Communications and Marketing – Use of Digital Images Privacy Notice
Service being provided
- To create and publish marketing and promotional materials
- To promote Council services, events and initiatives
- To publish images across communication channels, including:
- Website
- Social media
- Printed materials (e.g. newsletters, posters, brochures)
- Press releases
Categories of personal data we need to collect
- Name
- Contact Details
- Digital Image/Recording
Special Category data we collect
In some circumstances, images or recordings may reveal special category data, such as:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Health information (e.g. visible disabilities)
Where this applies, we will only process this data with your explicit consent
Data Controller and Processors
The Data Controller is Worcester City Council.
The Data Protection Officer for Worcester City Council can be contacted at
Purpose of Processing
Provision of a Marketing service
Lawful basis for processing personal data
Article 6(1)(a) – Consent. The individual has given clear consent for their personal data to be processed for a specific purpose.
Lawful basis for processing special category data
Article 9(2)(a) – Explicit consent. The individual has given explicit consent for the processing of their special category data.
Source of data
We collect personal information directly from you when you provide consent and participate in photography or recording for marketing purposes.
Who we share the information with
We may share your information where necessary with:
- Media organisations (e.g. press publications)
- Social media platforms (e.g. Facebook, Instagram, LinkedIn)
- Website providers and hosting services
- Printed media such as newsletters, posters etc.
- External designers, printers and marketing providers
- Internal council services involved in communications
Your information will not be shared for unrelated purposes.
Details of data transfers to a country outside the UK and safeguards in place
Where your image is published on social media or online platforms, your personal data may be transferred outside the UK. Where this occurs, appropriate safeguards are in place, such as adequacy regulations or standard contractual clauses.
Automated decision-making
We do not carry out automated decision-making or profiling in relation to this processing.
How we obtain your consent
Where consent is required, it may be obtained verbally or in writing before digital images are used. The method used will depend on the nature of the activity, the intended use of the images and any associated privacy risks.
How long we hold your information
We will retain images and recordings for as long as they are required for the purposes outlined above or until consent is withdrawn. Some materials (e.g. printed publications or archived web content) may remain in circulation after consent is withdrawn, but no further use will be made.
Your rights
You have rights under UK GDPR, including the right to:
- access your personal information
- ask us to correct incorrect or incomplete information
- ask for your information to be deleted (in certain circumstances)
- restrict how your information is used
- object to certain uses of your information
- request your information in a commonly used format (data portability)
- understand and challenge automated decisions and profiling.
Individual’s right to withdraw consent at any time
You have the right to withdraw your consent at any time by contacting
Once consent is withdrawn, we will stop using your image in future materials. However, it may not be possible to remove images already published (e.g. in printed materials or third-party publications).
Complaints and further information
If you have questions or concerns about how your information is used, please contact the Data Protection Officer:
Email:
Phone: 01905 722233
Postal address:
Data Protection Officer
Worcester City Council
The Guildhall
High Street
Worcester
WR1 2EY
If you remain dissatisfied, you have the right to complain to the Information Commissioner’s Office (ICO):
Website: https://www.ico.org.uk
Phone: 0303 123 1113
Postal address:
Information Commissioner's Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF
Changes to this notice
We may update this privacy notice from time to time. The latest version will always be available on our website.
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