1. Introduction

1.1 We are committed to safeguarding the privacy of HCA Entertainment Ltd’s employees, television contributors, video contributors, clients and contractors.  Please refer to our website privacy policy for website users.

1.2 This policy applies where we are acting as a data controller with respect to personal data; in other words, where we determine the purposes and means of the processing of that personal data.

2. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

3. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.

3.2 As Employees of HCA Entertainment Ltd we may process your information including your name, address, telephone number, email address, gender, date of birth.  The legal basis for this processing is our legitimate interests, namely the proper administration of our business OR the performance of a contract between you and us.   Should ‘special data’ be required to be processed the legal basis for this processing will be consent.

3.3 As Television Contributors & Video Contributors being filmed by HCA Entertainment Ltd or authorized contractors we may process your information including your name, address, telephone number, email address, gender, date of birth.   The purposes for which we may process your personal data are; contacting you regarding the production of a television programme / series HCA Entertainment Ltd has been commissioned to make or is trying to get commissioned, organising filming, fact checking or information gathering, to inform the contributor of transmission dates, any other legitimate purpose regarding the production of television programmes / series.  The legal basis for this processing is our legitimate interests. Should ‘special data’ be required to be processed the legal basis for that processing will be consent.

3.4 As Clients of HCA Entertainment Ltd we may process your information including your name, address, telephone number, email address.   The purpose for which we may process your personal data is the production of the product you are contracting HCA Entertainment Ltd to make including but not restricted to for example; commissioning discussions, contract discussions, creative discussions, pre-production meetings, production meetings, post production meetings & viewings, production delivery, production transmission.  The legal basis for this processing is our legitimate interests.          

3.5 As Contractors of HCA Entertainment Ltd we may process your information including your name, address, telephone number, email address.   The purpose for which we may process your personal data is the production of the product HCA Entertainment Ltd is contracting you to produce including but not restricted to for example; contract discussions, creative discussions, pre-production meetings, production meetings, post production meetings & viewings, production delivery, production transmission.  The legal basis for this processing is our legitimate interests.          

3.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [the proper protection of our business against risks.

3.8 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary 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.

3.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

4. Providing your personal data to others

Your personal data will not be used for marketing purposes and will only be passed onto individuals or companies that have a legitimate reason based on the proper administration of our business to have your personal data.     

4.1 We may disclose your personal data for a legitimate reason as set out in section 3 with regards to the organisation of the production of television programmes, series, other video types or HCA Entertainment Ltd projects.   

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, filing of accounts, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary 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.

6. Your rights

6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. 

6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

6.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

6.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

6.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

6.13 You may exercise any of your rights in relation to your personal data by written notice to us OR by the use of a Data Request Form.

7. Our details

7.1 This website is owned and operated by HCA Entertainment Ltd.

7.2 We are registered in [England and Wales] under registration number 03201650, and our registered office is at Chantry Lodge, Pyecombe Street, Brighton, United Kingdom, BN45 7EE].

7.3 You can contact us:

(a) by telephone, on 0207 287 7622; or 01367 810 764
(b) by email, info@hcaentertainment.com