Photography, Audio and Video Privacy Notice

Introduction

Revell Research Systems Limited (the Company, we, us, our) is providing you with this information in order to comply with the Data Protection Act 2018 and the General Data Protection Regulation 2016 (GDPR), which require us to tell you what we do with your personal information.

This notice relates to the personal data that is processed by us when you are photographed, filmed or recorded for work commissioned by us. The resulting photography, audio or video may contain personal data. Audio and video may also be broadcast live or at a later date.

We may commission photography, recording or filming for use in internal or external promotional material or for archive purposes. These commissions may be general in nature or cover specific events, such as networking, receptions, lunches, dinners, public relation activities, training events and prize giving ceremonies that we organise or that we are invited to. They may take place in public or private spaces. We may also be commissioned to photograph, record or film activities by our clients.

Data protection legislation considers photography, audio and video of identifiable individuals as personal data. However, it is not always simple to decide whether such content contains personal data as it depends on whether an individual can be identified. Clearly, there is a difference between a portrait and a stadium crowd. The more people in the photograph, audio or video recording segment the less likely individuals will be identifiable and the less likely that data protection legislation will apply.

Staff, associates, client personnel and members of the public may appear in photography, audio and video recordings.

We may use resulting photography, audio and video in a variety of online and offline media, including print, web and social media. It is possible for people to share posts from social media or save images from our web sites and social media accounts and re-use them.

We will not use your personal data in subsequent marketing communications without your explicit consent, although we may add details about your organisation to our marketing system as an interested party, which is outside the scope of privacy legislation.

Who is collecting this personal data?

Revell Research Systems Limited is collecting this data as the Data Controller.

Revell Research Systems Limited is registered with the Information Commissioner in the United Kingdom as a data controller under number Z186392X.

Who are we sharing your Personal Data with?

We may share your personal data processed under this notice with the following third parties:-

• The courts and those involved in legal proceedings and non-contentious matters, including solicitors and barristers
• Police and law enforcement agencies
• Our subsidiaries, our ultimate holding company and all its subsidiaries
• General public
• Agents acting on our behalf
• Service providers (including associates)
• Professional advisors

We will not sell or rent your data to third parties. We will not share it with third parties for marketing purposes.

Why are we collecting and what will we do with Your Personal Data?

We are collecting this information to help us develop our business or conduct client assignments. We may commission photography, audio and video recordings to support marketing activities, web development, archiving, health and safety, security, identity checks, learning, professional development, research and training.

We may process this data for the purpose of the proper administration of our business and in communicating with you as well as maintaining backups.

We may share data with the courts and associated professionals in establishing, exercising or defending your, another's or our legal rights. We may share data in reporting crime to or in co-operating with the police and law enforcement agencies.

What is the legal basis for processing?

Our lawful purposes are Contract and Legitimate Interest.

• contract - the Company processes personal data in performing a contract with staff, associates or clients involving photography, audio or video.
• legitimate interests - the Company has a legitimate interest in using photography, audio and video recordings for marketing, archival, health and safety, security, identity checks, learning, professional development, research and training as well as in protecting and asserting our, your or another's legal rights; and in properly administering its business and backing up data.

These lawful purposes are detailed in Article 6 of the General Data Protection Regulation (GDPR):-

• processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b)).
• processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (Article 6(1)(f)).

You may object to subsequent processing of your personal data that you initially agree to, but please be aware that we may not be able to uphold the request. For instance, we may use your image in print media.

If you wish to object during an event after your details have been captured then please ask our staff to delete the data. They will use their professional judgement as to whether to comply, which they will usually do unless there is a compelling reason to do otherwise. If you wish to object after the event but before the material is used then please contact us. We may be able to edit the material to remove you or render you unidentifiable.

How are we collecting this information?

We obviously capture your personal data in the photograph, audio or video recording we make.

If you might or do feature, or otherwise prominently appear, in a photograph or recording then we may also ask you to provide basic details about yourself, including how we might contact you in the future.

We will make reasonable efforts to inform people that photography, recording or filming is taking place at a venue. We will publish notices to advise people that photography, recording or filming is taking place (for example, as notices at the venue, on our web site, by email and at the time of booking, where applicable).

If the lawful basis is legitimate interests then people have the right not to appear in an identifiable way in photography, audio or video. Please contact us to let us know if you do not want to be photographed, recorded or filmed. Regrettably, if there is no way to prevent this, it may result in the person choosing not to attend the event.

You have the legal right to object to the processing of your personal data when the legal basis is legitimate interest. We will consider your request but we are not obligated to grant it. You can avoid being featured by acting on event signage to place yourself in photography or recording free zones, choosing to stand out of shot or leaving the whole area when the shoot or recording starts. You can also decide not to attend. You can ask the photographer or recording team not to include you. We ask our photographers and recording staff to ask people if they are willing to be included and asking you to step out of shot if you are not. We may provide indicators (coloured stickers or lanyards) at some events to wear so you are not included against your wishes.

Where the lawful basis is contract, you must appear in the photography or recording in order to fulfil the contract. For example, staff and associates may need to have their photograph taken and displayed on our web sites, intranet or Company identity cards.

What information are we collecting?

We typically collect the following personal information when you are in a photograph, audio or video recording:-

• your name and style of address
• gender
• job title
• organisation
• email address
• telephone number
• other contact details
• date, time and duration of capture
• the content itself including any embedded personal data whether photographic, audio or video

Who can see your information within the Company?

Only authorised directors, staff and associates may access your data.

How long is your information kept?

We will only keep your information for as long as necessary. The retention period is either dictated by law or our legitimate requirements. Once your information is no longer needed it will be securely and confidentially destroyed.

We typically retain personal data relating to enquiries for six years after the financial year in which they occurred based on the Limitation Act 1980 and often for considerably shorter periods where the conversation did not lead to a contract being formed.

How secure is your information?

We take stringent steps to keep your information secure. You can read more about our approach to security at www.rrs.co.uk/security.

Who keeps your information updated?

You are responsible for keeping your personal details up-to-date. Please advise the Company of any changes.

Will your information be used for any automated decision making?

No.

Our Privacy Statement

You can access the Company's Privacy Statement at www.rrs.co.uk/privacy. This statement provides you with more information about how we address data protection and privacy as well as informing you of your rights.

Other Privacy Notices

You are likely to interact with us in more than one way, so our other privacy notices may apply to you in different scenarios. We are open and transparent about how we use your personal data. You can find all of our Privacy Notices at www.rrs.co.uk/privacy.

Changes to this Notice

We may change this privacy notice at any time. Any changes to this privacy notice will apply to you and your data immediately. If these changes affect how your personal data is processed, the Company will take reasonable steps to make sure you know.

Further Information