WAYWARD PRODUCTION HOUSE PRIVACY POLICY
Last revised: 4/11/2021
Introduction
Wayward Production House is committed to processing personal information (“PI”), or sensitive personal information (“SPI”), in line with all applicable privacy and data protection laws. For the purposes of this policy “we”, “us” or “our” means Wayward Production House.
References to “you” or “your” refers to individuals whose PI is processed by Wayward Production House, including clients with direct or indirect relationships.
PI is information relating to an individual, which can be used either alone or with other sources of information to identify that individual. PI does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. SPI is a sub-category of PI that includes PI relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data. This is legislated for under the General Data Protection Regulation (2018).
The nature of the information that we collect will depend on the services we provide and our relationship with you. We categorize PI we process as follows (the PI listed for each category are non-exhaustive examples):
Identification data – These are the categories covered by Law under GDPR. It is not likely many of these will be processed by us.
Full name, title, gender, marital status, date of birth, passport number, driving licence number, national identification number, signature
Contact data
Personal address, telephone number, email address
Electronic Monitoring data
To the extent permitted by law, we may record and monitor your electronic communications with us
Financial data
Bank account number; credit card number
Marketing and Communications data
Marketing and communication preferences; tracking data relating to whether you have read marketing communications from us
Professional Information data
Position/job title, work address; telephone number; email address
Payment details to and from you; details of services you have provided to us or we have provided to you
Technical data
Your use of and interaction with our online services; your IP address; browser type and version; browser plug in types and versions; operating system
SPI
We collect PI in relation to you in a number of ways, including:
when you provide it to us in connection with a Wayward Production House product or service, such as an application form or via email.
if you are Representative of an organization or entity that is a client or vendor of Wayward Production House and that organization or entity provides us with your PI
throughout the course of our relationship with you, including where you change your details, provide additional PI, or where the services we are providing to you change
from public sources where you have manifestly chosen to make your PI public, including via public profiles on social media
from visits to our websites or through logging into any of our online services
We may also create or derive PI such as creating records of your interactions with us, subject to applicable law.
Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.
Purpose and legal basis for processing your PI
Basis of Processing (We will only gather your PI or SPI for these reasons)
· Identification data
· Contact data
· Services data
· Performance of a contract
· Legal or regulatory obligation
· Legitimate interests: ensuring we do not accept the proceeds of criminal activities or assist in fraudulent or any unlawful activities, such as terrorism
To deliver the services you have requested, including liaising with third parties · Identification data
· Contact data
To manage payments, fees and charges and to collect and recover money owed to us
· Identification data
· Contact data
· Services data
· Performance of a contract
· Legitimate interests: ensuring we can manage payments, fees and charges and to collect and recover money owed to us
To manager our relationship with you which will include notifying you about changes to our terms of business or this privacy notice
· Identification data
· Contact data
· Profile data
· Marketing and Communications data
· Professional Information data
· Performance of a contract
· Legal or regulatory obligation
· Legitimate interests: ensuring we can notify you about changes to our terms of business or this notice
· Legal or regulatory obligation
Broadly, we will process your physical image through recording and edit this in line with our contract for services.
To whom we disclose your PI
Only those who will be acting on your contract with us will have access to your PI.
Marketing and exercising your right to opt-out of marketing
We will not process your PI for marketing purposes if you have informed us you do not wish to receive marketing materials. You can request that we stop processing your PI for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a request to your usual Wayward Production House contact or by using the contact details set out in the “Contacting Us” section of this Privacy Notice.
Third-party marketing/sale of PI
We do not share or sell your PI to third parties for the third party to use for their own marketing or other purposes.
PI retention
We will process your PI for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims. Any digital media will only be held for as long as required for editing or 90 days otherwise
PI security
We use a range of measures to ensure a level of security appropriate to the risk of PI processing. These measures include:
education and training to ensure awareness of our privacy obligations when processing PI.
the ability to restore the availability and access to PI in a timely manner in the event of a physical or technical incident;
Cloud storage will be utilised and can only be accessed by 2 people with 2 factor authentication. Google and Microsoft will be the two companies providing this service for email and cloud storage solutions.
The security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. You should not send us any PI by open/unsecure channels over the internet. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.
Your rights
In certain circumstances you may have the following rights in relation to the processing of your PI:
Access
To request a copy of the PI we process in relation to you and to be informed about how we use and share your PI.
Object
To object to the processing of your PI if (i) we are processing your PI on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your PI for direct marketing purposes
Correction
To request that we update the PI we process in relation to you, or to correct PI that you think is incorrect or incomplete.
Erasure
To ask that we delete PI that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.
Restriction
To request that we restrict the way in which we process your PI, for example, if you dispute the accuracy of your PI or have raised an objection which is under consideration.
Portability
To request a copy of your PI that you have provided to us in a commonly used electronic format such as through the completion of an application form.
You may exercise your rights at any time by using the details set out in the Contacting us section. To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.
We may need to request specific information from you to help us confirm your identity and ensure your right to access to the PI requested, or to exercise any of your other rights. This is to ensure that PI is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the PI processed in relation to you, including, for example, the nature and location of your relationship with us.
We will respond to all legitimate requests in line with the timescales set out in applicable law.
You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.
Contacting us
Email us at info@waywardproductionhouse.co.uk
Complaints
If you have any concerns or complaints about the way your PI is processed, please contact us.
You also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your PI has arisen.
Cookie Notice
Cookies will be consented to on the basis of our website provider WordPress.com
Linked websites
This Privacy Notice is not applicable to third party websites that we do not own or control, or to any third-party website where Wayward Production House advertisements are displayed.
Changes to this Privacy Notice
We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. Any material changes will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
WAIVER
Wayward Production House will assume all guests at private functions consent to being filmed as part of our contract for services. In addition this assumes that all parent/guardians consent to under 18s being filmed for the purposes of completion of the contract for services and holding this data for up to 90 days.