SAY SO VOICES PRIVACY NOTICE

 

Introduction

Say So Voices respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you interact with us and tell you about your privacy rights and how the law protects you.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this Privacy Notice

This privacy notice aims to give you information about how Say So Voices collects and processes your personal data when you use our website and through your other dealings with us.

It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Controller

Say So Voices Limited is the controller and responsible for your personal data (collectively referred to as “Say So Voices”, “we”, “us” or “our” in this privacy notice).

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact us at [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review.  It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

This website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

  1. THE 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 different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, image, marital status, title, date of birth, and gender.
  • Contact Data includes postal address, email address and telephone numbers.
  • Financial Data includes National Insurance, VAT and bank account details.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Special Categories of Personal Data this is information about your health for insurance purposes only.  We do not collect any other special categories of personal data (e.g. relating to racial or ethnic origin, biometric data or criminal offences).

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with voiceover work). In this case, we may have to cancel a job you have with us but we will notify you if this is the case at the time.

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms (e.g. our new artist form) or by corresponding with us by post, phone, email or otherwise.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from third parties and public sources such as the internet or social media.
  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • 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.  In this case, 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 our legitimate 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.
  • Where we need to comply with a legal obligation that we are subject to.

Generally, we do not rely on your consent as a legal basis for processing your personal data although we will obtain consent from our artists to use any information about your health for insurance purposes, and in these cases artists can withdraw such consent at any time.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / activity

 

 Type of data

 

 Lawful basis for processing including basis of legitimate interest
To register you as a new artist, client or supplier Identity

Contact

 Performance of a contract with you
To provide you with a service including: assessing artists’ suitability for roles; shortlisting artists and overseeing their work; managing payments, fees and charges; collecting and recover money owed to us Identity

Contact

Financial

Marketing and Communications

 Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us and provide a high quality service)

 
To manage our relationship with you which will include notifying you about changes to our terms or privacy notice

 

 Identity

Contact

Marketing and Communications

 

 Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to keep our records updated and to ensure we provide a high quality service)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

 Identity

Contact

Technical

 

 Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Necessary to comply with a legal obligation
For legal and regulatory compliance purposes, for example, to ensure compliance with health and safety requirements and other legal or fiscal obligations, or in connection with litigation or an internal investigation or audit and to ensure compliance with anti-money laundering, bribery and corruption regulations, as well as equal opportunities monitoring Identity

Contact

Financial

Special Category

 Performance of a contract with you

Necessary to comply with a legal obligation

Consent

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing.

We may use your Contact Data to send you information about our services (for example in the form of newsletters) which may be relevant to you and you have not opted out of receiving that marketing.

We will not share your personal data with any third party for marketing purposes.

Opting out

You can ask us to stop sending you marketing messages or newsletters by contacting us at any time at [email protected].

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of services provided by us to you.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to use our site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

These are the cookies that we use on our website, which is a WordPress site:

Login Cookies

Login cookies contain authentication details and are used when a user logs into the WordPress admin dashboard. According to the WordPress Codex, a couple of different session cookies are set:

On login, WordPress uses the wordpress_[hash] cookie to store authentication details (limited to the /wp-admin/ area).

After login, WordPress sets the wordpress_logged_in_[hash] cookie. This indicates when you’re logged in and who you are.

When you try to access the back-end of your WordPress site, a check is done to see if the two cookies above exist and haven’t expired.

WordPress also sets wp-settings-{time}-[UID] cookies. The ID being your user ID from the WordPress users database table. This stores personal dashboard and admin interface settings.

Comment Cookies

By default, there are cookies set when someone comments on a blog post (with an expiration of 347 days). This is so they don’t have to fill out all the information all over again on each visit. The following three cookies are stored:

comment_author_[hash]

comment_author_email_[hash]

comment_author_url_[hash]

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 at [email protected].

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

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 law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the following third parties:

  • agencies and broadcasters wishing to engage voiceover talent;
  • those who provide a service to us (such as our IT providers);
  • our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the 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.

 

  1. INTERNATIONAL TRANSFERS

We may need to share your personal data outside the European Economic Area (EEA), for example with agencies and broadcasters based abroad who are interested in engaging voiceover talent.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • The country in question has been deemed to provide an adequate level of protection for personal data by the European Commission.
  • We have in place specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we transfer your personal data to our business contacts based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us at [email protected]if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of maintaining our relationship with you and satisfying any legal, regulatory, tax, accounting or reporting requirements. 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.

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.  You have the right to:

  • 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 and to check that we are lawfully processing it.
  • 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:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • 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.
    • 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. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, 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.

If you wish to exercise any of the rights set out above, please contact us at [email protected].

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 could 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 could 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.

 

Last updated: January 2019