Introduction
Purpose
This privacy notice covers the capture, storage and use of images of ONR staff, visitors and members of the public for promotional purposes. It does not cover images taken by CCTV or for security purposes.
ONR staff should refer to ONR’s Internal Privacy Notice for further information about how we comply with data protection legislation.
Visitors to ONR, employees of other organisations and members of the public should refer to our External Privacy Notice for further information about how we comply with data protection legislation.
Scope and applicability
This notice applies to all ONR employees, workers, contractors, secondees, apprentices, and non-executive directors, visitors to ONR and members of the public when we organise or attend events.
This notice does not form part of any contract of employment or other contract to provide services.
Policy
Photography and use of images
ONR maintain a photograph library of images which may be used on our intranet, website, social media channels and in other ONR publications.
We obtain images of staff by taking their photograph when they join ONR, are appointed to a role, occasionally whilst fulfilling their duties and at organised events or gatherings.
We obtain images of visitors to ONR, employees of other organisations and members of the public when they visit ONR offices and at events we organise or attend.
Lawful basis of processing
ONR rely on the lawful basis of Legitimate Interest for taking, storing and publishing images of people for promotional purposes.
We balance ONRs interests against the interests of people we photograph or video by:
- Providing a signpost to this notice when staff join ONR and when ONR organise an event or gathering where promotional still or video photography is to take place.
- Allowing staff members to request an opt-out of the use of thieir image going forward (this request should be made in writing via contact@onr.gov.uk). It is not usually possible to withdraw material that has already been published. If an opt-out request is deemed unreasonable it may be refused and the reason will be given.
- Informing attendees at events in advance that still or video photography will be taking place and how to avoid their image being taken.
- Providing signage at events announcing still or video photography is taking place and how attendees can avoid their image being taken or used.
- When an image of a staff member is to be used in one of our key corporate publications (e.g., annual report and accounts, corporate plan, CNI report) we will contact them again in advance of the publication and give a clear option to object. We will consider the reasons for an objection and confirm our decision to the staff member. We do not believe it is practical to give visitors or members of the public a change to object.
Types of images and other personal data
We take and publish photographs consisting of:
- Head and shoulders or full-length images of individuals. These will usually include a caption of the name and job title of the individual.
- Posed groups. These may include a caption containing names, job titles or team identity.
- Action images of individuals or small groups whilst working. These do not usually include a caption containing names.
- Informal images of individuals and groups at events or gatherings. These usually do not include a caption containing names.
We record and publish videos consisting of: - Individuals communicating trustworthy or promotional information direct to camera such as video updates or job experience videos. These will usually include a caption of the name and job title of the individual.
- Wide shot videos without audio of groups at events, usually without captioning.
Retention of images
We will retain the photographs in the ONR Photo Library for a maximum of eight years and may use them at any time during that period, unless an opt-out has been received.
Sharing information
We will not share images with the organisation without the permission of those shown.
Information rights
Please refer to the Privacy Notices mentioned above to contact ONR about the rights in relation to this processing.