Privacy Policy & GDPR

SPIRIT OF CONCORDE LTD- GDPR PRIVACY POLICY

INTRODUCTION
In order to conduct its business activities, it is necessary for Spirit of Concorde Ltd to act as a data processor in a very limited way with respect to gathering and using the personal data of individuals.  These can include clients, suppliers, employees, models, actors and other people the company has a relationship with or may need to contact.  This policy sets out how we collect, use and protect any information you give us when you use this website and/or our services.  
We are committed to safeguarding your privacy.  Should we ask you to provide certain information, you can be assured that it will only be used in accordance with this policy.  We may be required to update this policy from time to time in order to remain legal and compliant. You should check this page periodically to ensure that you are happy with any changes.

WHY THIS POLICY EXISTS
This GDPR Privacy Policy ensures Spirit of Concorde Ltd:

·       Complies with GDPR and follows good practice;

·       Protects the rights of employees, models, actors and clients;

·       Is open about how it stores and processes individuals’ data;

·       Protects itself from the risks of a data breach;

WHAT WE COLLECT
We may collect the following information:
Clients

·       Name, company name and job title;

·       Contact information including telephone number and email address;

·       Business address and postcode;

·       Other information relevant to your communication

Models & Actors

·       Name;

·       Contact information including telephone number and email address;

·       Demographic information including address and postcode;

·       Statistics and work experience;

·       Images and videos;

Employees and Freelance Crew

·       Name;

·       Contact information including address, telephone number and email address;

·       Details of previous work and/or employment;

·       Other information to enable us to fulfil a contract or terms & conditions including banking information

LAWFUL BASIS FOR PROCESSING
Our lawful reason for processing your personal information will be “legitimate interests”.  Under the GDPR guidelines these are as follows:

The lawful bases for processing are set out in Article 6 of the GDPR.

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

WHAT WE DO WITH THE INFORMATION WE COLLECT
Clients
We require this information to understand your needs and provide you with a better service and in particular, for the following reasons:

·       To provide ongoing customer service and maintain internal record keeping including for accounting purposes;

·       To enable contact by email or phone in relation to the enquiry you have made with us;

·       To periodically send update emails or other information relevant to your enquiry. 

Models, Actors & Contributors
We require this information for the following reasons:

·       Internal record keeping

·       We may contact you by email or phone in relation to client enquiries;

·       We are obliged to retain call sheet and release form information as a record of our contract and rights obtained.

RETENTION
Any personal data held by us for marketing updates will be kept by us until such time that you notify us you no longer wish to receive this information.

SECURITY
We are committed to ensuring that your information is secure and protected against unauthorised or unlawful processing, accidental loss, destruction and damage.

Paperwork
Personal data collected in paper form is stored in locked filing cabinets and shredded when no longer required

SECURITY BREACHES
Despite all the controls we have put in place to address all the key GDPR principles, there is still always a risk a data breach may happen.  In the unlikely event of this, the breach will be notified to all data subjects affected without undue delay. If appropriate, this will also be reported to the ICO within 72 hours of us becoming aware.  The person who should be informed of any breaches is Paul Darter and is contactable by email at all times at paul@spiritofconcorde.com

THIRD PARTY PROCESSING
We only disclose information that is necessary to deliver our services and we never allow your personal data to be used by any third party for any market research, marketing or other commercial purposes. Under GDPR law, we may be required to disclose your data for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. 

YOUR RIGHTS UNDER GDPR
Your principle rights under GDPR are:

·       the right to be informed;

·       the right of access;

·       the right to rectification;

·       the right to erasure;

·       the right to restrict processing;

·       the right to data portability;

·       the right to object; and

·       the right not to be subject to automated decision-making, including profiling.

This means you have the right to know what data we are holding for you at any time, the right to access this data, change it and/or have it removed from any further processing activity.

SUBJECT ACCESS REQUEST
If you would like to contact us with a subject access request, please use the email address paul@spiritofconcorde.com

with ‘GDPR Subject Access Request’ in the subject line.  We will contact you within ten days of receiving this request.
If you are unhappy with the way your subject access request has been dealt with, you have the right to report a concern with a supervisory authority.  In the UK, this is the Information Commissioner’s Office www.ico.org.uk/concerns/.

RESPONSIBLE PERSON FOR GDPR
Paul Darter, Spirit of Concorde, C/O Whewill & Sudworth

35 Westgate, Huddersfield, HD1 1PB