Privacy Policy

How Ilmer Past handles personal data in its historical archive, including living and deceased people, public records, newspaper quotations and requests for erasure.

Ilmer Past is a volunteer-led local-history archive for the village of Ilmer, Buckinghamshire. It transcribes and presents parish registers, censuses, wills, monumental inscriptions, parish meeting minutes, newspaper reports and similar sources. This page explains how that affects personal data. It is written with reference to the National Archives' Guide to archiving personal data, although that guide predates the 2026 changes to the law, so the legal references below follow the current legislation.

This is a plain-English explanation, not legal advice.

Who is responsible

The site is run by an individual volunteer as a community project. Contact [email protected] for anything in this policy, including requests about a specific page.

Purpose of the site

The site exists for archiving in the public interest and historical research. Its aim is to make the recorded history of a small community discoverable and to preserve it. It is not used for marketing, profiling, or making decisions about anyone.

Deceased people

Data protection law (UK GDPR and the Data Protection Act 2018) protects information about living individuals. It does not apply to people who have died. The great majority of people named here died long ago: baptisms, marriages and burials from the 1500s onwards, wills, gravestones, and censuses up to 1921.

Even so, we treat descendants with care. If a page about someone who has died contains something that is inaccurate or distressing to close family, please get in touch.

Living people

Living people may appear incidentally, for example as a named relative on a recent gravestone, or in a recent photograph or reference. Our approach:

• Historic material first. We publish census returns only once released by the National Archives (currently 1921, released in 2022), and we do not publish records that are closed to the public.
• Minimisation. We include only what the source itself records and what is needed to make the record understandable. We do not add contact details, current addresses, or information about health, family circumstances or criminal matters of living people.
• Presumption of death. As a rule of thumb, where we cannot tell whether someone is alive, we treat a person as living if they were born within the last 100 years and have no known date of death.
• Sensitive material. Where old records mention illness (health data), convictions (criminal offence data), illegitimacy or poverty relief, we present them as historical record only. If a living person could reasonably be identified as connected to such material, we will redact or omit it.

Information in the public domain and public documents

Almost everything on the site was already public, lawfully available in public archives, libraries, churches, churchyards or newspapers, including:

• Parish registers and church records, held in record offices and open to the public.
• Parish council and parish meeting minutes, which are open to inspection by local government electors for the area (Local Government Act 1972, section 228), and which councils commonly publish. Inspection rights are not themselves a licence to republish, so we apply the same proportionality test to them as to everything else.
• The London Gazette, the UK government's official public record. Its notices (such as probate, bankruptcy and honours) are published to be publicly read, and are available under the Open Government Licence.
• Censuses, wills and probate calendars, released to the public by the National Archives and the courts.
• Gravestones and memorials in a public churchyard.

Being public does not automatically make re-publication unrestricted, and we do not treat it as if it did. We consider whether re-publication in this archive is consistent with what people would reasonably expect and whether it is proportionate. In practice, historic records published for the purpose of public notice or public inspection carry no expectation of privacy in the way that a private letter would.

Compatibility with the original purpose

Parish registers, censuses, minutes and newspapers were created for other purposes: recording sacraments, counting the population, running a council, reporting the news. UK data protection law treats further use for archiving in the public interest or historical research as compatible with the original purpose (UK GDPR Article 8A, inserted by the Data (Use and Access) Act 2025, provided the safeguards in Article 84B are met). Compatibility does not by itself make processing lawful (Article 5(3)), so it still needs its own lawful basis. We do not use any of the data for an unrelated purpose.

That rule is aimed at further use by the body that first collected the data. This site is a separate, independent project, so we do not inherit the parish's, the General Register Office's or a newspaper's original purpose. We have our own purpose (archiving and historical research) and our own lawful basis, set out below.

Lawful basis

Our lawful basis is legitimate interests (UK GDPR Article 6(1)(f)). Our interest is preserving and sharing the recorded history of a community. Processing is necessary for that, and given the age and public nature of the records, the minimisation described above, and our willingness to act on individual concerns, we consider it proportionate to the interests of any living person named. We do not rely on "public task" (Article 6(1)(e)), because a volunteer archive has no task laid down in law. We do not rely on consent for the archive, since it would be impossible to obtain from the people named in historical records.

We follow the safeguards for processing for archiving and research purposes in UK GDPR Articles 84B and 84C. Identifiable data may be processed for these purposes only where the purpose cannot be fulfilled without it (Article 84B(1)). A register of named baptisms, marriages and burials, or a list of the names on gravestones, cannot serve its purpose without names. We also hold only the data needed, we do not use it to make decisions or take measures about any individual, and we do not process it in a way likely to cause substantial damage or substantial distress to anyone (Article 84C). Where old records happen to include special-category data, such as health, we rely on Article 9(2)(j) together with Schedule 1, Part 1, paragraph 4 of the Data Protection Act 2018. Criminal offence data, such as historic convictions reported in newspapers or court records, is handled under Article 10 and section 10(5) of that Act, again with Schedule 1, Part 1, paragraph 4. The same test applies to both kinds of data: the processing must be for archiving in the public interest and not likely to cause substantial damage or distress.

Journalism, newspapers and quotation

The site quotes from newspapers, such as the Bucks Herald, and other journalism, reporting events in the village. The material was published lawfully by news organisations, often for the express purpose of informing the public about court hearings, council business and community life.

Where we reproduce or discuss that reporting, we rely on the special purposes exemption in the Data Protection Act 2018 (Schedule 2, Part 5, paragraph 26), and on the general right to freedom of expression. The special purposes are journalism and academic, artistic and literary purposes. A local history site is most naturally academic and literary, and it republishes what journalists originally reported. The exemption applies where processing is undertaken with a view to publication, we reasonably believe publication is in the public interest, and we reasonably believe that complying with a particular provision would be incompatible with that purpose. In judging the public interest we have regard to the relevant codes of practice, such as the Editors' Code. We consider each case on its merits and do not treat the exemption as blanket.

Copyright and fair dealing

UK copyright law does not have a general "fair use" defence as in the United States. It has specific fair dealing exceptions in the Copyright, Designs and Patents Act 1988. We rely mainly on the exception for quotation (section 30(1ZA)) to quote short extracts from newspapers and other works that have already been made available to the public. The quotation must be fair dealing, no longer than the purpose requires, and accompanied by sufficient acknowledgement, so we always name the source and date. Where we are genuinely reviewing or criticising a published work, section 30(1) may also apply. We do not rely on the research exception (section 29) for material published on this site, as it does not permit publishing copies to the public.

Very old works, such as sixteenth-century registers and most nineteenth-century newspaper text, are out of copyright. Government records may be Crown copyright, reused under the Open Government Licence.

Some pages go beyond short quotation and reproduce a whole newspaper clipping or photograph, for example press images from the twentieth century. Reproducing a whole image is a weaker case for fair dealing, and such material may still be in copyright or of unknown ownership. We reproduce it to document local history, credit the source where we know it, and make no claim to own it. Other photographs and original material on the site belong to their owners or are used with permission.

If you own copyright in something here and would like it credited, licensed, or removed, please contact us and we will act promptly.

Right to erasure and other rights

If your personal data appears on this site, UK GDPR gives you certain rights, including access, rectification, objection and erasure. These are limited on an archive as follows:

• Deceased people: the rights do not apply, although we will still correct genuine errors.
• Erasure: the right to erasure (Article 17) does not apply to the extent that processing is necessary for archiving in the public interest or historical research and erasure would be likely to make that objective impossible or seriously impair it (Article 17(3)(d)), or for the exercise of freedom of expression (Article 17(3)(a)). An archive that could be altered on request would no longer be a reliable record. Removing a name from a parish register transcription, for example, would falsify the record.
• Objection and other rights: because we rely on legitimate interests, you may object under Article 21(1) and we must stop unless we can show compelling legitimate grounds. For archiving in the public interest, Schedule 2, paragraph 28 of the Data Protection Act 2018 disapplies several rights, including access, rectification, restriction, objection and portability, to the extent that they would prevent or seriously impair the archive. Where we also process for historical research, paragraph 27 may apply as well.

Those exemptions are not a reason to refuse everything. We will always consider a request from a living person, and where their concerns outweigh the archival value, particularly where a person is living, the information is not essential to the historical record, and there is a risk of harm, we will remove or redact it, or restrict what is shown. We will also correct inaccuracies. We aim to reply within one month.

To make a request, email [email protected] with the page address and what you would like changed. You also have the right to complain to the Information Commissioner's Office at ico.org.uk.

Retention

Archive content is kept permanently, as that is the purpose of an archive. Emails you send us are kept only as long as needed to deal with your message and any resulting change to the site.

Visitors, cookies and third parties

We do not run advertising or analytics, do not use tracking cookies, and do not ask visitors to create accounts. The site loads fonts from Google Fonts, which means your browser sends your IP address, and standard request details such as your browser type, to Google, a third party outside our control. Google handles that data under its own privacy policy, and it may involve transfer outside the UK. Some pages link to external sites (such as record offices, newspaper archives and mapping services) that have their own privacy policies.

The only personal data we collect directly from visitors is what you choose to send us by email, which we use only to reply.

Changes to this policy

We may update this policy as the site or the law changes. This version was last reviewed on 20 September 2026 and reflects the UK GDPR as amended by the Data (Use and Access) Act 2025.