Cameo Productions Limited: Privacy Notice

What is the purpose of this document?

Cameo Productions Limited (Cameo) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (GDPR). It applies to everyone whose personal data we process in our capacity as “data controller” for both Cameo Productions and Oddyo, with the exception of our employees, workers and contractors.

We are Cameo Productions Limited. We are registered in England with company number 03199896 and our registered office address is 19 Woodstock Street, London W1C 2AN, which is also our trading and contact address.

This notice is not contractual and we may update it at any time.

Data protection principles

We must comply with the principles relating to processing of personal data set out in the GDPR which, in summary, state that personal data shall:

  • be processed fairly and lawfully in a transparent manner;
  • be collected for specific, explicit and legitimate purposes and not be processed in any manner which is incompatible with those purposes;
  • be adequate, relevant and limited to what is necessary for that purpose;
  • be accurate and kept up to date where necessary, with every reasonable step being taken to ensure that personal data are accurate, having regard to the processing purpose, and are erased or rectified without undue delay;
  • be kept in a form which permits identification of data subjects for no longer than is necessary for that purpose; 
  • be kept secure, safe from unauthorised access, accidental loss, damage or destruction; and
  • be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction of damage, using appropriate technical or organisational measures.

Our collection, use and transfer of your data

Cameo Productions clients

In order to provide our services, we need to collect, store, review and transfer data relating to our clients or individuals working for our clients. Most of this information is provided by you but some might be obtained from other people involved with the production. The type of data we hold is usually just your name and work contact details.

In our conversations with radio stations to publicise entertainment releases, we may need to give contact details to other people involved, such as radio presenters and producers. We may include names in press releases, but only with the individual’s consent.

In order to comply with our own legal obligations, we might also need to provide personal data to HMRC or regulatory bodies such as Ofcom.

Our banks, accountants, auditors and insurers are also entitled to obtain specific data on request as part of our compliance checks and legal obligations, although they rarely need specific personal data. 

Oddyo users

Users of our Oddyo services are asked for the following information when they sign up: name, broadcast coverage area, broadcast platform, station listener demographics, weekly reach of the show, clip usage, preferred audio and video format for downloading, screening cities and social media details. This information is used by us for our legitimate interests in providing our Oddyo services.

We analyse the users’ use of our Oddyo website and report back to our film and entertainment company clients about this, which may contain specific information on one user’s activities on the website. We may give the users’ name, organisation and contact details to the relevant company. 

Media contacts and general stakeholders

We also collect information about many other people, mainly in the form of contact details (name, job title, organisation, address, e-mail address and telephone number, as well as other information from e-mail signatures and footers) of people interested in our services, contacts at clients and potential clients, contacts at suppliers and potential suppliers, people within the industry and other stakeholders. This information is usually provided directly from you and may be used for the legitimate interest of communicating with you in relation to specific issues or products that you are involved in, or productions that you might be able to assist with. We may also contact you to keep in touch or make introductions.

We keep the details of any complaints for our legitimate interest in trying to improve our business but this information will not be disclosed by us to any third parties.

Job applicants

If you apply for a job with us, we will keep your name, contact details, current salary, covering letter and CV and may use these to contact you about applicable jobs.

Shareholders

We use the contact details of our shareholders to send them updates about the business and their investment in it as well as agreements, resolutions and documents relevant to their shareholding. We also provide their name and shareholding details, as well as the name, home address, service address, date of birth, occupation and nationality of directors, to Companies House.

Onsite visitors

We keep a record of the names and organisations of all our visitors, to ensure that we can account for everyone in the premises in the event of an emergency. If you choose to use our guest wifi network, your use of this may be recorded for security reasons. 

We may take photographs for social media and online promotional purposes but we will not use these for any other purpose without your consent.

Organisations that may see your data

Our banks, accountants, auditors and insurers are also entitled to obtain specific data on request as part of our compliance checks and legal obligations, although they rarely need specific personal data. 

Our IT support and office management system providers have access to all data on our systems to provide their services to us for legitimate interests. We use cloud-based servers and hosting, staging, back-up and monitoring services provided by third parties, as detailed in the section below titled “Transferring information outside the EU”. We only allow our third-party service providers to use your personal data for specified purposes and in accordance with our instructions.

Update correspondence

We send out update e-mails to people who have asked to receive them, as part of our core business. We hope that you find these useful but if at any time you wish to opt out of these, please telephone 0207 499 3444, e-mail hello@cameopro.com or write to us at FAO Publicity team, Cameo, 19-20 Woodstock Street, Lower Ground Floor, W1C 2AN.

Special category personal data such as health information

"Special categories" of particularly sensitive personal information, such as information about a person's health or sexual orientation, require higher levels of protection. We may collect, store and use this information if you provide it to us and consent to us using it for a specific purpose, where it is necessary to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.  We may collect, store and use information about your health where it is useful to ensure your safety whilst you are in our offices. 

We do not envisage collecting, storing or using special category data.

Criminal convictions

We will not store or use information about any criminal convictions and offences, unless you have provided your consent to it.

Legal claims

Any personal data may be held and used for establishing, exercising or defending legal claims. 

Future sale

We may share your personal information in the context of our legitimate interests in a possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

Use of our website

Cookies are small files which are transferred from this website and stored on your computer's hard drive. We use cookies to keep track of your session when you use our website. We also use cookies to verify the identity of users when they log in. We use “session" cookies which are deleted when you close your browser, rather than ordinary cookies which remain on your hard disk until you delete them. Most browsers are automatically set to accept cookies and you should be able to configure your browser to refuse cookies if you wish. This may, however, affect your ability to use all the features on our website. We do not use cookies in a way that can identify particular individuals.

We also collect information about you from when you register on the site in order to receive newsletters or other services.

We keep a record of traffic data which is logged automatically by our server, such as your IP address, the URL you visited before ours, the URL you visit after leaving our site and which pages you visit, but not in a way that identifies any individual.

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Transferring information outside the EU

Our client and project files are stored on the server at our office, but backed up to cloud-based storage hosted by Amazon and held within the EU. We use Microsoft’s Office 365 for our main e-mail exchange, SharePoint and Skype for Business which are also all cloud-based, but their data centres are within the EU. 

We also use cloud providers such as Rackspace, Liquid Web, Amazon Web Services, and Google Docs for hosting, staging, back-up and monitoring services, and MailChimp for some of our e-mails. As these companies are US-based, your data may be transferred to the US as part of this service, but there are adequate safeguards in place as all of these organisations are self-certified to the Privacy Shield. Liquid Web may transfer your data outside of the EU and the US but only where appropriate safeguards are in place in the form of standard approved contractual clauses.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please telephone 0207 499 3444, e-mail hello@cameopro.com or write to us at FAO Data Protection Manager, Cameo, 19-20 Woodstock Street, Lower Ground Floor, W1C 2AN. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to continue our professional relationship, depending on the specific data, why we need it and what risks the provision of it poses to your rights and freedoms. For example, if a supplier fails to provide contact details of its finance department or the details needed for payments, we may not be able to pay them.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.  You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

How long will we use your information for?

Cameo Productions clients and Oddyo users

We hold client-based personal data for up to seven years after the termination of our services, in order to cover any legal or tax issues that arise afterwards.

General stakeholders

We will hold your personal data until we are satisfied that there is no longer any purpose for retaining it. 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 requirements. 

Job applicants

If you apply for a job with us, we will keep your name, contact details, current salary and CV on file for up to six months, although we may delete it before then if we do not anticipate any need for recruitment applicable to you within this time.

Anonymisation

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. 

Rights of access, correction, erasure, and restriction

You have a number of rights under the GDPR: 

  • the right to access personal data we hold;
  • the right to ask us to rectify or complete our records;
  • the right to ask us to delete personal data;
  • the right to object to us processing your personal data;
  • the right to restrict our processing; and
  • the right to ask us to transfer your personal data to another organisation.

These are not absolute rights and are subject to specific conditions and depend on our processing purposes. If you are interested in using any of these rights, please contact our Data Protection Manager for more information.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Complaints 

If you are unhappy with any aspect of our processing of your personal data, we ask that you talk to us about it first and discuss your concerns with our Data Protection Manager. If you are not satisfied with the outcome, you may lodge a complaint with the Information Commissioner’s Office.