The London Library is a registered charity in England and Wales (charity no. 312175). We receive no government funding and rely on the commitment of our membership and generosity of those who donate further to the Library. We take the privacy of everyone who engages with us very seriously and this policy outlines how The London Library will manage all the information that we hold on you and give you further detail on how you can change how we managed that information.
The London Library is the ‘data controller’ for the personal information that you provide us; and that we collect, use, and store. This activity is done in accordance with Data Protection law including the incoming Data Protection Bill (EU General Data Protection Regulation) and the Privacy and Electronic Communications Regulation.
The London Library retains, collects and uses your information in order to undertake activities necessary to the Library’s operations and development. We are committed to protecting your privacy and security, and we promise to respect any personal data you share with us. When you provide your data we aim to be clear about how we will store and use it, and not to do anything with it that you would not reasonably expect. In this policy we outline what information we retain, what information we collect and from where, how we use that data and how you can contact us to change how we hold and manage your data.
This policy was last updated May 2018.
The London Library contact details on information matters:
Address: The London Library, Data and Information, 14 St James’s Square, London, SW1Y 4LG
Phone: 020 7766 4700
Your rights and access to your data
You have the right to ask for a copy of the personal data we hold about you. This is called a ‘Subject Access Request’. We may in some cases charge an administration fee depending on the volume of work involved. You can also request to have the personal data we hold about you erased, to object to our use of your personal data, or to restrict the ways we use your personal data. To make any of these requests please see the further details below and then use the contact details above.
You also have the right to update or correct the personal information we hold about you and where you have provided consent for us to use your personal information you always have the right to withdraw you consent at any time.
If you would like to make a Subject Access Request to see a copy of the personal data we hold about you then you need to contact us in writing with a description of the type of information you would like to see and a valid photo id:
- Valid passport
- Valid driver’s licence or provisional drivers licence
- EU National Identity Card
We will respond to your request as soon as possible and no longer than one month unless there are exceptional circumstances.
If you wish to change, update or correct your personal information please contact us using the contact details found in the Introduction.
You have the rights to request that we erase your personal information, to object to our processing of your personal information and to restrict our processing of your personal information in any of the ways outlined in ‘Why we collect and use your information‘. There may be instances where we need to retain the data in order to process it for the purposes it was provided (e.g. processing a donation or registering you for an event) or where we are legally required to retain it, and we will explain those to you. Requests can be made using the contact details found in this policy.
You also have the right to request to see the legitimate interest balancing exercise we have undertaken to ensure your rights as an individuals are not impacted and to object to the outcome of that exercise. For more information on legitimate interest within GDPR and The London’s Library’s use of it please see Why we collect and use your information or alternatively visit the Information Commission’s Office website (www.ico.org.uk).
What information we collect and when we collect it
Your personal data is provided to us and collected in a number ways.
In most cases we store and use the personal data you give us when you decide to interact with us. This could include joining as a member of the Library, purchasing temporary tickets to use the Library, attending an event, signing up to our e-newsletter or making a donation.
In a small number of cases further personal information may also be gathered from public sources. And there may also be instances where personal data is provided by a third party, this will mainly occur when a gift membership is purchased or a book adopted for you by someone else.
If you join or renew as a member of The London Library you will be required to provide us with the following information:
- Telephone number(s)
- Email address(es)
We will also ask you to provide us with:
- Occupation at time of joining
- Date of birth
- Any orders or degrees you might have
- Name of spouse/partner (if Library member)
- What prompted you to join the Library
- Which part(s) of the collection interests you most
- A photograph
Some of this information you will also be asked to provide if you:
- Book tickets to any of our events including public tours
- Purchase a temporary ticket for the Library
- Sign up to receive The London Library e-newsletter
- Complete a survey
- Donate books to the Library
- Additional addresses and contact details
- Family or spouse/partner details and relationships to other members, visitors and/or donors
- Information about your use of the Library’s collections, services and facilities
- Events that you attend
- Current interests and activities
- Details of correspondence sent to you or received from you
- Your use of the Library including visits, online access and borrowing records
- Financial information related to your transactions with the Library, including payment method which could include your credit or debit card details, or a Direct Debit or Standing Order instruction
If you donate to the Library, respond to a fundraising campaign, or join or renew as a Founders’ Circle member you may provide further information including:
- Additional employment information
- Tax status for Gift Aid purposes
Visual information, in addition to your membership photograph, is also collected through CCTV footage in the Library in accordance with the CCTV Code of Practice and photographs taken during special events and other occasions. In any instances where photographs are being taken members and visitors will be notified of this in pre-event communications or posters.
Personal information may also be gathered from public sources such as Companies House and published in articles online or printed. For more information about what we may collect from public sources see the ‘Why we collect and use your information’ section below.
Finally information may be provided about you from third parties, for example a gift membership purchased or a book adopted for you by someone else. On occasion you may also be part of a mailing list that the Library has rented or purchased from a provider - in these cases you will have consented with the list provider to your details being shared with The London Library.
In all instances we will store and use your personal information only for as long as it is relevant and accurate for its intended purposes.
Why we collect and use your information
The main reasons for retaining, collecting and using your personal data are to fulfil your membership of the Library or any service or product you have requested or purchased. We want to ensure that we offer you a personalised experience, and inform you of events or updates you have asked to hear about or any additional information you need to know. We also use your personal information to understand our members, donors, visitors, prospective donors and customers - including their needs of the Library and interest in the Library.
We only retain, collect and use your personal data when a legal basis has been identified for doing so, in accordance with Data Protection Law. For most cases there are four reasons for such retention and processing that are relevant to The London Library; this is consent, compliance with legal obligation, legitimate interest or for contractual necessity.
In many cases we retain and use your personal data to provide a service, carry out a contract with you or for administrative purposes:
- To administer your membership(s), and/or Founders’ Circle membership, which may be by letter, email, phone or in person
- To send you information including Library news, details of your membership, the Library magazine and e-newsletter, special offers from our handpicked partners who have an affinity with the Library and its mission
- To invite you to events that are part of the service we provide you
- Provide a bespoke and personalised service to you where you have joined as a member or supporter of the Library
- To communicate with you about events for which you have purchased tickets
- To fulfil temporary ticket purchases
- To administer our book lending, reservation, recall and payment process
- To record your borrowing history for your use
- To administer any donations, bequests or legacy pledges you make
- To give you information, support, services, or products you ask for and are provided as part of your membership or philanthropic support
If you are not a member then we will use your personal information when you have given your consent by ticking a box on an appropriate form. This includes:
- When you sign up to receive The London Library e-newsletter
- When you sign up to hear about our events or news
- When you complete one of our Keep In Touch cards
There are also occasions where we have a need to collect, store and use your personal data for compliance with our legal obligations or where we have a legitimate interest. These may include:
- For financial processes including
- Claiming Gift Aid on your donations where we have valid declarations
- Collecting Direct Debit payments
- Processing Standing Order payments
- For internal administrative purposes and to let you know about changes to our services or policies
- To research and statistically analyse how members use the Library
- To learn about your interests and preferences so that we can ensure the marketing communications you receive from us are relevant, such as tailoring messages for particular interests of which you have notified us
- To send you targeted promotional, direct marketing or fundraising information that are most relevant to you. These types of communications may include:
- Library news
- To determine your interests and potential to support the Library (financially or otherwise) so that we can contact you in the most appropriate way and with the most relevant information. To help with this we may also use publicly available information such as listed directorships, geographical information, published works of reference and public website profiles. Please see more information below
- To keep a permanent record of Library membership and borrowing records
- Data screening and data cleaning to ensure we have accurate details for you
- Wealth screening and research, to help us understand our members, donors and potential donors
- To ask you take part in surveys related to the Library
The Library has always relied on membership fees and philanthropic support to grow our collection and play a central role in the intellectual and cultural life of the nation. For this to continue we will, for a small number of our members and customers, combine the information you provide with publically available information and from business or network contacts. This is done in order to understand people’s engagement in the Library and ensures that we find and connect with those who have the interest and potential to support it.
We will collect, store and use personal information where necessary in our legitimate interest as a charitable organisation, which might include:
- Conducting research in order to better understand who our members and donors are, who may choose to join and support us, and better target our communications and fundraising activity
- Monitoring who we deal with to protect our charity against fraud, money laundering and other risks
- Maintaining and administering our donor data base
- Assessing the likelihood of future donations
- Briefing senior staff and trustees so that when they meet you they can tell you about areas of our work and our future plans that are most exciting and interesting to you
- Improving our communication and fundraising content, methods, and services
- Better understanding your interest and preferences
- Use of publically sourced images to help identify individuals who attend our special events
This enables us to fulfil our legitimate interest of knowing our members, visitors, donors and potential donors; maximising the impact of our charitable resources and avoiding distress through making inappropriate approaches; while being mindful of your interests and privacy rights. In doing so we can raise more funds in a more cost-effective way. In all instances we will balance our legitimate interests as a charity against your rights as an individual, for more information please see the Your Rights section of this policy.
Information we might collect includes:
- Wealth and assets
- Family (this does not include information about children unless given to us personally or made explicitly public by the individual concerned)
- Residential location
- Hobbies and interest
- Level and frequency of gifts to The London Library and other organisations (including political parties where they are made explicitly public by the individual concerned)
Sources we might use include:
- Companies House
- Charity Commission and Scottish Charity Regulator
- Employment information you have made public
- Other charitable organisations where you have made your philanthropic support public
- News articles and publications
- Your current or previous company website
- Bloomberg and similar websites
We may on occasion use a third party supplier to undertake these activities or analyse our data. These suppliers will be subject to contractual agreements in compliance with Data Protection regulations which includes not retaining your data after completing the activity. We will always give you the opportunity to choose not to hear from us about fundraising, other Library activities or to decline further engagement with The London Library.
We may, in limited cases, use publically available data sources to identify individuals who we consider may be interested in discovering more about the Library. In making initial contact to introduce ourselves and find out if you are interested in learning more, we would provide an early opportunity to opt-out of further communication.
In all instances we will only store and use your personal information for as long as it is relevant and accurate for its intended purposes.
We believe it is important and within our legitimate interests to understand the Library's historical and future function as a library, its literary and cultural footprint and its impact over time.
To do this we will retain some limited information permanently as part of The London Library’s institutional archive for future research and understanding of the Library. Once personal data is considered to be part of the institutional archive then it will not be used in any way that supports direct marketing activity or processing relating to particular individuals. Information we may archive for research purposes includes:
- Who was in Library membership, how long they were a member and their occupation on joining
- A member’s nominee
- Donations to the Library including book donations, financial gifts and legacies
- Voluntary roles members may occupy in the governance of the Library
- Voluntary or paid roles members may occupy in supporting Library events, external activities and communications such as talks, magazine articles, festivals, lectures, discussions, literary prizes or awards and any resulting output from the event whether filmed, taped or text.
- A record of joint or collaborative work with members and non-members or non-member organisations and any correspondence or communication which illuminates the evolution and activities of the partnership.
- Correspondence or communication which discusses the value, use, strengths or weaknesses of the Library's collections
- Book loans and borrowing records
- Members' Suggestion Books and Visitor Books
How we keep your information safe?
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we store.
When we share any personal data we ensure that security is maintained through encryption. For more information on who we share your information with please see the ‘Who we share your information with’ section below.
Credit card payments are handled by our payment partner Secure Trading.
Organisations and suppliers based inside the European Economic Area (EEA) will be subject to the same data protection laws as companies based in the UK. In some cases, we will engage with organisations and suppliers outside the EEA included the United States, for example cloud-based systems, and if any of the computer servers used to host the website are outside of the EEA area. In these situations we will take steps to make sure that these suppliers provide an adequate level of protection in accordance with UK data protection law. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.
Who we share your information with?
We only share personal data that is relevant and proportionate for the practical delivery of a service for the Library (such as mailing the magazine). Our partners are subject to contractual agreements which to help ensure compliance with Data Protection legislation – this includes agreement that the third party supplier will not retain your data after the activity is completed.
The London Library will never sell, rent, share or trade your personal data to third parties for marketing purposes without your prior consent. On some rare occasions we may want to share your data with carefully selected partner organisations who have worked with The London Library, in these instances we will always ask for your permission.
We may share your details in a legally compliant way in the following circumstances:
- To send you a copy of our printed London Library magazine
- To canvas your opinion through surveys, in person or online, on matters relating to The London Library
- To send you communications using a bulk email distributor like Pure360, these might include:
- The London Library news and events
- Event invitations
- Direct mail relating to our fundraising appeals
- To meet regulatory requirements
- For a small number of our contacts and customers, to undertake screening and research activity
- Where you have consented to us sharing specific information with carefully selected and likeminded organisations
The London Library may share your information with our US based International Friends of The London Library (IFLL). IFLL have signed a legally binding contract to use, protect and store your data in a way that is legally compliant with UK and European data regulation.
In all cases where we share your personal data it will be encrypted to ensure security.
If you wish to raise a concern about the Library’s handling of your data you should first contact Peter Hyde at the Library. If you are unhappy with the response you receive from the Library, you can contact the Information Commissioner’s Office (ICO) at www.ico.org.uk or contact their helpline on 0303 123 1113. If you would like more information about the Data Protection Bill (EU General Data Protection Regulation) and the lawful basis for processing your data please see the ICO’s Guide to GDPR.