1. Who we are and the purpose of this Policy
The Lives of the First World War website is managed by Findmypast Ltd (FMP) in partnership with Imperial War Museums and Imperial War Museums Trading Company (IWM). Imperial War Museums Trading Company is a wholly owned subsidiary of IWM and for the purposes of this policy ‘Imperial War Museums’ and ‘IWM’ will mean both organisations.
‘Personal information’ can be defined as information about a living, identifiable individual.
This policy is effective from: 25 May 2018.
2. Responsibilities over the data we hold and who to contact
Responsibility for the personal data collected via the Lives site is the responsibility of Findmypast and IWM, who act as joint Data Controllers. Specifically:
Responsibility of IWM and Findmypast:
Sign up data (ie the information you enter on this screen: https://livesofthefirstworldwar.org/join and signups to receives updates from the Lives site are the joint responsibility of Findmypast and IWM
If you have queries regarding sign up, please contact Findmypast’s support team in the first instance by email at firstname.lastname@example.org, by calling +44 (0)20 3326 6300 [UK, IE, AU] / +1 (855) 246-8234 [US] or by post to Findmypast, 6 Chapel Place, Rivington Street, London EC2A 3DQ.
Responsibility of IWM:
Data relating to signups to receive marketing emails from IWM
Free access records
User generated content submitted by members of the site
If you have queries about any of these areas, please contact the IWM Information Governance team at email@example.com or by post at Imperial War Museum, Lambeth Road, London SE1 6HZ (marking the envelope for the attention of the Data Protection Officer). You can also contact the team by phone by ringing IWM’s main switchboard on +44 (0)20 7146 5000.
Responsibility of Findmypast:
Data relating to paid subscriptions with Findmypast, and signups to receive marketing from Findmypast
Access to data contained within genealogy records on the site is the responsibility of Findmypast
If you have queries about any of these areas, please contact Findmypast by email at firstname.lastname@example.org, by calling +44 (0)20 3326 6300 [UK, IE, AU] / +1 (855) 246-8234 [US] or by post to Findmypast, 6 Chapel Place, Rivington Street, London EC2A 3DQ.
3. Data Protection Officers
Both IWM and Findmypast have Data Protection Officers, who are responsible for overseeing how their organisations manage personal data. If you have an enquiry or complaint about how your personal data is managed you can contact them as follows.
IWM’s Data Protection Officer is Jon Card, the Executive Director of Collections and Governance, who manages IWM’s Information Governance team.
If you have any queries about the content of this policy, or how your IWM controlled data is managed, you can contact him and the IWM’s Information Governance team at email@example.com or by post at Imperial War Museum, Lambeth Road, London SE1 6HZ (marking the envelope for the attention of the Data Protection Officer). You can also contact him by phone by ringing IWM’s main switchboard on (020) 7146 5000.
Findmypast’s Data Protection Officer can be contacted at firstname.lastname@example.org or by post at Data Protection Officer, Findmypast, 6 Chapel Place, Rivington Street, London EC2A 3DQ.
4. Your rights over your information
You have the right to:
Have a copy of the personal information IWM holds about you.
Correct inaccurate information or have incomplete information completed.
Have your data erased (‘right to be forgotten or ‘right to erasure’) in certain circumstances.
Restrict the processing of your personal information in certain circumstances.
Data portability – have your information supplied in a commonly used format and transmitted to another organisation.
Object to the processing of your personal information.
Object to automated decision making or profiling.
Further information on these rights can be obtained from the Information Commissioner’s website at: https://ico.org.uk/
You can exercise these rights by contacting the IWM’s or FMP’s Data Protection Officer as detailed in Section 3 above.
If you are unhappy about the response you receive from IWM, you can contact the Information Commissioner’s office by writing to the Information Commissioner at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, or via their website at https://ico.org.uk/
5. Where your information is stored
Your information is stored by Findmypast, on servers in the UK. From March 2019, information controlled by IWM will be transferred to IWM storage, also in the UK.
The storage and management of IWM information by Findmypast is protected by a contract that sets out how the personal information is to be managed – and that contract will guarantee that the personal information will always have the same protection as information stored directly by IWM.
6. Personal data you submit when you subscribe to the site (free access)
The data we collect and who is responsible for it
If you sign up for free access to the site, the information you submit is controlled by Imperial War Museums and Findmypast.
When you sign up for free access to the Lives site, we collect the following information from you:
Your email address
You can also add the following information
Some details about yourself
Links to any website you might have, or your Facebook or Twitter pages
Sign up to receive marketing emails from the Lives site, Findmypast or IWM
General use of the information
We use these details to maintain your account with us and to track any contributions you make to the Lives site. Although we will not use your details to send out marketing information, we may on occasion contact you to inform you of any major changes that will affect your use of the site, including changes to this policy.
Your name is published online beside any contributions you make to the Life Stories Section, We do this because we believe it is important to record your contribution and it also encourages accuracy and accountability.
When you sign up to the Lives site, you enter into a contract with us that governs your use of the site’s facilities. If you do not provide the data we cannot verify any information you provide to the site or ensure your use of the site is in accordance with our terms and conditions.
If you consent, we may also use your details to send you marketing information –from the Lives site, Findmypast or third parties. If you do consent to this, you can unsubscribe at any time, by clicking the ‘unsubscribe’ link in the emails you are sent. You can also unsubscribe to marketing emails from Lives by changing your account settings. You can also contact us direct using the contact details in Section 3.
How long we keep your information
If you sign up for free access to the Lives site, we keep your data for as long as we believe your account is active – for a maximum of two years after your last use of the site or until we receive notification from you.
If you contribute to the Life Stories Section, your name and email address will need to be kept for as long as the information you have provided is online, so that we can track any rights to the information and verify its accuracy. You can ask for information to be removed by contacting us
7. Personal data you submit when you subscribe to the site for enhanced access to records (paid access)
The information we collect and who is responsible for it
If you sign up for paid access to the site, you are subscribing to the Findmypast service. The information you have entered for your free subscription is shared with Findmypast, who are also responsible for the payment details you submit. Findmypast do not keep a record of your credit or debit card details in our systems, see below (Sharing your information with third parties).
When you register on our website or place an order, we collect your name and email address. This allows us to process your registration, fulfil your order and send you important service messages. Sometimes, we may collect ask you to provide other contact details to carry out our surveys, such as phone number or address. You will always be given the option to not provide additional contact details at the time you complete the survey.
General use of the information by Findmypast
We will use your personal information for a number of purposes including
Manage the website (including your account).
To process orders and provide our services, goods or online content, to provide you with information about them and to deal with your requests and queries.
For administration purposes which means we may contact you for reasons related to goods or services ordered or online content you have signed up for, to let you know that a service or online site has been suspended for maintenance, if your subscription is about to expire to ask if you wish to renew it or if an online account has become dormant to ask if you wish to retain the account before we close it.
Provide advanced website features to you and others.
We use IP addresses and device identifiers to identify the location of users, to establish the number of visits from different countries, to limit/cap adverts of a certain type, personalise content and emails.
For analysis and research to improve our services and goods offered.
Improve your search results.
A certain amount of advertising is tailored to the individual based on viewing and/or purchase habits. This is a common practice known as online behavioural advertising.
We may show you relevant advertising on third party sites (e.g. Facebook, Google, and Twitter).
Conduct surveys with you (where you have consented to us contacting you for such purpose).
Where we provide personalised services, we may analyse the information you supply, as well as your activity on our (and other) services, so we can offer a more relevant, tailored service.
We may use and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
We use your email address to update you about new products, services, and subscription offers. We will only contact you with your consent. You are entitled to withhold this consent and refrain from receiving such communications at any time by selecting the appropriate option on the web form that collects your details. You can also update these options by logging into your account and adjusting your preferences, by contacting us by email at email@example.com, by calling +44 (0)20 3326 6300 [UK, IE, AU] / +1 (855) 246-8234 [US] or by post to Findmypast, 6 Chapel Place, Rivington Street, London EC2A 3DQ. We will always provide you with a way of opting out of receiving future marketing messages from us, each time we send them to you.
Sharing your information with third parties
We may from time to time provide your personal information to third parties for the purposes of providing you with our services. These third-party providers include payment processors, providers of card validation services, credit referencing providers, service providers who assist us with hosting our marketing campaigns and surveys. We do not keep a record of your credit or debit card details in our systems. Our payment processors do not decide what is done with your data and only process it on our behalf. These third parties may be located outside the European Economic Area; however, we only use providers that provide adequate protection for your information at all times.
When transferring any personal information out with the EEA we only do so under one of the legally recognised transfer mechanisms for ensuring the data is safeguarded. These are:
The country in question has been deemed safe for data transfer by the European Commission. Also known as an adequacy finding.
The contract for data processing contains the standard contractual clauses laid down by the European Commission to safeguard the transfer of personal data.
Binding corporate rules – this is where a large company’s own internal processes for international data transfer have been signed-off and agreed by the European Commission as safeguarding the data.
If the data is going to the USA it can be safely transferred to a company that is certified under the EU-US Privacy Shield.
Appropriate certification schemes
We will not provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us. You are entitled to decline receiving such 3rdparty communications by not selecting the appropriate box on the web form that collects your details or at any subsequent time by logging into your account and adjusting your preferences, by contacting us by email at firstname.lastname@example.org or by post to Findmypast, 6 Chapel Place, Rivington Street, London EC2A 3DQ
How long we keep your data
Some of the information you provide to us will be necessary to carry out repeated tasks, such as verifying your identity or payment details when signing in to use an account or providing our services to you or you are using an online checkout. We will keep this information for as long as you remain a registered user of any of our sites and for so long as reasonably necessary.
If your account is inactive for more than five years and you are no longer paying for a service, we reserve the right to delete any information you have provided to us
8. Personal data on the site: free access records and material submitted by subscribers (‘Life Stories’)
The information on the site and who is responsible for it
Some indexes and lists of individuals are made available free of charge on the Lives of the First World War site. Material submitted by subscribers to the Life Stories section is also free to view. This information is the responsibility of the IWM.
Use of the information
The data in these indexes and Life Stories intended to be used by individuals to research and commemorate the lives of those affected by the First World War. Due to the length of time since the First World War, the information in these lists will relate to the deceased and is not, therefore personal data.
However, some information submitted to Life Stories will relate to living individuals, for example when relatives are depicted in photographs. This material is posted in the public interest, for the purposes of historical research and commemoration only. If you post material to the site you are advised to obtain the consent of those concerned before you do so, and this is your responsibility.
How long the information is kept
The intention is to keep this information long term, as a research resource.
Who to contact with complaints or questions about the information
If you see information about yourself depicted in the ‘Life Stories’ section and you would like it removed, you can do two things:
Click on the cog icon on the site and select ‘Report Abuse’. You can submit a report via this function which will enable us to investigate
Alternatively, if you wish to report it to use direct, you can use the details given in Section 2
9. Personal data on the site: enhanced access records (paid access)
The information on the site and who is responsible for it
Information on the site that is free to search but can only be accessed in full via payment of a subscription, is the responsibility of Findmypast. This includes information such as:
Birth, Marriages and Deaths registers
Official military service records
General use of the data
The information in these lists is available for historical research. The information either relates to individuals who are deceased, or is contained in a publicly available register, such as the General Record Office register of Births, Marriages and Deaths
Who to contact with complaints or questions about the data
If you have a query about this data you should contact the Findmypast team at by email at email@example.com, by calling +44 (0)20 3326 6300 [UK, IE, AU] / +1 (855) 246-8234 [US] or by post to Findmypast, 6 Chapel Place, Rivington Street, London EC2A 3DQ.
10. Policy date and version control
This policy was agreed on: 25 April 2018
It replaces the policy of 01 July 2013, as amended on 10 Feb 2014; 10 May 2014 and 26 Jan 2015.