This policy describes how we use your personal data when you use our website (https://www.productionbureau.com/) or our apps or when we provide services to you. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.
You can read, print and save this whole policy to see specific information about:
· Who we are and how you can contact us
· What personal data we collect about you
· What we use your personal data for
· When we need your consent to use your personal data
· Personal data you are legally obliged to provide
· Your rights to know what personal data we hold and to control how we use it
· Automated decision making and profiling
· When we will share your personal data with others
· How we keep your personal data safe
· How we use your personal data for marketing
· When we will send your personal data to other countries
· How long we keep your personal data
· How you can make a complaint
· How we keep this policy up to date
Who we are and how you can contact us
We are Production Bureau Limited (referred to as “we”, “us”, “our” in this policy), registered company number 04115489, registered office at Hall Farm, Gowthorpe Lane, Swardeston, Norwich, Norfolk, NR14 8DS.
We are the “controller” in respect of the personal data which you provide to us.
We have appointed a Data Compliance Manager who is responsible for overseeing this policy and our compliance with data protection legislation. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the Data Compliance Manager using the details set out below:
Postal address: Hall Farm, Gowthorpe Lane, Swardeston, Norwich, Norfolk, NR14 8DS
Telephone: 01508 578 598
What personal data we collect about you
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer the following types of personal data about you:
· Personal data that you provide to us. There are lots of ways in which you may share your personal data with us, for example, you may make an enquiry via our website, post on social media sites that we run, use our apps or contact us in connection with services that you would like to buy, or have already bought, from us. The personal data that you provide to us may include your name, address, e-mail address and phone number, financial and credit card information, job role and employer and any other information you choose to provide to us.
· Personal data that we receive from third parties. If we work with other businesses or use sub-contractors these parties may collect personal data about you which they will share with us. For example, we may have your name and contact details passed to us by a mutual contact who refers you to us so that we can provide your with our services, or receive feedback from a sub-contractor we have instructed to help us provide you with services that you have requested.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
What we use your personal data for
We will only use your personal data where data production law allows us to do so. In most cases, we will rely on one of the lawful bases set out in the data protection legislation for processing your personal data, as follows:
· where we need to perform the contract we are about to enter into or have entered into with you;
· where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
· where we need to comply with a legal obligation; or
· where we have obtained your consent to a specific type of processing.
We use your personal data to:
· process and respond to any enquiry you make;
· provide you with the information, products and services that you request from us;
· keep you informed about the event you are attending;
· provide you with information about new products or services which may be of interest to you;
· manage and administer our business; and
· review and improve our service.
Personal data that we receive from third parties may be combined with the personal data that you provide to us and used for the purposes described above.
Personal data about your use of our website and/or our event apps is used to:
· administer our website and apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to improve our website and apps to ensure that content is presented in the most effective manner for you and for your computer or mobile device;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our site and apps safe and secure; and
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by data protection law.
Third party links
When we need your consent to use your personal data
Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
· we are entering into and carrying out our obligations under a contract with you and those obligations require us to use your personal data; or
· we need to use your personal data for our own legitimate interests.
Where we are using your personal data for our own legitimate interests, we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for those interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will explain how we wish to use your data and ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
Personal data you are legally obliged to provide
You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our services to you.
Your legal rights in respect of your personal data
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below for more information about these rights:
· Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
· Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please contact us.
Automated decision making and profiling
We do not make use of automated decision making or profiling.
When we will share your personal data with others
We share your data with the following people in the day to day running our business:
· any business partners, suppliers and sub-contractors we work with to provide you with goods or services that you have requested from us. This may include App, Freenlance, Transport, Hotel and Venue suppliers;
· advertisers and advertising networks (see How we use your personal data for marketing for more information; and
· analytics and search engine providers that assist us in the improvement and optimisation of our site and app.
We require all third parties to respect the security of your personal data and to treat it in accordance with data protection law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also share your personal information with third parties on a one-off basis, for example, if:
· we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets; or
How we keep your personal data safe
We take every care to ensure that your personal data is kept secure. The security measures we take include:
- only storing your personal data on our secure servers;
- ensuring that our staff receive regular data security awareness training;
- limiting access to your personal data to those employees, agents, contractors and other third parties who have a business need to know;
- keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises;
- maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems;
- enforcing a strict policy on the use of mobile devices and out of office working;
- putting in place procedures to deal with any suspected personal data breach; and
- maintaining our systems to the Governments Cyber Essentials Standard to ensure security of your data and our working practises.
Please remember that you are responsible for keeping passwords secure. If we have given you (or you have chosen) a password which enables you to access certain parts of our website or use our apps, you are responsible for keeping this password confidential. Please do not to share your passwords with anyone.
Unfortunately, sending 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 personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.
How we use your personal data for marketing
We will add your details to our marketing database if:
We use this marketing database in order to contact our existing clients, and potential clients who have expressed an interest in our services, in order to offer products or services which may be of interest. The lawful basis for this use of personal data is that it is in our legitimate interest to develop our products and services and grow our business.
- you make an enquiry about our services;
- you buy our services; and
- you have told a third party that you would like them to pass us your contact details so that we can send you updates about our services.
If you no longer wish to receive this type of communication, you can ask us to stop contacting you by calling or emailing us using the details set out in the Who we are and how you can contact us section above.
When we will send your personal data to other countries
Your personal data may be transferred to, and stored at, a destination outside the UK by us or by our sub-contractors. Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the UK.
Whenever we transfer your personal data outside of the UK, we will take all steps reasonably necessary to ensure that your data is treated securely by ensuring that at least one of the following safeguards is implemented:
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
· Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For example, one of the apps which we use for our events is created and run by KitApps Inc (trading as Attendify), a company based in California, USA. Any personal data you provide via the app will be collected and processed by KitApps Inc on our behalf. We have entered into a contract with KitApps, using the Standard Contractual Clauses adopted by the European Commission, and approved in the UK, to ensure that your personal data is protected.
How long we keep your personal data
We only keep your personal data for as long as we actually need it, for the purposes for which it was originally collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. In practice this generally means that we will keep:
· your name and contact details for marketing purposes until you unsubscribe;
· a record of the services (including a copy of your full customer file) we provide to you for 5 years; and
· complaint records for 5 years.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
If you would like further information about our data retention practices please contact us using the contact details found in the Who we are and how you can contact us section.
Please note that we may anonymise your personal data (so that it can no longer be associated with you) in order to use it for statistical purposes. We keep anonymised and statistical data indefinitely.
How you can make a complaint
If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the Who we are and how you can contact us section above.
You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.
How we keep this policy up to date
We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.
The easiest way to check for updates is by looking for the latest version of this policy on our website (https://www.productionbureau.com/) or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.
Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.
This is policy version 2 which came into effect on 25th May 2018[AJ1]