UKHMF Testimony: participants privacy notice
Privacy notice for participants of UK Holocaust Memorial Foundation (UKHMF) Testimony.
The following is to explain your rights regarding our use of your personal data and to give you the information you are entitled to under UK data protection legislation.
1. The identity and contact details of the Department for Levelling Up, Housing and Communities (DLUHC) and our Data Protection Officer
DLUHC is the Data Controller (the organisation responsible for processing your data). The Data Protection Officer can be contacted at [email protected]
2. What personal data we are collecting and why
If you participated in the UKHMF Testimonies project run between 2015 and 2016, which recorded your personal experiences of the Holocaust, we collected the following personal data about you:
- Your name
- Your home address -Personal data required to verify your identify (e.g. passport)
- Your personal experiences and opinions captured via a recorded video interview with you
- Your agreement to participate in the testimony project, including the permanent retention of your interview
We collected this personal data as part of a wider UK Holocaust Memorial Foundation (UKHMF) initiative to maintain awareness of the Holocaust in the United Kingdom and to ensure that the memory and the lessons of the Holocaust are never forgotten by future generations.
DLUHC’s specific role in using your personal data has been to collect your experiences via recorded interview, and then prepare and transfer your record to The National Archives (TNA) for use in future Holocaust-related research and educational initiatives.
3. Lawful basis for processing the data
UK data protection legislation sets out when we are lawfully allowed to process your data. The lawful basis that applies to this processing is
- UK GDPR Article 6(1)(e) – necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller
- Data Protection Act 2018 Part 2, Chapter 2, section 8(d) – the exercise of a function of the Crown, a Minister of the Crown or a government department.
The lawful basis that applies to processing of sensitive (“special category”) personal data is:
- UK GDPR Article 9(2)(j) and Article 89(1) – processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
- Data Protection Act 2018 Part 2, Chapter 2, section 8(d) – the exercise of a function of the Crown, a Minister of the Crown or a government department.
- Data Protection Act 2018 section 19 – additional safeguards for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes
4. With whom we will be sharing the data
Your personal data will be transferred by us to TNA, who are the UK public body responsible for the collection, preservation, and use of historical records.
As your personal data will be stored on our IT infrastructure until transfer to TNA, it will also be shared with our data processors who provide email, and document management and storage services. This is currently Microsoft Corporation.
Please note that, once your record has been passed to TNA, your personal data (recorded interview and associated documentation) will be further shared onwards by us with the operating body of the UK Holocaust Memorial and Learning Centre, once it has been legally established, as part of its mission to preserve the memory of the Holocaust.
5. For how long we will keep the personal data, or criteria used to determine the retention period.
We intend to have completed the transfer of your testimony interview to TNA in Autumn 2023. After we have transferred your record to TNA, we will keep your personal data for as long as necessary as part of our commitment to deliver the UK Holocaust Memorial and Learning Centre. Once legally established, all of your personal data will be transferred by us to the operating body of the UK Holocaust Memorial and Learning Centre and will be securely deleted from our IT systems.
6. Your rights, e.g. access, rectification, erasure
The data we are collecting is your personal data, and you have rights that affect what happens to it. You have the right to:
a. know that we are using your personal data, and why
b. see what data we have about you
c. ask to have your data corrected, and to ask how we check the information we hold is accurate
d. complain to the ICO (see below)
In some circumstances, you may also have the right to withdraw your permission to us having or using your data, to have all data about you deleted, or to object to particularly types of use of your data. We will tell you when these rights apply.
7. Sending data overseas
We will not be sending personal data to any countries not yet judged by the UK to have equivalent data protection standards as us. Our current data processor (Microsoft) processes department information within the UK.
8. Automated decision making
We will not use your data for any automated decision making.
9. Storage, security and data management
Your personal data will be stored in a secure government IT system used by the department and will only be used by staff delivering the UK Holocaust Memorial archival project.
10. Complaints and more information
When we ask you for information, we will keep to the law, including the Data Protection Act 2018 and UK General Data Protection Regulation.
If you are unhappy with the way the Department has acted, you can make a complaint.
If you are not happy with how we are using your personal data, you should first contact [email protected].
If you are still not happy, or for independent advice about data protection, privacy and data sharing, you can contact:
The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow, Cheshire,
SK9 5AF
Telephone: 0303 123 1113 or 01625 545 745 https://ico.org.uk/