Scottish Queer International Film Festival GDPR, Data Management and Privacy Policy

This document was put together thanks to guidance from other festivals and individuals, including Take One Action Film Festival and Alchemy Film & Arts. We thank them for their generosity.

Download a pdf version of this policy here.

ABOUT SQIFF

SQIFF (Scottish Queer International Film Festival) was formed with the aim of adding to the exciting and growing amount of queer film stuff happening around Scotland. Since 2015, we have held an annual Festival in Glasgow alongside providing year round events across various locations. SQIFF aims to build community through queer films. Our goal is to get people watching, talking about, and making more queer films. We want to screen movies that people might not otherwise get a chance to see and create inspiring and informative events across Scotland. Moreover, we want to support marginalised groups within the LGBTQIA+ community by providing a networking system for queer filmmakers, as well as filmmaking workshops for audiences wanting to start on the medium. We want to challenge inequalities and barriers to accessing the arts.

This GDPR, Data Management and Privacy Policy outlines SQIFF’s commitment to ensuring the appropriate use of personal information across its activity.

This GDPR + Management Policy includes information on:

  • Policy Statement
  • Purpose
  • Principles
  • SQIFF’s commitment to ensuring safe environments for Trans, Non-Binary and/orGender Diverse People, and people of the Global Majority

POLICY STATEMENT

Scottish Queer International Film Festival (SQIFF) is an organisation committed to legal and appropriate use of data in the area of LGBTQIA+ film exhibition. As such, SQIFF intends to ensure all its activities and dealings are in line with UK data management law.

PURPOSE

The purpose of this policy is to ensure SQIFF acts in accordance with its responsibilities regarding GDPR. This policy lays out our specific commitments to data protection and data management, and makes SQIFF responsible to the public as well its employees, for acting on those commitments.

PRINCIPLES

Data Protection

Article 5 of the GDPR requires that personal data shall be:

  1. Processed lawfully, fairly and in a transparent manner in relation to individuals.
  2. Collected to specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving processes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes.
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
  4. Accurate and, where necessary, kept up to date; every reasonable step much be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay.
  5. Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals.
  6. Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

General Provisions

  1. This policy applies to all personal data processed by the Charity.
  2. The Responsible Person shall take responsibility for the Charity’s ongoing compliance with this policy.
  3. This policy shall be reviewed at least annually.
  4. The Charity shall register with the Information Commissioners Office as an organisation that processes personal data.

Lawful, fair and transparent processing

  1. To ensure its processing of data is lawful, fair and transparent, the Charity shall maintain a Register of Systems.
  2. The Register of Systems shall be reviewed at least annually.
  3. Individuals have the right to access their personal data and any such requestsmade to the charity shall be dealt with in a timely manner.

Lawful purposes

  1. All data processed by the Charity must be done on one of the following legal bases: consent, contract, legal obligation, vital interest, public task or legitimate interests.
  2. The Charity shall note the appropriate lawful basis in the Register of Systems.
  3. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
  4. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Charity’s systems.

Data minimisation

  1. The Charity shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

  1. The Charity shall take reasonable steps to ensure personal data is accurate.
  2. Where necessary for the lawful basis on which data is processed, steps shall beput in place to ensure that personal data is kept up to date.

Archiving / removal

  1. To ensure that personal data is kept for no longer than necessary, the Charity shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
  2. The archiving policy shall consider what data should/must be retained, for how long, and why.

Security

  1. The Charity shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
  2. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
  3. When personal data is deleted this should be done safely such that the data is irrecoverable.
  4. Appropriate back-up and disaster recovery solutions shall be in place.

Photo Consent

  1. SQIFF will place photography warnings throughout the venue, stating that participants/audience members can approach a volunteer or member of staff if they have concerns about photographs being taken;
  2. Any up-close or individual photographs taken by SQIFF, or any video footage taken (e.g. for voxpops) will be accompanied by a completed informed consent form, which SQIFF will be responsible for.

Breach

In the event of a breach of security leading to the accidental, or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO.

How you can control our use of your information

You can unsubscribe from our mailing list at any time, by emailing [email protected].

We will always do our best to ensure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate, and we will promptly correct any information found to be incorrect.

You may request details of personal information which we hold about you by emailing us: [email protected]

COMMITMENT TO TRANS, NON-BINARY AND/OR GENDER DIVERSE PEOPLE AND PEOPLE OF THE GLOBAL MAJORITY

We are committed to providing an environment that is welcoming, accessible and inclusive for all attendees, staff, guests and volunteers, in person and online. In particular, SQIFF works to provide the safest environment for Trans, Non-Binary and/or Gender Diverse People and people of the Global Majority.

Please refer to SQIFF’s Trans, Non-Binary and/or Gender Diverse People Statement and Anti-Racism Policy to see our full statement and measures.

We welcome any comments and suggestions that can help us to develop our GDPR, Data Management and Privacy Policy: [email protected].

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