Your data privacy and the protection of of your personal data is a top priority for us. Changes to data protection legislation came into force on 25 May 2018 under the General Data Protection Regulation (GDPR).
Accordingly the Foundation has updated its Privacy Policy which you can read below.
Users who have given their consent by subscribing to the Foundation's regular eNewsletter can unsubscribe at any time from the email (newsletter) itself or by contacting us.
Privacy Policy
1 Ulster Historical Foundation (‘UHF’ or ‘the Foundation’)
Ulster Historical Foundation is an educational non-profit and registered charity (registration no. NIC100280) based at Bradley Thallon House, Unit 44D, Kiltonga Estate, Belfast Road, Newtownards, BT23 4TJ.
The Foundation is registered with the Information Commissioner’s Office (ICO), Reg. No. Z7585371.
1.1 Introduction
Ulster Historical Foundation is committed to ensuring that your privacy is protected. Where we ask you to provide certain information by which you can be identified when using our website, then you can be assured that it will only be used in accordance with this privacy policy.
Ulster Historical Foundation is the ‘data controller’ and if we hold personal data about you, in the language of GDPR you are the ‘data subject’.
Our privacy policy is designed to be in accordance with the General Data Protection Regulation (GDPR). This policy explains how we will use the personal data that we hold.
We might need to change this privacy notice from time to time. If we do, we will let you know.
2 Why does the Foundation need your information?
In order to provide our services, we may need to process personal data from time to time (that is information about someone who can be identified from the data). This personal data may be about you or other people.
Personal data is ‘any information relating to an identified or identifiable living person’. The data held by the Foundation falls into three main categories:
- Historical data pertaining to deceased individuals and drawn from various sources including public records, church records, census material, etc.;
- Current/contemporary data pertaining to individuals (usually members and clients) which has been provided by them in commissioning the Foundation to deliver specific services; and
- Financial and administrative data required to enable the Foundation to function.
3 Personal data that the Foundation collects
- Personal or sensitive data including: name, address, DOB, email address and telephone number;
- In some circumstances financial data supplied directly to us by clients, such as credit card[1] information or personal cheques (which might give personal details); and
- Preferences and interests (for example if you are interested in publications, online records, membership, events, etc).
Note: personal data collected does include individuals not resident within the EU.
3.1 Special Categories of personal data
It is possible that some of the information which we collect and store about clients/customers may include some data which falls within the Special Categories of personal data.[2]
For example, in some instances clients who have commissioned genealogical research may provide the Foundation with personal data on living relatives e.g., siblings, parents, relatives, in order for our research team to deliver the service which they have commissioned us to undertake.
UHF rarely asks for this, rather it may be furnished by the client as part of a wider family tree. If a living relative is the subject of the commissioned research, we do not contact such living relatives but we can provide information that is held in the public domain.
3.2 General
We may also collect, use and share Aggregated Data such as statistical or demographic data which we collect. Aggregated Data may be derived from personal data but since it cannot be used to identify an individual, it is not personal data.
4 The Foundation holds personal data about the following groups (data subjects)
- clients and customers who use our services
- members who have joined the Ulster Genealogical and Historical Guild to avail of the various services and benefits of membership of the ‘Guild’
- donors and those who have given financial or other support to us
- subscribers to our eNewsletter
- users of the Foundation’s website
- volunteers and supporters, and employees or prospective employees
- those who attend our functions, events, book launches, conferences and courses
5 How do we obtain your data?
In most cases the information we hold about you has been provided directly to us by you. We collect personal data from you when you:
- commission research, purchase publications, buy credits to use to search our online historical records databases, register for a genealogy course or conference;
- contact us to join the Ulster Genealogical and Historical Guild;
- make a financial donation or in-kind gift to the Foundation;
- subscribe to our eNewsletter;
- contact us for advice or support;
- register to attend an event such as a lecture, book launch, course or conference; visit our website, create user accounts, and indicate your preferences;
- complete one of our surveys; and
- apply for a job with us, including if you send your cv to us on a speculative basis.
In some cases we may collect data from someone else. Examples include where existing members or supporters feel you may be interested in using our services, attending or hosting one of our events, or supporting our work, and they suggest your name to us.
We may also collect data from publicly available sources. Examples include information gathered from online media, including social media like Facebook or Twitter.
6 How do we process your personal data
The Foundation complies with our obligations under GDPR, by keeping personal data up-to-date, by storing and destroying it securely, by not collecting or retaining excessive amounts of data (other than historical data on deceased individuals for the purposes of undertaking its work), by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring appropriate technical measures are in place to protect your personal data.
We use personal data to manage, deliver and promote our core charitable activities, these include:
- promote the aims and objectives of the Foundation through our range of activities;
- send communications to you about the Foundation;
- notify you about events, course, classes, book launches, new books and other historical and genealogical news, relevant to your expressed preferences;
- give information on special offers and new product alerts and account updates;
- provide you with help, advice and support;
- fundraise for the Foundation, including processing of Gift Aid declarations;
- publicise lecture tours, appearances at fairs, festivals and community educational classes;
- communicate with members and publish their research interests and personal data (where prior explicit consent has been given by them for their information to be placed in various public research publications); and
- inform members and pay-per-view users of new historical database releases or upgrades.
7 What is the legal basis for processing your personal data
We use the following lawful bases to process personal data:
- UHF processes data under Article 89 of the GDPR (Schedule 2 Part 6 UK Data Protection Bill) pertaining to historic records and information.
- Explicit consent of the data subject so that we can keep you informed about new products and services news, events and activities.
- Explicit consent of the data subject so we can process Gift Aid donations.
- Where processing is necessary for carrying out obligations under employment, social security or social protection law or other agreement.
- Where we have legal obligations under UK or EU law, such as fraud prevention, the exercise of consumer rights, and under equal opportunity responsibilities.
- Where it is in our legitimate interest to provide confirmations or updates about products or services we provide you with, such as fulfilling your request to attend events, participate in courses, or help you with advice and support.
- Where it is in our legitimate interest to provide our membership service by keeping members informed about their membership status, new products and services, activities, updates, including member newsletters.
- Where you have subscribed to receive our eNewsletter you will have given consent for us to store your contact information and to contact you by subscribing.
You can unsubscribe at any time from the email itself or by contacting us.
8 Sharing your personal data
The Foundation will treat your personal data as strictly confidential and will never sell your data, nor do we rent or trade personal data with other organisations or businesses solely for the purposes of marketing or to make a profit. Information in respect of Guild members (if they have so authorised) may be sold (to cover production costs) in book form (The Directory of Irish Family History Research) to public libraries, etc. to enable greater circulation of potential research material.
We will not disclose personal data to any third party or external organisations, other than data processors carrying out work on our behalf.
We may pass on your personal data if we have a legal obligation to do so, or if we have to enforce or apply our Terms and Conditions of Use and other agreements. Otherwise it will only be shared with third parties with your explicit consent.
9 Your rights under the General Data Protection Regulation
GDPR provides you with the following rights:
- to be informed about the processing of your personal information;
- to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
- to object to processing of your personal information;
- to restrict processing of your personal information;
- to have your personal information erased (the ‘right to be forgotten’);
- to request access to your personal information and to obtain information about how we process it;
- to move, copy or transfer your personal information (‘data portability’); and
- to lodge a complaint with the Information Commissioner’s Office.
The Foundation is committed to upholding your rights. You can contact us for further clarification or any concerns you have regarding your personal data that we hold (see contact details below).
10 How long will the Foundation keep information about you
It is our policy to ensure that all personal data held by us is handled correctly and appropriately according to the nature of the information, the risk associated with mishandling the data, including the damage that could be caused to an individual as a result of loss, corruption and/or accidental disclosure of any such data, and in accordance with any applicable legal requirements.
10.1 Data security and retention policy
We keep data in accordance with the guidance set out and to enable UHF to deliver the services we have contracted to provide for you. We make sure that we do not collect more personal information than we need in order to carry out our activities and minimise the period of time we hold it for. We review our practices regularly.
In some cases, we retain records for the length of time that we are legally obliged to do so (for example, invoices, payment information, Gift Aid declarations, job application and monitoring information, minutes of general meetings and trustee decisions). In other cases, we apply our retention policy when we no longer require personal data and ensure its secure deletion or disposal.
When we use third party services and cloud services to process personal data we take due diligence to make sure that they are reputable and have appropriate data protection practices.
We may store aggregate data without limitation (on the basis that no individual can be identified from the data).
10.2 Other
Other retention periods are based on reasonable needs of the charity in terms of delivering services and on previous experience which demonstrate the need for a varied retention policy in respect of certain data generated by the work of the Foundation. The GDPR legislation provides some exemptions in respect of scientific and historical research where data may continue to be held to enable ongoing research. These include, for example:
10.2.1 Guild members
We will retain indefinitely our members’ research interests, which have been published online and in hardcopy format in our members’ annual Directory of Irish Family History Research (and formerly the Subscribers’ Interests Lists) which has been published with the explicit consent of members, as they are a storehouse of valuable genealogical data (on deceased individuals and therefore outside of the remit of GDPR guidance on personal data).
Members give their explicit consent to their personal data being produced in research publication format when subscribing to the Guild. Members can specify their preference when subscribing to the Guild, to have their personal data excluded completely from the published Directory or exclude their personal data (address and email address) and substitute instead a c/o address, which is the Foundation’s office address.
The members’ personal data (name, address and email address) is not published online.
A member can change their preferences at any time by contacting the Foundation’s office, and this change will apply from that point forward.
10.2.2 Research clients
We will hold family history research reports commissioned by our clients indefinitely as they are a storehouse of valuable genealogical data (on deceased individuals and therefore outside of the remit of GDPR guidance on personal data). The files will be stored offsite in a secure location and physical access to the data is limited.
11 Further processing
If we wish to use your personal data for a new purpose, not covered by the privacy policy, then we will provide you with a new policy. The new policy will explain the new use of your personal data prior to the commencement of processing. It will set out relevant purposes and processing conditions. Where and when necessary we will seek your prior consent to the new processing.
12 Cookies and Analytics
We may collect information about your visits to our sites, including, where available, your IP address, operating system and browser type. The data cannot be used to identify any individual. To help us gather this information we may use cookies; small files stored on the hard drive of your computer. Cookies allow us to improve our site and deliver a better service.
We use Google Analytics, a popular web analytics service provided by Google Inc. Google uses cookies to collect and analyse information about how the website is used. Google undertakes not to associate your IP address with other data held by Google. If you do not wish to accept cookies you can activate the appropriate settings on your browser, however, you may be unable to access some parts of our sites. To find out more about cookies visit: www.aboutcookies.org.
We will keep your information confidential except where disclosure is required and permitted by law.
13 Links to other websites
This privacy notice does not cover any third party websites linked to from within our own suite of websites (www.ancestryireland.com, booksireland.org.uk, www.historyfromheadstones.com).
14 Changes to Privacy Policy
Any changes that we make to the privacy policy will be displayed on this page and where appropriate UHF will notify you via email. This privacy policy was last updated 23 May 2018.
15 Contact
If you have any questions about this privacy policy, about the way in which we process your data, or if you wish to change the way we use your data, including how we communicate with you, please contact the Foundation as follows:
E-mail: enquiry@uhf.org.uk
Address: Ulster Historical Foundation, Bradley Thallon House, Unit 44D, Kiltonga Estate, Belfast Road, Newtownards, BT23 4TJ.
[1] The majority of the Foundation’s financial transactions are made using a third party payment gateway – Paypal, we do not have access to such credit/debit card details. Where clients/customers/members/donors provide credit card information or personal cheques to us directly (by regular post or a personal visit to our offices), these details are used once for a single transaction authorised by the client/customer/member/donor and then the data is destroyed.
[2] Special Categories of personal data includes details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data.
