DATA.LEGAL.COOKIES.
ECHO VELVET LTD PRIVACY POLICY
In this privacy statement any reference to EVL, we, us or our is to Echo Velvet Ltd. Echo Velvet Ltd is a company registered in England and Wales (company number 13131329.) with registered offices at 71-75 Shelton Street London WC2H 9JQ.
WHO WE ARE
Echo Velvet Ltd is an independent, multi-media production company working in television, film, audio, events, digital and commercial.
DATA PROTECTION
EVL highly values the importance of protecting the privacy of its staff, contributors and all those (including third parties) involved in the creation, production and distribution of its content. This Privacy Policy sets our procedures and measures used in order to protect all Personal Data collected, processed or stored regarding any identified or identifiable living person. This policy will explain how we look after your personal information and inform you of your rights and regulations relating to the protection of personal data, in accordance with UK laws and guidance, including the Data Protection Act 2018 and the General Protection Regulation ((EU) 2016/679) (GDPR),
EVL reserves the right to amend this policy as needed, to comply with changes in laws, regulations, corporate practices and procedures or requirements imposed by data protection authorities. Any modification will come into force immediately from the date on which the updated policy is distributed
YOUR PERSONAL DATA: WHAT INFORMATION DO WE COLLECT & WHY?
Personal data collected by us or provided to us is either provided directly by the individual concerned (and in the case of Special Category Data this includes the completion by you of self-declaration forms, statement of health forms, visa or other application forms or similar) or by a third party acting on behalf of an individual (and in the case of Special Category Data this includes letters or other communications about your health from a medical professional or the results of any medical examinations or test) or obtained from a publicly available source, including press articles, social media profiles, online searched, database searches ( and in the case of Special Category Data this includes publicly available information such as articles, social media posts and accounts) about your political or religious views, sexual orientation, ethnicity. Where we receive personal data that relates to an individual from a third party acting on behalf on an individua, we request that this third informs the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.
Information collected will be relevant to the relationship and/or communications between EVL and the individual. Only necessary data will be collected.
Personal data may be processed for various purposes, including but not limited to:
- Job applicants, staff and contractors – Contact and other Information from you – in relation to any enquiries, or other issues. This can include names, addresses, images of individuals, telephone numbers, personal email addresses, bank and pay roll details including NI number and tax status, passport particulars, dates of birth, next of kin, internet protocol addresses and information automatically collected when an individual uses a computer/the internet (“Personal Data”).
- Social media data – When such access is made to our website or other on-line services from a social media service or you direct us to social media services, you are authorising us to collect and use such personal data in accordance with this Privacy Policy.
- Other Sources – We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available services.
- Collection of Personal Data includes, whether or not by automatic means, collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure (including by transmission, dissemination or otherwise making available), alignment or combination, blocking, erasure or destruction of said data.
- Responding to member of the public enquiries, job applications, enquiries and/or applications to participate in a show, assessing suitability of individuals who participate in our shows as contributors.
- Marketing – Personal information will not be used for any marketing or sales purpose, unless specific permission is given by you, in the exploitation of our programming.
- Website – When you visit our website, the site may collect information which will be used to ensure our website is presented in the most effective way for you and your computer, and for internal record keeping. For further information please read the cookies section below.
WHAT DATA IS PROCESSED BY US AND WHY?
All data processed by us, in compliance with the laws of England and Wales, for the processes included below:
- Members of the public, who contact us by phone, email, via our website, online, or otherwise in writing – this information may include your name, address, email address, IP address, phone number and handwriting – to correspond with you and for administrative purposes, where necessary to fulfil legitimate business practices
- Contributors, Staff & Contractors, information may include your name, address, email address, IP address, phone number and handwriting – to correspond with you and for administrative purposes, (where necessary to fulfil legitimate business practices and for the performance of our contract with you or steps taken prior to entering into it); your image, passport details or other national identification, driving licence, national insurance or social security number and other official documentation – to verify your indent in compliance with relevant laws (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it); your employment qualifications and experiences – to access your suitability to take part in our programmes and/or comply with contractual and regulatory obligations (with such processing being necessary for the purpose of our legitimate interests).
- Information to access your suitability, about your personal, home and family life to take part in our programmes and/or comply with contractual and regulatory obligations (with such processing being necessary for the purpose of our legitimate interests).
- Information about you on social media and the internet including images of you and other information – to verify your identity and to assess your suitability to take part in our programmes (with such processing being necessary for the purposes of our legitimate interests);
- Information regarding your mental and/or physical health – to assess your suitability to take part in our programmes and/or comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it – and undertaken with your consent or if made publicly available to you) (see Special Category Data below);
- Information about any criminal convictions or cautions you have or any criminal activity or proceedings you been involved in – to assess your suitability to take part in our programmes and/or to comply with contractual or regulatory obligations (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it – and undertaken with your consent or if made publicly available to you) (see Special Category Data below);
- Your financial details including your bank account details – for the purpose of reimbursement of pre-approved costs or expenses (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it); your age, gender, gender identity, ethnicity, disability and sexual orientation – for diversity analysis monitoring (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it – and undertaken with your consent or if made publicly available to you) (see Special Category Data below);
- Information contained in footage filmed for our programmes or provided to us including a very wide range of personal information about you including: your image; your age; date of birth; handwriting; information about your personal, home and family life and your work history, qualifications and experiences (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you);
- Information about your racial and ethnic origin, political opinions, religious or philosophical beliefs, membership or a trade union, health, sex life or sexual orientation (with such processing being necessary for the purposes of our legitimate interests and/or the performance of our contract with you – and if made publicly available by you or undertaken with your explicit consent and/or in connection with public interest journalism) (see Special Category Data below); and
- Information about any criminal convictions or cautions you have or any criminal activity or proceedings you have been involved in (so called ‘criminal convictions and offences data’) (with such processing being necessary for the purposes of our legitimate interests and/or the performance of our contract with you – and if made publicly available by you or undertaken with your explicit consent and/or in connection with public interest journalism) (see Special Category Data below);
We need the information in such footage for editorial reasons and for the production of our programmes, for contractual reasons and obligations we have to third parties, and/or to comply with our obligations to you pursuant to our contract with you. If we intend to process your personal information with your consent, we will seek your explicit consent.
We will only process your personal information for our legitimate interests where our legitimate interests do not override your own legitimate rights and interests.
Following the exploitation of our programmes, any information about you in them will have been manifestly made public by you and we may also continue to process it on that basis.
WHO DO WE SHARE YOUR INFORMATION WITH?
EVL will only share personal data with others where we are permitted to do so, within a framework of contractual arrangements and security mechanisms in place to protect the data to comply with our data protection, confidentiality and security standards.
Only relevant staff and departments will use your information for the purpose of producing the programme and providing financial, contractual and legal advice and/or services for the development. Production and distribution of the programme.
We may pass your information (including Special Category Data) to our third-party service providers such as agents, subcontractors and other associated organisations for the purposes of facilitating your applications for inclusion in a programme your or interested in taking part, whether on or off screen.
This may include third parties who are contractually engaged service providers, e.g IT Services, health & safety advisors, insurance brokers and underwriters, legal advisors and accountancy services. However, when we use third party service providers, we disclose only those elements of your information that are necessary to deliver the required services.
We may share your information with other organisations, from time to time, including with companies involved with out business activities (e.g broadcasters, post-production houses, sales agents, distributors, financiers), broadcasting regulators (e.g Ofcom), the police or other regulatory bodies as required by law in connection with the investigation of crimes or to establish, excise or defend legal rights.
We may share Special Category Data about you with members of the production team, and with the parties set out above, and (to the extent you provide such information as part of your contribution to a programme and the same is incorporated in a programme and/or we include details of your biography background and past experiences in a programme) with the public on transmission of the programme in which you appear.
SPECIAL CATEGORY DATA
Data protection legislation recognises certain “Special categories” of personal information, which is information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health, and information concerning a person’s sex life or sexual orientation. Information relating to criminal offences and convictions is treated in a similar way.
SECURITY
EVL takes seriously the security of all data collected. Appropriate measures and safeguards to ensure personal information is kept safe and secure include the following:
- Information is restricted to those personal who required the information to fulfil their contractual obligations. All information is stored on a secure server with areas of the server being restricted to minimal staff to comply with this policy.
- Staff are trained on data protection, confidentiality and security.
- Data mapping on who is allowed what information are in use.
- All staff have a framework of policies and procedures to ensure security, these are reviewed regularly.
The transmission of information via the internet and/or email is not completely 100% secure and although we do our best to protect your personal data, we cannot guarantee the security of your data transmitted by these means; any transmission is at your own risk. Once we have received your information, we will use our procedures and security measures to try to prevent unauthorised access.
DATA STORAGE AND RETENTION
EVL do not retain your information for longer than in necessary for the purpose it was collected. The duration for retention is based on requirements for us to comply with legitimate interests and to perform our contractual obligations, or as required by law or regulatory obligations.
For those participating in our programmes, we will likely keep your information for as long as required to produce, exhibit, exploit, distribute, advertise, publicise and promote the programme that your information relates to, in accordance with our legitimate interests and legal obligations.
Personal data that is no longer required will be deleted and/or destroyed.
DIVERSITY MONITORING
EVL contributes to a television industry-wide diversity monitoring initiative called Diamond. Diamond uses personal information regarding on and off-screen contributors to programmes to monitor the diversity of television production in the UK and how viewers might perceive diversity on screen. There is a legitimate interest in collecting diversity information about our industry.
If you have provided us with your name and email address (and unless you have requested us not to) we will share this with Creative Diversity Network Ltd (CDN) and the broadcaster of the programme you have participated in via Soundmouse and/or Silvermouse online systems, and you will be invited to participate in the Diamond project and to provide information regarding your diversity characteristics, such as gender, ethnicity, disability, age, gender identity and sexual orientation. All information is collected, processed and stored anonymously on the Diamond system, with the relevant data held by CDN and the applicable broadcaster as data controllers, CDN and the applicable broadcaster will retain your name and email address for this purpose in Silvermouse and/or Soundmouse for as long as diversity monitored by them. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice. EVL do not accept any responsibility or liability for these policies, websites or any of their content.
Further information about Diamond can be found here:
http://creativediversitynetwork.com/diamond-contributors/
YOUR RIGHTS
You have certain rights over your personal data including the following:
- Individuals may request access to their personal data held by us;
- Request that we rectify any inaccurate personal data that we hold about them;
- Request that we erase their personal data;
- Where we process personal data based on consent, individuals may withdraw their consent at any time;
- Individuals may have other rights to restrict or object to our processing or personal data and the right to data portability; and
- Individuals may request information about any automated data processing that we may undertake.
If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact [email protected]
Please note these rights are not absolute are limited to certain defined circumstances. Accordingly, we may not be able to comply with any such requests.
COOKIES
WHAT ARE ‘COOKIES’?
Whenever you use our websites, our mobile sites, our mobile applications or our applications on any other device, information may be collected through the use of cookies and similar technologies. Cookies are small text files which are downloaded to your computer or device when you visit a website or application.
Cookies are very useful and do lots of different jobs, helping to make your experience on websites as smooth as possible. For example, they let you move between web pages efficiently, remembering your preferences, and generally improving your experience. Where relevant, they might also help to ensure that adverts you see online are relevant to you and your interests.
Cookies, in no way give us access to your computer or any information about you, other than the data you choose to share with us.
Your web browser (such as Internet Explorer, Mozilla Firefox or Google Chrome) then sends these cookies back to the website or application on each subsequent visit so that they can recognise you and remember things like personalised details or your user preferences. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.
Managing your cookies: most modern browsers will allow you to:
- See what cookies you’ve got and delete them on an individual basis.
- Block third party cookies.
- Block cookies from particular sites.
- Block all cookies from being set.
- Delete all cookies when you close your browser.
This may prevent you from taking full advantage of your website.
THIRD PARTY AND OTHER LINKS
EVL’s website may, from time to time, contain links to and from ither websites. If you follow a link to any other website, please be advised that these websites may have their own privacy policy and we not accept any responsibility or liability for these policies, websites or any of their content.
LOCATION OF DATA COLLECTION NAD PROCESSING
Although Echo Velvet Ltd is based in the UK, we do operate globally which means that data collected may be transferred to and stored in a destination outside the UK and/or European Economic Area (“EEA”). Where is takes place, we will ensure that adequate safeguards are in place to ensure the safety and security of your personal information and that it is processed in compliance with this privacy statement.
CHANGES TO OUR PRIVACY POLICY
EVL reserves the right to review and amend this policy as needed, at any time, to comply with changes in laws, regulations, corporate practices and procedures or requirements imposed by data protection authorities. Any modifications will come into force with immediate effect, upon distribution. All changes will appear on our website.
HOW TO CONTACT US
EVL has a Data Protection team, who are primarily responsible for Echo EVL’s compliance with this Privacy Policy.
The Data Protection team will take appropriate technical, physical, and organizational measures to protect Personal Data against unauthorised access, unlawful processing, accidental loss or damage, and/or unauthorised destruction.
The Data Protection team will undertake yearly reviews of what Personal Data has been acquired, processed or stored and ensure that all such Personal Data is relevant for the purpose and is not excessive.
All senior executives, managers, legal and business affairs and IT teams fully familiarize themselves with this policy, its requirements and provide appropriate support to the Data Protection team.
DATA PROTECTION
Contact email : [email protected]
FURTHER INFORMATION
Further information about data protection compliance and best practice guidelines is also available on the applicable regulator’s website:
A. http://www.ico.gov.uk/ UK: Information Commissioner’s Office –
B. https://www.ftc.gov USA: Federal Trade Commission
You also have the right to complain to the Information Commissioner’s Office in the UK or equivalent regulator if based outside the UK.