Sculpture in the City privacy Notice

The City of London Corporation (“the City Corporation”) is committed to protecting your privacy when you use any of our services. This Privacy Notice explains how we use information about you and how we protect your privacy.

If you have any concerns or questions about how we look after your personal information, contact the City Corporation’s Data Protection Officer, also the Comptroller and City Solicitor, Michael Cogher. You can email information.officer@cityoflondon.gov.uk. or write to PO Box 270, Guildhall, London EC2P 2EJ

Please note – this Privacy Notice was updated on 17 September 2025.

1. Your personal information

Personal information is anything that directly or indirectly identifies and relates to a living person, such as a name, address, telephone number, date of birth, unique identification number, photographs, video recordings etc.

All personal data collected will be evaluated periodically and only kept as long as necessary or in line with legal requirements.

When engaging with you we note that the following personal data may be processed:

  • Name
  • Contact details – e.g. email address, phone number.
  • IP details in instances where you have accepted Cookies form our website.

Some personal information is ‘special category data’ and needs more protection due to its sensitivity. This includes any information about an identifiable individual that can reveal their sexuality and sexual health, religious or philosophical beliefs, racial origin, ethnicity, physical or mental health, trade union membership, political opinion, genetic/biometric data. Personal information relating to criminal offences and convictions, although not ‘special category data’, is still sensitive in nature and merits higher protection.

2. Why do we need your personal information?

We will collect and process the above data about you:

  • To help investigate any concerns or complaints you have about our services.
  • To respond to any correspondence received from yourself concerning a meeting/event or the receipt of communication.
  • To administer the use of photograph/recordings where these have taken place.
  • To administer the Sculpture in the City process for arranging new artworks.

3. How the law allows us to use your personal information

There are a number of legal reasons why we will need to collect and use your personal information in different circumstances.

Generally, we collect and use personal information where:

  • Where you, or your legal representative, have given consent and or your explicit consent in the event of special category data being processed.
  • It is necessary for the performance of a contract.
  • It is necessary to protect the vital interests of an individual.
  • It is necessary for the purposes of legitimate interests pursued by the data’s controller.
  • It is necessary for archiving, research, or statistical purposes.

4. Consent

If we have consent to use your personal data for any particular reason, you both have the right to remove your consent at any time. If you want to remove your consent, please contact information.officer@cityoflondon.gov.uk and tell us about the personal data being used and where it is being used or the department using this data, so we can respond to your request.

5. Your rights regarding your personal information

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at information.officer@cityoflondon.gov.uk

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

You can ask us to:

  • Provide you with a copy of the personal information that we hold about you.
  • Correct personal information about you which you think is inaccurate.
  • Delete personal information about you if you think we no longer should be using it.
  • Stop using your personal information if you think it is wrong, until it is corrected.
  • Transfer your personal information to another provider in a commonly used format.
  • Not use automated decision-making processes to make decisions about you.

6. With whom do we share your personal information?

In some circumstances, we use other organisations to either store personal information or use it to help deliver our services to you. Where we have these arrangements, there is always an agreement in in place to make sure that the organisation complies with data protection law.

Sometimes we have a legal duty to provide personal information to other organisations.

We may also share your personal information when we consider/believe that there is a good reason to do so, which is more important than protecting your privacy. This doesn’t happen often, but in these circumstances we may share your information:

  • To find and stop crime and fraud; or
  • If there are serious risks to the public, our staff or to other professionals
  • To protect a child; or
  • To protect adults who are thought to be at risk, for example if they are frail, confused or cannot understand what is happening to them.

For all these reasons, the risk must be serious before we can override your right to privacy.

If we are worried about your physical safety or feel we need to take action to protect you from being harmed in other ways, we will discuss this with you and, if possible, get your permission to tell others about your situation before doing so.

We may still share your information if we believe the risk to others is serious enough to do so.

If this is the case, we will make sure that we record what information we share and our reasons for doing so. We will let you know what we have done and why, if we think it is safe to do so.

In addition, we note that the City of London Corporation engages Lacuna and Urban Learners, as data processors to arrange any events or tours of our sculptures. As such, personal data may be shared between all three parties where it is appropriate to do so.

7. How do we protect your personal information?

We have a legal duty to make sure we hold your personal information (on paper and electronically) in a secure way, and to only make it available to those who have a right to see them. Examples of our security include:

  • Encryption, meaning that information is hidden so that it cannot be read without special knowledge (such as a password).
  • Pseudonymisation, meaning that we will use a different name or identifier to hide parts of your personal information from view. This means that someone outside of the City Corporation could work on your information for us without ever knowing it was yours.
  • Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it.
  • Training for our staff allows us to make them aware of how to handle personal information, and how and when to report when something goes wrong
  • Regular testing of our technology and ways of working, including keeping up to date on the latest security updates (commonly called patches).

You can find more details of our Information Security expectations in our IT Security Policy, which is available upon request.

8. Where do we store your personal data.

The majority of personal information is stored on systems in the UK or EU. However, there are some occasions where your information may leave the UK/EU either to get to another organisation, or where it is stored in a system outside of the EU.

We have additional protections on your personal information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.

9. How long do we keep your personal information?

We will only hold your personal information for as long as it is necessary to fulfil our legal duties or business purposes.

Further advice?

For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

0303 123 1113 (local rate)
01625 545745 (national rate number)
Information Commissioner’s Office website