Conwy Archive Service Privacy Notice

CCBC is committed to protecting your privacy.  This privacy notice should be viewed alongside Conwy County Borough Council (CCBC)’s overarching privacy notice which can be viewed at: www.conwy.gov.uk/privacynotices

The information we collect

We obtain personal information from you when you deposit/donate documents with/to us, when we issue you with an Archives Card to allow access to our collections, when you apply to volunteer, attend or participate in events we are involved in, when you order or request copies of items we hold, when you fill out visitor surveys we carry out and when you send us correspondence, enquiries and research requests.  This information will or may include your name, email address, postal address, telephone number, emergency contact details and third party information you may provide.

Any personal information we gather, when we receive collections of documents for permanent preservation or when these documents are accessed, is necessary for the performance of our service carried out in the public interest and in line with, but not limited to, our legal basis for processing under the Local Government (Wales) Act, 1994 (s. 60). 

Collections of documents we receive either internally or via a depositor/donator for permanent preservation within the archive may include special category or personal sensitive data that is necessary for archiving purposes in the public interest, or scientific and historical research purposes.

What we will do with your information

When deciding what personal information to collect, use and hold, we are committed to making sure that we will:

• only collect, hold and use personal information where it is necessary and fair to do so.
• keep your personal information secure and safe.
• securely dispose of any personal information when it is no longer needed.
• be open with you about how we use your information and who we share it with
• adopt and maintain best practice high standards in handling any personal information.

In addition the information may be used for audit purposes as CCBC is required by law to protect the public funds it administers and so may use any information you have provided for the prevention, detection and investigation of fraud and irregularity, for the performance of a contract, or task carried out in the public interest, or to comply with a legal obligation.   Part 6 of the Local Audit and Accountability Act 2014 and the Accounts and Audit (Wales) Regulations are the Legal basis.

How this information is used

As a volunteer

Your personal information is only used in relation to your volunteer role or as a supporter to tell you about events and send newsletters. When you sign up as a volunteer you will be given the option to consent to receiving newsletters and other event details.  You will be able to withdraw consent at any time.  We will maintain a log of this consent until such time as there is no business need to keep it or consent is withdrawn.

Your personal information may be shared within Conwy County Borough Council if it is needed to provide you with a service, for example providing you with required access to a computer to help catalogue collections.

As a depositor/donor

Your personal information is a required part of processing any documents deposited/donated with/to us.  A signed accession form is used to establish and evidence the agreed terms of deposit between Conwy Archive Service and you as the depositor/donor.  This accession form is to be viewed alongside the Terms of Deposit.  The information you provide as part of this process is used to inform our understanding of the context, provenance, condition, intellectual property rights, copyright and ownership of the documents deposited.  The accession form is a record of the terms of deposit and will be kept permanently.

Personal data from the accession form will be input into our collections software, adding to our depositor database and accessions database.  Any correspondence we receive from you may be kept with the original accession forms or used to inform our understanding of the documents deposited where appropriate.  Any correspondence we receive from you via post or email not relevant to the documents deposited will be retained for business purposes for a set period of time before confidential disposal as per our Service retention schedule.

Your contact details may be used to contact you to inform you of Service changes or change in policy to your deposited documents.  Additionally you may be contacted for more information regarding your deposit/donation or to seek your permission to pass on your details to a third party.  If a donation/deposit is to be transferred to another more appropriate place of deposit your details may be passed on via an accession form copy.

As a visitor

Your personal information as a visitor will be gathered in one of two ways:

• As a non-reader (e.g. for an event).

Your personal information is gathered via a visitor register.  This is required as it informs us you are in the building and also when you were in the building.  The information gathered may include your name, address, telephone number and reason for visit.  We use this information for building safety reasons in case of an emergency, for example fire, but also for COVID-19 ‘Track, Trace and Protect’, security reasons and to inform our visitor statistics.  For purposes of statistics personal information will always be anonymised.

• As a reader

If you wish to view original documents you will require an Archives Card.  You will need to provide at least two forms of evidence showing your signature and current address, for example a driving licence and a passport.  An Archives Card will include your name and current address, plus your unique reader number. 

The Archives Card is part of a wider nationally recognised network run by the Archives and Records Association (ARA), providing access for you to a whole range of archive services around the United Kingdom who are also part of the scheme. For technical reasons the ARA uses iFinity PLC, a data processor, to process your data. Your personal information will be held by them on their database systems.  As a third party organisation the ARA or iFinity PLC will never sell or transfer your personal information without your express consent.  The processing is carried out on a not-for-profit basis and relates only to the membership of the scheme.

The Archives Card scheme is used to reduce risk around security to documents considered of permanent historic and cultural significance, and to help in the unlikely event documents have been accidently or maliciously damaged or stolen.  This system will be used to log your visits when you arrive at the Archive and also to gather non-personalised statistical data.  During the COVID-19 pandemic, the Archive Card system will be used for “Track, Trace and Protect’ purposes if necessary.

In order to view original items a Document Request Slip will need to be filled out.  This will provide your name, date and details of what you wish to look at.  This slip is used to track items coming in and out of secure storage, to minimise any risk of loss to items in our care.  The slips also provide the service with an audit trail of documentary access improving security and informing usage statistics.  Where statistical analysis takes place no personal information is used or recorded. The data is processed within the UK and is not transferred outside this jurisdiction for any reason. If ARA need to transfer your data outside of the UK in the future, you will be notified prior to the transfer and they will ensure there are appropriate security measures in place to protect the transfer of your personal data. 

For further information please see ARA Archives Card Privacy Notice, found here: https://archivescard.com/ARA/About/Privacy_Notice/ARAHUB/About/Privacy_Notice.aspx?hkey=67ccdabd-1adc-4dc0-accb-7aee92d438e2

While using our service you may wish to make copies of documents in our care, either for personal use or for a form of publication.  Where this doesn’t contravene an agreement with a depositor/donator you will either have to obtain a Camera Licence by filling out a Camera Licence Form if you wish to take pictures or complete a Copyright Declaration Form.  For these forms you would provide a signature, address, details of what you wish to copy, date and signature.  They are required as evidence that you accept the terms of use of a copy and that if you wish to publish or share copies you will seek additional agreed permission with the Conwy Archive Service and/or the current copyright owner where that isn’t the Conwy County Borough Council.

Keeping your personal data safe

Your personal information is kept securely regardless of format, whether electronically or in hardcopy within CCBC records management systems, the ARA or other named third party data processors.  This would be in line with the Corporate Records Management Policy and IT Security Policy. 

Archived documents containing special category or personal sensitive data are closed for access for a lengthy period of time, normally with a 100 year closure period.

How long we will hold your information

Any information disclosed to us will only be kept for as long as there is a reasonable business need as recorded in our document retention schedule.  Once your personal information is no longer needed, or where you have withdrawn consent, it will be confidentially destroyed in line with the CCBC Corporate Records Management Policy.

Information provided through the Archives Card scheme registration process is kept by ARA and the data processor iFinity PLC while you are a member of the scheme. Your Archives Card must be renewed every five years. In order to renew your card, you must verify once again your identity and current address at a participating archive. Should your membership expire and not be renewed, your data will be kept for a further ten years. This is for security reasons in the case of an investigation into loss or damage to an archive collection. Should you start but not complete your registration, your data will be kept for a period of three months, following which it will be destroyed.

Disclosing information to outside parties

Your personal information may be shared within Conwy County Borough Council or with external partners, in order for us to carry out a function or to deliver a service to you.  External partners are principally the Archives and Records Association who run and maintain the Archives Card scheme or other County Record Offices if record donations/deposits would be more suitably placed with them.  Your consent to do this will have been requested on our Accession Form.

Your information rights and accessing your records

You may wish to know your information rights and/or access a copy of your records under the Data Protection legislation.  Please see the Corporate CCBC Privacy Notice for further information.  If you have actively given consent and there is no legal basis beyond your consent for us holding your personal information, you have the right to withdraw your consent at any time.  If you wish to do so please contact: