We are committed to protecting the privacy of your data. We wish to respect any personal data you share with us and keep it safe. We aim to be clear when we collect your data and not do anything you wouldn’t reasonably expect.
If there are significant updates, we will inform those people with whom we are in regular contact, such as email subscribers and clients.
Who we are
Fotonow SW CIC is a media production company and education provider. We are social enterprise and use our profits to support community media projects. We also seek grant funding to enable us to run other community-based media projects. We produce a range of photographic, film and media products for clients to exhibit in a variety of ways, including at events, broadcast, online, social media and other similar distribution. We also engage with individuals on our media workshops, to support them to produce their own media works.
This policy applies to Fotonow SW CIC, Foto+ Collective (our commercial brand), Camper Obscura, and any project run through these brands.
When you provide your data to us through any of the above brands, Fotonow SW CIC is the data controller for the purpose of the Data Protection Act 1998 and General Data Protection Regulation will be Fotonow SW CIC.
Our address is: Fotonow CIC, Ocean Studios, The Factory Cooperage, Royal William Yard, Plymouth, PL1 3RP.
Why we collect information
We collect information to allow us to:
- Create media works, such as photographs, video and audio recordings, for Fotonow projects or projects commissioned by our clients;
- Provide you with information or a service you have requested from us;
- Provide you with information which we think you will be interested in;
- To understand how people use the information we provide on our website;
- To tailor information and services we provide to ensure they are relevant to you;
For all client projects, commissions and corporate work, and Fotonow commercial projects where we are being paid to create media works for another party/client/business we ask that clients offer a legitimate interest statement to us on request. In this respect, the legitimate interest is held by our client and the onus will be on our client to offer transparency and action to participants and contributors associated with the films we make for this purpose. Clients will offer us an indemnity for this purpose.
We also collect information to provide you with information, products or services that you request from us (for example, newsletters or guidance on our projects); where you agree, communicate details of Fotonow activities that you may have participated in to others (for example by publishing stories and photos on our social media channels and Website); provide you with other information such as details of events we think you may be interested in attending, products or services which we feel may interest you, when we have your consent to do so. This may include newsletters, updates, information in relation to specific projects, voluntary surveys or questionnaires for you to complete, details of relevant volunteering opportunities, and details of any promotions and competitions we are running. We may personalise our communications with you (for example, to ensure that our communications are tailored taking into account your age, location and previous involvement with Fotonow); to keep a record of your relationship with us; Notify you about changes to our service; Comply with applicable laws and regulations and requests from statutory agencies; and carry out any obligations or provide you with any other services, functionality or content which you specifically agree to on our Website.
How we collect information
- When you give it to us directly:
We ask for contributors and participants consent for all media services we provide. We will expressly obtain active consent from an individual that the photos or footage is to be used for each specific purpose. Further, at the time of obtaining consent, we will explain to individuals that they are able to withdraw consent at any time but also that this would not render processing on the basis of consent prior to withdrawal to be unlawful. Individuals must also be able to easily and freely withdraw consent at any time and use their right to be forgotten. If consent is withdrawn, we will be able to provide a legitimate interest statement for our requirements for Fotonow-led projects.
You may also give us your personal data when you take part in any of our workshops, projects or activities; to receive our e-newsletter; to receive further information or products; when we request it via our Website (for example, enter into any competitions or promotions online); when you volunteer with us; when you respond to a survey or when you otherwise engage with us on our Website. When you give us information in this manner, we may collect and store this information.
- When you visit our Website:
We may collect information about you when you use our websites. Whenever you input information into our websites, we will collect the information that you give to us.
We use “cookies” to identify you when you visit our websites. Amongst other things this helps us to understand our Website users and may enable us to improve the Website experience for you and/or other users. Please refer to our Cookies Policy for details on how and why we use this data.
We may collect other information from your use of our websites, such as your IP address and access times.
We may link our websites directly to other sites. This privacy notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit.
What personal data we hold
We collect some data directly from you when you become a contributor on one of our client commissions, become a participant on a Fotonow workshop/activity, register for our newsletters, or access our website. We may typically hold some of the following information about you:
- Your full name;
- an indication of the gender which you most closely associate with;
- Postal address;
- Telephone number(s);
- Email address;
- Your signature;
- Billing address;
- Your company or organisation name;
- Audio recordings;
- Records of your correspondence with us;
- Information you enter onto the Website.
But we may request other information where it is appropriate and relevant, for example:
- Birth year or alternatively a relevant age range
- Ethnicity or cultural background – this is sometimes required by funders for evaluation purposes
- Details of why you have decided to contact us;
- Details of how you would like to be involved and what you intend to do with the information we provide;
- Information about you that will enable us to be more precise in what we send you or how we approach you.
We may collect and manage information from children in some circumstances, such as:
- For youth and community project work;
- Workshops and activities;
- Photography/film/media projects.
Where consent is required, if it is possible and appropriate we seek consent from a parent or guardian in the process of collecting information about children, and we only hold information about children that is absolutely necessary for the purpose of the project/event that they are participating in.
Where a parent gives consent on behalf of a child, we may contact that child after their 18th birthday, to check if they wish to maintain their relationship with us.
Archiving & data retention
We keep data for as long as there is a need to keep it in connection with the purposes for which it was collected.
Fotonow records photographs and video and asks its clients and commissioners whether they need us to store this content and archive it for future client specific purposes.
We understand how valuable this content can be, not just for a current project but also for future projects. We therefore archive all of our projects. We will work with our partners and clients to comply with their own specific GDPR policies and will observe these in order to remain consistent with their obligations to individuals.
We keep consent forms on file as evidence of receipt of active consent from all participants and contributors. These are kept during the course of the project that they relate to and for up to two years after this time, depending on whether they are still relevant to showing that Fotonow have asked for consent.
We archive survey and evaluation forms to use for our social impact reports and evaluation for workshop programmes, projects and educational learning purposes. We will delete or anonymise your data held in the archive where we consider it is no longer of value or interest.
We may keep your personal data after a particular matter or exchange has concluded but purely for record keeping purposes and to be able to respond to queries. In some cases, we are also obliged to retain your personal data to comply with legal or statutory obligations (for example, to keep records of contractual or financial matters).
Whilst the specific time periods vary depending on the circumstances, in general we will not keep communication records that include personal data for more than 6 years after a particular matter or exchange has concluded. In the event that you ask us to stop sending you marketing communications, we will retain certain details, such as your name, to help us ensure that you are not contacted again.
Communications and marketing
We may contact you by post and telephone, and where you have provided consent, by e-mail, to let you know about our events and activities (and those of third parties) that might be of particular interest to you; our products; about the work of Fotonow more generally; We provide the opportunity for you to opt-out from receiving our marketing communications every time we contact you.
You can opt-out from receiving our marketing communications, or update your contact preferences at any time by emailing: firstname.lastname@example.org or using the ‘unsubscribe’ option in our email marketing materials.
How we keep your data safe and who has access to it
We are committed to ensuring that there are appropriate technical controls in place to protect your personal details including from misuse and unauthorised access.
We do not sell or share your personal details with third parties for them to use for marketing purposes.
We work with service providers and other third parties who help us to operate and to provide and improve our information, products and services, and we may share information with them for this purpose.
We may allow our staff, consultants and/or external providers acting on our behalf to access and use your information for the activities we have described above (e.g. to deliver mailings, to analyse data and to process payments). We only permit them to use it to deliver the relevant service, and if they apply equivalent levels of protection that we do.
We may need to disclose your personal information upon request to regulatory and government bodies, law enforcement agencies and suppliers we engage to process data on our behalf. We may also merge or partner with other organisations and in so doing, acquire or transfer information.
The information we collect from you may be transferred to, shared and/or otherwise processed at a destination outside the European Economic Area (“EEA”). If we do we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
Corrections to your information
Except in limited circumstances, you have the right to obtain details of the information that we hold about you. If you would like to do so please contact us using the details below.
We also want to make sure that your personal information is accurate and up to date. Please let us know if your details change. You may also ask us to correct or remove information which is inaccurate.
You can also opt-out of receiving all or some of our marketing communications or request that we stop processing data about you for certain purposes at any time by contacting us using the details below.
If you are unhappy with the way in which we have handled your personal data please contact us using the details below.
In certain circumstances you have a right to require us to stop processing your personal data in a particular way, or for your data to be erased from our database. If it is not necessary for the purpose you provided it to us for (e.g. providing you with a service or item you have requested) or we do not otherwise require the data to be archived for future reference, we will do so.
The legal basis that we rely on for processing your data is either where:
- You have provided your consent to us using your data in a certain way;
- It is within our legitimate interests, or
- It is necessary in connection with the performance of a contract with you; or
- It is necessary to for compliance with a legal obligation to which we are subject.
You have a right to ask for a copy of the information we hold about you. If you want to access your information, please send a description of the information you want to see and proof of your identity to email@example.com
Please let us know if you have any queries or concerns about the way that your data is being processed by contacting us on the details below. You are also entitled to make a complaint to the Information Commissioner’s office, and for further information see the Information Commissioner’s guidance here:
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to firstname.lastname@example.org