Privacy Notice

Purpose of this privacy notice

This is the privacy notice of Baker Richards Consulting ltd, which provide the UK Heritage Pulse service (also referred to as ‘Heritage Pulse’, ‘us’, ‘we’ and ‘our’) on behalf of the National Lottery Heritage Fund and Historic England.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to give you information on how we collect and process personal data through your use of this website, including any data you may provide through this website when you, for example, sign up for UK Heritage Pulse email bulletins, make comments on our website, subscribe to our services, take part in a survey etc. We’ll also tell you about your privacy rights and how data protection law protects you.

Our website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Data Controllers

The National Lottery Heritage Fund is an operating name of the Trustees of the National Heritage Memorial Fund.

This website is a UK-based website and takes care to comply with relevant data protection legislation such as the Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (GDPR). The National Lottery Heritage Fund and Historic England are jointly data controllers for the purposes as defined by DPA 2018 & UK-GDPR.

The data controllers have appointed Baker Richards Consulting ltd and Indigo Cultural Consulting ltd as data processors. Our contact details are c/o Baker Richards Consulting ltd, Milton Hall, Ely Road, Cambridge, CB24 6WZ. Our telephone number is 01223 318210. For all data processing queries relating to UK Heritage Pulse contact info@baker-richards.com, or write to the address above.

If you have any questions relating to this privacy policy or how we use your personal data, you may also send them to Fair.Processing@heritagefund.org.uk or post them to the Data Protection Officer, National Lottery Heritage Fund, International House, 1 St Katharine’s Way, London E1W 1LA. You may also contact data.protection@HistoricEngland.org.uk or write to the Information Governance Manager, Historic England, The Engine House, Fire Fly Avenue, Swindon, SN2 2EH.

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

The personal data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

• Identity Data includes your title, first name, last name, username, date of birth, gender.
• Contact Data includes your job title, employer, contact address, billing address, email address(es), telephone number(s).
• Profile Data includes your username and password and may in future include your profile picture, social media handles and biography if you choose to provide them.
• Technical Data includes your IP address, login data, browser type and version, location, operating system and platform and may include details of any other technology on the devices you use to access this website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
• Usage Data includes information about how you use our website, products and services.
• We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
• We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Web Analytics Tracking

Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You are not opted out. Uncheck this box to opt-out. You are currently opted out. Check this box to opt-in.

The tracking opt-out feature requires cookies to be enabled.

If you fail to provide personal data

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we collect your personal data

We use different methods to collect data from and about you including through:

Directly. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email, webform or otherwise. This includes personal data you provide when you:

• Create an account on our website;
• Write articles for our website;
• Comment on articles on our website;
• Subscribe to our email bulletins;
• Take part in surveys or competitions;
• Enrol for events or webinars.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• With your consent
• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Personalisation

We may use your Identity, Contact, Technical, Usage and Profile Data to tailor the service we provide to you.

You will receive communications from us if you have requested information from us or registered on our website.

Opting out

You can instantly opt-in or opt-out of our email bulletin services at any time by clicking the ‘opt-out’ link at the bottom of any bulletin at any time. Alternatively email info@baker-richards.com, telephone us on 01223 318210 or write to us at UK Heritage Pulse, c/o Baker Richards Consulting ltd, Milton Hall, Ely Road, Milton, Cambridge, CB24 6WZ.

Where you opt out of receiving email bulletins, this will not apply to personal data provided to us as a result of enrolment in UK Heritage Pulse.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

What is a cookie?

Cookies are text files containing small amounts of information (letters and numbers) which are downloaded to your device when you visit a website. They are widely used to collect standard internet log information and gather evidence in order to improve the website and the user experience. For example, cookies allow us to recognise and count the number of visitors to different parts of our websites and their geographical make-up, but also to make certain website features work, for example secure access to private areas of a website.

If the settings on the software that you are using to view our website(s) (your browser) are adjusted to accept cookies, we take this, and your continued use of our website, to mean that you accept our use of cookies.

Can cookies be turned off?

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so, however, will likely limit the functionality of our and a large proportion of the world’s websites as cookies are a standard part of most modern websites. It may be that your concerns around cookies relate to so called ‘spyware’. Rather than switching off cookies in your browser, you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

What cookies do we use?

We use analytical cookies to help us to improve the way our website works, for example by making sure users are finding what they need easily. These are non-essential cookies that allow us to collect information about how visitors use the website, for instance which pages visitors go to most often. We use Google Analytics, a web analytics service provided by Google, Inc. to set cookies in order to evaluate use of our websites and compile a report for us.

By continuing to use our websites, you agree that we can place this type of cookie on your device. Should you wish to remove or not use Google Analytics cookies, you can Opt-out of Google Analytics cookies.

We use the following cookies:

_ga	Used to distinguish unique users by assigning a randomly generated number as an identifier. It is used to calculate visitor, session and campaign data for the sites analytics reports
_gat	Used to optimise website performance. It limits the collection of data on high traffic sites
_gid	Used to optimise website performance. It stores and updates a unique value for each page visited

Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.

We also use strictly necessary cookies. These are essential in order to enable you to move around the website and use its features. Without these cookies, services you have specifically asked for, like securely accessing your user page or remembering your cookies preferences, cannot be provided.

We use the following cookies:

_ASPXAUTH	Authentication cookie. Indicates that a user is logged in. Expires when user logs out
_sk_ _cms_user_id cms_passhash	Authentication cookies. These are cookies set by the content management system which applies to logged in users only.
RequestVerificationTokens	Security cookie. Prevents cross-site request forgery (CCRF)
Cookie_notice_accepted cookieconsent_status	Remembers user’s cookies preferences

We do not use third-party cookies or cookies for advertising.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact info@baker-richards.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we share your personal data with

We may have to share your personal data with the parties set out below for the purposes of providing the service.

• our staff;
• third party service providers and partners who assist and enable us to use the personal data to, for example, provide support to you; deliver services or tp provide functionality on the website or services.  We ensure that our suppliers protect your personal information as securely as we do.
• regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary or where the law or regulators require us to do so in order to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights;
• an additional or replacement data processor or data processors, their agents and advisers;
• other people where we have your consent.

We require all staff and third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our staff or third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International Transfers

Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate and internationally-recognised safeguards.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
• If you wish to exercise any of the rights set out above, please contact info@baker-richards.com

No fee required – with some exceptions

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Changes to this notice and your duty to inform us of changes

This version was last updated on 23 September 2021 and historic versions may be obtained by contacting us.

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact info@baker-richards.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office.