Privacy

policy

This policy explains how Quite Frankly Productions Limited collects and uses personal information, and the rights people have over it. Our employees receive a separate privacy notice.

1. Who we are

Quite Frankly Productions Limited (“Quite Frankly”, “we”, “us”) is a video production company registered in England and Wales with number 04941188, at Studio 2, 25 Easton Street, London WC1X 0BE. We are registered with the Information Commissioner’s Office under number Z1903994.

For anything in this policy, contact our privacy lead at info@quitefranklyproductions.com, by phone on 020 7636 5497, or by post to the address above.

2. Our role

2.1 When we make films for clients, we usually act on the client’s behalf. For people filmed as part of a client project (for example, a client’s employees), the client is generally the controller of that information and its own privacy notice applies. We act as its processor.

2.2 We are the controller, and this policy applies, when we decide how information is used: for example, for our own clients, suppliers and freelancers, people who contact us or use our website, job applicants, contributors we cast or film directly, and films made by the Quite Frankly Foundation.

3. Whose information we collect, and what

Website visitors and people who contact us - Name, email, phone, organisation, message; technical data such as IP address, device, browser and pages visited

Clients and prospective clients - Names, job titles, business contact details, correspondence, meeting notes, marketing preferences

Suppliers and freelancers - Contact details, skills, rates, availability, bank and tax details, invoices, insurance and right-to-work checks

People who appear in or contribute to our films - Name, contact details, image, voice and words, release forms, and any information shared on camera

Job applicants - CV, covering letter, employment history, qualifications, references, interview notes, right-to-work documents

3.1 Contributors sometimes choose to share sensitive information on camera, such as health, ethnicity, religion or personal experiences, especially in charity films. We only record and use this with the person’s explicit consent, and only for the film it was given for.

3.2 We collect information directly from you, from your employer if you work for a client or supplier, from recruiters and referees, and from public sources such as company websites and LinkedIn when researching prospective clients.

4. Why we use it, and our lawful basis

Replying to enquiries and messages - Legitimate interests: running our business and responding to people who contact us

Delivering projects and managing client relationships - Contract, where the contract is with you; otherwise legitimate interests in working with your organisation

Engaging and paying suppliers and freelancers - Contract; legal obligation for tax, accounting and right-to-work checks

Filming contributors and using their contribution in the agreed film - Contract (the release form) or consent; explicit consent for any sensitive information

Showing our work in our showreel, website and awards entries - Legitimate interests in promoting our business, within what the client and contributor have agreed

Sending business news and updates to people at client and prospective client organisations - Legitimate interests; you can unsubscribe at any time using the link in every email

Recruitment - Taking steps before entering a contract; legal obligation for right-to-work checks

Website security and statistics - Legitimate interests in running a secure, working website; see section 10 on cookies

Keeping records, meeting legal duties and handling disputes - Legal obligation; legitimate interests in protecting our legal position

4.1 Where we rely on legitimate interests, we have weighed our interests against yours and concluded they are not overridden. You can ask us for details of that assessment and object at any time (section 8).

4.2 Where we rely on consent, you can withdraw it at any time. This does not affect what we did before you withdrew it. Once a film has been delivered to a client or published, it may not be possible to remove a contribution from it, which we will explain before filming.

4.3 We do not make decisions about people based solely on automated processing, and we do not sell personal information.

5. Who we share it with

We share personal information only where needed for the purposes above, with:

• Our sister companies in the United States (Quite Frankly Productions USA Inc) and India (Quite Frankly Productions India Pvt Ltd), which work with us on projects;

• The client a film is made for, where you appear in or contribute to it;

• Freelancers, crew, editors and post-production partners working on a project;

• Service providers that support our business, such as cloud storage, file transfer, email, IT support, payroll and accounting;

• Travel agents, airlines and hotels, when arranging travel for a shoot;

• Our professional advisers, insurers and bank;

• HMRC, regulators, courts and the police, where the law requires; and

• A buyer or investor, if all or part of our business is sold or restructured.

Our service providers may use the information only on our instructions.

6. International transfers

Because we work across offices in London, New York and Bangalore, and use cloud services, personal information may be transferred outside the UK. When it is, we make sure it is protected by:

• UK adequacy regulations, including the UK Extension to the EU–US Data Privacy Framework where the recipient is certified; or

• The ICO’s International Data Transfer Agreement or International Data Transfer Addendum, together with any extra safeguards needed.

You can ask us for details of the safeguards that apply to your information.

7. How long we keep it

Enquiries that do not lead to work - 2 years from the last contact

Client and supplier contact records - For the relationship, then 2 years

Invoices, contracts and financial records - 6 years after the end of the financial year they relate to

Marketing contacts - Until you unsubscribe; we review inactive contacts every 3 years

Release forms and consents for films - For as long as the film is used, then 6 years

Rushes and project files - Archived indefinitely so clients can re-use them; you can ask us to delete footage of you, subject to the client’s rights in the film

Job applications that are unsuccessful - 6 months after the role is filled

Website statistics - Up to 14 months

When information is no longer needed, we delete it securely or anonymise it.

8. Your rights

You have the right to:

• Ask for a copy of the personal information we hold about you;

• Ask us to correct information that is wrong or incomplete;

• Ask us to delete your information, or restrict how we use it;

• Object to our use of your information where we rely on legitimate interests, and to stop marketing at any time;

• Ask us to transfer information you gave us to another organisation, where we rely on consent or contract; and

• Withdraw your consent, where we rely on it.

These rights have some legal exceptions. To use any of them, contact us using the details in section 1. There is normally no charge. We will respond within one month, or tell you within that month if we need up to two more months because the request is complex.

9. Complaints

If you are unhappy with how we have handled your personal information, please complain to us first by email or post using the details in section 1. We will acknowledge your complaint within 30 days and tell you the outcome without undue delay.

If you are still not satisfied, you can complain to the Information Commissioner’s Office at ico.org.uk/make-a-complaint or on 0303 123 1113.

10. Cookies

10.1 Cookies are small files stored on your device when you visit a website. We use:

Strictly necessary - Makes the site work and keeps it secure Always on

Analytics - Tells us, in aggregate, how the site is used so we can improve it Only with your consent

Video players - Set by the video platform we use when you play a film embedded on the site Only with your consent

10.2 The cookies we use are listed in our cookie settings, which you can open at any time from the link in the footer. You can also block or delete cookies in your browser, though parts of the site may then not work.

11. Changes to this policy

We will update this policy when our practices or the law change. The date at the top shows when it was last updated. If we make significant changes, we will tell people we are in contact with.