Footage First Limited Privacy Notice
About Footage First
Footage First Limited is a UK registered company engaged in audio-visual content production and related activities.
Footage First’s registered office is at St Paul’s House, 23 Park Square, Leeds, England, LS1 2ND
Footage First is committed to protecting the privacy of others and complying with all relevant data protection laws and regulations. This Privacy Policy sets out how Footage First collects and uses information about individuals, including those who are involved in the advertising and other content that we obtain and/or produce (collectively “Content”).
Please contact Footage First if you have any questions or concerns at: hello@footagefirst.co.uk
Why do we collect personal information?
We collect and process personal information in connection with Content for a number of reasons including:
operating and managing our business effectively and lawfully;
contacting individuals about taking part, and assessing individuals’ suitability to take part in Content that we produce;
as part of and in connection with our Content-making and other activities;
producing, exhibiting, exploiting, distributing, publicising, advertising and promoting our Content by any media (now known or hereafter invented) throughout the world; and
responding to queries from members of the public.
What personal information will we collect and why?
We will, are likely, or may process the following information about you in connection with the Content we produce which we may obtain from you directly or from a third party:
1. your name, your gender, your age and date of birth, your address and contact details such as your email address and telephone number, your handwriting, as well as other basic details about you. We need this information to correspond with you and to contract with you and for administrative and other purposes.
2. your image, your gender, your age and birth date, information contained within your passport, your driving licence and possibly other official documents which identify you. We need this information to check your identity and to ensure compliance with relevant laws and regulations.
3. information about your past and present personal, home and family life. We need this information to be able to assess your suitability to take part in Content and to comply with our contractual and regulatory obligations.
4. information about your past and present professional life including information about your current role and work schedule, your previous work history, your qualifications and your experiences. We need this information for administrative purposes, to be able to assess your suitability and availability to take part in Content and to comply with our contractual and regulatory obligations.
5. whether you consent or object to being identified in Content and if you object, the basis of your objection. We need this information to assess your suitability to take part in Content and to comply with our contractual and regulatory obligations.
6. information about you that is on social media and the internet including images of you and other personal information that is contained there. We need to process this information in order to verify your identity and to assess your suitability to take part in Content.
7. information concerning your physical or mental health. We do not routinely collect such information, but may process limited details where this is necessary to identify and implement reasonable adjustments..
8. information concerning any criminal convictions or cautions. We do not routinely collect this information, but may process limited details where we believe this is necessary to protect the safety of our staff, visitors and contractors, or where we have a legitimate business interest in safeguarding our business and our clients’ brands from association with criminality. Any such processing will be carried out only where permitted by law and subject to appropriate safeguards. .
9. your age, gender, gender identity, ethnicity, disability and sexual orientation. We will use this information for diversity analysis monitoring.
10. any and all personal information revealed or recorded on cameras and/or microphones and contained within footage and/or sound recordings made for Content (or provided by a third party to us in connection with Content) including your image and voice and potentially a very wide range of personal information relating to you revealed by you and others including without limitation:
10.1. your name; your gender; your age and date of birth; your address and contact details; information about your past and present personal, home and family life; information about your financial affairs; information about your past and present professional life including information about your current job, your position, work schedule and the nature of your work, your previous work history, your qualifications and your experiences and the details of any legal claim made by or against you and enforcement action taken against you or on your behalf, including any assets seized and the circumstances surrounding the seizure.
10.2. information concerning your racial and ethnic origin, political opinions, religious or philosophical beliefs, your membership of a trade union, your health and any medical treatment you receive, your sex life or your sexual orientation (“special category data”); and
10.3. information concerning any criminal convictions or cautions you may have and any other criminal activity you may have been suspected of or involved in; information concerning the nature and status of any arrests, charges, prosecutions, court proceedings or other interactions between you and the authorities (“criminal convictions and offences data”).
This information may be revealed incidentally within footage and/or sound recordings provided to us by third parties in connection with the Content, and is processed only to the extent necessary for editorial reasons and for the production, editing, delivery and exploitation of the Content, to comply with applicable legal obligations and to perform our contractual obligations.
Lawful bases for processing the above information
The first column of the following table refers to the types of personal information set out in the numbered paragraphs above. The second column lists the lawful bases we rely upon in order to process these types of data.
Para Lawful Basis
1 Processing is:
necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
Necessary for the performance of our contract with you or in order to take steps prior to entering into the contract.
2 Processing is:
necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
necessary for the performance of our contract with you or in order to take steps prior to entering into the contract.
3 Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
4 Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
5 Processing is:
necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
necessary for the performance of our contract with you or in order to take steps prior to entering into the contract.
6 Processing is necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce.
7 Processing is:
· necessary for the purposes of our legitimate interests and others; and / or
· necessary for the performance of our contract with you or in order to take steps prior to entering into the contract; and
· undertaken with your explicit consent.
8 Processing is:
· necessary to protect the safety of our staff and other contractors; and / or
· necessary for the purposes of our legitimate interests in safeguarding our business and our clients’ brands from association with criminality; and
carried out only where permitted by law and subject to appropriate safeguards under the Data Protection Act 2018.
9 Processing is:
· necessary for the purposes of our legitimate interests and others’ e.g. those that publish the Content we produce; and
· undertaken with your explicit consent.
10 Processing is:
· necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and/or
· necessary for the performance of our contract with you and/or with third parties and/or in order to take steps prior to entering into the applicable contracts; and/or
· necessary to comply with applicable legal obligations.
10.1 Processing is:
· necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and / or
· necessary for the performance of our contract with you or in order to take steps prior to entering into the contract and / or
· undertaken in connection with public interest journalism and/or
· necessary to comply with applicable legal obligations.
10.2 Processing is:
· necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and / or
· necessary for the performance of our contract with you and/or with third parties, and/or in order to take steps prior to entering into the applicable contracts; and
· undertaken with your explicit consent; and / or
· undertaken in connection with public interest journalism.
· In addition,
(i) following exploitation of Content, such information may be information manifestly made public by you and if so we may rely on the relevant provisions of the DPA 2018 for any further processing of that information; and /or
(ii) processing may be necessary to comply with applicable legal obligations.
10.3 Processing is:
· necessary for the purposes of our legitimate interests and others e.g. those that publish the Content we produce; and / or
· necessary for the performance of our contract with you and/or with third parties, and/or in order to take steps prior to entering into the applicable contracts; and
· undertaken with your explicit consent; and / or
· undertaken in connection with public interest journalism
· In addition,
(i) following exploitation of Content, such information contained within the Content may be information manifestly made public by you and if so we will rely on the relevant provisions of the DPA 2018 for any further processing of that information; and/or
(ii) processing may be necessary to comply with applicable legal obligations
Legitimate Interests
Where we rely on ‘legitimate interests’ as the lawful basis for processing data, such legitimate interests include our legitimate interests in making and providing Content for our clients to exploit, potentially worldwide. We only process data on this legal basis where we have considered that, on balance, our legitimate interests are not overridden by your interests, fundamental rights or freedoms.
Consent
Generally, we anticipate that individuals will give their informed consent to take part in and work on Content that we produce.
Where you have entered into a contract with us to participate in Content, we may be entitled to distribute and show the relevant Content whether or not you later change your mind about participation.
Consenting to take part in Content, and our reliance on your consent to process your personal data are two distinct, different things. We will not generally rely on your consent to process your personal data if you appear in Content. This is something which we normally do as part of our legitimate business interests, for contractual purposes and/or in connection with public interest journalism.
Where we do rely upon ‘consent’ to process your personal information, you have the right to withdraw your consent at any time, although please note that we may be relying on other lawful bases at the same time.
Sharing your personal information
Your personal information is processed by our employees and staff. Sometimes we use third parties who are contractually engaged to provide services to us that may involve the sharing of personal information e.g. IT services, legal and accountancy services. We also may need to share your personal information with other organisations from time to time including with:
· companies involved with our business activities e.g. broadcasters, SVOD platforms, post-production houses, sales agents, distributors;
· advertising regulators and advisory bodies e.g. Advertising Standards Authority, Clearcast. British Film Classification Service;
· the police or other regulatory bodies as required by law in connection with the investigation of crimes.
Although we are based in the UK, our business is global and so we may need to transfer your personal information outside the UK.
Wherever your information is transferred to organisations outside the UK, we will ensure that adequacy regulations or appropriate safeguards, such as standard data protection clauses recognised or issued in accordance with the UK data protection regime, are in place to ensure the safety and security of your personal information and that it is processed in accordance with this privacy notice (unless an exemption applies). You can find out more about these safeguards by contacting us using the contact details below.
How we store your personal information
We have implemented appropriate measures to ensure that your personal information is kept safe and secure e.g. by storing it securely, and by keeping electronic data on secure servers and hard drives with appropriate levels of security including encryption and firewalls. However, the internet is an open system and we cannot guarantee that unauthorised third parties will never be able to defeat those measures.
We will only keep your personal information for as long as we need to. For those participating in our programmes, we are likely to retain your personal information for as long as is necessary in order to produce, exhibit, exploit, distribute, advertise, publicise and promote the programme in accordance with our legitimate interests and legal obligations. Personal information that is no longer required will be deleted/destroyed.
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