Privacy Notice

Last updated: January 2024

1. Introduction

This Privacy Notice sets out how Walk on Air Films Limited (“we”/“us”) uses and protects any information that you give us. We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this Privacy Notice.

2. About Us

Company Name: Walk on Air Films Ltd
Country of Registration: Northern Ireland
Company Number: NI673243
Registered Office: Crescent Arts Centre, 2–4 University Road, Belfast, BT7 1NH
Tel: +44 7738 710 881
Email: martha@walkonairfilms.com

3. What We Collect

  • name and job title;
  • contact information including email address;
  • demographic information such as postcodes;
  • details about you, if you are applying to and ultimately taking part in a programme;
  • details about you, if you have sent us an application for a job or speculative work;
  • details about you, if you are supplying us with services;
  • your image; and/or
  • any other personal information you choose to disclose to us or we capture in the course of our relationship with you.

4. How We Use Your Information

a. Purpose: to answer your queries or complaints.
Personal information used: your name and contact details submitted.
Lawful basis: legitimate interests to answer your query or complaint and improve the services we provide or to otherwise contact you in the course of our relationship with you.

b. Purpose: direct marketing on a specific programme where you have opted to receive communications from us.
Personal information used: your name and email address you have registered on the site with.
Lawful basis: consent. We will always ask you to agree before using this information and you may withdraw your consent at any time by contacting us via our contact details in section 15 below.

c. Purpose: applications for a job or speculative work.
Personal information used: all the CV/career information you have sent or disclosed to us, or we may obtain from other sources (e.g., referees, social media, etc).
Lawful basis: legitimate interests to consider you for work and future opportunities.

d. Purpose: applications to be on a programme, taking part, or contributing to a programme.
Personal information used: contact details and any information you choose to disclose to us, including information on your race, ethnicity, your physical and mental health, sexual orientation, and information relating to any criminal offences. If you choose to take part in a programme, this may also include other personal information (such as details of your education, employment and lifestyle and information on social media about you). If the applicant is a child, this will include the contact details of the parent or guardian.
Lawful basis: depending on where we are in the application and production process, this may be based on your consent, the legitimate interests of us or third parties (such as co-producers, the commissioner, broadcasters, distributors of the programme) to make and exploit the programme and keep proper records, for the fulfilment of our contractual obligations to you or so that we and the third parties referred to above can comply with our legal obligations.

e. Purpose: to provide services to us.
Personal information used: your name, contact details, VAT No and bank account details.
Lawful basis: to comply with our obligations under our contract with you (e.g., to make payment to you for your services). We also have a legitimate interest to consider you for further work opportunities.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time by contacting us as described in section 15 below. We will generally only ask for your consent for direct marketing. Withdrawal of consent will not affect any prior use, and we may still process personal information on other legal bases.

5. Change of Purpose

  1. 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.
  2. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis.
  3. We may process your personal data without your knowledge or consent where required or permitted by law.

6. Where We Collect Your Personal Information From

We collect personal information from a number of sources (non-exhaustive):

  • Directly from you (e.g., when you contact us, meet us face to face, or complete electronic/paper forms).
  • From our website (see section 7.e.).
  • Where you apply to work or participate on a programme:
    • from publicly available sources (e.g., social media platforms);
    • from other sources that you give us permission to access (e.g., medical health checks, criminal offences data) and from your referees.

7. Who We Share Your Personal Information With

  1. Programme applicants/participants: co-producers, broadcasters and distributors; worldwide public disclosure to the extent your personal information is included in a programme; and the Creative Diversity Network for Diamond diversity research (see 9.c.).
  2. Service providers and advisors (IT support, data analysis, legal/financial advisors, etc.).
  3. The Government or regulators where required by law.
  4. Police and law enforcement to assist with the investigation and prevention of crime.
  5. Website logs: we log IP addresses, browser type, ISP info, referring/exit pages, and timestamps to analyse trends, administer the website, track movements, and gather broad demographics (not linked to personally identifiable information); we may use Google Analytics (see our Cookie Policy) and provide third parties with aggregate statistics that do not identify individuals.

8. Transferring Your Personal Information Internationally

  • If your personal information is included in a programme, that programme may be made available worldwide.
  • Directors/individuals working for us may access personal information outside the UK/EU in limited circumstances under our security measures and English law arrangements.
  • In limited cases, third parties we disclose to may be outside the UK/EU; we will impose legally required protections before disclosure.
  • Contact us (section 15) for more details on these arrangements.

9. Retention, Updating and Removal of Your Personal Information

  1. We will not transfer or store your information outside the EEA except as expressly stated in this Notice.
  2. If you take part in a programme, we determine retention based on the amount, nature and sensitivity of data, risk of harm, purposes, alternatives, and legal requirements—usually for the programme life cycle, including distribution.
  3. If a UK-commissioned programme participates in the ‘Diamond’ diversity initiative via Silvermouse, you may opt out. See creativediversitynetwork.com/diamond/.
  4. Job applicants: we may keep your CV for ~12 months for future roles; candidate information is kept until the end of recruitment or a further 12 months. Those engaged will have data kept per our Internal Privacy Notice.
  5. Programme applicants: we keep your application until the end of casting; if unsuccessful, it is securely destroyed unless we have permission to retain for the next series. If selected, 9.b. applies.
  6. Please keep your personal information accurate and up-to-date; contact us (section 15) to update details.
  7. We will notify you and any applicable regulator of a data-protection breach where legally required.

10. Security

We use security measures (such as passwords and firewalls) to protect information under our control. We cannot guarantee these measures are or will remain adequate, but we take data security seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect.

11. Your Rights in Relation to Your Personal Information

You may have the following rights: to be informed; access; rectification; erasure (in limited circumstances); restriction; objection; data portability; and to object to certain automated decision-making. Some rights may not apply due to requirements/exemptions. For general information on your rights, see the ICO: https://ico.org.uk/your-data-matters/. To exercise rights, contact us (section 15).

Complaints will follow our procedure: initial review and response within 28 days; you may request escalation to a senior person for further response within 28 days. You can also complain to the UK Information Commissioner’s Office: https://ico.org.uk/make-a-complaint/. We encourage you to contact us first.

We do not charge a fee to exercise rights unless a request is clearly unfounded, repetitive or excessive. We may verify identity and request further information. We aim to respond within one month, notifying you if more time is needed for complex/multiple requests.

12. Direct Marketing

We will only send you emails on a specific programme where you have opted to receive communications. You can opt out at any time via the unsubscribe link or by contacting us (section 15).

13. Links to Third-Party Sites

Our website may include links to third-party websites, plug-ins and applications. Clicking those links may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy statements. Please read their privacy notices.

14. Changes to This Privacy Notice

We may alter this Privacy Notice at any time. Changes will be posted on the website and take effect three business days after posting. If you object to any alteration, please contact us (section 15).

15. Contacting Us

If you need to contact us about this Privacy Notice or any matters relating to the personal information we hold on you, write to us at: Walk on Air Films Limited, Crescent Arts Centre, 2–4 University Road, Belfast, BT7 1NH or email martha@walkonairfilms.com.