Presenter Network (the “Company”) is required to maintain certain personal data about living individuals for the purposes of satisfying operational and legal obligations. The Company recognises the importance of the correct and lawful treatment of personal data; it maintains confidence in the organisation and provides for successful operations.
The types of personal data that the Company may require includes information about the name, address, email, phone number, age, location and any other information as users of the website www.presenternetwork.com (“Website”) may submit. This personal data, whether it is held on paper, on computer or other media, will be subject to the appropriate legal safeguards as specified in the Data Protection Act 1998.
The Company fully endorses and adheres to the eight principles of the Data Protection Act. These principles specify the legal conditions that must be satisfied in relation to obtaining, handling, processing, transportation and storage of personal data. Anyone who lawfully obtains, handles, processes, transports and stores personal data for the Company must adhere to these principles.
1 – PRINCIPLES
The principles require that personal data shall:
Be processed fairly and lawfully and shall not be processed unless certain conditions are met;
Be obtained for a specified and lawful purpose and shall not be processed in any manner incompatible with that purpose;
Be adequate, relevant and not excessive for those purposes;
Be accurate and, where necessary, kept up to date;
Not be kept for longer than is necessary for that purpose;
Be processed in accordance with the data subject’s rights;
Be kept secure from unauthorised or unlawful processing and protected against accidental loss, destruction or damage by using the appropriate technical and organisational measures;
And not be transferred to a country or territory outside the European Economic Area, unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
2 – SATISFACTION OF PRINCIPLES
In order to meet the requirements of the principles, the Company will:
Observe fully the conditions regarding the fair collection and use of personal data;
Meet its obligations to specify the purposes for which personal data is used;
Collect and process appropriate personal data only to the extent that it is needed to fulfill operational or any legal requirements;
Ensure the quality of personal data used;
Apply strict checks to determine the length of time personal data is held;
Ensure that the rights of individuals about whom the personal data is held, can be fully exercised under the Act;
Take the appropriate technical and organisational security measures to safeguard personal data;
Ensure that personal data is not transferred abroad without suitable safeguards.
DESIGNATED DATA CONTROLLER OF PRESENTER NETWORK
The Company’s Information Compliance Manager is responsible for ensuring compliance with the Data Protection Act and implementation of this policy. The Information Compliance Manager is Richard Litchfield, e-mail: firstname.lastname@example.org. Any questions or concerns about the interpretation or operation of this policy should be taken up in the first instance with the Information Compliance Manager.
STATUS OF THE POLICY
This policy has been approved by the management of the company and any breach will be taken seriously. Any user of the Website who considers that the policy has not been followed in respect of personal data about themselves should raise the matter with the Company’s Information Compliance Manager in the first instance.
3 – SUBJECT ACCESS
All individuals who are the subject of personal data held by the Company are entitled to:
Ask what information the Company holds about them and why.
Ask how to gain access to it.
Be informed how to keep it up to date.
Be informed as to what the Company is doing to comply with its obligations under the 1998 Data Protection Act.
WEBSITE USER RESPONSIBILITIES
All users of the Website are responsible for:
Checking that any personal data that they provide to the Company via the Website is accurate and up to date.
Informing the Company via the Website of any changes to information which they have provided, e.g. changes of address.
Checking any information that the Company may send out from time to time, giving details of information that is being kept and processed.
If, as part of their responsibilities, users of the Website collect information about other people (e.g. about other users of the Website or production companies, talent contacts or employees), they must comply with the Policy and with the Data Protection guidelines.
The need to ensure that data is kept securely means that precautions must be taken against physical loss or damage, and that both access and disclosure must be restricted. The Company shall use all reasonable endeavours to ensure that:
Any personal data which they hold is kept securely
Personal information is not disclosed either orally or in writing or otherwise to any third party without prior permission having been obtained
4 – RIGHTS TO ACCESS INFORMATION
Users of the Website and other subjects of personal data held by the Company have the right to access any personal data that is being kept about them on computer and also have access to paper-based data held in manual filing systems. This right is subject to certain exemptions which are set out in the Data Protection Act. Any person who wishes to exercise this right should make the request in writing to the Company’s Information Compliance Manager. The Company reserves the right to charge the maximum fee payable for each subject access request. If personal details are inaccurate, they can be amended upon request.
The Company aims to comply with requests for access to personal information as quickly as possible, but will ensure that it is provided within 40 days of receipt of a request unless there is good reason for delay. In such cases, the reason for delay will be explained in writing to the individual making the request.
PUBLICATION OF INFORMATION
Information that is already in the public domain is exempt from the 1998 Act. This would include, for example, information on staff contained within externally circulated publications, material submitted to the Website which is already available on You Tube (or any other website). Any individual who has good reason for wishing details in such publications to remain confidential should contact the Company’s Information Compliance Manager.
The need to process data for normal purposes has been communicated to all data subjects. In some cases, if the data is sensitive, for example information about health, race or gender, express consent to process the data must be obtained. Processing may become necessary to operate the Company policies, such as health and safety and equal opportunities.
RETENTION OF DATA
The Company will keep some forms of information for longer than others but shall use all reasonable endeavours to ensure that information is not kept for longer than necessary.
© Presenter Network Ltd. 2015.