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Dulwich Picture Gallery wants to provide clear and concise information on how we use personal information and protect privacy. We will use the information that we collect about you in accordance with the Data Protection Act 1998 and the Privacy and Electronic Communications Regulations 2003. From 25 May 2018 new data protection rules known as the General Data Protection Regulation (and related UK legislation) come into effect; this policy has been drawn up to comply with those rules.
Who we are
Dulwich Picture Gallery is the UK’s oldest purpose-built public art Gallery, with a world class collection of Old Master paintings housed in Sir John Soane’s iconic building at Gallery Road.
Dulwich Picture Gallery is a charitable company limited by guarantee, company number 10445344 and registered charity number 1171287, with its place of business at Gallery Road, London SE21 7AD, and is governed by a Board of Trustees who are also Directors under the Companies Act. Dulwich Picture Gallery Enterprises Limited, company number 03173890 (‘DPGE’), is a wholly owned subsidiary of Dulwich Picture Gallery which trades on the Gallery’s behalf and exists to support it. The Friends of Dulwich Picture Gallery is an independent charitable association no 803727 whose purpose is to support the Gallery.
Under this policy, ’Dulwich Picture Gallery’ refers to both Dulwich Picture Gallery and DPGE, and ‘we’ refers to both Dulwich Picture Gallery (as defined in this paragraph) and the Friends of Dulwich Picture Gallery (the ‘Friends’). Together, for the purposes of how we control and manage the personal data of supporters and visitors, we are the Dulwich Picture Gallery group.
We will never sell, rent or exchange your details with any other organisation outside the Dulwich Picture Gallery group.
What information do we collect?
- Information we collect from you
You give us your information in a variety of different ways: when you buy a ticket, make a purchase from our shop, buy something on our website, sign up for one of our events, update your preferences/interests on our website or email newsletter system, make a donation, join the Friends or one of our Patron groups, or communicate with us. We also keep your details when you sign up to receive email newsletters from us. If you share any access requirements or other special requirements with us we will note this in your customer record.
If you make a purchase, sign up for an event or give a donation we usually collect your name, contact details and your bank or credit card information (if making a transaction). We maintain a record of your transaction history, but we never store your card number (although we may keep a note of the last four digits to help us identify transactions). If you select to store your card details via our online ticketing website, your card details are tokenised and encrypted in accordance with leading industry security standards by our Payment Provider, Payment Express.
Where it is appropriate (and you have the right to decline to give this information) we may also ask for your age, gender, ethnicity, information relating to your health or, if making a donation, why you have decided to donate to us.
In accordance with your requests, preferences or the terms you have signed up to, we may use this data to provide you with the events, products, services or information you asked for, ensure we know how you prefer to be contacted, understand how we can improve our communications or events, administer your donation, or to process Gift Aid.
We keep a record of the emails we send you, and we may track whether you receive or open them so we can make sure we are sending you the most relevant information. We may then track any subsequent actions online, such as buying a ticket.
If you participate in one of our social prescription-style programmes, for example Prescription for Art, we may receive information from a doctor, carer or family member in order to enable us to deliver the service to you.
- Information we collect from others
Depending on your settings or the privacy policies of social media and messaging services like Facebook, LinkedIn or Twitter, you might give third parties (like Dulwich Picture Gallery) permission to access information from those accounts or services.
- Information we collect during your visit to the Dulwich Picture Gallery website (or "Cookies")
Like most websites, we receive and store certain details whenever you use the Dulwich Picture Gallery website. We use “cookies” to help us make our site – and the way you might use it – better. Cookies mean that a website will remember you and enable online transactions. It also helps us understand how you use our website, where we can make improvements and how best to tell our audiences about events they might be interested in.
What kind of cookies do we use?
We use a session cookie to remember your log-in details and, for example, what you’ve put in your online shopping basket. These we deem strictly necessary to the working of the website. If these are disabled then various functionalities of the website will not work.
We share session cookies between our main website (www.dulwichpicturegallery.org.uk) and our online ticketing subdomain (my.dulwichpicturegallery.org.uk). Sharing the cookies across both our secure sites allows us to create a seamless user experience.
Session cookies from our newsletter signup software (provided by GetSiteControl) also determine whether or not we show you our pop-up newsletter sign-up option – this is set not to display to returning users in order to improve the user experience.
To view more information on session cookies, please click here.
Cookies for Site Analytics and Performance
We use Google Analytics as our main tool to understand how our site is being used in order to improve the user experience.
Within Google Analytics, we also record basic anonymous transactional data (e.g. order value, products purchased) so we can effectively evaluate the performance of our digital marketing.
Remarketing & Display Advertising
Abandoned basket emails
How we keep your details safe and secure
Your personal data, including in your capacity as our Friend or Patron, will be held and processed on Dulwich Picture Gallery’s systems on behalf of the Dulwich Picture Gallery group. We maintain a customer relationship management (CRM) system to hold contact details and a record of your interactions with Dulwich Picture Gallery such as ticket purchases, donations, Gift Aid declarations, memberships, queries, customer service issues, complaints and attendance at special events. This CRM is also used to manage membership of, and communications from, the Friends. Where possible we aim to keep a single record for each customer.
Your data is always held securely. Access to customer information is strictly controlled. The CRM system can only be accessed by people who need it to do their job. Certain data, for example any sensitive or financial information, has additional levels of control and safeguards and is only made visible to members of staff who have a reason to work with it.
Our CRM system is hosted by our supplier on servers in Ireland within the EEA and under EU data protection regulations. We comply with all applicable UK and EU data protection legislation in force in respect of any personal information you submit to us. The personal data you submit to us will only be used for the specified purposes indicated to you and, except where we are so required by law, will not be passed onto unauthorised third parties without your explicit consent. Please note that for technical reasons, we may sometimes need to use the services of a supplier outside the European Economic Area (‘EEA’) and transfer your personal data to countries outside the EEA that may not have the same level of data protection as countries within the EEA. However, if we intend to do this, before any transfer takes place we will put in place contractual arrangements to ensure that there is adequate protection of your data and that these comply with European data protection regulations.
We may need to disclose your details if required to the police, regulatory bodies or legal advisors.
Any information held on children and vulnerable adults is secured so that only staff who have been through an enhanced DBS clearance check who need to use it for work can access it. We will only share information about concerns with agencies who need to know, and would involve parents and/or carers as appropriate in line with our safeguarding policy.
We will only ever share your data in other circumstances if we have your explicit and informed consent.
You have the right to have the right to be forgotten and we will delete all data held on you (unless we are legally bound to keep it).
What we use your personal information for and why
- What we use your personal information for
We use your personal information to manage your interactions with us: in personal visits to the Dulwich Picture Gallery, in visiting our website, or in communicating with us (including to make purchases, give gifts or memberships, or make appropriate fundraising asks).
We aim to be clear when we collect your data and not to do anything with it that you would not reasonably expect. We set out our reasons for what we do below.
- Why we use your personal information
Fulfilment of a contract
When you make a transaction with Dulwich Picture Gallery we may need to make contact with you to fulfil the contract in relation to that contract. This includes the following:
- Purchasing a ticket online – we will email you about your booking, including ticket confirmation and in the event of cancellation.
- Friends membership – in accordance with membership terms, we will contact you with the magazine, Gallery updates, information on Private Views, membership renewal, direct debit payments etc.
- Patron members, for example currently of our 1811 Club or Desenfans Circle – we will contact you with various updates from the Gallery, invitations to events, and information on projects.
Your Legitimate Interests or those of Dulwich Picture Gallery
We may contact you about things which we feel are of interest to you or which, based on what we know about you, are in the interests of our charitable objectives to let you know about. This will from time to time include marketing and fundraising, but at any stage you can tell us that you do not wish to receive such information and we will stop contacting you with it.
Such a legitimate interest will constitute a lawful ground for contacting you about our services and activities, subject to your rights and any applicable e-privacy rules on electronic communications. Some examples are:
- If you purchase a ticket to an exhibition then marketing other similar exhibitions to you would be a legitimate interest
- If you purchase a ticket to an exhibition, under a legitimate interest we may email you a short online survey allowing you to give us your feedback. These surveys are completely voluntary, the data collected is anonymous and the results are regularly used to assess our charitable objectives.
- If you make a purchase from the shop online then marketing other shop products to you would be a legitimate interest
- If you have previously supported an appeal for funding then other appeals would be a legitimate interest
- If you are a frequent ticket buyer then marketing membership of the Friends to you would be a legitimate interest
- If you are an active Friend then marketing one of our higher-level Patron membership schemes to you would be a legitimate interest
- If you are a major donor approaching Dulwich Picture Gallery, then carrying out basic due diligence would be a legitimate interest (and may be legally required of us)
- We consider the other fundraising activities set out further below (in the section "Fundraising") likewise to be a legitimate interest
We reserve the right to bring other legitimate interests to your attention in the future. Broadly, however, any reasonable activity designed to promote the Dulwich Picture Gallery's objectives – including offers, promotions, marketing and fundraising activity, and due diligence about our donors – would be a legitimate interest, provided it is carried out lawfully and fairly.
Giving you control – your consent and preferences
Where required by law, or where we think it appropriate, we will rely on your consent to tell you about events, shop offers, priority booking and information about our site. Occasionally, again in line with your preferences, we may include information in these communications from partner organisations or organisations who support us.
We make it easy for you to tell us how you want to hear from us, either by registering on our website and setting or updating your preferences in the “My Account” section, by clicking the ‘Update Preferences’ link in any of our e-newsletters, or by telling our Ticket Office team over the phone or in person. You can opt out from these marketing communications at any time – every email sent to you will tell you how to do this.
Visiting the ‘My Account’ section enables you to choose whether you would like to receive our newsletter and marketing and fundraising communications from Dulwich Picture Gallery by email or post, and which type of communication you wish to receive. Once you have an account, you can manage your preferences at any time. Unless one of these boxes appears as ticked it means we will not be contacting you for marketing and fundraising purposes. We will include opt-out instructions in any marketing or fundraising communications you receive from us.
We do not sell personal details to third parties for any purpose. We will only share personal details for the purposes of marketing if you have given explicit consent for us to do this. But if we run an event in partnership with another named organisation your details may need to be shared in order that they can help us run the event, and this will be notified to you.
If you have opted out of marketing communications, we may still need to get in touch with you. For example we may email you to give you important information about the events you’ve booked or to tell you about any changes to those events; or to confirm details of purchases made.
We will give you the opportunity to opt out, at any time, from any marketing or fundraising email postal or telephone communications you receive from us.
The way in which we communicate with you will depend on the nature of your relationship with us.
If you are subscribed to one of our membership schemes, for example a member of the Friends, the 1811 Club or the Desenfans Circle, we will communicate with you about the Gallery and aspects of your membership as part of the fulfilment of your membership. On all communication with you we will provide you with the opportunity to opt out of the communication. While you remain a member we will continue to communicate with you specifically about your membership.
If you have opted in to receiving marketing or fundraising communication from Dulwich Picture Gallery we will continue to communicate with you unless you tell us you would like us to stop. However, if you have not interacted with us for a certain period of time since your consent, we will then make contact to check if you still want us to communicate with you – in most cases within three years. At this stage, if you do not opt in to receiving communication we will cease to communicate with you, unless you opt in to communication again at a later date.
- Further ways we may use your personal data
Fundraising is vital for the financial stability for Dulwich Picture Gallery. We receive no regular statutory income and only receive around 20% of our income from ticket sales, so we rely on the generosity of individuals, trusts and companies. This is why we consider fundraising activity to be within our legitimate interests.
We believe that the most appropriate way to raise money is to make tailored asks for support, which are appropriate to individuals’ circumstances and for relevant projects. To help us make appropriate requests we look at the data we hold on individuals and information held within the public domain. This may include information found in places such as Companies House, your biography on your work website or information that has been published in articles or newspapers.
We do not use third party companies to undertake any form of wealth screening with any of the data we hold.
You can opt in to receive information about supporting Dulwich Picture Gallery by logging in to our website and updating your preferences in the “My Account” section, or by speaking to the Development Department. We will tell you about our current appeals that we think are most relevant to you, and can offer invitations to events where you and your family can get closer to our artistic programme by joining one of our Patron schemes - the 1811 Club or Desenfans Circle.
Our supporters tell us that they generally prefer a personal approach and want us to respond to their specific interests; this means we maintain information to ensure we have appropriate communications with our supporters or potential supporters. We want to ensure our communications to our supporters are personal, relevant and timely. We may analyse geographic, demographic and publicly available information relating to you in order to better understand your interests, to send you the most relevant communications and ensure we offer you opportunities which are of interest.
In addition, we invite some people who might be interested in joining one of our supporter groups to special events eg. drinks receptions or Private Views or to tell you about our need for support and the benefits we offer for supporters. Guests we invite might include current supporters, Friends, people who have made donations in the past, audiences who attend concerts and events regularly, audiences who have identified a specific programme interest in the “My Account” section of our website, friends of current supporters, our Board and staff. We make sure that our invitations are appropriate and cost effective by conducting research and analysing our database which might include looking at audience members’ ticket history, address and previous donations as well as publicly available information (including newspaper articles, listed Directorships, social media profiles and biographies on employers’ websites).
We invite a select number of guests to our fundraising events to ensure they are financially viable. If you haven’t had an invitation but are interested in supporting and would like to attend please do let us know on firstname.lastname@example.org
Friends of Dulwich Picture Gallery
When you join as a member of the Friends of Dulwich Picture Gallery we collect information about you in order to manage your membership appropriately, including to:
- send your membership benefits by post i.e. your membership welcome pack and cards, InView magazine and What’s On Guide etc;
- provide you with services (i.e. send you an email bulletin or text message)
- talk to you about Dulwich Picture Gallery and Dulwich Picture Gallery Enterprises Limited (i.e. fundraising communication about our charitable work and notification of shop discounts);
- personalise your experience of Dulwich Picture Gallery (i.e. to build a picture of your interests which means we can tell you about programme and product offerings that are most relevant to your interests)
Where adequate measures have been taken to secure your personal data, for example by way of a cryptographic hash function, this data may be provided to third parties, for example an outsourced mailing house or membership card supplier, to process lawfully and in accordance with any consents you have previously given.
We may share anonymised personal information with other organisations, such as funders, who use this to analyse our audience development programmes, ticket sales and self-generated funding to understand the impact of their support.
We use third party distributers to distribute materials, for example a mailing house will collate and send out WhatsOn. WE have explicit agreements with these third parties and they do not store your data.
We will not otherwise share your personal information with third party organisations except as clearly stated in this policy (namely, where required by law or if your preferences permit it).
We are a member of the Fundraising Regulator and aim to comply with their fundraising guidance. Should you wish to lodge a complaint this will trigger a removal of you from any further fundraising communications from Dulwich Picture Gallery. We report annually to the Fundraising Regulator on any complaints we have received.
Sometimes we ask you to provide sensitive personal information (sometimes called "special category information"), which includes health and dietary information, religious or ethnic information, trade union membership, or criminal or criminal records information: for example when you book for certain events or participate in some activities, or when you apply for a job. As with all the personal information we hold, sensitive information is held securely and restricted to those who need to use it. We will delete sensitive information when we no longer need it.
You have the following rights related to your personal data:
- The right to request a copy of personal information held about you
- The right to request that inaccuracies in personal data we hold be corrected
- The right to request us to stop processing your personal data
- The right to withdraw consent, where we are relying on it
- The right to object to use of your personal data for our direct marketing or fundraising activity
- The right to request erasure of any irrelevant, inaccurate or unnecessary information we hold
- The right to lodge a complaint with the Information Commissioner's Office or Fundraising Regulator
Please note that these rights are not absolute rights in every case: for example, the right to receive copies of your personal data is subject to various exemptions, and any objection to processing or to correct or erase data can be refused if we have a good and lawful reason to continue processing.
This policy was last updated on May 2018.
- Email us at email@example.com
- Or write to us at: Data Protection, Dulwich Picture Gallery, Gallery Road, London SE21 7AD
Ticketing Ts & Cs
Tickets are valid only for the date, time and exhibition stated. Please check your ticket(s) and/or confirmation email on the receipt as mistakes cannot always be rectified.
Tickets cannot be exchanged or refunded.
If purchasing a concession priced ticket(s) please ensure that the person the ticket(s) is intended for meets the correct criteria and brings proof of eligibility on the day of attendance.
A senior ticket is for visitors aged 65 and over.
If collecting your ticket(s) in person from the Gallery please ensure you bring your confirmation email and/or proof of identity or collection may be denied.
During your visit please retain your ticket(s) safely for production on request by Gallery staff.
The Gallery may refuse entry to latecomers or require latecomers to wait until a suitable time to be admitted.
Tickets for the temporary exhibition are only valid for entry once; no re-admission allowed.
The Gallery reserves the right to alter the advertised arrangements for any exhibition, cancel any exhibition time slot and/or close the exhibition without notice. In any such event, the Gallery’s maximum liability to you shall not exceed the total amount you paid for your ticket(s).
Should cancellation of any event, be necessary, the Gallery will attempt to contact all customers who have booked tickets in advance to arrange exchange or refund of tickets. This contact will be in the form of email for online customers, so customers are advised to check their email inbox before visiting the Gallery to avoid an unnecessary journey should an event be cancelled. If an alternative visit date cannot be arranged, the Gallery will then refund the full price paid, including the payment processing fees, to customers.
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