PRIVACY POLICY
Professional genealogy has always been concerned with client confidentiality and the privacy of information submitted. The new data protection legislation has helped codify what all responsible professional genealogists have been doing all along, and requires us, amongst other things, to have a written privacy policy. I have always done, and will always continue to do, all that I reasonably can to keep your personal information safe, handling it in a responsible manner and complying with the data protection laws.
Anthony Adolph (www.anthonyadolph.co.uk) is a freelance professional genealogist at 123 Victor Road, London, SE20 7JT, Data Protection Public Register number Z6639808. I am happy to deal with any queries or requests regarding the data held about you. Please contact me at mail@anthonyadolph.co.uk.
Information I collect
When you send an enquiry, I collect your name and whatever other contact details you have supplied. This allows me to process your enquiry and keep in touch. When you commission research I will also ask you for your postal address, in case e-mails fail and because many reports come with supporting documentation which needs to be posted. I will also collect from you family history information (I usually recommend sending full names, dates and places of birth, marriage and death, occupations and religious denomination for the earliest couple of known generations) that is necessary to undertake the work (usually, tracing ancestors or cousins, and/or drawing a family tree) that you have commissioned.
How I use the information, and data sharing
I will use your personal information solely for the purpose for which you sent it, i.e., communicating with you about genealogical research and undertaking the work itself. I may contact you after sending you my initial response to your enquiry, to check that it arrived safely and see if you would like to take up the quote. I am contact you after sending you the report, to make sure it arrived safely and to see if you would like any new work undertaken, building on the results of the last round, for instance, or perhaps starting to explore a new line of your ancestry which we have not investigated already. I may contact you further down the line, too, if new information or opportunities for research have come to light, as this is an ever improving field.
Client confidentiality has always a paramount concern of professional genealogists such as myself. No personal information you supply will be shared with any third parties unless you have specifically instructed me to do so, or where it is necessary in order for me to fulfil the research you have commissioned: i.e., if you have asked me to obtain a copy of your birth certificate, I may tell a trusted fellow-searcher your name and birth date, but even in such circumstances I will only pass on whatever information is strictly necessary for the performance of the research, so confidentiality is maintained. The Information Commissioner’s Office, which administers the new data protection rules, is very concerned over the ‘sharing of personal information outside the European Economic Area (EEA)’. To be clear, if you have asked me to look for personal information concerning you or your family outside Europe, I will communicate with trusted research colleagues overseas accordingly – I have a well-established network of them all over the world – but, again, I will only send them information which is necessary for the work, and no more. In most cases, the most any searcher will be told are the details of the earliest known ancestor. There are no circumstances under which I would look for any personal information about a client without them knowing that this will happen as part of the research they have explicitly requested.
When registering with the Information Commissioner’s Office, genealogists are given a standard template which cannot be edited. This includes the statement ‘where necessary or required I share information with: relatives, guardians or other people associated with the person whose personal information I am processing; enquirers; survey and research organisations’. As clarified above, this blanket statement is not true, and the idea of so much as communicating at all with a ‘survey organisation’ is unconscionable.
The only exceptions to the above are the demands of government departments legally empowered to see my files: should H.M. Revenue and Customs (HMRC) or, ironically, the Information Commissioner’s Office wish to see my accounts and client files in the course of their routine tax or data protection inspections, I am – like everyone else – legally obliged to cooperate, and powerless to refuse.
Sometimes, clients commission me to try to find living relatives. I those cases, I will use public records (particularly birth, marriage and death record, telephone directories and electoral registers) to do so, and communicate the results obtained from those public records to my client, who may then use that information to contact the people concerned, who, we hope, will turn out to be the living relatives concerned. I do not use any more surreptitious methods than this – I am not a private detective and have no interest in becoming one. If anyone who has been traced in this way wishes, the information I hold concerning them will be deleted, immediately, upon request (to mail@anthonyadolph.co.uk).
Data retention
Family history information never goes out of date. Whilst I am not obliged to keep client details (except under HMRC’s seven year rule), I may, as a professional genealogist, keep some or all of your details for considerably longer, so that you can come back later to commission more research. I recently had a client who came back after 12 years to ask me to pick up where I had left off before, and because of improvements in the indexing of parish registers, I was able to crack the case where, 12 years ago, we were stuck. However, if you do not want me to keep any details concerning you, other than those which I am legally obliged to retain by HMRC, I am happy to delete them – please simply let me know by e-mailing mail@anthonyadolph.co.uk.
How I protect your information
I have commercially reasonable and appropriate security measures (including a firewall and virus checker) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. I have procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where I am legally required to do so.
Correcting your information
You are entitled to have your personal information updated and corrected, so please let me know of any changes in your contact details and circumstances. You are entitled to ask me to confirm what personal information I hold about you and to have this corrected, altered or deleted, and I will always be happy to do so, provided this does not contravene my obligation to keep records for HMRC. No fee will be charged for this unless your request is (in the ICO’s words) ‘clearly unfounded or excessive’ – I am, apparently, entitled to charge a fee or refuse to comply with the request under such very unlikely circumstances.
Withdrawing consent
You have the right to withdraw your consent to any processing that is currently being done under your consent. Consent can be withdrawn by e-mailing mail@anthonyadolph.co.uk. Once I have received notification that you have withdrawn your consent, I will no longer process your personal information, unless I have another legitimate basis for doing so under the terms of our engagement (I ask you to agree, when we start a round of research, that the round cannot be cancelled without the agreement of both parties), or under law (i.e,, the retention of details for tax purposes).
It should be emphasised that none of the foregoing substantially alters the standards which professional genealogists have been upholding all along.
Right of complaint to the regulator for data protection
If you have any questions or concerns regarding this, please contact me at mail@anthonyadolph.co.uk and I will be happy to help.
You also have the right to complain about data protection issues to the Information Commissioner’s Office (ICO): Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF, 0303 123 1113 or 01625 545 745, https://ico.org.uk/concerns, casework@ico.org.uk.
Last updated: 24 May 2018
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