Privacy and data protection
Website privacy policy
This policy explains how United National Photographers Ltd collects, uses, stores and protects personal data when you visit unp.co.uk, contact the UNP Picture Desk, commission a photographer or otherwise engage with our services.
1. Who controls your data
United National Photographers Ltd is the data controller for the personal data described in this policy. This means that UNP determines why and how that personal data is processed.
UNP operates a central Picture Desk and a managed network of professional photographers. Depending on the assignment, a client, commissioning organisation, venue, publisher or other party may also have separate responsibilities as a data controller.
2. Key definitions
The following terms are used throughout this policy:
- Personal data
- Information relating to an identified or identifiable living person. This may include a name, email address, telephone number, image, job title, location or other information capable of identifying someone directly or indirectly.
- Processing
- Any operation performed on personal data, including collecting, recording, organising, storing, using, sharing, editing, archiving or deleting it.
- Data controller
- The organisation that determines the purposes and means of processing personal data.
- Data processor
- An organisation that processes personal data on behalf of a data controller and under its instructions.
- Picture Desk
- UNP’s central coordination team responsible for enquiries, quotations, photographer bookings, assignment management, image delivery and client communication.
3. Personal data we collect
We aim to collect only the personal data reasonably necessary to operate the Picture Desk, provide photography services, administer assignments, communicate with clients and meet our contractual and legal obligations.
Depending on your relationship with UNP, this may include:
- your name, job title, employer or organisation;
- business and personal contact details that you choose to provide;
- the content of enquiries, correspondence, briefs and instructions;
- assignment dates, locations, access information and production details;
- names and contact details of client representatives, subjects, contributors, venue contacts and suppliers;
- quotation, purchase-order, invoicing and payment information;
- model releases, permissions, consent records and image-use instructions where applicable;
- photographs, captions, image metadata and associated assignment records;
- website usage, browser, device, referral and approximate location information collected through permitted analytics technologies;
- records of telephone calls, emails, meetings and other business communications; and
- information required to manage complaints, legal claims, insurance matters or regulatory obligations.
Please do not send special-category personal data or confidential personal information unless it is necessary for an assignment and has been agreed with the Picture Desk in advance.
4. How we collect personal data
We may collect personal data directly from you, from the organisation you represent, from an authorised agency or commissioning party, or during the planning and delivery of a photography assignment.
- Initial enquiry We receive information through telephone calls, email, website forms, referrals or direct contact with the Picture Desk.
- Quotation and booking We record the information needed to understand the brief, confirm availability, prepare a quotation and arrange the assignment.
- Assignment coordination We share relevant operational details with the selected photographer and other people who need that information to deliver the assignment.
- Photography and captioning Images and associated information may be recorded, edited, captioned, transmitted and stored in accordance with the agreed brief and intended use.
- Delivery and administration We retain records required for image delivery, account management, licensing, invoicing, taxation, dispute resolution and future reference.
5. How and why we use personal data
We process personal data only where there is an appropriate legal basis. The basis used will depend on the information, the circumstances and the reason for processing.
| Purpose | Typical lawful basis |
|---|---|
| Responding to enquiries and preparing quotations | Steps requested before entering into a contract and UNP’s legitimate business interests |
| Booking, coordinating and delivering photography assignments | Performance of a contract and legitimate interests |
| Managing photographers, suppliers, venues and assignment logistics | Performance of a contract and legitimate interests |
| Producing, captioning, delivering, licensing and administering images | Performance of a contract, legitimate interests and, where applicable, consent |
| Maintaining financial, tax and business records | Legal obligation and legitimate interests |
| Protecting legal rights, handling disputes and preventing misuse | Legitimate interests and legal obligation |
| Maintaining website security and understanding website performance | Legitimate interests and, where required, consent for non-essential technologies |
| Sending relevant business communications to existing contacts | Legitimate interests or consent, depending on the communication and recipient |
6. Photography and image subjects
Photographs of identifiable people may constitute personal data. The lawful basis and responsibilities associated with an assignment will depend on its nature, setting, commissioning organisation and intended use.
UNP photography may be commissioned for press, editorial, public-relations, corporate, event, public-sector, education, healthcare, retail or internal-communications purposes.
Clients are responsible for giving UNP accurate instructions about access, permissions, safeguarding, confidentiality and intended image use. Where releases, notices or consents are required, responsibility for arranging them should be agreed before photography begins.
Images created for legitimate journalistic, artistic or literary purposes may be subject to specific data-protection provisions and exemptions. The application of those provisions depends on the circumstances of the assignment and use.
7. Who we share personal data with
We share personal data only where reasonably necessary for the relevant purpose. Recipients may include:
- photographers, videographers, drone operators and other authorised production personnel;
- clients, commissioning organisations and their authorised agencies;
- image-delivery, cloud-storage, hosting, email, communications and information-technology providers;
- accountants, payment providers, insurers, professional advisers and debt-recovery services;
- venues, security teams, access coordinators and event organisers;
- publishers, media organisations or distribution partners where required by the agreed brief;
- regulators, courts, law-enforcement bodies or public authorities where disclosure is required or permitted by law; and
- a purchaser, successor or adviser involved in a legitimate corporate restructuring or transfer of the business.
Photographers and suppliers working through UNP receive only the information reasonably required to carry out their role. Appropriate contractual, confidentiality and data-protection arrangements are used where applicable.
UNP does not sell personal data.
8. International transfers
Some technology, storage, communications or professional-service providers may process information outside the United Kingdom.
Where personal data is transferred internationally, we take reasonable steps to ensure that an appropriate transfer mechanism and relevant safeguards are in place, as required by UK data-protection law.
10. Data retention periods
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including contractual, operational, licensing, accounting, taxation, insurance and legal requirements.
Retention periods may vary according to the nature of the record, the assignment, the intended use of the images and any continuing legal or contractual need.
| Data category | Purpose | Indicative retention |
|---|---|---|
| General enquiries that do not lead to an assignment | Responding to the enquiry and maintaining an appropriate business record | Reviewed periodically and deleted when no longer reasonably required |
| Client, supplier and assignment records | Contract administration, service history, licensing, dispute management and legitimate business reference | Normally retained for up to six years after the relevant relationship or assignment, unless a longer or shorter period is justified |
| Financial, invoicing and taxation records | Accounting, taxation and statutory record-keeping | Normally six years from the applicable record or accounting period, or longer where legally required |
| Model releases, permissions and consent records | Evidence of agreed image use, permissions and assignment administration | Retained for as long as reasonably necessary in connection with the images, licence, publication, contractual relationship or possible legal claims |
| Photographs, captions and editorial metadata | Image delivery, licensing, archive integrity, editorial record and future legitimate use | May be retained for an extended period where justified by contractual, licensing, journalistic, artistic, historical or legitimate archive purposes |
| Website analytics information | Website measurement, security and service improvement | According to the settings and retention periods of the relevant service and the choices recorded through the website |
Information that is no longer required may be securely deleted or anonymised. Backup copies may remain for a limited period until they are overwritten through normal system processes.
11. Data security
We use proportionate technical and organisational measures intended to protect personal data against unauthorised access, accidental loss, misuse, alteration or disclosure.
These measures may include:
- controlled access to business systems and assignment information;
- password protection and account-security measures;
- secure website connections and reputable hosting services;
- restricted sharing of briefs and personal information;
- contractual and confidentiality requirements for relevant suppliers; and
- review of access when personnel, systems or operational requirements change.
No internet transmission or storage system can be guaranteed to be completely secure. We nevertheless take reasonable steps appropriate to the nature of the information and the risks involved.
12. Your data protection rights
Depending on the circumstances and the applicable lawful basis, you may have the right to:
- request access to personal data held about you;
- ask us to correct inaccurate or incomplete information;
- request erasure of personal data in certain circumstances;
- request restriction of processing in certain circumstances;
- object to processing based on legitimate interests or to processing for direct marketing;
- receive certain personal data in a portable format where the right applies;
- withdraw consent where processing is based on consent, without affecting earlier lawful processing; and
- raise a concern with the Information Commissioner’s Office.
Data-protection rights are not absolute and may be subject to legal conditions, exemptions and the rights of other people.
We may need to request information to confirm your identity and understand the scope of your request. We will respond without undue delay and normally within one calendar month, subject to any extension or other provision permitted by law.
You will not normally be charged for exercising a data-protection right. A reasonable fee may be permitted in limited circumstances, such as where a request is manifestly unfounded or excessive.
13. Complaints
Please contact UNP first if you have a concern about how we have handled your personal data. We will review the matter and try to resolve it promptly.
You also have the right to complain to the UK supervisory authority:
Information Commissioner’s OfficeWycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Further information is available from the Information Commissioner’s Office .
14. Contact UNP about personal data
Contact us if you have a question about this policy, wish to exercise a data-protection right or have a concern about how your information has been handled.
Data Protection Enquiries
United National Photographers Ltd
Email privacy@unp.co.uk
Telephone 0845 600 7737
Please provide enough information for us to identify the relevant records and understand your request. Do not send unnecessary identity documents or sensitive personal information unless we specifically ask for them through an appropriate method.
Changes to this policy
We may update this policy when our services, systems, suppliers or legal obligations change. The current version will be published on this page with its effective and review dates.