This data protection and privacy notice provides information on how Creative Portal (also referred to in this notice as "we" or "us") uses personal data relating to users of its websites and services (referred to in this notice as "you"). Our websites and services are referred to in this notice as the "Sites" and the "Services".
This policy was last updated on 17/01/2020, in response to the European Union's General Data Protection Regulation – referred to, throughout, as GDPR.
1. Who are we?
Creative Portal is a company in England and Wales.
2. What personal data do we collect and why?
As an online community, we use the information you give us to improve our service and to tailor your experience through the site around your interests and professional background. For this reason, our reason for processing data under GDPR is, for the most part, based on Legitimate Interests.
We appreciate that, on joining our network, you have trusted us with our data. With this in mind, we pledge to respect your privacy, and be open about what we collect and how we use it. We will go to all reasonable lengths to ensure your data is kept safe.
We will work with you to ensure you are able to exercise the rights granted to you, as a data subject under GDPR. You can contact us using the contact details set out below.
2.1. Visiting our website
If you visit our website, we will log your IP address and aggregate details about site usage.
2.2. Registration and subscription details
If you register with us and/or subscribe to certain Services, your registration and subscription details will be retained by us for the purposes of administering your account. Details we process for this purpose include: your name, address, email address and account passwords.
Where required for our subscription Services, your payment details will be collected and used by our third party payment provider for administering Contracts on our behalf. We may access such details to address any queries or confirm payments.
We will also collect your date of birth for verification purposes, and to confirm you are over 18 years old. In exceptional circumstances, we may ask you to confirm your date of birth as a security question for identification purposes.
2.3. Your profile(s) and other content
If you upload a profile and other content, this will be visible to other users in accordance with the Services we provide to them. The information included within your profile varies depending on what type of user you are. Some information is required, and some is optional – this will be made clear at the point the information is requested. You can manually edit and/or rectify most of your data.
You will have the choice whether your telephone number is made visible to other registered users. Unless you are classified as a Service Provider, your email and postal addresses are not visible to other users and your telephone number is not visible to unregistered users (unless you voluntarily enter any of these details in a free text field). See also clause 7 below.
You will also have the choice of whether your profile will be picked up by third party search engines, such as Google. Our Sites may provide an internal messaging Service for communications between registered users, meaning you do not need to publish your personal email address in order for employers or other users to contact you. See also our Contacts policy.
We will not publish your real age, but if you are an actor or other performer, you may be required to provide a playing age – see our Age policy for more details.
2.4. Contacting us
If you contact us (via email, telephone, post or otherwise), we may collect and retain your contact details and the contents of your communication. We shall use such details for the purpose of handling your query and keeping records of communications. See also clause 2.5, below.
2.5. Other use of your personal data
We may also use your personal data for the purposes of:
- checking your compliance with our terms of service;
- website administration and maintenance, and quality control;
- investigating complaints and conducting risk assessments;
- compliance with legal obligations, or protection and enforcement our legal rights and those of other users; and/or
- managing actual or potential business transactions (eg in the case of an acquisition of our business).
Please also see paragraphs 3 and 4 below in relation to marketing communications, site analysis and monitoring.
3. Marketing communications from us and third parties
We may send you marketing materials by email or post, or contact you by telephone for marketing purposes. We will only do this if relevant to the Services provided to you or otherwise with your consent.
If you are a candidate, you will have the option whether or not to receive communications (using our internal messaging system) from certain third party service providers, such as photographers and showreel providers. You may change your mind at any time by updating your profile settings.
If you recommend a friend to us for our Services, we may contact such friend using contact details provided by you in order to enquire whether they are interested in our Services. It is your responsibility to inform your friend that we may contact them in this way and ensure that they are happy for us to do so.
If you wish to verify a credit, we may contact your referee using contact details provided by you. It is your responsibility to inform your referee that we may contact them in this way and ensure that they are happy for us to do so.
4. Cookies, site analysis and monitoring
If you access a user’s profile, your IP address and, if you are a registered user, your profile will be logged. The user whose profile you have viewed is given access to the log of who has viewed their profile and when. See also our Views and Stats policy.
We may also use third party services such as Google Analytics to track the pages users have viewed on our Sites. The information collected is used anonymously for statistical purposes.
5. How do we collect your personal data?
We collect the majority of personal data directly from you. We may also collect certain information from other users, for example, agents providing details of candidates or users recommending a friend (see paragraph 3 above). Other information about you, eg your previous roles or productions, may be collected from publicly available sources.
Where we collect personal data from you relating to other individuals (such as your staff or, if you are an agent, your candidates whom you represent), it is your responsibility to ensure such individuals are aware of that their details are being disclosed to and processed by us (unless this is not required in accordance with the requirements of GDPR and other relevant legislation).
6. Special category data
We only collect or process special category data where directly relevant or incidental to the provision of our Services, for example where:
- your profile or application for a job (including text, photos and other images of you) reveals racial or ethnic origin;
- you have opted to disclose your membership to an industry union, such as Equity;
- steps taken to monitor or ensure non-discrimination in the provision of our Services involves the use of sensitive personal data; and/or
- actions taken to prevent or detect of illegal activities give rise to the processing of actual or alleged offences.
7. Use of your personal data by other users
Personal data within your profile, or otherwise submitted by you as content for the Sites, may be accessed by other users in accordance with the Services provided to them. Whilst we seek to ensure all users agree to our terms of service, we are not responsible for the use or misuse of your personal data by other users (including, by way of example, any misuse of a candidate’s personal data by casting professionals, film-makers or other employers).
However, you may report to us if you experience any misuse of your personal data by any other user or third party in relation to our Sites or Services. We shall, at your expense, reasonably co-operate with you in enforcing our contractual terms against other users who have misused your personal data.
8. Disclosure of your personal data to other third parties
We may disclose your personal data for the purposes outlined at paragraph 2 above to third parties where relevant to such purpose, including:
- our service providers and professional advisers;
- governmental bodies and law enforcement authorities;
- any purchaser or (on terms of confidentiality) likely purchaser of our business; and
- other third parties where required or permitted by law.
9. Storage and security of your personal data
Your personal data is stored in electronic and physical records maintained by us and/or our service providers. Whilst our offices are located in the UK, our services providers may have servers located in a country within or outside of the European Economic Area, whose laws may not provide the same protection for personal data as within the European Union.
We keep your information for as long as we need to do in order to fulfil the service we offer, or to comply with requests from law enforcement agencies or regulators.
Please note that given the nature of the internet, data transmitted over our Sites or by email is not completely secure from unauthorised access or misuse.
10. Removal of your details from our Sites
You may request removal of your profile(s) and data from our Sites at any time, though we ask that you put such requests in writing. Please see clause 10.1 of our Terms and Conditions.
11. Access to your details
We welcome you contact us if you wish to exercise any of your other rights under GDPR. These include:
- your right to be informed
- your right to access and correct personal data
- your right to erasure
- your right to data portability
- your right to object to data processing
- your rights relating to automated decision making and profiling
All cases will be reviewed individually, in accordance with this policy, alongside GDPR and other relevant legislation.
If you have any queries in relation to the processing of your personal data by Creative Portal, please contact us:
111 Gloucester Rd, Bishopston, Bristol BS7 8AT
Telephone: 0843 289 9750