Fitzgeralds Photography Policy
Fitzgeralds respects the privacy of individuals and is committed to protecting their personal information. As required by the Guernsey General Data Protection Regulation 2017, we follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access. The Company's policy on the collection and use of personal information is outlined below and states what data we collect, why we collect the data, how it is used, the lawful basis on which your personal data is processed and what your rights are under the Data Protection Laws.
By attending a photography session with Fitzgeralds, you are providing a Lawful Basis to Process. As all attendees have the right to refuse to have their photograph taken, their agreement is understood once they have posed for the photograph. Fitzgeralds is not able to photograph any children under the age of 16 without parental/guardian permission. By signing the Contract you are agreeing that you have parental/guardian permission for them to be photographed.
For the purposes of best practice, Fitzgeralds assumes that all photographs are taken on private property and abides by the extra legislation in place.
Portrait Photography
When a client books a portrait session with Fitzgeralds, we may request and hold the following information:
- Contact name of the Person Making the Booking
- Address
- Telephone Number
- Email Address
- Names of those wishing to be photographed including the ages of those under 16.
This information is used:
- To book the photography session, should the above information not be supplied, the session may not be able to be undertaken.
- To provide you with our services, to create and deliver the products you have ordered and to contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us.
This information is stored on our database in case we need to contact the client regarding their booking. On a rolling programme, we will delete the data seven years after the last transaction with Fitzgeralds.
How information taken will be held and stored including the actual photograph images.
- Photographs are taken on a digital camera and transferred from the camera card to our internal secure server. Fitzgeralds operates a Firewall and Sophos Protection which is maintained by Clarity Ltd. Any SSL certificates are maintained as necessary.
- All images and orders are processed through an internal image management system and may be held for a period not exceeding ten years in case of re-orders. After this time period, the images and orders may be deleted. Please note that images may be deleted prior to ten years due to technology and system space.
- Digital files may be purchased and supplied. Once delivered to the Company, Fitzgeralds no longer has any control over what happens to those images and the responsibility falls to the purchaser (subject to Copyright Laws).
- Clients may select to either collect their order directly from Fitzgeralds or have it posted to them. Our liability for ceases upon collection, or once accepted by Guernsey Post. Should the client wish to track their order, they may request to have it sent by either recorded or special delivery postage.
- Should the client choose to collect their order from Fitzgeralds, we will make repeated attempts to contact them. If the order has not been collected within a period of 3 months, it may be destroyed unless an agreement has been made with them.
- Any questions about their order must be made within 3 days of receiving their order.
Liability and Complaints
Privacy Policy
- With your consent, we may use your photographs to promote and advertise our business, including in our studio, printed publications, promotional materials, on our website and other digital advertising of our services and in social media forums such as Facebook. Please note we will not use any images taken of children at school or pre-school in any form of marketing.
- Subject to consent being supplied on the contract, Fitzgeralds will not use the images for marketing or publicity purposes.
- Any photographs which are printed in error or damaged in the laboratory will be securely shredded.
- In order to take advantage of some of our services, the client may need to supply us with the personal details of a third party, for example, name and address if they wish us to send them prints directly. We will not use this information for anything other than providing the service for which the information was supplied.
- We will not disclose any personally identifiable information without permission unless we are legally required to do so for example, pursuant to a court order or for the purposes of prevention of crime or fraud.
Payment
- Orders may be paid in person at our offices via cash, cheque, credit/debit card or BACS. Cheques are kept for a maximum of one week in a lockable drawer after which they are paid into our nominated bank account. Once received by our bank account, our liability ceases and if parents wish to review their privacy policy, you can see it at their website (Natwest International). Likewise, should parents choose to make a BACS payment, Fitzgeralds will not receive any of their personal information other than the name of the account from which the payment was made, and any reference supplied.
- Credit and Debit cards are processed in-store through our physical SumUp terminal. The merchant copy of the credit card slip is kept in a lockable drawer until it is reconciled the next working day. Then it is attached to the relevant report for that day and stored for a period not exceeding seven years.
- If payment is made over the telephone by card, the details will be input directly into a secure online card system which encrypts all information so that it cannot be intercepted. Once processed, Fitzgeralds has limited access to the data entered on the payment gateway site for the purpose of amending a transaction if required. No card details are stored on paper or electronically. Fitzgeralds does not accept card details by email and should a client send them to us by email, the email will immediately be deleted from our system.
- Orders paid online through our website www.fitzgeralds.co.gg is by secure on-line credit card payment. To make this possible this site contains a link to other sites, that of PayPal who are our chosen Credit Card Authorisation Bureaus. If you wish to review their Privacy Policies, you can see this at their websites.
- When you have placed your order and are required to make payment, you are transferred to the payment site, which means we do not process your financial information and therefore are not able to store it. Your payment, using the PayPal system, is transacted through Secure Server Software, which encrypts all information so that it cannot be intercepted.
- You will have linked to the Payment System from our web site. We cannot be held responsible for the privacy policies and practices of these third parties, so we recommend that you check their privacy policy. You must contact its owner or operator if you have any concerns or questions that are specific to their site.
Cookies
We may temporarily store some information on your computer when you use our website. These pieces of information are called 'Cookies' and they make possible your use of our web site, which requires 'Cookies' to be enabled. You can set your browser to notify you when you receive a cookie, which allows you to choose whether or not to accept it. If you decide not to accept, you may not be able to use the Fitzgeralds service.
Non- personal Information
We may automatically collect non-personal information about your visit to our website, such as the type of browser used or the web site from which links to us are made. This information will only be used to assist us in providing an effective service on this web site. We do not supply the owners and operators of third party web sites which have a link to our site with information about the number of users linking to our site from their web site.
Breaches in Security
Should a breach occur, the following protocol will be adhered to:
- Identification of breach
- The breach will be immediately reported to John Fitzgerald (Managing Director) or Emma Hodge (Office Manager) once it has been identified.
- They will then conduct an internal investigation to discover how serious the breach is. Depending upon their findings:
- The breach will be rectified, and procedures put into place to ensure it does not happen again.
- If the breach is considered to be severe ie: results in the high risk to the rights and freedoms of an individual, it will be reported to the Guernsey Data Commissioner and relevant school within a timescale of no more than 72 hours after the initial breach was reported.
Changes to Privacy Policy
If we change our privacy policy, we will post the new policy on our website www.fitzgeralds.co.gg. Please visit this Privacy Policy statement on a regular basis to make sure you have read the latest version and you understand what we do with your personal information.
Contact us
If you have any queries or problems with regard to this Privacy Policy or the uses to which we put your personal information please e-mail us at john@fitzgeralds.co.gg or write to us at Fitzgeralds at Rue Des Caches, St Martins, Guernsey, GY4 6PH. This document is also available at our website www.fitzlab.com.