1 Who we are
1.1 About us
We are Medical Aid Films Limited (“MAF”), a charity registered in England and Wales (Company Reg. No. 06296236).
1.2 How to contact us
2.1 Purpose and scope of this policy
This policy sets out how Medical Aid Films processes personal data in line with the UK General Data Protection Regulation (“GDPR”).
Using personal data allows us to employ people and engage with volunteers, raise funds, develop and distribute our services, and gain a better understanding of, and engage with, our stakeholders and in turn provide you with relevant and timely information about the work that we do.
The purpose of this policy is to explain why we process your personal data and your rights in relation to your data. We are committed to respecting and protecting your personal data and being transparent about what we do with it, in accordance with your reasonable expectations and applicable laws and regulations.
We appreciate your support and the trust you give us when you provide us with your personal data.
2.2 Key terms
2.3 Our legal basis for processing personal data
We will only use your personal data if we have a legal basis to do so. This means that we will only use personal data where we have your explicit consent, where it is necessary in order to perform a contract with you, to comply with a legal duty or right, to protect your vital interests, or where the processing of your personal information is in our legitimate interest and not overridden by your rights, interests and freedoms.
There are generally three legal bases under which we would ordinarily process your data:
In addition, when special categories of personal data are processed it is necessary to meet one of the specific conditions in Article 9 of the GDPR. Medical Aid Films ensures that it only processes special categories of personal data when it has a lawful basis and meets one of the Article 9 conditions, which will usually be either through obtaining explicit consent, or as permitted as an employer.
3 Information we collect, processing we undertake and legal basis for processing
On some occasions, we may provide links to third party websites that are not operated on our behalf. When this is the case, we will notify you that you are leaving our Website and entering a website operated by a third party. In these circumstances, any personal data that you may submit to the third party’s website will be processed in accordance with the third party’s privacy statement.
Our site may also have “plugins” (such as Facebook “like button”) through a third party website. These and similar features are also governed by the third party’s privacy statement.
When you make a donation, pledge, attend an event or become a supporter of Medical Aid Films we use your personal data to record that you have given us financial support, fulfil any contract with you and undertake marketing. Our legal basis for this processing is the legal obligations to keep proper records, obligations under a contract and our legitimate interest to recognise your valuable contribution and send communications and invitations in appreciation.
As a supporter we may collect the following information about you:
We may also create information about you that becomes your personal data such as:
As a donor we may also combine the personal information we hold with publicly available information (such as directorships listed at Companies House or publicly available sources like news reports).
This is known as profiling and our legal basis for this processing is our legitimate interest to build a more personalised relationship by building a more detailed profile of you. This enables us to communicate more effectively with you and communicate with you on topics that we believe are of interest.
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful.
You can change your preferences and also object to the way we process your data, including the way we communicate with you at any time using the contact details in Section 1. In the case of marketing emails, we will always provide you with an option to unsubscribe in every email that we send you.
3.3 At events
From time to time we take photos and video at our events. Your image may be captured and recorded if you attend one of our events. You consent to this when you purchase a ticket to our events or when you enter our premises. When we are filming we will let those in the vicinity know so that the area can be avoided if you do not want your likeness to be captured or recorded. If you can be identified from an image, audio or video that we wish to use to promote Medical Aid Films through advertising or via third parties, then we will ask you to consent to such use when signing a release form. We protect these images as personal data. We collect these, and also permit some of our service providers to do so, in order to produce, market and distribute content.
3.4 Content users
We process personal data in order to market and distribute product and to support users. Personal data processing will usually be limited to the processing of professional contact details, however we may also process login and password data. Medical Aid Films will analyse data about users and may ask for information from you prior to accessing content. You may also be asked to opt in to marketing and to participate in surveys etc. in order to enable Medical Aid Films to better understand who is accessing content and improve content and distribution channels. Processing for marketing is undertaken on the legitimate interests legal basis, distribution and support processing is undertaken in order meet our obligations under a contract.
3.5 Employees and volunteers
Images of employees and volunteers as well as a profile may be put on the Medical Aid Films website, social media and other promotional material.
We will collect personal data directly from you and from other sources as required to recruit, employ and manage you. This includes references, citizenship and immigration status, ID documentation, financial information, criminal record information, performance information, health information (and possibly other special categories of personal data) and other information. Information will be collected directly from you and also recruitment companies, government agencies and background screening agencies, other employers and people able to provide references, employee benefit providers and from online and public sources, such as Companies House, social media profiles etc. We will process your personal data in order to meet the obligations of the employment contract, satisfy legal obligations and also to meet the legitimate interests of Medical Aid Films, such as performance assessment, diversity analysis of employees, undertake investigations, security of buildings, to provide access to buildings and systems, monitoring the use of systems for data security purposes etc.
We will process your personal data as is appropriate to your activities. This may include personal data collected from you and also from third parties, such as background and criminal record screening, references checking as well as contact information and identification documentation. Financial information may be processed in order to make payments for expenses etc. to you. Your personal data will be processed. We will process your personal data in order to meet the obligations of any contract with you, satisfy legal obligations and also to meet the legitimate interests of Medical Aid Films, such as to undertake investigations, to provide access to buildings and systems, security of buildings, monitoring the use of systems for data security purposes etc.
3.6 Contributors, Contractors and Suppliers
We are making films through time lapse photography and video. Individuals identifiable and involved in these films consent when signing a release form. We protect these images as personal data. We collect these, and also permit some of our service providers to do so, in order to produce, market and distribute content.
We will collect and retain professional contact details, CVs, references, background checks etc. On occasion is it likely that financial details used to make payment for services will also be personal data. This personal data is processed under the legitimate interests of Medical Aid Films and to meet contractual obligations with the contractor or supplier.
While children have the same rights as adults over their personal data, we take particular care when processing children’s personal data, following data protection principles and with a particular emphasis on fairness in processing.
In running some of our activities or making films we may collect personal data from or about children and for this we rely on parental consent where at all practicable. We only retain children’s personal data for so long as reasonably necessary to fulfil the purposes required.
Where we use children’s images it is our policy to collect a signed release form which records parental/guardian consent.
3.8 Special Category / Sensitive personal data
Due to the nature of our work, the films and images produced may enable an individual to be identified and disclose specific relevant health information. Explicit consent will always be obtained in these instances.
In addition, there are some situations where we will need to process sensitive information in connection to other activities of Medical Aid Films, for example if you are an employee or volunteer, have an accident at one of our events or if you tell us about a disability. If we record your sensitive personal data, we will take extra care and follow additional procedures to ensure your privacy rights are protected. Our legal basis for collecting sensitive personal data in these instances will usually be so that we can fulfil legal obligations or to fulfil a contract with you.
3.9 Marketing purposes
See 4. ‘Marketing’ below
Marketing doesn’t just mean offering things to buy, but also includes news and information about what we do. What information and communications you receive from us will depend on whether you are a donor, a prospective supporter or a user of our services.
If you are a current donor, if you have opted to, you will receive our regular digital communications about our events and activities, our charitable work and offers. We will send this information by post or email until you ask us not to.
We aim to send communications that you would reasonably expect to receive as a supporter with minimal impact on your privacy; this may be postal information on our latest fundraising appeal or an email with retail offers where you have previously brought goods or tickets from us.
Fundraising and marketing emails will only ever be sent when you have given us your explicit consent to receive them. We may also call you about our work but we will always get your prior consent to do so.
4.2 Analysis and grouping
We may analyse data about our donors to understand common characteristics and preferences. We may analyse various types of information including demographic information (e.g. age or location). By analysing data and grouping people together by common characteristics, we can provide more relevant communications, offers, and information, improve our activities and services, and operate more efficiently.
4.3 Research and profiling
We may also use personal data to build profiles of categories of supporters and add profiles to the individual supporter’s record. This enables us to understand our supporters, improve our relationships, and provide a better supporter experience.
Medical Aid Films does not carry out profiling that has any significant legal effect on you. If we think that any profiling activities that we carry out may have a significant legal effect, then we will ask for your consent to ensure you are informed and have control. We will not use profiling on children or special categories of data.
You have the right to object to this profiling. If you would like to do so, please let us know by contacting us using the details in Section 1.
4.4 Special circumstances
If you do not fall within one of the above categories, why and how we process your data will depend on how you interact with us, for example, if you ask us for information or sign up for a newsletter we will need to collect some personal data from you.
We will only use this information to provide the necessary service or information that you have requested, unless you have given us your explicit consent to use your information in other ways.
You can change your preferences at any time and can object to how we process your data by contacting us using the information in Section 1.
4.5 Where we store your personal data
We maintain appropriate safeguards, procedures and technology in order to keep your personal data secure and also require that third parties we choose to process your personal data do the same.
We use up to date physical and technical measures to keep your information safe, prevent unauthorised access to it and to prevent misuse or unauthorised disclosure of it.
We control who has access to our secure electronic databases and provide staff and volunteers training on our data protection policies and procedures. We also check these are being followed.
4.6 How long we keep your information
We keep your personal data safely for as short a time as we need it or legally have to keep it. In doing so, we:
The time periods for which we retain your personal data depend on the purposes for which we use it.
We have set destruction limits taking into account legal rules, your rights and our needs and have a continuous programme that securely destroys your personal data when we have reached the relevant time limit.
|6 years from the date of the last donation or contact from the supporter
|Employees, and volunteers
|6 years from the termination of employment or volunteering ceases
|Consents are retained indefinitely, unless the media in which the consent is given is archived, at which point it will be deleted 6 years after the media has been archived. All other personal data is deleted after 6 years. Final and rough cuts of films will be kept indefinitely.
|6 years from the end of the contract
|6 years from last contact with the user
4.7 Sharing your personal data
We will never sell your personal data.
We may share data, including personal data, with our third-party vendors who may need to have access to your personal data for the purpose of providing services to us. We do not permit our third party service providers to use any personal data that we share with them for their own marketing purposes or for any other purposes other than in connection with the services they provide to us, unless you have provided your consent for them to do so.
In some circumstances, our third party service providers may collect your personal data on our behalf. When our service providers collect your personal data on our behalf, we ensure that they enter into contracts which only permit them to process your personal data in accordance with our instructions and this Privacy Statement.
We may also share your personal data with third parties if we are required to do so by law or contract, to respond to legal process, to protect our customers or staff, to protect lives, with your consent, to complete a transaction, or to protect the rights or property of Medical Aid Films.
Your personal data may also be shared with those that commission us to produce films. This would include copies of consent forms and other personal data of those involved in production.
We may also share your personal data if it is necessary to:
4.8 International Transfers
Personal data will only be transferred outside of the UK when strictly necessary.
When personal data is transferred outside of the UK for the purposes of day to day operational activity of Medical Aid Films (e.g. because a cloud based solution is based abroad), we will make sure that there are adequate levels of protection in place as required under the GDPR. This may include the enactment of standard contract clauses as published by the Information Commissioner’s office. This will always be the case when processing personal data of supporters. Explicit Consent will always be obtained prior to the transfer of special categories of personal data to a jurisdiction that is not deemed to have equivalent data protection.
In all other instances, such as for content production and when supporting content users, international transfers may take place, however Medical Aid Films will not ensure safeguards to the standard of the GDPR are in place in these instances. Instead transfers will only take place with the explicit consent of the data subject or when the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject. Given the nature of the personal data that would be transferred in these instances and the occasional frequency of transfers, MAF believes that the risk of harm to data subjects is minimal. Transfer will be minimised to the extent necessary, for example to make logistical arrangements for employees and contractors (e.g. booking flights, accommodation etc.) and distribution of the content.
5 You are in control
5.1 Change your preferences and opt out
You are in control of what we do with your personal data. If you would like to change your choices, or how we communicate with, just let us know.
To change your preferences or opt out, please contact:
Medical Aid Films HR
There are “unsubscribe” buttons on all electronic communications which allow you to opt out of future communications.
5.2 Updating your information
Please let us know if your personal data is inaccurate because your details have changed (for example you have moved house). Please let us know using our contact details.
When updating your personal data by phone or email, we may ask you to verify your identity before we can act on your request.
5.3 Your rights
You have several legal rights in relation to your personal data. These data subject rights are the right to request:
More information can be found at the website of the Information Commissioner’s Office.
5.4 Access to information
You can find out if we hold your personal data and ask for a copy of it by making a ‘subject access request’.
If we do hold personal data about you, we will:
Medical Aid Films HR
We will respond as soon as possible (and within one month of the date of receipt of your request and the information we need to respond).
6 How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at:
Medical Aid Films HR
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://ico.org.uk/make-a-complaint/