WEBSITE PRIVACY POLICY
The policy: This privacy policy is for this website; www.andreasarlo.com and governs the privacy of its visitors. It explains how we comply with the EU’s GDPR (General Data Protection Regulation) legislation and the DPA (Data Protection Act).
This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR and DPA are adhered to.
THE DPA & GDPR MAY 2018
This website complies with the DPA (Data Protection Act 1998) and the GDPR (General Data Protection Regulation), effective from May 2018.
CONTACTING US
This website, andreasarlo.com, collects private user data using the following form: Contact Form – www.andreasarlo.com/contact-us/, which generates emails sent to: andrea@andreasarlo.com
The data from these forms is emailed to the address listed above and also stored on the website server, in most cases dating back to when each form was created. The website server is accessible by the website administrators for www.andreasarlo.com at Everybody Smile. Everybody Smile never access or share this data other than by request from Andrea Sarlo.
By completing this contact form you agree to Andrea Sarlo contacting you about Andrea Sarlo Photography’s photography services. You will not be added to any mailing lists and will only be contacted by Andrea Sarlo or my assistant Susan Onslow in relation to your enquiry. Your personal details will not be passed onto any third parties. They will only be stored in the email account for Andrea Sarlo Photography only be accessed by Andrea Sarlo and her assistant Susan Onslow. If you wish to request for any email(s) containing your personal information to be deleted, please email andrea@andreasarlo.com.
EMAIL MARKETING
Andrea Sarlo Photography does not engage in email marketing specific to our services. Your personal details will not be used for any such marketing purposes nor will they be passed onto any third parties.
CLIENT GALLERIES
Andrea Sarlo Photography creates a client gallery for each client to whom photos are delivered as part of the services contracted. Andrea Sarlo Photography’s client galleries are externally hosted by Everybody Smile. Their privacy policy can be found here: https://www.everybodysmile.co.uk/proofing-privacy-policy/
To visit Andrea Sarlo Photography client gallery you will be required to enter a password. After 12 months has passed since a gallery was created it will be deleted.
Should you choose to order online from the Andrea Sarlo Photography client gallery by logging into you are agreeing to opt in to receive relevant, gallery-specific emails. The order process is hosted by Everbody Smile.
If you wish to request for your personal data (email address) to be deleted from Everybody Smile’s servers, please email andreasarlo.com.
EXTERNAL WEBSITE LINKS & THIRD PARTIES
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website.
We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note that they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.
CLIENT DATA HELD ON FILE
We take care over the processes around looking after personal data stored on our physical systems. Andrea Sarlo Photography holds the following personal data of clients:
1. names
2. addresses
• phone numbers
within soft copy and sometimes hard copy contracts as well as soft copy client ‘day plan’ documents. Soft copy contracts and day plans are safely stored within my password protected home office PC and backed up to two encrypted external hard drives. Hard copy contracts are filed in my secure home office.
Client photos are safely stored within my password protected home office PC and backed up to two encrypted external hard drives.
CLIENTS AND WEDDING GUESTS CAPTURED IN PHOTOS
Under GDPR legislation, a photograph may in some instances constitute a form of personal data where they can be processed to allow “the unique identification or authentication of a natural person”. Andrea Sarlo Photography will never photograph an individual as a means of unique identification or authentication unless consensually contracted to do so. Guests at weddings appear in photos taken by Andrea Sarlo Photography as a part of the visual recording of the event in photos. Guests captured in portraits or in group photos do so as part of the event and their rights are protected by Andrea Sarlo Photography as detailed in this privacy policy.
In terms of explicit GDPR compliance, Wedding clients and guests are photographed within the parameters of GDPR legislation on the basis of ‘legitimate interests’. The taking of photographs of wedding guests when viewed as a form of processing personal data is necessary for the legitimate interests of Andrea Sarlo Photography as a photography business unless there is a good reason to protect a given individual’s personal data which overrides those legitimate interests.
Operating within the parameters of legitimate interests as laid out in GDPR legislation, the disproportionate effort involved in providing privacy policy information to all wedding guests at the event and the degree to which it would distract us from performing our job renders it infeasible to do. Wedding clients are therefore requested in their contract to direct their guests to read this privacy policy in advance of the event and to advise them to contact us in advance with any concerns around the processing of their personal data, namely being photographed.
WITHDRAWAL OF CONSENT
Anyone photographed by Andrea Sarlo Photography, whether a client or wedding guest, and whether past or current may withdraw consent for a photograph in which they appear to be displayed. The process for this is to email Andrea Sarlo Photography at andrea@andreaphotography.com specifying the photo in question. Persuant to the request, Andrea Sarlo Photography will then remove the photo from online and printed display wheresoever it appears.
SOCIAL MEDIA POLICY & USAGE
We adopt a safe and responsible Social Media Policy. While we may have official profiles on social media platforms users are advised to verify the authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.
DISPLAY OF IMAGES
We may display any photographs to promote Andrea Sarlo Photography on the Andrea Sarlo Photography website and blog, on social media, on wedding blogs, on wedding photography related websites, in exhibitions, in advertising, brochures, magazine articles and other such material, providing that the images used are used lawfully and without damage to Andrea Sarlo Photography’s client(s). The rights of the people captured in these photographs are protected by Andrea Sarlo Photography as detailed in this privacy policy.