness for analysis.

(b) the period of retention of marketing data will be determined based on the consent still being valid, once consent is removed so is the data.

(c) the period of retention of photographic image data will be indefinitely, as a part of our archive, as this is important intellectual property of the company.

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

8. Your rights – To comply with Article 13(2), 6(1), 7(3), 9(2), 14, 15, 16, 17, 18(1), 21 and 77 of the GDPR

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:

(a) the right to access;

(b) the right to rectification;

(c) the right to erasure;

(d) the right to restrict processing;

(e) the right to object to processing;

(f) the right to data portability;

(g) the right to complain to a supervisory authority; and

(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by visiting the “My Profile” section when logged into our website.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.12 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

9. About cookies

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: JSESSIONID, tspc-cpt, _cfduid);

(b) status – we use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: JSESSIONID, tspc-cpt, _cfduid);

(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for these purpose are: _qca, _ckAgreeXanda, _ga, _gid, _uset, _seg, _stid, _unam, _utma, _utmb, utmc, _utmz, PREF, NID, id, _drt_, UID, UIDR, mc, d, favourites_archive_photo, upsell_photo_dismiss);

(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: JSESSIONID, tspc-cpt, _cfduid);

(e) advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: _qca, _ckAgreeXanda, _ga, _gid, _uset, _seg, _stid, _unam, _utma, _utmb, utmc, _utmz, PREF, NID, id, _drt_, UID, UIDR, mc, d);

(f) analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: _qca, _ckAgreeXanda, _ga, _gid, _uset, _seg, _stid, _unam, _utma, _utmb, utmc, _utmz, PREF, NID, id, _drt_, UID, UIDR, mc, d);

(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: _qca, _ckAgreeXanda); and

(h) YouTube – we use these third party cookies to allow us to embed YouTube videos in our content (cookies used for this purpose are: VISITOR_INFO1_LIVE, PREF).

11. Managing cookies

11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/en-gb (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

11.2 Blocking all cookies will have a negative impact upon the usability of many websites.

11.3 If you block cookies, you will not be able to use all the features on our website.

12. Our details

12.1 This website is owned and operated by The School Photography Company.

12.2 We are registered in England and Wales under registration number 5639678, and our registered office is at Beaumont Close, Banbury, OX16 1TG.

12.3 Our principal place of business is at Beaumont Close, Banbury, OX16 1TG.

12.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on 01295 250812; or

(d) by email, using info@schoolphotographs.co.uk

13. Data protection officer – To comply with Article 37(1), 13(1)(b) and 14(1)(b) of the GDPR

13.1 Our data protection officer’s contact details are: dataprotection@schoolphotographs.co.uk

Privacy Policy | Environmental Policy | Cookies Policy | GDPR Statement

Introduction and Aim

The School Photography Company, as part of its company commitments, recognises its obligations to comply with the law and to carry out its business in an as environmentally sound manner as possible. We are therefore committed to reducing our environmental impact and continually improving our environmental performance as an integral and fundamental part of our business strategy and operating methods.

It is our priority to encourage our staff, customers, suppliers and all business associates to do the same. Not only is this sound commercial sense for all, it is also a matter of delivering on our duty of care towards future generations.

We are the first UK school photographers to go single use plastic-free.  Our bespoke system allows parents access to all their photos taken with one order form per child, this is greatly reducing paper wastage.

Our policy is to:

• Wholly support and comply with or exceed the requirements of current local and national environmental legislation and codes of practice, including applicable EU and UN regulations.
• Minimise our waste and then reuse or recycle as much of it as possible, by applying the waste hierarchy of reduce, re-use, recycle in all our activities. Utilising respected companies for our waste management and chemical waste management.
• Minimise energy and water usage in our buildings, vehicles and processes in order to conserve supplies and minimise our consumption of natural resources, especially where they are non-renewable.
• Operate and maintain low emission company vehicles with due regard to environmental issues as far as reasonably practical and encourage and train staff in the use of economical driving practices and use car sharing where appropriate.
• Promote the use of travel alternatives such as e-mail or video/phone conferencing.
• Apply the principles of continuous improvement in respect of air, water, noise and light pollution from our premises and reduce any impacts from our operations on the environment, including climate change criteria and local community requirements.
• As far as possible purchase products and services that do the least damage to the environment and adhere to Fairtrade practices and encourage others to do the same. 
• Assess the environmental impact of any new processes or products we intend to introduce in advance.
• Ensure that all employees understand our environmental policy and conform to the high standards it requires.
• Update our Environmental Policy on a regular basis and at least annually, in consultation with staff, associates and customers and review our progress and targets in accordance with best practice. 

Our products:

The moulding for our frames is purchased from a supplier that has a certified woods policy and meets the required standards and has FSC and PEFC Certification.

Our mounts are fully recyclable and compostable; they are produced from sustainable forestry and have FSC and PEFC certification. The UK paper mill that they are sourced from is 100% carbon neutral and all their energy is produced with their newly constructed bio-mass boiler. This means the mill boasts a world class standard when it comes to clean, efficient energy systems used for their production.

Our cardboard packaging is made from recycled and sustainable sources and is also recyclable for our end user. The company that makes our packaging is FSC accredited and has attained ISO 9001.

Privacy Policy | Environmental Policy | Cookies Policy | GDPR Statement

A cookie is a small piece of data stored by a website within a browser on the website visitors computer. We use cookies to help us to improve our site and to provide us with information about usage of the website. Certain third parties also place cookies on your device when you browse our website.

The web browsers you are currently using will allow you to have some control over the saving of cookies on your computer, tablet or smartphone through your browser settings. For further information about cookies, including how to view which cookies have been saved to your device as well as how to manage, delete and block cookies, visit https://www.xanda.net/cookie-policy/.

Our website may save cookies on your device as soon as you visit any page unless you have set your browser to refuse cookies. We use a number of suppliers who may also set cookies on or for their websites. The School Photography Company does not control the dissemination of these cookies; these are cookies found in other companies’ internet tools which we are using to enhance our site, for example third party services have their own cookies, which are controlled by them.