1. Who we are.

The aim of JHASW, also known as Jewish History Association of South Wales, is to collect, preserve, and make publicly available the tangible and intangible cultural heritage of the Jewish communities of south Wales, including (but not limited to) historical records, artefacts, and oral histories.

Our supporters, contributors, volunteers, and employees are important to us, and we are committed to keeping your data safe, making clear what information we collect from you, and how we use it.

This notice sets out how we use and protect your data. The processing of personal data is governed by the UK General Data Protection Regulation (UK GDPR).

JHASW is a Registered Charity in England and Wales, Charity Registration Number: 1178852.

JHASW is the data controller. This means it decides how your personal data is processed and for what purposes.

To exercise all relevant rights, submit a query, or lodge a complaint, please in the first instance contact Klavdija Erzen, the JHASW Project Manager, at klavdija.erzen@jhasw.org.uk, postal address c/o Cardiff Reform Synagogue, Moira Terrace, Cardiff, CF24 0EJ.

2. What data we collect and how we use it.

The type and quantity of data we collect and use depends on why you have provided it.

We will only collect, store, and use your personal data:

• Where this is necessary to fulfil legal obligations that apply to us.
• Where it is necessary for our legitimate interests relating to running our daily operations, as long as, in each case, these interests are in line with applicable law and your legal rights and freedoms.
• Where you have consented to this for specified, explicit and legitimate purposes.

2.1. Supporters.

If you support us, for example by signing up to an event, making a financial contribution, signing up to Gift Aid, and/or signing up to receive JHASW updates and news, we will usually collect your name, contact details, whether you would like to be contacted, and how we would do so. If appropriate, we may also ask to collect your date of birth, financial details, Gift Aid eligibility, and reasons for support.

We collect this data so that we can keep you up to date with information you have requested or may be interested in; to ask for more support; to run our events; to fulfil our legal responsibilities for financial and Gift Aid reporting.

2.2. Volunteers

If you volunteer with us or enquire about our volunteering opportunities, we will usually collect the following data: your name; date of birth; contact details; bank details; employment status; Welsh language knowledge; past volunteering experience; criminal convictions; emergency contact details; disability (including physical and mental conditions); what voluntary position you are interested in; what skills and experience, relevant to the volunteering role, you have, and what skills/experience you wish to gain by volunteering with JHASW. At the beginning of your participation in the project we will ask you what you already know about the Jewish heritage in south Wales, and at the end what you have learnt about the heritage, what difference this makes to you and your life, how you will utilise the knowledge you have gained, and the personal benefits of volunteering. We will also collect your university and course details, and a student number if you are a student.

We collect this data so that we can contact you about volunteering opportunities that come up; ensure the safety of our volunteers, staff, and members of the public; refund your expenses; evaluate our work; anonymously measure our inclusion and accessibility across our volunteering programmes.

We also collect Equal Opportunities monitoring data, but this is anonymous.

2.3. Paid staff.

If you apply for a paid position with us, we will usually collect the following data: your name; date of birth; contact details; educational history; work history; employment status; Welsh language knowledge; criminal convictions; disability (including physical and mental conditions).

We also collect Equal Opportunities monitoring data, but this is anonymous.

If you work with us in a paid position, we will collect, in addition to the above data, your bank details and emergency contact details.

We collect this data to select the most suitable candidate for a particular job position; pay your salary and refund your expenses; fulfil our financial responsibilities towards DWP and HMRC; ensure your safety; ensure the safety of people we engage with (volunteers and members of the public); evaluate our work; anonymously measure our inclusion and accessibility.

2.4. Oral history interviewees.

We are recording life stories and experiences from members of the Jewish communities in south Wales to preserve them for future generations.

We may complete or ask you to complete a pre-interview questionnaire, which will help us structure and correctly transcribe or summarise your oral history interview. The questionnaire will be deposited with the National Screen and Sound Archive of Wales (NSSAW) as part of your oral history contribution. It will not be passed to any other third party without your permission.

We will record the details of your story and your contact details, which we will use as proof of your ownership and consent when we deposit your oral history with NSSAW. With your permission, we will also use your oral history for specific purposes (publication on the People’s Collection Wales or our website; use in exhibitions, reference, research, publications, and for educational purposes).

We will ask you to sign an Oral History Permission Form (including permission for a pre-interview questionnaire and a recorded interview) and an Oral History Recording Agreement (to sign-off the terms under which your interview will be stored, preserved, and used).

2.5. Tangible material contributors.

We are collecting tangible historical material (historical records and artefacts) from the members of the Jewish communities in south Wales.

We will record your contact details, which we will use as proof of your ownership and agreement when we deposit the material with archives and museums. With your permission, we will also use the material you are contributing for specific purposes (publication on the People’s Collection Wales or our website; use in exhibitions, reference, research, publications, and for educational purposes).

We will ask you to sign a separate Permission Form to collect personal data and a Copyright Permission Form.

2.6. Photographs.

Our supporters and volunteers kindly let us use photographs and images of them in our newsletters and for marketing purpose.

We keep these images stored in a secure location and will only use them with the subject’s permission.

2.7. Suppression List.

Should you not wish JHASW to contact you in the future, we will retain your contact details on file. This will enable us to ensure that we comply with your wishes.

We will hold this data indefinitely. Should you wish to engage with JHASW again then please get in touch with the JHASW Project Manager: klavdija.erzen@jhasw.org.uk.

3. Sharing your data.

We will never share your data with other organisations, except in the following circumstances:

3.1. When you contribute an oral history.

We share your details, provided in an Oral History Permission Form and an Oral History Recording Agreement, as a proof of your ownership and consent, with National Screen and Sound Archive of Wales (NSSAW) with whom we archive your oral history for permanent preservation and public access.

We may also use recordings for other purposes, but only when given explicit consent for each use. In each case, you will be asked if you agree, by signing an Oral History Recording Agreement. You will also be given the option to request that you remain anonymous.

These other purposes are:

• Publication on the People’s Collection Wales or our website.
• Use in exhibitions, reference, research, publications.
• Use for educational purposes including lectures and presentations.

We will not publish oral histories (audio files and/or summaries) on any other website or digital platform without your permission.

3.2. When you contribute tangible material (e.g. historical records and artefacts).

We share your details with National Screen and Sound Archive of Wales (NSSAW) and/or the local museums and archives in south Wales with whom the tangible material you contribute is deposited for permanent preservation and public access.

We are digitising the material we receive and may use the digital copies for other purposes, but only when given explicit consent for each use. In each case, you will be asked if you agree, by signing Copyright Permission. You will also be given the option to request that you remain anonymous.

These other purposes are:

• Publication on the People’s Collection Wales website.
• Publication on JHASW website and social media.
• Use in exhibitions, reference, research, publications.
• Use for educational purposes including lectures and presentations.

4. Keeping your data safe and up to date.

JHASW complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. Access to your data is regularly reviewed and only accessible to the relevant staff and volunteers.

Data required for archiving purposes can be kept indefinitely and there is no requirement to keep archiving data up to date. If you have kindly donated to us, we are required to keep this data for seven years. We will keep other data until it is no longer required, and then delete it or dispose of it securely.

5. How we use your personal data.

5.1. We use your personal data for the following purposes:

1. Legal purposes, for example as evidence of your ownership and consent, when depositing your oral history and/or tangible historical material with National Screen and Sound Archive of Wales (NSSAW) and/or the local museums and archives in south Wales, or publishing the digitised material on the People’s Collection Wales website.
2. Administrative purposes, for example, to manage our employees and volunteers, maintain our accounts and records, administer our supporters’ records, and process Gift Aid applications.
3. Exhibitions, reference, research, and publication, for example, we use data collected through a Pre-interview Questionnaire to research and prepare for an oral history interview.
4. Educational purposes including lectures and presentations.
5. Collection management purposes, for example, to catalogue your oral history and/or tangible material contributions.
6. Fundraising and promotion, for example, to inform you, by email or post, about news, events, and activities run by JHASW.

5.2. The legal basis for our use of your personal data.

The legal bases for processing personal data are set out in Article 6 of the GDPR. The legal bases for our use of your personal data will be:

1. Legal obligation where the processing is necessary for us to comply with the law (not including contractual obligations), for example, processing Gift Aid.
2. Legitimate interests where the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. This applies for example to information collected to manage oral histories or tangible material.
3. Consent where the individual has given clear consent for us to process their personal data for a specific purpose, for example, newsletter distribution lists.

In addition, Article 9 of the GDPR applies to processing special categories of personal data, for example, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and data concerning health.

Because of the nature of our collection, all our oral histories, and most of our other material, will contain special category data. Article 9, paragraph 2 (j) states that we may process the special data categories where processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes. For the processing of special category data for archival purposes, we rely on Section 4(a) of Schedule 1 of the Data Protection Act 2018 – "necessary for archiving purposes…in the public interest".

6. Your rights and your personal data.

We will only collect the data that we need to carry out the purposes listed in this document. Unless subject to an exemption under the GDPR, you have the following rights regarding your personal data:

1. The right to request a copy of your personal data which JHASW holds about you. Individuals cannot be granted access to or be given a copy of data about themselves where doing so would unreasonably disclose the personal data of another person, for example, if it is contained in someone else’s interview which remains confidential and closed to public access.
2. The right to request that JHASW corrects any personal data if it is found to be inaccurate or out of date (data collected for archiving purposes does not have to be kept up to date).
3. The right to request your personal data be erased where it is no longer necessary for JHASW to retain such data. The right is not absolute and only applies in certain circumstances.

Where consent is the legal basis for processing, you have the right to withdraw your consent and have your personal data erased at any time.

The right to erasure does not apply if the processing is necessary for "archiving purposes in the public interest" and "scientific research and historical research" where erasure is likely to render impossible or seriously impair the achievement of that processing (Article 89 of GDPR).

So, requests to amend or delete archived oral history interviews and/or written life stories can be declined. Thus, the so-called ‘right to be forgotten’ (‘erasure’) does not in practice apply to oral history material and written reminiscences.

4. The right, where there is a dispute about the accuracy or processing of your personal data, to request that a restriction is placed on further processing.
5. The right to make a complaint with the Information Commissioners Office, if you are unhappy with the way that we handled your personal data.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

7. Interactive Trails

Our Heritage trails website collects information such as your location from your device. This is used to show your distance from each of the trails. We do not store this information and is used to process distances from trails only.

Data Privacy Notice_v.4_January 2021