Triratna Picture Library and Archive GDPR policy

Updated 11th December 2023

Archives and archiving are important. The Universal Declaration on Archives states:
Archives record decisions, actions and memories. Archives are a unique and irreplaceable heritage passed from one generation to another. Archives are managed from creation to preserve their value and meaning. They are authoritative sources of information underpinning accountable and transparent administrative actions. They play an essential role in the
development of societies by safeguarding and contributing to individual and community memory. Open access to archives enriches our knowledge of human society, promotes democracy, protects citizens’ rights and enhances the quality of life.

(The Universal Declaration on Archives, prepared by the International Council on Archives, was adopted by UNESCO on 26 October 2011 – see http://unesdoc.unesco.org/images/0021/002134/213423e.pdf)

The purpose of the Triratna Picture Library is to document the birth and development of a pioneering Western Buddhist Community. Our lawful basis for processing data is ‘Archiving Purposes in the Public Interest’, including:

• enabling research and investigation of all kinds, including academic, historical or genealogical research
• enabling the discovery and availability of personal, community and corporate identity, memory and history
• enabling commercial and non-commercial re-use

Many of these images have been in the public domain, used in newsletters, posters, and in other publications, some for more than fifty years.

We recognise that our purpose makes necessary the use of special category data: those implying subjects’ religious, spiritual, or philosophical beliefs. Where possible we use tags and metadata – for the most part we using subjects’ Buddhist, rather than civil, names – to enable users to locate images of influential individuals in the development of our Buddhist Community (including themselves). There is no other reasonable or less intrusive way to fulfil our archiving purpose in the public interest – i.e. if we did not make available these data, it would not tell the history of our Community.

The data controller carefully reviews each image before uploading to assess and mitigate any risks that may be unknown to the data subject. This includes whether the image’s presence in the library, and its subsequent re-use, might cause the subject(s) substantial damage or distress, or infringe upon their right of privacy. Where there are concerns, we restrict the availability of the image to our offline archive. We also respond swiftly to requests for images to be removed from public access.

The requirement to contact individuals photographed up to 60 years ago, and before GDPR legislation came into effect, in order to seek consent prior to making their images available would be disproportionately costly, time-consuming, and in many cases impossible. Insisting upon seeking consent from subjects in pre-GDPR era images would prevent us achieving the purpose of this archive. Identifying key individuals involved, dates on which significant events took place, as well as their location, are essential to serving this purpose. We hold no information superfluous to this purpose out of respect for the principle of data minimisation.
For photographs taken post-GDPR, we contact the photographer to ensure that they gained consent from the subject(s) for their image to be made publicly available in this way.
In addition to this notice, we will respond to requests for evidence that our processing of any image in the library is lawful, fair, and transparent.

Triratna Picture Library and Archive Privacy Policy

Updated 11th December 2023

Our contact details

Name: Dharmachari Mokshapriya
Address: Urgyen House, Adhisthana, Coddington Court, Coddington, Ledbury HR8 1JL, United Kingdom
E-mail: info@urgyenhouse.org

The type of personal information we collect

We currently collect and process the following information:

• Personal identifiers (photographs of faces, Triratna Buddhist Order names, and civil names where these are not available)
• Location and date of photographs
• Email address and name of donors and licensees

How we get the personal information and why we have it

Most of the personal information we process is provided to us indirectly, from members of the Triratna Buddhist Community donating photographs to the archive, along with recollections of the names of those photographed, and the locations and dates at which the photographs were taken.

We use the information that you have given us to document and share the story of the birth and development of a pioneering Western Buddhist Community.

In addition to this, when individuals or institutions make donations for downloading or using individual images, or to obtain a license for doing so, we process their name and email address for the purpose of communication with them, fundraising, and sharing developments of the project.

Under the UK General Data Protection Regulation (UK GDPR), the lawful basis we rely on for processing this information is ‘Archiving Purposes in the Public Interest’, including:

• enabling research and investigation of all kinds, including academic, historical or genealogical research
• enabling the discovery and availability of personal, community and corporate identity, memory and history
• enabling commercial and non-commercial re-use

Your information is securely stored.

We keep images, personal identifiers, and any location and date data indefinitely within our archive.

We keep email addresses and names of our donors for up to 10 years before deleting them permanently from the computer on which they are stored (using ‘secure empty trash’).

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at info@urgyenhouse.org if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at info@urgyenhouse.org

You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

What are cookies?
Cookies are small data files that are sent from a website to your computer or mobile phone. They are stored on the hard drive of your device. Some are stored just for the duration of your visit to the website, others are stored for much longer periods.
Cookies are used to remember useful information which allows certain functionality within the website to work, for example remembering where you have reached within an order process, or if you’ve logged in to a site. Cookies can’t harm your computer.
This page tells you about how the Urgyen Sangharakshita Trust uses cookies and how you can make choices about deleting and rejecting cookies. By using the Urgyen Sangharakshita Trust’s websites, you consent to our use of cookies.

How we use cookies
We use cookies to make our website work better for you.
No official Urgyen Sangharakshita Trust website uses cookies that give us access to any personal information about you.

How long do cookies last?
Cookies last for different lengths of time depending on what they are used for.
Session cookies are temporary cookies and are only stored until you leave the website or when you close your web browser.
Persistent cookies last for a fixed period of time, defined within the cookie, and allow the website to recognise the device again when the user returns to that website on that device.
Information about the duration of cookies used on triratnapicturelibrary.org will be published in the near future.

Who sets the cookie?
First party cookies – these are set by the website that you are visiting and can only be read by that website.
Third party cookies – these are set by an organisation other than owner of the website. This might be for the purposes of website measurement, being able to watch a video on the site or for the purposes of advertising.
Both first and third-party cookies are set on triratnapicturelibrary.org. We will be publishing a list of these in the near future.

How cookies are used
On www.triratnapicturelibrary.org.uk we use cookies that perform a different variety of functions. The categorisation and definitions are based on the guide published by the International Chamber of Commerce:

Strictly necessary cookies
These types of cookies are used to make sure parts of a website work and that you can use the site effectively, such as remembering certain information on a form when you go to another page before the form has been completed.
On triratnapicturelibrary.org.uk we use ‘Strictly Necessary’ cookies to:
Remember information you’ve entered on our join and donate forms when you navigate to different pages in a single web browser session
Remember correct membership or donation values when you have made a payment to us.
The cookies that we have defined as ‘Strictly Necessary’ cookies will NOT be used to:
Gather information that could be used to advertise products or services to you.
Remember any preferences you have set beyond the current visit.
If you prevent these cookies you may not be able to use certain features on triratnapicturelibrary.org

Performance cookies
These cookies are used to measure the performance of websites and see how websites are used. We use ‘Performance’ cookies to improve how the website works and measure our marketing activity. Information that is collected using these cookies are aggregated and anonymous and we are not able to identify individual users with these cookies.
On triratnapicturelibrary.org we may use ‘Performance’ cookies to:
Provide aggregated statistics on how our website is used.
See how effective our marketing activity is (we don’t use this information to target adverts to you when you visit other websites).
Help us improve the website by measuring any errors that occur and also to improve the performance of the site.
Test different designs of page on our website.
Cookies we have defined as ‘Performance’ cookies will NOT be used to:
Gather information that could be used to target you with advertising on other websites.
Remember any preferences you have set beyond the current visit.

Functionality cookies
These types of cookie allow websites to remember choices you make (for example, your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services on the site such as watching a video. These cookies do not track your browsing activity on other websites.
We use ‘Functionality’ cookies on www.triratnapicturelibrary.org. to:
Remember settings you’ve applied such as layout and text size.
Remember if you have already completed our online survey.
Cookies defined as ‘Functionality’ will NOT be used to:
Gather information that could be used to target you with advertising on other websites.

Advertising or Targeting cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
We use ‘Advertising’ cookies on triratnapicturelibrary.org. to:
Link to social networks like Facebook, who may subsequently use information about your visit to target advertising to you on other websites.
Identify that you have visited the Triratna Picture Library website, so that we can show you relevant adverts from the Triratna Picture Library.

Cookies used on www.triratnapicturelibrary.org
On triratnapicturelibrary.org. we use both first and third party cookies.
Third-party cookies are ones that are not set directly by the Urgyen Sangharakshita Trust, but they may be dropped onto your computer by a third party when you use one of our websites, or do certain things on one of our websites.
For instance:
we use Google Analytics and E-tracker to help us improve the website. These analytics tools use cookies that are not controlled by the the Urgyen Sangharakshita Trust but which are active when you use our website.
the ‘share’ buttons let you share pages with your friends through websites like Twitter and Facebook. These sites may set a cookie when you login to share things.
As third party cookies aren’t set by us, we can’t control how they work – but we can control which websites we choose to work with. We take your privacy seriously and we would never work with a website we don’t trust.