It’s really important to us that you are comfortable and clear about your relationship with Rotten Park Road, and we’re committed to doing what we can to provide more information about how we respect and maintain the privacy of our members.
These changes are all in line with the upcoming changes to European Union data protection law, effective from May 25, 2018, for all members globally and they include explaining to you in more detail how we use your information, including your choices, rights, and controls.
Here’s a summary:
As we represent performers, it is our requirement to gain our clients' consent, ensuring we have the documented authorisation to act on behalf of our performers.
We are telling you even more about what we do with personal information - our updated terms provide more information about what we collect, why we need it and how we manage it so you understand what happens with your information when using our services.
We are giving you more access to your information - our updated terms detail the different rights you have in accessing information so you can take the lead and control your personal information.
If you do not agree with these new terms for whatever reason, please do contact us at email@example.com so we can discuss your options with you.
"you" means the user of our website or Spotlight Services.
"we/us/RPR" means Rotten Park Road, including Rotten Park Road Management Limited, Company Number 11074751 and Rotten Park Road Productions Limited, Company Number 11073846.
"Services" means any of the services available, and
"Site" means the site located at rottenparkroad.com and and other connected sites.
Acceptance of this Policy and RPR Terms
We regard the lawful and correct treatment of your personal information by us as very important to our business. To this end we fully endorse and adhere to data protection law across Europe in the form of the General Data Protection Regulation (GDPR) and the equivalent data protection law in the UK.
As per the ICO guidelines, RPR is exempt from registering with the however, it is important that we adhere to the principles of the Data Protection Act (DPA) and that we understand best practice for managing information. To summarise, we:
- only process information necessary to establish or maintain membership or support;
- only process information necessary to provide or administer activities for people who are members of RPR or have regular contact with it;
- only share the information with people and organisations necessary to carry out the RPR's activities. If if individuals give us permission to share their information, this is OK.
- only keep the information while the individual is a member or supporter or as long as necessary for member/supporter administration.
How do we make sure your data is used lawfully?
We will only collect, use, store, share (and any other of the defined uses of processing data) where there is a lawful basis as defined by data protection legislation, and do not collect more information than we need to fulfil the purpose. We document what lawful bases are relied upon for our processing activities. Lawful bases include where you have given consent and where processing is necessary for the performance of a contract with you. More information on how we use these lawful bases is provided below:
- Consent – In certain situations we can process your data with your consent. Where we process data based on consent, we will ask you for your explicit consent (you have to take an action) which you can withdraw at any time, but it will not affect the lawfulness of processing before then. For children under 16, consent will be gained from the parent or guardian.
- For example, you ticking a box to receive email marketing communication from us.
- Contract – In certain situations, we need your personal information to comply with our contractual obligations. Where we rely on contract, we will ask you to agree to the use of your personal data necessary for entering into or the performance of your contract with us.
- For example, by becoming a RPR Management client we will collect information about you so we can deliver the service to you.
When do we collect your personal information?
We will collect personal information from you when you:
- Become a registered member with us;
- Complete a survey or feedback form;
- Provide feedback or review our Site and/or Services;
- Correspond with us on social media;
- Contact us with a form of query, compliment or complaint (plus other types of enquiries) via phone, email or post;
- Use other features of our site.
What personal information do we collect?
We will only ever ask you for the necessary information needed to process your data. We may process data including the following personal information about you, where supplied:
- Date of birth;
- Address(es) or location data;
- Telephone number(s);
- Information pertaining to disability and ethnicity;
- Physical details such as height;
- Training and skills;
- Information/ documents to enable us to vet an application;
- Information/ documents you may provide to prove age, identity or other requirement where the law requires this to confirm discount eligibility;
- Photographs, video and audio clips;
- Career history;
- URLs and links to social media;
- Bank and payment data.
How will we use your personal information?
We (or third party data processors acting on our behalf) may collect, store, use and share your personal information for the following purposes:
- To make your public profile information available to appropriate individuals and organisations; such as casting directors.
- To keep your details and records up-to-date and accurate;
- To provide you with important service communications relating to RPR products or services.
- To invite you to attend RPR and partner events;
- To answer your enquiries or otherwise communicate with you;
- To vet your professional background, but only when you are joining as a Spotlight Member/Client;
- Internal record keeping;
- To assist in the creation and editing of audio and visual content;
- To improve our products and services;
- To understand about information to better inform business decisions;
- To verify your identity;
- To comply with any legal obligation such as to share data with law enforcement; and
- To customise our site to your interests
What personal information do we share?
We sometimes share personal information with carefully selected and trusted third parties. Wherever possible only information contained within your public profile would be released to such third parties. To keep your data safe and maintain your privacy we have the following approach:
- We only provide the information they need to undertake that service;
- They can only use the information for that specific purpose;
- We maintain a close relationship to make sure that your data is protected and your privacy maintained;
- We mandate that if or when the service stops, they must return or delete any information held.
Here are the examples of the types of trusted third parties we work with:
- Spotlight and appropriate casting platforms in other territories,
- Law enforcement in complying with the law, or to enforce our Terms and Conditions or to protect the rights, property, or safety of ourselves, our customers or other third parties, and
- If we acquire any new business, and/or sell all or part of our business.
How long do we keep your information?
We will not keep personal information for longer than it is necessary, and will only retain information for as long as needed to carry out our functions and that purpose. Personal information is retained in line with our retention schedule.
Where your information may be processed
We will retain payment details briefly (the duration of time it takes to complete each transaction) whilst purchases are made through our online shop. Payment card details are not stored on our servers beyond this.
Links to other websites
Keeping your personal information up-to-date
RPR provides you with access to your personal information and tools to manage this. If you have provided us with personal information, it is your responsibility to ensure that it is correct and up to date. This will enable us to provide you with the best service possible. Please contact us as soon as possible if you believe that any information we are holding on you is incorrect or incomplete.
You have a number of rights to your information that can be accessed by contacting us at firstname.lastname@example.org
To make sure we protect you and your information, we will need to verify your identity for any requests we receive from you before we begin to process your request.
As a Parent or Guardian representing a child, you are a third party acting on behalf of your child and it is your responsibility to inform the child of their rights, and to act solely in your child’s best interests. Parents or guardians have the right to exercise the below rights on behalf of the child that they represent.
If this is a third party acting on your behalf, we will request that they provide proof that they have your consent to represent you.
If we decide not to action your request we will explain our justification for refusal.
- Access your information – you can request access to or a copy of your personal information and check what information we hold about you.
- Change or correct your information – if you wish to have any errors corrected, you can request this – although this is not an absolute right and we may request for further information.
- Take your information – you can ask for a copy of your personal information to be provided in a reusable and machine-readable form.
- Object to, limit or restrict the use of your information – you can ask that we stop using parts or all of your personal information or limit its use if you believe that this personal information is unlawfully held.
- Delete your information – you can ask that your personal information is deleted if you believe it is no longer necessary for the purposes it was collected.
- Legitimate interest – if we are processing your information on the grounds of legitimate interest, you can ask us to stop this if there are reasons related to your individual circumstances. We have to do this unless we believe we still have an overriding legitimate reason.
If you are unhappy
The theme throughout this Policy is that RPR treats your privacy with the utmost importance and we strive to meet the highest standards when collecting and using personal information. If for whatever reason you believe that our collection or use of your information is unfair or inappropriate, we encourage you to email us and tell us. We will take any complaints we receive about your privacy very seriously.
You also have the right to complain to your supervisory authority if you are unhappy with how your personal information has been collected, used or managed which within the UK is the Information Commissioner’s Office (ICO) who can be contacted by calling 0303 123 1113 or by visiting www.ico.org.uk.