GDPR Policy – Data Privacy Notice
This document outlines Kaleidoscope Creative Films Agency Limited EU GDPR policy. It is a ‘live’ document and we will update it as new information becomes available..
Kaleidoscope Creative Films Agency Limited is a small company with fewer than 5 employees. We have two main areas of business:
Film & media production, photography and journalism
Translation and editing through Simon Says (https://blog.simonsays.ai/faq-simon-says-extension-for-final-cut-pro-x-fbd9c49f2cc8)
Why do we collect data?
We collect data for normal business activities:
to complete our projects and contractual obligations
to research stories and projects for journalism projects
through documents and content supplied to us as part of our work (i.e. documents for translation, film files for review, text for content etc)
to market our services to existing and new clients
to invoice our clients, pay our suppliers and complete our annual accounts
as part of our own due diligence to comply with our public liability and indemnity insurance.
We do not sell or trade data or pass on data to third parties without the specific written permission of the data supplier. For example, if we are asked to recommend a colleague for a job etc.
We will share data if required to do so by law (e.g. by the police or as part of a legal process) or as part of our regular accounting activities (invoicing etc).
How do we collect data?
We collect data in usual ways:
Business to business contact scenarios (trade shows, meetings etc)
Introductions and recommendations
E-mail contact and on-line agency contacts (e.g. Linkedin etc)
Through our website & social media
Contact information in the public domain
What data do we collect?
Client/customer information: contact names, job titles, addresses, email, contact number, web addresses, social media information, billing information & bank details
Contributors for journalism/film projects: contact names, job titles, addresses, email, contact number, web addresses, social media information, photographs and digital film
We do not collect sensitive personal data (health, sexual orientation, dates of birth, school/college info etc) unless this is required for a particular project (e.g. a film or a journalism piece)
How do we store data?
Our contact lists are stored in Apple iOS (Mail & Contacts) and Google Android/Gmail address books, Gmail. All our computers and devices are password-protected with antivirus software installed.
We do not use facial recognition software.
We use some software as part of our workflows that stores data and metadata including:
Adobe Photoshop/Lightroom – for photography projects
Final Cut Pro/Adobe Premiere Pro/Davinci – film editing software
Quickbooks – cloud accounting software. This is shared with our accountants K3 Accounting
We understand that data stored on these systems cannot be deleted for legal reasons including the following:
Public liability and indemnity insurance purposes.
We need to be able to defend our work and back reference projects in case of legal challenge.
Data (including film footage and archive material) from old journalism projects/films may be required in future productions
Compliance for TV/film journalism.
It is a requirement that all invoices and company paperwork should be retained for 7 years for HMRC VAT purposes and longer for income tax purposes.
As such, if you have contributed to a project prior to 2018 (e.g. as an interviewee on or off camera or as vox pop etc.) this contribution will remain as part of that published work and as part of the rushes and research material that support that work. For legal reasons, we are required to retain information in the event that we need to defend published work.
As of 2018, anyone contributing to a project will be asked to complete a contributor consent form and this will cover data protection and rights. These contributor forms will be kept indefinitely or for as long as the programme/report that they pertain to remains active.
Data management & viewing your data
We regularly update our contact lists and delete old & irrelevant contacts.
If you wish to be removed from our contact list please send us an e-mail to email@example.com.
Although the final version of the film/photo may potentially be hosted on aforementioned websites permanently. We hold the RAW video content for a maximum of 4 years via external hard drives located in our offices (See address in footer).
This RAW content is destroyed by formatting the drive by using the Apple computer Disk utility – this process permanently deletes the content.
We have synthesised our GDPR policy from the following advice:
The Difference Collective: https://www.thedifferencecollective.com/how-can-freelancers-prepare-for-the-gdpr/
Apple Contacts etc: http://adage.com/article/digital/apple-revamps-privacy-controls-comply-gdpr/312920/Film London: http://filmlondon.org.uk/filming-people
Clients website (contact us for more info)