GDPR Privacy Notice

Introduction

The General Data Protection Regulations require us to have a simple-to-understand Privacy Statement or Notice about the personal data we hold, how it is processed and the limits of that processing.

We process a very limited amount of personal information for certain legitimate business purposes, which include the following:

-where the processing enables us to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers;
-to identify and prevent fraud;
-to enhance the security of our network and information systems.

Data held to allow the fulfilment of our services

To see how we define “our services” and “clients”, please refer to Section 3 of our published Terms and Conditions at:
http://chrismugford.com/terms-2/

In order to fulfil our contractual obligations to our clients, it is necessary for our clients to supply us with a limited amount of personal data from their organisation, their customers and their suppliers. The extent of this data is controlled by our clients. This data is used to allow us to create filming schedules, contact individuals to inform of filming requirements and to assign the copyright of the film content.

This data is limited to the individual’s name, postal address, email address and contact telephone number. The data is held securely on one computer hard drive in a locked office. It can be accessed by only two nominated people. It is archived indefinitely in order to comply with our clients’ IP obligations.

No further processing is undertaken at any stage. The data is never released in part or whole to any third party.

Special Categories

We do not hold any Special Categories of data, as defined by the Regulations.

Marketing, including digital contact, emails etc

The General Data Processing Regulations allow us to undertake occasional email marketing as a “Legitimate Interest” to which our business is entitled. We have imposed upon ourselves a strict policy that limits the processing of personal data. We do not attempt to profile individuals from analytics or digital feedback and we make no follow-up to the email marketing unless expressly invited to do so by a recipient. Neither do we pass personal data on to any third party. This policy is the result of a balancing test that we have undertaken and we are confident that as a result, the individual’s interests do not override these legitimate interests.

In sending this email to a limited number of recipients that we believe would benefit from its contents, we have checked that “legitimate interests” is the most appropriate basis. In doing so:
We understand our responsibility to protect the individual’s interests;
We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision;
We have identified the relevant legitimate interests;
We have checked that the processing is necessary and there is no less intrusive way to achieve the same result;
We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests;
We only use individuals’ data in ways they would reasonably expect;
We are not using people’s data in ways they would find intrusive or which could cause them harm;
We do not pass data on to any third parties;
We have considered safeguards to reduce the impact where possible;
We have offered an opt out;
If our LIA identifies a significant privacy impact, we have considered whether we also need to conduct a DPIA. (Data Protection Impact Assessment);
We keep our LIA under review, and repeat it if circumstances change;
We include information about our legitimate interests in our privacy notice;

The very limited data processing that we do for these purposes means that we will ensure we always keep personal data rights in high regard and take account of these rights. Any individual has the right to object to any processing whatsoever if desired and if an individual wishes their data to be removed altogether, they have the option to click on an “unsubscribe” link.

Contact

Any issues relating to this notice and personal data (including the withdrawal of consent) should be addressed to the company’s registered office:
Treharbas
Lanteglos
Camelford
Cornwall
PL32 9UT
Or by email:
[email protected]

                                                                                                                                                                                                                                                                                                                                           

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