Version 18th May 2018
We are the controller of your data (data provided to us by you) and are responsible for it. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We are also a processor of data on behalf of a controller (data provided to us by our clients), in which case we are not responsible for it, but the same standards of privacy will apply.
We treat any personal information (which means data from which you can be identified, including your name, address, e-mail address) that you give us, or that we obtain from you/our clients, in accordance with the provisions of the General Data Protection Regulations. Under these regulations we have a legal duty to protect any information we collect from you.
Contacting Us & Complaints
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at firstname.lastname@example.org
You have the right to make a complaint at any time to the Information Commissioner?s Office (?ICO?), the UK supervisory authority for data protection issues. The ICO?s website can be viewed at www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please always contact us in the first instance.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (to provide you with services). In such a case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. We accept no liability under contract if it cannot be performed due to your withholding of data from us.
Data We May Collect
Personal data means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How We May Collect It
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us data by filling in enquiry forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you, for example:
- Enquire or instruct us for our services;
- Send us invoices for payment
- Give us feedback.
- Other Data Controllers or Processors. When our client is a data controller or data processor of your data (and so we are a processor or sub-processor, respectively), we may be provided with your data in order to fulfil our contract with our client. We do not take responsibility for the privacy standards of our client, but endeavour to ensure they meet with the legal minimum. In any event, our standards of privacy will apply to your data whether we have obtained information directly from you or from a controller client. At the conclusion of the contract the data collected will be either retained or deleted according to the requirements of each client. If it is retained then it will be retained in accordance with the privacy standards outlined in this policy.
How We Use Your Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative), and your rights, before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Where we need to comply with a legal or regulatory obligation.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
We will only process personal data, including sensitive personal data, lawfully where it has a valid basis for the processing. Generally, processing is necessary for the performance of a contract to which the data subject is party and is necessary for the legitimate interests pursued by a client or Throwaway Productions Ltd except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. This ground may apply to the processing of the personal data of any third party data subjects whose personal data are provided by the client.
Reasons for Collection and Processing of Data:
We will only collect personal data for a specific, legal and legitimate purpose and be in accordance with the individual?s consent or the processing is otherwise permitted by law.
- You contact us via email or our website
- We register you as a new customer or supplier
- To manage our relationship
- Performance of a contract with you, process and deliver work (e.g. film production)
- Permission and release forms (for appearance in still or motion picture content)
- Managing financial payment processes and general accounts management
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Sharing Your Data
We may have to share your personal data with the parties set out below for the purposes set out above.
- Professional advisers acting as processors including lawyers, bankers, accountants and insurers based in the United Kingdom, who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data Security & Retention
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. As above, they will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. However, we retain video footage and stills indefinitely.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and contractual legal limitation purposes.
We do not sell, trade or rent your information to other parties.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a ?data subject access request?). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or legitimate business reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
In most circumstances you will not have to pay a fee to access your personal data (or to exercise any of the other rights above).
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to hasten our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.