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Privacy Notice – General Data Protection Regulation (“GDPR”)

I care about your privacy. This notice contains information about the data and information
collected, stored and otherwise processed about you and the reasons for the processing. It also
tells you who I share this information with, the security mechanisms I have put in place to protect
your data and how to contact me in the event you need further information.
Who am I?
I, Dave Snocken, collect, use and am responsible for personal information about you. When I do
this I am the ‘controller’ of this information for the purposes of the GDPR and the Data
Protection Act 2018.
If you need to contact me about your data or the processing carried out you can use the contact
details at the end of this document.
What do I do with your information?
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Information collected
When carrying out video production services and the marketing thereof I collect some or all of
the following personal information that you provide:
a) personal details
b) family details
c) lifestyle and social circumstances
d) goods and services
e) financial details
f) education, training and employment details
g) physical or mental health details
h) racial or ethnic origin
i) political opinions
j) religious, philosophical or other beliefs
k) trade union membership
l) sex life or sexual orientation
m) genetic data
n) biometric data for the purpose of uniquely identifying a natural person
o) criminal proceedings, outcomes and sentences, and related security measures
p) other personal data relevant to providing video production services, including data
specific to the video in question.
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It is rare for many of these categories of information to be provided, but it depends upon the
nature of the video I am engaged to produce and what is discussed therein.
 
Information collected from other sources.
The same categories of information may also be obtained from third parties, such as clients of
mine, people who I am discussing the video with, people who appear on videos I produce, your
family and friends, and members of the public.
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How I use your personal information: Purposes
I may use your personal information for the following purposes:
i. to provide video production services, including the filming, storing, editing, transferring
and displaying of videos and clips and stills thereof;
ii. for the use, publication, streaming, broadcasting or distribution of videos I have produced
or worked on or in connection with,
iii. to promote and market my services
iv. to keep accounting records and carry out office administration
v. to take or defend legal or regulatory proceedings or to exercise a lien
vi. to respond to potential complaints or make complaints
vii. to respond to requests for references
viii. when procuring goods and services
ix. as required or permitted by law.
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Whether information has to be provided by you, and why
If I have been asked by you to produce a video your personal information has to be provided, to
enable me to provide you with video production services, to run the administration of my
business, and to keep accounting records.
If you have appeared in a video I am producing, your personal information has to be provided, to
enable me to provide video production services in connection with that video, to run the
administration of my business, and, potentially, to keep accounting records.
 
The legal basis for processing your personal information
I rely on the following as the lawful basis on which I collect and use your personal information:
 

•  If you have consented to the processing of your personal information, then I may process

your information for the Purposes set out above to the extent to which you have
consented to me doing so.

•  If you are a client, processing is necessary for the performance of a contract for video

production services or in order to take steps at your request prior to entering into a
contract.

•  If you have entered into a contract for another purpose connected with my provision of

video production services, such as for appearing in or providing content for a video I am
producing, processing is necessary for the performance of such a contract or in order to
take steps at your request prior to entering into a contract.

•  In relation to information which is in categories (g) to (o) above (these being categories

which are considered to include particularly sensitive information and which include
information about criminal convictions or proceedings) I rely on your consent for any
processing for the purposes set out in purposes (i), (ii), (iii), (iv), (vii) and (viii) above.

•  In relation to information in categories (g) to (o) above (these being categories which are

considered to be particularly sensitive information and include information about
criminal convictions or proceedings), I am entitled by law to process the information
where the processing is necessary for legal proceedings, legal advice, or otherwise for
establishing, exercising or defending legal rights.
 In relation to information which is not in categories (g) to (o) above, I rely on my
legitimate interest and/or the legitimate interests of a third party in carrying out the
processing for the Purposes set out above.

•  In certain circumstances processing may be necessary in order that I can comply with a

legal obligation to which I am subject (including, for example, to assist in a criminal
investigation of something caught on camera).
 
Who will I share your personal information with?
It may be necessary to share your information with the following:

•  data processors, such as my production assistants, editing personnel, email providers, data

• storage providers, data transfer providers, website hosts, streaming services,

• broadcasters, or any other organisation through which the video is published,

• distributed, streamed, broadcast or otherwise made available and/or viewed

•  other video production professionals or personnel

•  clients

•  family and associates of the person whose personal information I am processing

•  any regulatory authorities

•  current, past or prospective employers

•  business associates, professional advisers and trade bodies, e.g. my insurers

•  the intended recipient, where you have asked me to provide a reference

•  the general public in relation to the publication of videos.

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I may be required to provide your information to regulators, such as the Information
Commissioner’s Office. In the case of the Information Commissioner’s Office, there is a risk that
your information may lawfully be disclosed by them for the purpose of any other civil or criminal
proceedings, without my consent or yours.
I may also be required to disclose your information to the police or intelligence services, where
required or permitted by law.
 
Sources of information
The personal information I obtain may include information which has been obtained from:

•  clients

•  people appearing on videos

•  websites

•  social media

•  other video production professionals or personnel

•  people making referrals

•  family and associates of the person whose personal information I am processing

•  any regulatory authorities

•  current, past or prospective employers

•  business associates, professional advisers and trade bodies, e.g. my insurers

•  the intended recipient, where I have been asked to provide a reference

•  the general public in relation to the filming and publication of videos

•  data processors, such as my production assistants, editing personnel, email providers, data

• storage providers, data transfer providers, website hosts,

•  public sources, such as the press, public registers and websites.

 
Transfer of your information outside the European Economic Area (EEA)
This privacy notice is of general application and as such it is not possible to state whether it will
be necessary to transfer your information out of the EEA in relation to any particular video or for
a reference. However, if you reside outside the EEA or your video, a video including your
personal information or the role for which you require a reference involves persons or
organisations outside the EEA then it may be necessary to transfer some of your data to that
country outside of the EEA for that purpose. If you are in a country outside the EEA or if the
instructions you provide come from outside the EEA then it is inevitable that information will be
transferred to those countries. If the relevant video containing your personal information is a
documentary, then it is likely that it will be necessary to transfer some or all of your data to a
country or countries outside of the EEA for the purposes of producing, publishing, distributing,
streaming, broadcasting, and/or otherwise making the documentary available to others. If this
applies to you and you wish additional precautions to be taken in respect of your information
please indicate this when initially engaging me and/or agreeing to appear in or provide content for
one of my videos.
 
Some countries and organisations outside the EEA have been assessed by the European
Commission and their data protection laws and procedures found to show adequate protection.
The list can be found here. Most do not. If your information has to be transferred outside the

EEA, then it may not have the same protections and you may not have the same rights as you
would within the EEA.
 
If I publish a video containing your information then this will be published in a way that enables
it to be accessed internationally.
I will not transfer personal information outside the EEA except as necessary for providing video
production services, including where file transfer or hosting services have their servers outside
the EEA and/or because the relevant video is a documentary.
 
If you would like any further information please use the contact details at the end of this
document.
 
How long will I store your personal data?
I will normally store all your information:
 where it is contained within a video or video file for at least 10 years after I finish
working on a particular video project. This is because I need to be able to produce show
reels in order to market my services effectively and to be able to show potential clients.
After 10 years, any further retention will be reviewed and the data will be marked for
deletion or marked for retention for a further period. The later is likely to occur only
where information contained therein is not particularly sensitive.
 An exception to this is where it is contained within a video or video file that is a
documentary or was produced in connection with a documentary, in which case it may
be stored indefinitely. This is because I may need to be able to make the documentary,
or parts thereof, available to be used, published, streamed, broadcast, distributed and/or
otherwise made available without time limit.
 Names and contact details held for marketing and administration purposes will be stored
indefinitely. This applies to both previous and potential clients and includes where
someone has informed me that they do not wish to be contacted again to ensure that I
comply with said wishes and do not inadvertently identify them again in the future as a
potential client to contact.
 Notes and documents relating to videos I have produced will be stored locally by me for
up to 5 years following the completion of a video project. This is to enable me to deal
with any future queries and to assist with my business. After that time data with be
reviewed and either deleted or retained. This period of retention does not apply to that
sent by email, social media or instant messaging, which may be held until the end of my
career in order to be able to deal with any future enquiries and to provide a record of
what was discussed and communicated when producing a video, and which is unlikely
to include sensitive personal data.
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Consent
As explained above, I am relying on your explicit consent to process your information in
categories (g) to (o) above. You provided this consent when you agreed that I would provide a
video or you would appear in a video.
 
You have the right to withdraw this consent at any time, but this will not affect the lawfulness of
any processing activity I have carried out prior to you withdrawing your consent. However,
where I also rely on other bases for processing your information, you may not be able to prevent
processing of your data.
If there is an issue with the processing of your information, please contact me using the contact
details below.
 

Your Rights
Under the GDPR, you have a number of rights that you can exercise in certain circumstances.
These are free of charge. In summary, you may have the right to:
 

•  Ask for access to your personal information and other supplementary information;

•  Ask for correction of mistakes in your data or to complete missing information I hold on

• you;

•  Ask for your personal information to be erased, in certain circumstances;

•  Receive a copy of the personal information you have provided to me or have this

• information sent to a third party. This will be provided to you or the third party in a

• structured, commonly used and machine readable format, e.g. a Word file or hard copy;

•  Object at any time to processing of your personal information for direct marketing;

•  Object in certain other situations to the continued processing of your personal

• information;

•  Restrict my processing of your personal information in certain circumstances;

•  Request not to be the subject to automated decision-making which produces legal effects

• that concern you or affects you in a significant way.

 
If you want more information about your rights under the GDPR please see the Guidance from
the Information Commissioners Office on Individual's rights under the GDPR.
 
If you want to exercise any of these rights, please:

•  Use the contact details at the end of this document;

•  I may need to ask you to provide other information so that you can be identified;

•  Please provide a contact address so that you can be contacted to request further

• information to verify your identity;

•  Provide proof of your identity and address;

•  State the right or rights that you wish to exercise.

 
I will respond to you within one month from when I receive your request.
How to make a complaint?
 
The GDPR also gives you the right to lodge a complaint with the Information Commissioners’
Office if you are in the UK, or with the supervisory authority of the Member State where you
work, normally live or where the alleged infringement of data protection laws occurred. The
Information Commissioner’s Office can be contacted at https://ico.org.uk/make-a-complaint/.
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Future Processing
I do not intend to process your personal information except for the reasons stated within this
privacy notice. If this changes, this privacy notice will be amended and a revised notice will be
accessible through the website or a link on emails I send.
 
Changes to this privacy notice
This privacy notice was first published in July 2018. It was reviewed and an amended version
published in November 2020.
 
I continually review my privacy practices and may change this policy from time to time. When I
do it will be accessible through the website or a link on emails I send.
 
Contact Details

If you have any questions about this privacy notice or the information I hold about you, please
contact me at dave@fepmedia.com or by phone at 07761 391123.

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