GDPR and Privacy Policy

This outlines EatSleep Media’s EU/UK GDPR policy. It is a ‘live’ document and we will update it as new information becomes available. We have registered with ICO and this registration covers all EatSleep Media businesses.

Business overview

EatSleep Media Limited is a small company with fewer than 5 employees. We have two main areas of business:

Film & media production and audio production
Sports websites and journalism

Why do we collect data?

We collect data for normal business activities:

to complete our projects and contractual obligations
to research stories and projects for journalism projects
through documents and content supplied to us as part of our work (i.e. documents for research purposes, film, audio and image files for review, text for content etc)
to market our services to existing and new clients
to invoice our clients, pay our suppliers and complete our annual accounts
as part of our own due diligence to comply with our public liability and indemnity insurance.

We do not sell or trade data or pass on data to third parties without the specific written permission of the data supplier. For example, if we are asked to recommend a colleague for a job etc.

We will share data if required to do so by law (e.g. by the police or as part of a legal process) or as part of our regular accounting activities (invoicing etc).

How do we collect data?

We collect data in usual ways:

Business to business contact scenarios (networking events, meetings etc)
Introductions and recommendations
Filming and recording consent forms
E-mail contact and online agency contacts (e.g. Linkedin etc)
Through our website and social media
Contact information in the public domain

What data do we collect?

Client/customer information: contact names, job titles, addresses, email, contact number, web addresses, social media information, billing information and bank details.

Contributors for journalism/film projects: contact names, job titles, addresses, email, contact number, web addresses, social media information, photographs and digital film

We do not collect sensitive personal data (health, sexual orientation, dates of birth, school/college info etc) unless this is required for a particular project (e.g. a film or a journalism piece)

How do we store data?

Our contact lists and other documents are stored on Google Cloud servers which meets internationally recognised standards for privacy and security.

Video footage, audio recordings and photographs may contain personal information including a person’s face, ethnicity and information which could lead to the identification of their culture and/or religion.

In the first instance, video footage is stored on SD cards before being transferred to our Mac computers for editing. The SD card is then wiped for re-use.

When a project is finished, footage is archived to external hard drives which are not connected to the internet.

If footage is needed again, it is copied from the external hard drives to our Mac computers for editing and deleted again on completion of the project.

Audio files are recorded on SD cards before being transferred to our Mac computers for editing. Final projects are exported to Google Cloud servers for distribution, either to clients, or via social media, web-based platforms, or other media outlets including television and/or radio.

Audio files are kept on our Mac computers for a period of two years at the most, or until such time as an archive or disk clearance is needed. Then they are deleted.

Photographs are mainly taken on mobile phones. We use images for a number of applications including social media posts across our own channels to showcase our work, either through the partners we are working with or with ‘behind the scenes’ images.

Photographs shared to social media will be available to view in perpetuity on a public platform, unless we receive a specific request to remove them.

Images may also be used on ESM affiliated websites, including Welsh Football Fans, to illustrate articles. Again, photographs will be available to view in perpetuity on a public platform, unless we receive a specific request to remove them.

Photographs are generally stored on ESM staff mobile devices but removed regularly to free up disk space, unless we have deemed the image to be of historical significance, in which case it will be stored on our Google Cloud servers.

Software

We do not use facial recognition software.

We use some software as part of our workflows that stores data and metadata including:

Adobe Photoshop/Lightroom – for photography/design projects
Adobe Premiere Pro/After Effects – film editing software
FreeAgent – cloud accounting software. This is shared with our accountants.

We understand that data stored on these systems cannot be deleted for legal reasons including the following:

Public liability and indemnity insurance purposes.

We need to be able to defend our work and back reference projects in case of legal challenge.
Data (including film footage and archive material) from old journalism projects/films may be required in future productions
Compliance for TV/film journalism.
Accounting
It is a requirement that all invoices and company paperwork should be retained for 7 years for HMRC VAT purposes and longer for income tax purposes.

As such, if you have contributed to an EatSleep Media project prior to 2018 (e.g. as an interviewee on or off camera or as vox pop etc.) this contribution will remain as part of that published work and as part of the rushes and research material that support that work. For legal reasons, we are required to retain information in the event that we need to defend published work.

As of 2018, anyone contributing to an EatSleep Media project will be asked to complete a contributor consent form and this will cover data protection and rights. These contributor forms will be kept indefinitely or for as long as the programme/report that they pertain to remains active.

Journalism

We adhere to specific guidance from the ICO about the collection and processing of data for journalism, broadcast journalism & film/TV projects. The guidance can be viewed here.

Data management and viewing your data

We regularly update our contact lists and delete old & irrelevant contacts.

If you wish to be removed from our contact list please send us an e-mail to alex@eatsleep.media.

GDPR Advice

We have synthesised our GDPR policy from the following advice:

This policy was last reviewed in September 2020 and is re-evaluated annually, or with updates in guidance and/or legislation.