How we use your information
This privacy notice tells you who we are and what to expect when the National Gallery of Ireland (the Gallery) collects your personal information. When you use our services, you trust us with your information and we want to assure you that we take your rights seriously.
This notice applies to information we collect about:
- Visitors to our digital channels
- Devices detected by our free Wi-Fi service
- Visitors to the Gallery and anyone else who uses and supports our services
- Job and volunteering applicants
It also provides information on:
- How we use your personal information
- Your rights to access and correct the information we hold about you
- How to contact us for queries or complaints about our use of your personal information, and to unsubscribe from marketing communications.
Who we are
The Gallery’s mission is to care for, interpret, develop and showcase art in a way that makes us an exciting place to visit. We aim to provide an outstanding experience that inspires an interest in and an appreciation of art for all and are dedicated to bringing people and their art together. The Gallery’s parent department is the Department of Culture, Heritage and the Gaeltacht. The Gallery is also a registered charity (CHY No. 2345).
Friends of the National Gallery of Ireland (Friends) is a self-funding cultural organisation with charitable status (Registered Charity Number: 20158958) committed to promoting the Gallery and its collection. Its purpose is to support the work of the Gallery and expand awareness and appreciation of the visual arts. Through a range of educational events, the Friends encourage interest in the Gallery, art and architecture, both in Ireland and abroad. Friends is also subject to the Gallery’s policies and procedures, including this notice.
The Gallery and/or Friends are the data controller(s) of your personal information.
Throughout this notice:
“the Gallery” and “we” refer to the Gallery and Friends; and
“Website” refers to the following websites operated by the Gallery:
When you visit the Website, we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the Website, to compile statistical reports on website activity and to personalise and improve our visitors’ experiences of using the site. We use Google Analytics to help us analyse such data but do not share any personally identifiable information with it.
We use ShopperTrak to monitor footfall at the two Gallery entrances; in the Print Gallery; Rooms 6 – 10; in the Café, and in the Gallery Shop. Visitors’ movements are tracked by counters which “tag” their electronic devices in order to find out the average dwell time spent in temporary exhibitions. No personally identifiable data is collected by ShopperTrak during this process, as it uses the MAC address of the electronic device, and each MAC is irreversibly anonymised.
Identifying dwell time assists us in informing us how entry times for ticketed events are spaced and helps us to ensure room capacity restrictions, as set out in loan contracts for works of art and as required in order to meet our health & safety legislative obligations and our duty to protect works of art with appropriate environmental controls, are met. We are also required to regularly report on visitor numbers and footfall monitoring assists with this. Anyone wishing to opt out from ShopperTrak should follow these precise steps:
• Email the request to [email protected]
• Ensure the subject line only comprises the 17 characters that make up the MAC address of the device to be opted out (e.g 00:1a:2b:3c:12:34)
• Do not include any other information about themselves in the subject or main body of the email
• An automated reply will acknowledge receipt
• Within 24 hours of receipt that device will then be excluded from any ShopperTrak installation globally and no data will be stored from then on.
When you visit the Website, we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the Website, to compile statistical reports on website activity and to personalise and improve our visitors’ experiences of using the site. We use Google Analytics to help us analyse such data and Shoppertrak to monitor footfall throughout the Gallery, but do not share any personally identifiable information with them.
If we do want to collect personally identifiable information via the Website or other digital channels, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
We reserve the right to disclose personal information provided by you to us where required or otherwise permitted by law, to operate our systems properly and to protect us and/or other users of the Website.
This notice does not cover links to external websites on the Website or use of our social media channels. We encourage you to read the privacy notices of those websites and social media providers. We are not responsible for the content or privacy practices of other websites.
Devices detected by our free Wi-Fi service
Free Wi-Fi access is available throughout the Gallery via our free Wi-Fi network. If you access this network, you will be asked to provide your email address and agree to terms and conditions of use of the Wi-Fi.
Your data is processed as follows:
- anonymous data detailing the individual wireless devices carried within the Gallery are detected and retained for 24 hours. The details stored are MAC address, wireless access point location, time and date. This anonymous data alone cannot be used to identify you.
- This anonymous data is used to generate a daily internal report monitoring general visitor flows throughout the Gallery, informing us about visitor interaction with the physical environment.
- If you successfully connect to and use the public Wi-Fi Internet service, you will be required to give your email address and accept the Wi-Fi terms and conditions of use. We are obliged to retain your email address and individual wireless device details for compliance reasons and our practice is to retain and securely store these for 24 hours before deleting them.
- If you do not use the free Wi-Fi network, but you have Wi-Fi enabled on your smartphone, tablet or another internet-enabled device, your device can still be detected by the network. We record data about the location and type of devices in the Gallery that have Wi-Fi enabled so that we can monitor the flow of visitors around the Gallery and to improve our services.
We will not link the anonymous device data with any other personal data that identifies you individually without your express permission. If in future we want to process your data in this way to offer you additional services, before doing so we will always ask you if you agree to take part.
People who use and support our services and why we collect data
The main purposes for which we collect and process the details of customers, visitors, Friends, service users, enquirers, donors and potential donors are:
- to provide the service, goods or information that they have requested
- for administration purposes e.g. ticketing, donations or fulfilling orders from our Shop and Images websites
- to fulfil our tasks, in the public interest, of:
- loaning, exhibiting, securing and protecting the National Collection
- acquiring works of art
- receiving donations and subscriptions and undertaking fundraising (to further our charitable aims)
- increasing and diffusing knowledge of the visual arts, including via our education programmes and our Library & Archives
- securing the proper care and preservation of works of art
- to comply with law
- to gather feedback.
We may also hold and analyse your data in order to continue to improve our understanding of our target audiences and of our supporters. This is with a view to providing world class, transformative, visitor-focused experiences, customer service and educational engagement, and to look at ways in which we might in the future use the latest technologies to improve and personalise the services that we offer. As part of this, we may analyse personal information collected from you, and occasionally from third parties, to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information. Occasionally your information will be used to improve ads targeting on Facebook, Instagram and Twitter. Your information is never visible to these third parties and will not be used to support repetitive or 'spammy' advertising. It simply helps us ensure that we are reaching those mostly likely to be interested in the Gallery and saves valuable advertising budget. Apart from this activity, personally identifiable data held by us will not be used by us for automated decision-making or profiling.
We may contact you from time to time by post, email, phone and/or SMS with news and information about the Gallery that we feel may be of interest to you, such as research, education and fundraising, and about our other events, activities, products and services. We will not use your personal information for such marketing purposes if you have indicated that you do not wish to be so contacted and we will only contact you in accordance with the preferences that you have indicated to us.
When you subscribe to our services or give consent to receiving news and information from us, you can cancel your subscription, withdraw your consent to being contacted, change your preferences or change your preferred method of contact at any time by clicking here. Subscribing for email newsletters and other marketing communications is optional. You do not need to subscribe to marketing from us when you buy products, book tickets, donate or use any of our other services. We will not share your personal data with anyone else for marketing purposes.
If you are gifted a Friends membership, the person giving you that gift has provided your contact details to us for the purpose of servicing your membership.
If you choose to send us personal details, for example by post or email, we process this data in the course of assessing, managing or responding to your communication. Processing your data is necessary to perform a task carried out in the public interest or for our official functions.
We occasionally outsource functions when we do not have the in-house capacity or expertise required, such as the use of a mailing house for mailings, CCTV monitoring services and analytical services that enable us to target our communications with customers and supporters more effectively. In such cases, we will only use reputable firms and have contracts and processes in place that ensure the safe and confidential processing of personal data at all times. We will always ensure an adequate level of protection is provided for personal information transferred outside the European Economic Area. The main organisations that we currently share your data with include:
Purpose of Processing
Secure online payments for Shop and Images
Ticketing, donations and online registration for Friends membership
Secure online payments for ticketing, donations and online registration for Friends membership
Group mailings sent by email, e.g. What’s On, newsletter (based in the United States and certified as being EU-US Privacy Shield-compliant)
Volunteer management system (based in Canada, the data protection regime of which has been deemed adequate by the EU Commission)
Vacancies and job opportunities
Visitor Surveys (based in Singapore, Australia, the United Kingdom and the United States)
Cloud-based fundraising client relationship management system for charities (based in the United States and certified as being EU-US Privacy Shield-compliant)
Monitoring footfall and dwell time
Noonan Security Services
The Gallery uses Closed Circuit Television (CCTV) images to provide a safe and secure environment for staff and visitors and to protect the National Collection and other Gallery property from loss or damage. CCTV images are retained for 28 days and then destroyed, save for where an incident has been recorded and there is an ongoing investigation of claim arising from it.
Children and Vulnerable Persons
Education is one of our core activities. As part of our Education Programme, we provide services and activities aimed at children and vulnerable people, such as workshops, outreach programmes, work placements and art competitions.
Personal contact details of children may be processed by us in order to administer these activities as follows:
- For children aged 17 years or under, we will always obtain the express consent of their parent or legal guardian before doing so
- When providing services to a child online (including ticketing for workshops aimed at young people), we will seek proof that the data subject is aged 16 years or over and obtain their explicit consent in easy to understand language. We will not provide online services to those aged under 15 or under.
Personal contact details of vulnerable persons may be processed by us in order to administer these activities as follows:
- For vulnerable persons who can provide consent on their own behalf, we will always obtain their express consent before doing so
- For vulnerable persons who do not have the capacity to provide consent on their own behalf, we will always obtain the express consent of their guardian or nominated representative before doing so.
Job and volunteering applicants
If you apply to work or volunteer at the Gallery, we will use the information you supply to us to process your application and to monitor recruitment statistics. Where we want to disclose information to a third party, for example, where we want to take up a reference, we will not do so without informing you beforehand. Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, after which it will automatically be destroyed, unless you have asked us to destroy it earlier or allowed us to retain it for longer by written request. We currently use Candidate Manager to help manage and administer the recruitment process and share your data with them for this purpose.
You can register your interest for job opportunities at the Gallery here.
Data Subject Rights
You have the right to request a copy of information that we hold about you by making a Subject Access Request. On request, we will also correct your data according to your preference should errors be identified and/or delete all of your personal data, unless we have to keep it to comply with statutory retention requirements or, in the case of some technical logs, cannot modify or delete it. In any such case, we will restrict your data for further processing so that it can no longer be used. You also have a right to object to the further processing of your data and the right to receive your data in electronic form. Where you have consented to us processing your data, you have the right to revoke that consent at any time.
If you wish to exercise any of these rights, please contact our Data Protection Officer by clicking here or using the contact details given below.
If you believe that your data is not being processed by us in accordance with applicable data protection laws, you have the right of appeal to the Data Protection Commissioner.
Keeping your data
In general, we do not keep your data for any longer than is necessary for the purpose for which it was obtained from you. Sometimes we are required to retain your personal data for a particular reason, including:
- where we have your express consent to do so, where you are 18 years or older
- for online services only, where we have your express consent to do so and we have been able to verify that you are 16 years or over
- for children aged 17 years or under, where we have the express consent of their parent or legal guardian to do so
- for those vulnerable persons capable of giving consent on their own behalf, where we have their express consent to do so
- for those vulnerable persons not capable of giving consent on their own behalf, where we have the express consent of their parent, guardian or nominated representative (as applicable) to do so
- where we are required to do so to meet legal or regulatory requirements
- where we have a contract with you and we need to use your data in order to carry out our obligations under that contract
- where we are carrying out a task in the public interest
- where we have a legitimate interest in doing so (in relation to Friends only)
- for statistical, archival or historical research purposes.
Certain of our IT systems log information that cannot be modified and, in limited circumstances, cannot be deleted. Access to these systems is tightly controlled and the data captured therein is put beyond use.
We are currently reviewing and updating our records management policy and retention schedules. As a result, as we move towards compliance, personal data may in certain circumstances be held longer than the minimum period required. We hope to publish further details of retention periods soon and ask you to bear with us during this time.
We will take care to ensure that your information is accurate, kept up to date and stored securely and will do our best to carry out our services using the minimum amount of personal data possible.
We adopt Transport Layer Security measures to protect information sent to and from the Website from interception and hacking. However, there are risks involved with the transfer of information across the internet and the users of the Website should be aware of such risks.
Complaints, enquiries and feedback
The Gallery tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of their information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. Please contact our Data Protection Officer here or using the contact details provided below.
How to contact us
For general enquiries, please email us at [email protected].
To opt out from receiving marketing communications from us, update your contact details or change your contact preferences at any time, you can write to us at: Visitor Experience, The National Gallery of Ireland, Merrion Square West, Dublin 2, D02 K303 or click here. You can also click the “unsubscribe” link at the bottom of our emails. Please ensure that you state your full name and address to help us locate your records. If your personal details change, please help us to keep your information up to date by notifying us.
As outlined above, you are entitled to view, amend or delete the personal data that we hold about you. If you wish to exercise any of these rights, please contact our Data Protection Officer here or in writing to: The Data Protection Officer, The National Gallery of Ireland, 89 Merrion Square West, Dublin 2, D02 K303.
If you have any queries in relation to National Gallery Images, please contact [email protected].
If you have any queries in relation to the Shop, please contact [email protected].
If you have any queries in relation to Friends, please contact [email protected].
Use of our services and changes to this notice
By using our services, you confirm that you have read, understood and agreed to this notice. We keep this notice under regular review. You are advised to visit this page periodically in order to keep up to date with any changes to it. By continuing to use our services after any such changes, you shall be deemed to have accepted any such revised notice.
This privacy notice was last updated on 5 February 2019.