This Policy sets out the obligations of Sightline Media Limited, a company registered in United Kingdom under number 07952772, whose registered office is at The Barn, Old Barn Cottage, Down Lane, Compton, Guildford, GU3 1DQ. (“the Company”) regarding data protection and the rights of customers, business contacts, prospects, persons appearing in video footage filmed or video footage retained by the Company (“data subjects”) in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).
The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.
The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.
2: The Data Protection Principles
This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:
- Processed lawfully, fairly, and in a transparent manner in relation to the data subject.
- Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
- Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
- Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
- Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of the data subject.
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organisational measures.
3.The Rights of Data Subjects
The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):
- The right to be informed (Part 12).
- The right of access (Part 13);
- The right to rectification (Part 14);
- The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
- The right to restrict processing (Part 16);
- The right to data portability (Part 17);
- The right to object (Part 18); and
- Rights with respect to automated decision-making and profiling (Parts 19 and 20).
4. Lawful, Fair, and Transparent Data Processing
- The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:
- The data subject has given consent to the processing of their personal data for one or more specific purposes;
- The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
- The processing is necessary for compliance with a legal obligation to which the data controller is subject;
- The processing is necessary to protect the vital interests of the data subject or of another natural person;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
- The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
- If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:
- The data subject has given their explicit consent to the processing of such data for one or more specified purposes (unless EU or EU Member State law prohibits them from doing so);
- The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law (insofar as it is authorised by EU or EU Member State law or a collective agreement pursuant to EU Member State law which provides for appropriate safeguards for the fundamental rights and interests of the data subject);
- The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
- The data controller is a foundation, association, or other non-profit body with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
- The processing relates to personal data which is clearly made public by the data subject;
- The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
- The processing is necessary for substantial public interest reasons, on the basis of EU or EU Member State law which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
- The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems or services on the basis of EU or EU Member State law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the GDPR;
- The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of EU or EU Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
- The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the GDPR based on EU or EU Member State law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.
5. Specified, Explicit, and Legitimate Purposes
- The Company collects and processes the personal data set out in Part 21 of this Policy. This includes:
- Personal data collected directly from data subjects; and
- Personal data obtained from third parties.
- The Company only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).
- Data subjects are kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.
6. Adequate, Relevant, and Limited Data Processing
The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.
7. Accuracy of Data and Keeping Data Up-to-Date
- The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.
- The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.
8. Data Retention
- The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
- When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
- For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.
9. Secure Processing
The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.
10. Accountability and Record-Keeping
- The Company’s Data Protection Officer is Keith Thomas located at the Company’s registered address; telephone 01483 813311.
- The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.
- The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
- The name and details of the Company, its Data Protection Officer, and any applicable third-party data processors;
- The purposes for which the Company collects, holds, and processes personal data;
- Details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;
- Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
- Details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy); and
- Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.
11. Data Protection Impact Assessments
- The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and where the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.
- Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
- The type(s) of personal data that will be collected, held, and processed;
- The purpose(s) for which personal data is to be used;
- The Company’s objectives;
- How personal data is to be used;
- The parties (internal and/or external) who are to be consulted;
- The necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
- Risks posed to data subjects;
- Risks posed both within and to the Company; and
- Proposed measures to minimise and handle identified risks.
12. Keeping Data Subjects Informed
- The Company shall provide the information set out in Part 12.2 to every data subject:
- Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
- Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
- if the personal data is used to communicate with the data subject, when the first communication is made; or
- if the personal data is to be transferred to another party, before that transfer is made; or
- as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
- The following information shall be provided:
- Details of the Company including, but not limited to, the identity of its Data Protection Officer;
- The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
- Where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the personal data;
- Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
- Where the personal data is to be transferred to one or more third parties, details of those parties;
- Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);
- Details of data retention;
- Details of the data subject’s rights under the GDPR;
- Details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;
- Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);
- Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
- Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.
13. Data Subject Access
- Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.
- Employees wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Data Protection Officer at the Company’s registered office: The Barn, Old Barn Cottage, Down Lane, Compton, Guildford, GU3 1DQ.
- Responses to SARs shall normally be made within one month of receipt, however this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
- All SARs received shall be handled by the Company’s Data Protection Officer.
- The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
14. Rectification of Personal Data
- Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.
- The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
- In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.
15. Erasure of Personal Data
- Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:
- It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
- The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
- The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);
- The personal data has been processed unlawfully;
- The personal data needs to be erased in order for the Company to comply with a particular legal obligation.
- Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
- In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).
16. Restriction of Personal Data Processing
- Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
- In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
17. Data Portability
- The Company processes personal data using automated means – through contact forms and subscription forms on its website sightline.co.uk, or through email-shots via MailChimp (https://mailchimp.com/legal/privacy/) or BombBomb (https://bombbomb.com/terms/) .
- The company uses DiscTracker a MAC based system for cataloguing and quickly accessing the location of video footage and sound recordings stored on discs or hard drives at our off-site secure storage at Kelly’s Storage in Guildford. We can quickly respond to any requests from a person or company to locate footage that they appear in and, if requested, delete that footage – except where a person has signed a Waiver Release form waving their right to ask for media they appear in to be deleted.
- Where data subjects have given their consent to the Company to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between the Company and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).
- To facilitate the right of data portability, the Company shall make available all applicable personal data to data subjects in the following format:
- A CSV spread sheet in Excel, either downloaded from the automated data collecting system (MailChimp) or from a data list stored on our PC network.
- A video compilation of footage the subject appears in – delivered on a video file via We Transfer or Drop Box
- Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.
- All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.
18. Objections to Personal Data Processing
- Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
- Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
- Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.
- Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the GDPR, “demonstrate grounds relating to his or her particular situation”. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.
19. Personal Data Collected, Held, and Processed
The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):
|Data Ref.||Type of Data||Purpose of Data|
|Customer||Name, company name, email address, phone number, business address, sometimes home address||For maintaining contact with the customer to enable us to deliver our services to them – and to update them on our company activities and services.|
|Prospects||Name, company name, email address, phone number, business address||For telling the prospect about our services and how we can help them by delivering our services to them.
|Subscriber to forms on our website||Name, company name, email address, phone number, sometimes business address
|To enable us to respond to requests for receiving information from us about our services, as well as information we offer to supply such as blogs and helpful documents about our services or video production as a medium.|
|Exhibition stand visitors||Name, company name, email address, phone number, business address||To enable us to follow up an interest in our services or a competition we might run at the exhibition.|
|Contributors (people) in Video and Audio productions||Digital or analogue video and sound recording media files||For the recording of and editing into video and audio materials as part of the service we provide to our customers/clients.|
20. Data Security – Transferring Personal Data and Communications
The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:
- All emails containing personal data must be encrypted using Outlook’s encryption settings.
- All emails containing personal data must be marked “confidential”;
- Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
- Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
- Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted using Outlook’s deletion process.
- Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;
- Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient.
- All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.
21. Data Security – Storage
The Company shall ensure that the following measures are taken with respect to the storage of personal data:
- All electronic copies of personal data should be stored securely using passwords and the Microsoft Application’s and Apple Mac’s data encryption features;
- All hardcopies of personal data, along with any electronic copies stored on physical removable media should be stored securely in a locked box, drawer, cabinet, or similar;
- All personal data stored electronically should be backed up daily into Drop Box. All backups should be encrypted.
- All video and audio media should be backed up and stored off site in a secure storage facility – in our case this is Kelly’s Storage in Guildford.
- No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of Keith Thomas at the Company’s registered office.
- and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
- No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken).
22. Data Security – Disposal
When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.
23. Data Security – Use of Personal Data
The Company shall ensure that the following measures are taken with respect to the use of personal data:
- No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from Keith Thomas at the Company’s registered office.
- No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of Keith Thomas at the Company’s registered office.
- Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
- If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and
- Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Keith Thomas to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.
24. Data Security – IT Security
The Company shall ensure that the following measures are taken with respect to IT and information security:
- All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords;
- Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
- All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates after the updates are made available by the publisher or manufacturer or as soon as reasonably and practically possible, unless there are valid technical reasons not to do so; and
- No software may be installed on any Company-owned computer or device without the prior approval of Keith Thomas.
25. Organisational Measures
The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
- All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
- Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
- Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
- All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;
- The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
- All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;
- All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the GDPR; and
- Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.
26. Transferring Personal Data to a Country Outside the EEA
- The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
- The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
- The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
- The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
- The transfer is made with the informed consent of the relevant data subject(s);
- The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);
- The transfer is necessary for important public interest reasons;
- The transfer is necessary for the conduct of legal claims;
- The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
- The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.
27. Data Breach Notification
- All personal data breaches must be reported immediately to the Company’s Data Protection Officer.
- If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
- In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
- Data breach notifications shall include the following information:
- The categories and approximate number of data subjects concerned;
- The categories and approximate number of personal data records concerned;
- The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
- The likely consequences of the breach;
- Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.
28. Implementation of Policy
This Policy shall be deemed effective as of 24th May 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
This Policy has been approved and authorised by:
|Position:||Director, Sightline Media Limited|
|Date:||24th May 2018|
|Due for Review by:||1st October 2018|
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“personal data”means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
“We/Us/Our”Means Sightline Media, a limited company registered in England under company number 07952772, whose registered and trading address is The Barn, Old Barn Cottage, Down Lane, Compton, Surrey GU3 1DQ.
2. Information About Us
- Our Site is owned and operated by Sightline Media, a limited company registered in England under company number 07952772, whose registered address and trading address is The Barn, Old Barn Cottage, Down Lane, Compton, Surrey GU3 1DQ.
- Our VAT number is 239813190
- Our Data Protection Officer is Keith Thomas and can be contacted by email at [email protected], by telephone on 07554 019436, or by post at The Barn, Old Barn Cottage, Down Lane, Compton, Surrey GU3 1DQ.
What Does This Policy Cover?
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- The right to be informed about Our collection and use of personal data;
- The right of access to the personal data We hold about you (see section 12);
- The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
- The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to Us using your personal data for particular purposes; and
- Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
4. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
- business/company name;
- job title;
- contact information such as email addresses and telephone numbers;
- demographic information such as post code, preferences, and interests
- IP address;
- web browser type and version;
- operating system;
- a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
4.1 Legal basis for processing this data
You are a valued customer, client or associate. We will only store and use your data for one or more of the following reasons:
- you contacted us or subscribed to information we offer, using one of the forms on this website
- you contacted us by other means than through this website requesting information from us about our services, etc.
- you are one of our clients or potential clients
- you are one of our suppliers or potential suppliers
- we were been given your contact details by a third party to aid us in offering our help or services to you
5. How Do We Use Your Data?
- All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
- Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails or completing forms on this website), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- Supplying Our services and products to you (please note that We require your personal data in order to enter into a contract with you);
- Personalising and tailoring Our services and products for you;
- Replying to emails from you;
- Market research;
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone or post with information, news, and offers on Our services or products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
- We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. The period of retention of your Data will therefore be determined on the following bases:
- For as long as it is applicable to our purposes or as long as we are providing our services or products to you or offering our services or products to you.
6. How and Where Do We Store Your Data?
- We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
- Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
- Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
- Steps We take to secure and protect your data include encryption, secure PC networks, secure cloud storage.
7. Do We Share Your Data?
- Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority. We may share your data with other companies in Our group: Nedderdale Limited trading as Sightline TV and Sightline Video Limited trading as Sightline.
- We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
- We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- The third-party data processor used by Us and listed below is located in the UK. They take all reasonable steps to ensure that your data is treated safely and securely and under the compliance of GDPR.
- Lead Forensics. Please view the Lead Forensics GDPR compliance policy: https://www.leadforensics.com/software-data-compliance
- In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
8. What Happens If Our Business Changes Hands?
- In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data?
- In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information
You may access all areas of Our Site without providing any data at all. However, the ‘Contact Us’ page and the various subscribe-to forms on our site do require you to submit certain data in order to enable us to respond to you.
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at [email protected], or using the contact details below in section 13.
12. Contacting Us
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What is a cookie?
Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to ‘remember’ you and your preferences, either for a single visit (through a ’session cookie’) or for multiple repeat visits (using a ‘persistent cookie’). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as ‘first party cookies’), or by other websites who serve up content on that site (‘third party cookies’).
The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie Guide. A list of all the cookies used on this website by category is set out below.
Category 1: strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
The following is a list of the cookies that we have defined as ‘Strictly Necessary’
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What these cookies will be used for
- Remembering previous actions (e.g. entered text) when navigating back to a page in the same session.
What these cookies will NOT be used for
- Gathering information that could be used for marketing to the user.
- Remembering customer preferences or user IDs outside a single session (unless the user has requested this function).
By using our website, you agree that we can place these types of cookies on your device.
Category 2: performance cookies
These cookies collect anonymous information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
The following is a list of the cookies that we have defined as ‘Performance’
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What these cookies will be used for
- Web analytics — where the data collected is limited to the website operator’s use only, for managing the performance and design of the site. These cookies can be third-party cookies but the information must be for the exclusive use of the publisher of the website visited.
What these cookies will NOT be used for
- Re-targeting adverts
By using our website, you agree that we can place these types of cookies on your device.
Category 3: functionality cookies
These cookies remember choices you make to improve your experience. These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
The following is a list of the cookies that we have defined as ‘Functionality’
- NO COOKIES OF THIS TYPE ARE USED BY THIS WEBSITE
Category 4: targeting cookies or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
The following is a list of the cookies that we have defined as ‘Targeting’
- NO COOKIES OF THIS TYPE ARE USED BY THIS WEBSITE