- Introduction
This privacy notice aims to give the Model (referred as “you”, “your” below) information on how the Photographer has collected and will process the following categories of personal data about the Model:
The Photograph (as defined in the Model Release Form between the Model and the Photographer) and related contact details, including name, phone number and home address (the Related Data).
This privacy notice only relates to how the Photographer will process the Photograph and the Related Data.
You must read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you[, for example, if you are using our website] so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
- Important information and who we are
Controller
The Photographer is the data controller and responsible for your personal data (collectively referred to as “Photographer”, “we”, “us”, or “our” in this privacy notice).
Contact details (Defined in the Model Release)
Full details are:
Full name of Photographer; Email address; Postal address; and Telephone number.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). The Photographer would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact the Photographer in the first instance.
- Your duty to inform the Photographer of changes
It is essential that the personal data the Photographer holds about you is accurate and current. Please keep the Photographer informed if your personal data changes during your relationship with the Photographer.
- The data the Photographer has collected and how it was obtained
The Photographer have collected the Photograph and Related Data.
- How the Photographer will use your personal data
The photographer will only use your personal data when the law allows the Photographer to. The Photographer will use your personal data in the following circumstances:
- On the basis of your consent.
- Where the Photographer needs to comply with a legal or regulatory obligation.
Below, in table format, we have a description of how we plan to use your personal data and which legal bases we rely on to do so. References to Specified Activities for the Specified Purpose, Photograph and Related Data are as defined in the Model Release Form.
| Purpose of processing your data | Data | Lawful basis for processing including basis of legitimate interest (if applicable) |
| Specified Activities for the Specified Purpose | Photograph | Consent |
| Managing the photographer’s relationship with you, including:
•Notifying you of changes to the photographers’ privacy policy. •Storing your contact details so that the Photographer can contact you. •Keeping a record of your consent. |
Photograph, Related Data | •Necessary for our legitimate interests ([to maintain a record of your contact details in case we need to contact you regarding the Photograph; to keep our records updated)
•Necessary to comply with a legal obligation. |
- Disclosures of your personal data
The Photographer may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
The Photographer require all third parties to respect the security of your personal data and treat it according to the law. The photographer does not allow third-party service providers to use your personal data for their own purposes and only permits them to process your personal data for specified purposes and under the photographer’s instructions.
- International transfers
Whenever the Photographer transfers your personal data out of the UK, the Photographer ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- The Photographer will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the ICO.
- Where the Photographer uses certain service providers, the Photographer may use specific contracts approved by the ICO, which give personal data the same protection it has in the UK.
- Where the Photographer uses providers based in the US, the Photographer may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between the UK and the US.
- Data security
The Photographer has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, the Photographer limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data according to the photographer’s instructions and are subject to a duty of confidentiality.
The Photographer has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
- Data retention
The Photographer will only retain the Photograph and Related Data for as long as necessary to fulfil the purposes the Photographer collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, the Photographer consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether the Photographer can achieve those purposes through other means, and the applicable legal requirements.
- Your legal rights
You have, in connection with your personal data, under certain circumstances, the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request the erasure of your personal information. This enables you to ask the Photographer to delete or remove personal information where there is no good reason for the Photographer to continue to process it. You also have the right to ask the Photographer to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where the Photographer is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Withdraw consent at any time concerning the photographer’s use of the Photograph for the Specified Purpose, which relies on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. The Photographer will advise you if this is the case when you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the Photographer in writing.
If the Photographer receive notification that you have withdrawn your consent to the use of the Photograph for the Specified Purpose, the Photographer will no longer process the Photograph for the Specified Purpose and, subject to our retention policy, we will dispose of the Photograph securely. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
No fee is usually required.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, the Photographer may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, the Photographer may refuse to comply with your request in these circumstances.
What the Photographer may need from you
The photographer may need to request specific information from you to help the Photographer confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. The photographer may also ask you for further information concerning your request to speed up our response.
Time limit to respond
The photographer will try to respond to all legitimate requests within one month. Occasionally, it may take the Photographer longer than a month if your request is particularly complex or you have made several requests. In this case, the Photographer will notify you and keep you updated.
- Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. The Photographer make sure he/she considers and balances any potential impact on you (both positive and negative) and your rights before he/she processes your personal data for our legitimate interests. the Photographer does not use your personal data for activities where our interests are overridden by the impact on you (unless the Photographer have your consent or are otherwise required or permitted to by law). You can obtain further information about how the Photographer assesses his/her legitimate interests against any potential impact on you regarding specific activities by contacting the Photographer.
Complying with a legal or regulatory obligation means processing your personal data where necessary for compliance with a legal or regulatory obligation that the Photographer are subject to.
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