Image library Privacy Notice

The Centre for Ageing Better (AB) has created a free age positive image library (image library) showing positive and realistic images of people over 50 in a bid to challenge negative and stereotypical views of older age. The photos show realistic depictions of ageing and are help tackle ageism and challenge the idea that all older people are frail and vulnerable. The library, which contains over 3,000 images and is regularly updated, offers journalists, organisations and individuals a wide selection of images which can be used for free. 

All images are published under CC0 1.0 Universal (CC0 1.0).

Summary of the Privacy Notice 

Participation of the individuals who appear in the image library is voluntary. The collection and use of images in the image library is not undertaken on the basis of consent provided by the participating individuals. If you appear in images published in the image library, your personal data will be processed on the lawful basis of ‘legitimate interests’ and not ‘consent’. 

If your image is added to the image library, your image will be published on the internet. AB will also share your image with other image libraries, the details of these are provided in this Privacy Policy below. Images in the image library are free to use and can be used and reproduced by any individual or organisation, located anywhere in the world. 

Your personal information will be shared with AB’s suppliers who provide services that support the operation of the image library. 

Who is this information for? 

This privacy notice relates to the way in which AB handles personal information relating to the image library. This privacy notice is for individuals whose image appears in the image library. 

Participation of individuals who appear in the image library is entirely voluntary, individuals have no obligation to allow their images to be used in the image library. 

This version of the Privacy Notice was published in November 2023 and applies to the collection and use of personal information by AB from November 2023. It aligns with the requirements of the Data Protection Act 2018 (DPA) and the General Data Protection Regulation as enacted in the United Kingdom (UK GDPR).  

Who are we? 

For the purposes of the UK GDPR and DPA, the controller of your personal information is the Centre for Ageing better (AB, the Charity) [a registered charity in England and Wales (registered charity number: 1160741) a registered company in England and Wales (company number:8838490)]. The Charity’s contact details are as follows:  

• Address: 15 Alfred Place, London, WC1E 7EB  

• Telephone number: 020 3829 0113   

• Email: [email protected]  

  The Data Protection Lead for the Charity is Director of HR and Operations, who may be contacted via the above phone number and email address.  

How we obtain your personal information 

We may collect your personal information in the following ways: 

• Information that you give us directly: for example, you may provide us with your personal information when your photograph is taken, or if you contact us; and 

• Information shared by other third parties: we may receive information about you from other third parties who share your image and other personal information with us. Other third parties who may share your personal information with us include, and photographers who are contracted by AB to provide images to the image library. 

Types of personal information we process 

We collect and use this personal data for the purposes described in the section ‘How we use your personal information’ below. The personal information we collect about you includes: 

• Information about individuals in the form of still images; 

• The location of where the image was captured; 

• The time and date at which the image was captured; 

• Your bank account details if you request payment 

• Your name and contact information, including email address ; 

• Correspondence between us, for example, if you email or write to us; and 

• Records of requests relating to your data subject rights.  

Only the personal information contained in the images themselves is published online in the image library. Personal information such as name, location, emails, times and dates are not published in the image library. 

Certain categories of personal information are regarded by data protection law as more sensitive than others. Known as ‘special category personal data’, this relates to information about your health, racial or ethnic origin, details of sexual life, sexual orientation, religious beliefs, political opinions or any genetic or biometric data that is used to identify you. This information, and any information about criminal offences or convictions, warrants a higher level of protection under data protection law.  

The processing of personal information in the image library does not include any processing via technical means which allows identification or evaluation of any personal characteristics of the individuals shown in the image library. As such, in accordance with Recital 51 GDPR, AB considers that special category personal data is not being processed for the purposes of the image library.  

How we use your personal information 

We will use your information in order to perform the functions necessary to make available and maintain the image library and to improve our products and services. We will use your personal information for purposes such as: 

• To administer the collection of images from the sources described in the section ‘How we obtain your personal information’ above; 

• To edit and alter images, for example to remove unnecessary information like street names, or car registration information; 

• To make payment to you if you have requested that 

• To administer and maintain the image library and its functionality; 

• To communicate with you about changes to our Terms, or Policies; 

• To respond to queries, and requests, including requests relating to data subject rights (for more information see the section ‘Your rights’); and requests for payment. 

• Meet our research and product development needs and to improve our services; 

• Meet our lawful obligations. 

• To periodically contact you in the event of opportunities or issues about the age-positive image library’ 

Personal information collected in connection with the image library will not be used for marketing purposes. We do not use your personal information in automated decision-making, including profiling (i.e. we do not make decisions about you by way of automated means without human involvement). We do not rent, sell or share your personal information in any other way than that described in this privacy notice. 

Our legal basis for processing your information 

Data protection law requires us to have a lawful basis for processing your personal information. Depending on the purposes for which we use your data, we may rely on one or more of the following lawful bases: 

• Legitimate interests: Processing for the purposes of crating and maintaining the image library will be process on the basis of “legitimate interests” pursued by AB and other third parties (as long as those legitimate interests are not overridden by your rights and freedoms). Examples of the interests relied upon for such processing include: 

• It is in the wider public interest to promote realistic images of ageing and increase the visibility of older people.  

• It is in the interest of AB to maintain such a library in accordance with its charitable aims 

• One of the intended outcomes of the image library is that older people, including those featured in the images, will benefit from increased visibility of that demographic. 

• Legal obligations: It may be necessary for us to use your information to comply with our legal obligations.  

Participation of the individuals who appear in the image library is voluntary. For the avoidance of doubt, processing is not undertaken on the basis of consent provided by the participating individuals. If you appear in images published in the image library, your personal data will be processed on the basis of legitimate interests and not consent. 

How we keep your personal information safe 

We understand the importance of security of your personal information and take appropriate steps to safeguard it. 

Your personal information when held on the Charity’s website is fully protected and encrypted. AB undertakes due diligence on all IT service providers, including website hosting, to ensure appropriate security measures are in place. 

We always ensure that only authorised persons have access to your personal information, which means only those members of our staff who need to access your data to fulfil their roles. Everyone who has access to personal information is appropriately trained and aware of their obligations to ensure confidentiality and security of your data. We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.  

Please note, we interact via the internet and email, and no external data transmission over the internet can be guaranteed to be 100% secure. So, while the Charity strives to safeguard your personal information, we cannot guarantee the security of any information you provide online and you do this at your own risk. 

Who we share your personal information with 

Images contained in the image library are published on the internet and as such can be viewed and accessed from anywhere in the world. Once published in the image library, AB cannot control or offer any guarantees as to how and where images will be used. Once images are removed by AB from the image library, the images may persist including elsewhere online or on local device storage. 

AB shares images with other image libraries. Only images are shared with image libraries, no other categories of personal information are shared. Other image libraries that your image may be shared with include: 

• Pexels. Privacy information can be found here https://www.pexels.com/privacy-policy/ 

• Unsplash. Privacy information can be found here https://unsplash.com/privacy 

• Noun Project. Privacy information can be found here https://thenounproject.com/legal/privacy-policy/ 

We may disclose your personal information to the following third controllers, to enable us to provide our services, fulfil our charitable objectives or comply with our legal obligations. We may share personal information with: 

• Our legal and other professional advisors; and 

• Law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations.  

We also need to disclose your personal information to companies who provide services for us, and who process your personal information on AB’s behalf. For example: 

• Cloud storage providers and website hosts; and 

• Digital Asset Management Systems (for example, ResourceSpace) 

• Other IT service providers. 

We select all third-party service providers with care and provide them with the minimum amount of information necessary to provide their service.  We always a have an appropriate agreement in place that requires them to protect personal information to the same standard as we do. 

Transfers of your personal information to other countries 

We may transfer your information to countries or territories outside the UK, which are subject to different data protection laws. We may do this where for example, we use suppliers in a third country or data is stored on servers or devices located outside the UK.  

We meet the UK GDPR requirements by ensuring that personal information is protected as if it were being held in the UK. The lawful safeguards that we may use include: 

• the personal information is protected because the country to which we transfer data to either benefits from an adequacy determination; and 

• the International Data Transfer Agreement (IDTA) or the IDTA Addendum, which are legally-approved standard data protection clauses for transfers from a controller to a processor recognised or issued further to Article 46(2) of the UK GDPR. 

Processor	Function	Country or countries where personal information is stored	Is the country subject to an adequacy decision?
Microsoft	Software and cloud storage provider	UK   EEA	Yes
Acquia	Website hosting provider	Ireland  (Images may be served from servers located in other countries depending on the location of the user)	Yes
Cloudflare	Web security provider	US, UK and EEA	Yes
WeTransfer	Data transfer system	EU (if user is in the EU)
AWS	Hosting Provider	Ireland	Yes
ResourceSpace	Image Library Storage	England	Yes

To obtain more information about the appropriate safeguards that are in place for personal information that is transferred outside the UK, please contact the Data Protection Lead for the Charity, who may be contacted via [email protected] 

As stated is the section ‘Who we share your personal information with‘, images contained in the image library and in other image libraries who AB share images with, are published on the internet and as such can be viewed and accessed from anywhere in the world. Once published online, AB cannot control or offer any guarantees as to how and where images will be used. Once images are removed by AB from the image library, the images may persist elsewhere online or on local device storage. 

How long we keep your personal information for 

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for us to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.  

If you would like further information about our retention periods, please contact [email protected] 

Your rights 

Data protection law provides individuals with various legal rights, which may be exercised in certain circumstances. You have the following legal rights over your personal information: 

• The right of access (commonly referred to as a “subject access request” or “SAR”): This right enables you to obtain a copy of the personal information we hold about you as well as other information about how we are processing your personal information. 

• The right to rectification: This right enables you to require us to correct the personal information we hold about you if it is inaccurate or incomplete. 

• The right to erasure (also known as the right to be forgotten): In certain circumstances, you have the right to request that personal information we hold about you is erased (such as where we no longer need your personal information for the purpose it was originally collected for). 

• The right to restrict processing of your personal information: You may ask us to restrict the use of your personal information in certain circumstances (such as where you believe your personal information is incorrect and we need to verify the accurate of the personal information we hold) 

• The right to object: You may object to our processing of your personal information where we are processing your personal information on the basis of “legitimate interests”.  

• The right to data portability: This right allows you to request that we transfer your personal information to you or another third party in a commonly used, machine-readable format. Please note, this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you. 

• The right to withdraw consent: Where we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time, and may do so by contacting us via [email protected]. If you decide to withdraw your consent, that does not mean that our use of your personal information before you withdrew your consent is against the law. 

Please note, some of your legal rights are subject to safeguards, limitations or exemptions.  

If you are an individual who appears in the images on the image library, you have the right to object to this. If you wish to object to your image appearing in the image library, or if you wish to exercise your other rights, please contact us via [email protected] and we will respond within the time limits set out in data protection law. 

Complaints 

If at any time you are not happy with how we are processing your personal information then you may raise the issue with the Data Protection Lead in the first instance. 

If you are not satisfied with the handling of your issue, you may raise a complaint with the Information Commissioner’s Office, which regulates and enforces data protection law in the UK.  

Details of how to do this can be found at https://ico.org.uk/make-a-complaint/.  

Keeping your information up to date 

We really appreciate it if you could let us know if your contact details change. You can do so by contacting us at  [email protected] . 

Changes to this Privacy Notice 

This privacy notice was published on 15 November 2023. This privacy notice may be changed from time to time. We will advertise any changes on our website or, if the changes are significant, we will contact you directly with the information.