On this page you can read the following:
This website and its social media feeds content is copyright of The Film and Television Charity, 22 Golden Square, London. W1F 9AD (Registered Charity No: 1099660. A Company limited by guarantee. Registered in England and Wales No: 4816786)
Reproduction of part or all of the contents in any form is prohibited other than the following:
You may print or download to a local hard disk extracts for your personal and non- commercial use only. You may copy the content to individual third parties for their personal use, but only if you acknowledge the website as the source of the material.
Individuals may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.
Organisations may not use, reproduce or exploit our content without our express written permission.
1.0 Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We do not spam or support the practice
- We will never sell, rent or make public your personal information or, except as necessary to carry out our charitable objects, otherwise share it
2.0 Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
UK Data Protection Act 2018 (DPA)
EU General Data Protection Regulation 2018 (GDPR)
This site’s compliance with the above legislation, means that this site may be compliant with the data protection and user privacy legislation set out by many other countries and territories as well, but this site and our activities are focused on the United Kingdom. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0) for clarification.
3.0 Personal information that this website collects and why we collect it
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, we use Google Web Analytics (GWA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GWA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GWA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider GWA to be a third party data processor (see Section 6.0 below).
FYI: Disabling cookies on your internet browser will stop GWA from tracking any part of your visit to pages within this website.
3.2 Contact forms and email links
Should you choose to contact us using an enquiry form, complete an online order, make an online donation or fill out a form in order to download an information pack, the data you supply will be stored by this website as further detailed in section 6.1 (with the exception of your payment information). Some data may be passed to or processed by the third-party data processors defined in Section 6.0. Some data will also be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP).
Any information sent to the charity using an email address within the page content is sent directly to the charity’s email servers using whatever email protocols your own device has set up (i.e. using the local email client) and no record of these communications is held on the website server at all. Therefore, this information is held only within the Charity’s email system which is provided by a third party data processor defined in Section 6.0.
3.3 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic newsletter-style emails from us.
4.0 How we process your personal information
4.1 Submitted data
Data submitted to us for processing will be securely retained within our secure IT system. All data within this system is subject to additional password protection and encryption.
We retain only the basic data required to deliver our services to you. This is typically Name, Address, Email address, Subscription start/end details and contact opt-in details.
Where you have applied for financial assistance as part of your application you may be required to provide information about your personal finances, your family or household, your health, any disabilities, your eligibility for other financial support services, details about your employment, your employment history and your CV. We may also process your bank account details for the purposes of making a payment to you. We may use identity documents you provide for the purposes of verifying your identity.
We may process information about your transactions with us if you donate to us or we make a payment to you.
4.2 Opt-out list
We also maintain a list of people who have opted out of receiving communications from our organisation. Should you attempt to opt-in having opted out previously we will contact you to confirm this decision and for your approval to remove you from the opt-out list. All mailings will be screened against our opt-out list.
4.3 Right to be forgotten
We fully support your right to be forgotten which can be applied by writing to our Data Protection Officer at Section 9.0 giving your identifying details and requesting removal of all material from our data systems. Our DPO will conduct a full sweep of all systems and remove your personal data, this includes our opt-out lists. Once complete the DPO will advise you of this action. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4.4 Identity Verification
Where we or our sub-processors use an identity verification service to verify your identity as part of a grant making process, we may collect information about you from such service provider, further details of which can be found in section 6.7. The information we or our sub-processors share with such service providers includes: Name, Address, Date of Birth and Mobile phone number and the information provided to us or our sub-processors by such service providers includes Name, Address, Date of Birth and Mobile phone number.
4.5 How we use your personal 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 we have entered into a contract with you or made a grant to you or you have made a donation to us, or in each case we or you are considering doing so.
- 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.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Where you have provided sensitive personal data (usually as part of a survey or, usually limited to personal data about your health, in respect of a grant application), we will only process the data with your consent or, where permitted under the DPA and the GDPR and where consistent with our charitable objectives.
Where you have applied for a grant we will use the information you have provided (described in section 4.1) to assess your application.
4.6 Your legal rights
Under certain circumstances, you have rights under the DPA and GDPR in relation to your personal data 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 as further described in section 4.2.
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 override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
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 wish to exercise any of the rights set out above, please contact our Data Protection Officer, referred to in section 9.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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 speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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
4.6 How Long Your Personal Data is Stored for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.5.0 About this website’s server
This website is hosted on a server provided and managed by TSOHost, details of which can be found in Section 6.1.
6.0 Our third-party data processors
We use several third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in Section 2.0.
6.1 Website Hosting Provider (Amazon Web Services)
6.5 Fat Beehive
We utilise Fat Beehive as the agency for the website, they have implemented the platform and as a result have access to live site data.
6.7 British Film Institute (BFI)
The BFI is assisting us with processing applications for grants made from the COVID-19 Relief Fund and may also assist with answering phone calls and administration. Your application for such a grant will be shared with the BFI. The BFI may also carry out identity verification using third party processors, such as GB Group plc (GBG), further details of which can be found in section 4.4.
7.0 Data Security and Data breaches
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. 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 report any unlawful data breach of the personal data we hold, this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data Controller
The data controller of this website is: The Film and Television Charity, 22 Golden Square, London. W1F 9AD.
9.0 Data Protection Officer
Alan de Sousa Caires, The Film and Television Charity, 22 Golden Square, London. W1F 9AD
Telephone: 0207 437 7186
10.0 ICO independent advice
For independent advice about data protection, privacy and data-sharing issues, you can contact the Information Commissioner at: https://ico.org.uk/global/contact-us/
11.1 Change log
- 15/03/2018 – Website launch with initial policy
- 03/07/2018 – New policy published on website
- 08/04/202 – Policy updated