This policy explains what data we collect about you and why, how we use it and who we share it with, as well as your rights as a data subject. Your information is very important to us and we will look after it in line with all laws and regulations relating to the protection of personal data, including the General Data Protection Regulation ((EU) 2016/679).
WHO ARE WE?
Any reference to “we”, “us” and “our” is to Hamlett Films Limited. We are known as the “data controller” of your personal data and you can contact us at email@example.com or write to us at Data Protection Officer, 13, Ellingfort Road, London, E8 3PA, for more information about how we process your data, including how to exercise your rights as a data subject.
WHAT PERSONAL INFORMATION DO WE PROCESS ABOUT YOU?
The information we process may include your name, address, email address, IP address, gender, date of birth, age, phone number, passport details or other national identifier, driving licence, your national insurance or social security number and income, employment information and details about your previous roles and personal history. We collect information about you from a number of sources, including from you directly. See below for more information.
- Information that you give us:
- from any documentation that you complete when you apply for a role or part in, or contribute to, a programme or film when you provide it to us in correspondence and conversations (e.g. application telephone interviews, pre-filming questionnaires and release forms);
- when you apply, participate or contribute to a programme or film, and you provide information which is relevant to your application or contribution. The information will be dependent on the nature of the programme or film, but where relevant this could also include special category data such as medical information, political opinions, sexual orientation and where relevant your criminal history. The nature of the programme and the information which we will be asking you for will be explained to you in advance; and
- with your consent, we will pass your email address to Silvermouse and Soundmouse who may contact you as part of the television industry’s commitment to monitoring diversity as part of the Diamond project. This is the diversity monitoring system managed by the Creative Diversity Network (CDN) on behalf of UK broadcasters BBC, ITV, Channel 4, Channel 5 and Sky. You can find out more about Diamond here: http://creativediversitynetwork.com/diamond-contributors/.
- Information we obtain from others:
- publicly available and accessible directories and sources;
- social media platforms, including Facebook, Instagram, Twitter, Linkedin;
- governmental and competent regulatory authorities to whom we have regulatory obligations;
- agents and production companies;
- fraud prevention and detection agencies and organisations; and
- where we need to do so for regulatory purposes, and this is in the public interest, crime enforcement and criminal records agencies.
HOW DO WE USE THIS INFORMATION?
We collect information about you to assess your suitability to contribute and participate in a programme or film. If you are selected to participate in one of our programmes or films we will use the personal information you have provided us for the purposes of developing, producing, distributing and administering the programme or film you have chosen to participate in.
Your personal information will not be used for any marketing or sales purposes. However we may, subject to your agreement, contact you about other programmes or films we think you may be interested in.
However we use your information, we will make sure that such use complies with all laws and regulations relating to the protection of personal data. Such laws and regulations allow us to use personal data for a variety of reasons. These include:
- in order to perform our contractual obligations with our clients, customers and suppliers;
- where we have obtained your consent;
- in order to discharge our legal and regulatory obligations;
- in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- as is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business (being the development, production and distribution of programmes and films);
- to commercially make full use of either the entire programme, film or clips thereof in the UK and around the world, for the period in which we have rights in the programme or film. We also keep an archive copy of the programme or film after our rights have expired;
- to share with our professional advisors and/or the commissioning entity or commissioning broadcaster that we are producing the programme or film for, any co-producer that we are producing the programme or film with, and/or any financier of the programme or film;
- maintaining compliance with internal policies and procedures; and
- monitoring the use of our intellectual property.
WHO DO WE SHARE YOUR INFORMATION WITH?
Your information will be used by the relevant production team for the purposes of producing the programme or film and preparing contractual documentation and payment, if required.
No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of Hamlett Films requires access to any personal data that they do not already have access to, such access should be formally requested from the Data Protection Officer.
We will not share your personal information with any third parties, unless you give us your consent to do so or we are authorised to do so by law.
DATA STORAGE AND RETENTION
We do not retain your information for longer than necessary for the purpose it was collected. Data will be stored securely using passwords and in the case of “special category data” or “sensitive personal data” by use of encryption. After such time that we no longer need the data, all electronic copies will be deleted.
We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.
In general we keep your information only for the period we have legal rights to exploit the programme that your information relates to. We will usually delete your personal information at the end of that period, but it is likely this period will be 6 years.
ACCESSING YOUR INFORMATION
You have rights when it comes to how we handle your personal information. These rights include:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
- Please contact us at firstname.lastname@example.org, or write to Data Protection Officer, Unit 13, Ellingfort Road, London, E8 3PA, or you may call 020 8525 04 38 if you wish to make a request.
If you would like a copy of some or all of your personal information, please contact us directly using the contact details above. If we cannot comply with your request to exercise your rights we will usually tell you why.
LINKS TO OTHER WEBSITES
Our website may, from time to time, contain links to and from other websites. If you follow a link to any other website please note that these websites may have their own privacy policies and we do not accept any responsibility or liability for these policies.
This policy was last updated in May 2023.
INFORMATION COMMISSIONER’S OFFICE (ICO)
Hamlett Films’ ICO Registration Number: ZB406287
The ICO is the UK’s independent body set up to uphold information rights.
If you have any concerns about our use of your personal information, you can make a complaint to us at Data Protection Officer, Unit 13, Ellingfort Road, London, E8 3PA; or email@example.com with “FAO Data Protection Officer” in the subject heading.
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk