Film and Video Umbrella (“FVU”) is an organisation working in the visual arts. We make and curate artists’ moving-image works and exhibit them in collaboration with galleries and other organisations.
We currently have a single office, located at: 8 Vine Yard, London SE1 1QL, UK
FVU’s contact details are: +44 (0)20 7407 7755 / email@example.com
We are constituted as a Charitable Incorporated Organisation registered with the Charity Commission for England and Wales. Our Charity Number is: 1165046.
This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal data. We may update this Policy from time to time without notice to you, so please check it regularly.
1. When we collect information about you
(1) When you give it to us DIRECTLY
You may give us your personal data where you sign up to our e-bulletin, when you contact us by phone, email, SMS or post, where you agree to participate in an audience survey, where you work with us as an artist, a volunteer, or a freelance contractor, where you apply for employment with us, where you make a submission to FVU as an artist, curator or writer responding to one of our open call opportunities, where you agree to appear in a film, video, photograph or audio recording, when you buy anything from our online shop, and/or when you donate money to us.
(2) When you give it to us INDIRECTLY
Your information may be provided to us by others, including users of our services, independent event organisers, other fundraising entities, sponsors and supporters of our organisation. Your information will also be provided to us when you follow us or otherwise interact with us on or via Twitter, when you like and/or join our page on Facebook, or otherwise interact with us in other ways on or via Facebook, Instagram, Youtube, Soundcloud Vimeo or similar social media. You may inadvertently appear in a film, video, photograph or audio recording.
(3) When you give permission to OTHER ORGANISATIONS to share it or it is AVAILABLE PUBLICLY
We may combine information you provide to us with information available from external publicly available sources. We use this information to gain a better understanding of you, and to improve our work, products, communications and fundraising activities.
(4) When you visit our WEBSITE
2. What information do we collect?
We may collect, store and use the following kinds of personal data:
(1) We will typically hold your name and contact details, including email address, physical address and telephone numbers.
(2) Information about your computer and about your visits to and use of this website, including your IP address, geographical location, browser type, referral source, length of visit and number of page views. We will only ever review this data in anonymised aggregate form.
(3) Information about services and products of interest to you or any marketing and/or communications preferences you give.
(4) Any other information shared with us as described in paragraph 1, above.
Do we process sensitive personal data?
Applicable law recognises certain categories of personal information as sensitive and therefore requiring more protection, including health information, ethnicity and political opinions. We may collect sensitive personal data about you. Examples of this may include when you complete an audience survey, or when you complete an equal opportunities monitoring form as an artist we work with, an applicant to one of our artist or job opportunities, or a freelancer we hire. We would only collect sensitive personal data if there is a clear reason for doing so, and will only do so with your explicit consent. This data is then stored in anonymised aggregate form.
3. How and why will we use your personal data?
Personal data, however provided to us, will be used for the purposes specified in this Policy.
We may use your personal information to:
(1) send you information about our work;
(2) handle the administration of any donation or other payment you make via credit/debit card, cheque, standing order of BACS transfer;
(3) collect payments from you and send statements and/or receipts to you;
(4) handle the administration of any application you make to us, including for employment/volunteering opportunities, or in relation to your creative work;
(5) conduct equal opportunities monitoring;
(6) better understand how people are using our website and social media channels, and improve your browsing experience by personalising your interaction with our website;
(7) conduct research, including research into our audiences using audience segmentation tools, as well as the research described more fully in paragraph 4 below;
(8) deal with enquiries and complaints made by or about you relating to the website or us in general; and
(9) audit and/or administer our accounts.
4. Supporter research/profiling including wealth screening
With your consent, we may use your personal information to undertake research to gather further information about you from publicly accessible sources (as described in paragraph 1 above) and note down information that you tell us about yourself. This helps us to get a better understanding of your background, interests and preferences in order to improve our communications and/or interactions with you (including fundraising), to help ensure they are targeted to be relevant and appropriate, and provide information (sometimes through third parties) about petitions and other aspects of our services which we consider may be of interest to you.
You can opt out of the collection of information for such purposes at any time by contacting us at firstname.lastname@example.org
5. Communications, fundraising and marketing
Where you have provided the appropriate consent, we will contact you by e-mail, to let you know about our events and/or activities that we consider may be of interest e.g. about the work of FVU and to ask for donations or other support.
6. Payments made via our website
7. Children’s data
If you are aged 12 and under, in relation to any service we provide, we may only process your data if we have prior consent from a parent or guardian, and will only hold your information to the extent that it is necessary for the purpose that such information has been provided to us.
8. Other disclosures
9. Security of and access to your personal data
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure of or access to your personal information. For example, we conduct regular data deletions and anonymise data where applicable.
Your information is only accessible by appropriately trained staff, volunteers and contractors.
We may use agencies and/or suppliers to process data on our behalf. We may also merge or partner with other organisations, and in so doing transfer and/or acquire personal data.
Please note that some countries outside of the European Economic Area (“EEA”) have a lower standard of protection for personal data, including lower security requirements and fewer rights for individuals. We may transfer and/or store personal data collected from you to a destination outside the EEA, for example, so that it may be processed for us by agencies and/or suppliers. If we transfer and/or store your personal data outside the EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your personal data.
10. Your rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes such as being unsubscribed from our email list at any time. You also have the following rights:
(1) Right to be informed – you have the right to be told how your personal information will be used. This Policy and other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
(2) Right of access – you can write to us to ask for confirmation of what information we hold on you, and to request a copy of this information. Provided that we are satisfied that you are entitled to see the information requested, and we have confirmed your identity, we have 40 days to comply with this request. As of 25 May 2018, we will have 30 days to comply.
(3) Right of erasure – as of 25 May 2018, you can ask that we delete your personal information from our records. In many cases, we will propose to suppress further communications with you, rather than delete it.
(4) Right of rectification – if you believe that our records of your personal information are inaccurate, you have the right to ask that those records be updated.
(5) Right to restrict processing – you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
(6) Right to data portability – where we are processing your personal information under your consent, and this processing is carried out by automatic means, you may ask us to provide the relevant personal information to you (or another service provider) in a machine-readable format.
To exercise these rights, please send a description of the personal information in question using the contact details in section 16 below.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you consult ICO guidance or please contact us using the details in section 16 below.
You are further entitled to make a complaint about us or the way we have processed your data to the Information Commissioner’s Office (“ICO”). For further information on how to exercise this right, please see the guidance here. The contact details of the ICO can be found here.
11. Lawful processing
We are required to have one or more lawful grounds to collect and use your personal information. The lawful grounds upon which we are relying are the following:
We will ask for your consent to use your information to send you electronic communications such as newsletters and marketing emails, for targeted advertising and profiling, and if you ever share sensitive personal information with us.
(2) Contractual relationships
The majority of our interactions with subscribers, website users and artists are voluntary and not contractual. However, it will sometimes be necessary to process personal information so that we can enter contractual relationships with people. For example, if we commission you to make a work, if you apply for employment or for a student placement with us, or if you purchase something via our online shop.
(3) Legitimate interests
Applicable law allows for personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
We will rely on this ground to process your personal data when we believe it is more practical or appropriate than asking for your consent, for example in the pursuit of the following activities:
Delivery of our charitable purposes as set out in our charitable objects; Auditing for financial or regulatory compliance purpose; Statutory reporting.
(ii) Publicity & Income Generation
Conventional direct marketing and other forms of marketing, publicity or advertisement; Unsolicited commercial or non-commercial messages, including campaigns, income generation or charitable fundraising; Analysis, targeting and segmentation to develop strategy and improve communication efficiency; Exercise of the right to freedom of expression or information, including in the media and the arts; Processing for research purposes (including marketing research).
(iii) Operational Management
Employee and volunteer recording and monitoring for recruitment, safety, performance management or workforce planning purposes; Provision and administration of staff benefits such as pensions; Physical security, IT and network security; Maintenance of suppression files; Processing for historical, scientific or statistical purposes.
(iv) Financial Management & Control
Processing of financial transactions and maintaining financial controls; Prevention of fraud, misuse of services, or money laundering; Enforcement of legal claims including debt collection via out-of-court procedures.
(v) Purely Administrative Purposes
Responding to any solicited enquiry from any of our stakeholders; Delivery of requested products or information packs; Communications designed to administer existing services, including delivery of products; Thank you communications and receipts; Maintaining a supporter database and suppression lists.
When we use your personal information in reliance on the basis of legitimate interests, we will consider if it is fair and balanced to do so, and will seek to satisfy ourselves that doing so is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
12. Data retention
We keep data for as long as it is required in connection with the purpose(s) for which it was collected and is processed. As a general rule, we will not keep your data for more than six years after the date of your last interaction with us.
In certain cases, this will differ i.e. where we feel that the data is particularly sensitive or not strictly necessary to retain, we will keep it for less than six years.
Alternatively, where we feel that it is appropriate and not unexpected by you, we will keep your personal data for longer than six years. For example, we may keep artist, curator and writer applications to our open call opportunities for up to ten years.
Artworks in all mediums that we commission (including commissioned writing) and relevant files relating to those artworks will be kept indefinitely (for posterity), and we feel that artists will reasonably expect this, given the importance of artists’ work and the preservation of all forms of art. This may affect you not just as an artist, but if you are captured in film, video, photograph or audio file that forms part of an artwork, or in documentation of an artworks’ exhibition or an event pertaining to that artwork.
In the event that you ask us to stop sending you direct marketing/fundraising/other electronic communications, we will keep your name and contact details on our internal suppression list to ensure that you are not contacted again.
13. Policy amendments
We keep this Policy under regular review, and reserve the right to update it from time-to-time by posting an updated version on our website, not least in order to reflect any future changes in applicable law. We recommend that you check this Policy occasionally to ensure that you remain happy with it.
14. Third party websites
We link our website directly to other sites. This Policy does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.
Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed either by emailing us at email@example.com or writing to us at the following address:
8 Vine Yard, London, SE1 1QL, UK
+44 (0)20 7407 7755