At Cooper’s Talent Agency (CTA) we are committed to protecting and respecting your privacy in compliance with the General Data Protection Regulation (GDPR). This privacy policy governs the collection, storage and use of personal information collected by CTA (“Cooper’s“, ‘CTA’, “the Agency”, “we” or “us“), both via our website at http://www.cooperstalent.com/ (the “Site“) and through our provision of agency services to you and our clients (“Services“), either as an individual candidate or as a contact at one of our clients.

Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of services to you and our clients and is in accordance with applicable data protection laws.

This policy does NOT cover any specific use of your personal information by an actual or potential employer or hirer to whom we may provide your personal information. That use will be governed by the relevant employer’s or hirer’s privacy policy.

This Privacy Policy does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Please read this privacy policy carefully – by accessing or browsing the Site or requesting the provision of Services from us, you confirm that you have read and understood this privacy policy in its entirety.

Data protection principles

 

The legislation sets out various data protection principles. These include that personal information is:

 

• used fairly and lawfully
• used for limited, specifically stated purposes
• used in a way that is adequate, relevant and not excessive
• accurate
• kept for no longer than is absolutely necessary
• kept safe and secure
• not transferred outside the European Economic Area without adequate protection

 

The legislation requires that there is a clear legal basis for collecting and processing personal information. In general CTA relies on the individual’s consent in order to collect and process their data. Where there are exceptions such as a legal obligation, contractual agreement or CTA’s legitimate interest, they will be noted below.

The personal information we collect about you

When you access and browse the Site (including when you submit personal information to us through data entry fields on the website) and where we provide Services to you or an actual or potential employer or hirer of your services, we will usually collect the following information from or about you:

• your name;
• your postal address;
• your phone, and email details;
• your current and previous employment/work details, including job titles and employers;
• recruitment specific details such as any professional certifications, education and qualifications, skills, career history and any other information relevant to help us provide our services;
• any other information which you include in your CV, a completed application form or in a subsequent specific request for further information sent by us to advance the recruitment process;
• any information which has been published or made available on a social media profile or job board /site such as Spotlight(whether by you or a third party), or in any news media;
• any email communications, including attachments, which you send to us

This applies whether your services are provided to a hirer direct, or via a third party in relation to whom Visions is appointed to co-ordinate recruitment.

How we store and use your personal information

We collect, store and use your name, addresses and employment information for our legitimate interests, so that we can recommend opportunities and jobs to you that you may be interested in and to help us to provide suitable candidates for our clients who engage us to assist them fulfil their recruitment requirements.

We will store information that we obtain in relation to you so that we are able to contact you about future roles and opportunities. This storage and use of your personal information allows you to be contacted about roles which may be of interest to you, now or in the future, and we do not believe that this storage and use will unduly prejudice your rights or freedoms.

We will only share your name, address and availability with casting directors or production companies for the purpose of suggesting you for a job or confirming a job.

Telephone numbers collected will be used for communication through WhatsApp which is securely encrypted

 

Under s.37 Children & Young Persons Act 1963 we will, when applying for a performance licence, share with the appropriate local authorities via their encrypted channels:

 

• child’s name
• date of birth
• post code, area where child is living
• authority to which council tax is paid.

 

This information has to be securely passed on to the local authority for them to approve whether the performance of any type can take place. We are required under this Act to retain this information for 6 months from the date of the performance after which CTA will securely destroy the information it holds on children under 16yrs EXCEPT such information which will enable payment of fess and / or repeat fees to said client.

 

We may use your information to:

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• make the Site and our Services available to you
• carry out our obligations arising from any contracts or agreements entered into by you and CTA
• seek your feedback on the services we provide
• notify you of relevant changes to our services
• send you communications which you have requested and that may be of interest to you for legitimate business purposes
• process an employment application or support an application for a chaperone licence
• suggest you / your child for various roles with employers
• as described above: notify local authorities as required by law that a member of CTA is participating in a performance and in any applications for performance licences.

 

Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Site and then Services, or which are desirable in order to make them to operate more effectively. In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.

The relevant circumstances are:

• detecting and preventing fraud;
• ensuring that our own processes, procedures and systems are as efficient as possible;
• analysing and enhancing the information that we collect;
• determining the effectiveness of our promotional campaigns and advertising; and
• where you have given us your consent, contacting you (including by WhatsApp, SMS and email) with services and opportunities which we think may interest you.

In some, relatively limited, circumstances we need to handle your personal information in a certain way to be able to comply with our legal obligations – for example: if we are requested to disclose your personal information to regulatory bodies; if we need to demonstrate our compliance with applicable law; any tax and national insurance legislation relating to payment for work undertaken and immigration law.

Anonymous data

We collect anonymised details about visitors to our website for the purposes of aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.

How we share your personal information and who we share it with

We will disclose information under the following circumstances:

• Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
• Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
• Our Services: When we are using your personal information in the context of our recruitment services, then we may share your personal information with our producers or directors where we believe that you may be appropriate for a particular role or vacancy with that producer or director. This will only be done with your consent.

Where personal information is shared with clients, umbrella companies or hirers in the circumstances described above, then those organisations will handle your personal information in line with their own privacy policies.

Our use of data processors

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Third Party Service Providers work on our behalf. We may pass your information to our third-party service providers, agents’ subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond the CTA network for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. The following is a list of our data processors:

 

Posting

 

When sending letters we will share your postal address with the delivery service (normally Royal Mail).

 

Website hosting

 

We use a third party service, One.Com to host our website. One.Com are contractually obliged to treat any information on our private website as confidential and only use such information for the purpose of providing CTA with web hosting.

How we protect your data

 

When you give us personal information we take steps to ensure that it’s treated securely. All electronic information you provide CTA is kept confidential on encrypted and/or password protected hard drives and is only accessible by relevant members of CTA who require access to undertake their role. All confidential paperwork is kept in a lockable filing cabinet. The cabinet is located in an office which is locked overnight and to which only relevant members of CTA have access.

 

Non – sensitive data may be communicated over the internet which can never be guaranteed to be 100% secure. As a result we cannot guarantee the security of any information you transmit to us and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

Data Retention

We retain information (including personal information) for the minimum reasonable time period to allow us to provide our services and will delete it after that time except where we need to keep any personal information to comply with our legal obligations, resolve ongoing disputes, enforce our agreements or ensure the correct payment of repeat fees to our clients.

Data movement

 

Going forward, all personal data exchanged between CTA and clients / parents will be sent securely in one of the following ways:

 

• WhatsApp is a free end – to end encrypted form of social media. New members telephone numbers are added, with consent, to the appropriate groups for all their selected activities so that they can be notified of relevant events.
• Email - if an email address is provided we assume consent to use it for administrative purposes. We may use it to notify you of forthcoming events which will be of interest to you / your child. CTA will take particular care over email addresses which in addition to the GDPR are subject to the Privacy and Electronic Communication Regulations (PECR).
• Via a pass-worded document (password provided by CTA)
• Via postal service (where a physical signature is required)

 

We will not contact you for marketing purposes by email, phone, WhatsApp or text message unless you have given your prior consent.  We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted.

Use of cookies on our website

Like many other websites, the CTA website uses cookies. 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. While cookies collect statistical data about your browsing actions and patterns, they do not identify you as an individual. This helps us to improve our website and deliver a better more personalised web user experience. If you reject cookies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. Please read more about how we use cookies and what information is collected using cookies in our cookie policy.

Links to other websites

 

Our website may contain links to other websites run by other organisations. This privacy policy applies only to the CTA website so we encourage you to read the privacy statements on the other websites you visit. CTA cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. In addition, if you linked to our website from a third party website, CTA cannot be held responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the privacy policy of that third party site.

Transferring your information outside of Europe

 

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. Currently our servers are located within the European Union and the United States (covered under the EU-U.S Privacy Shield Framework).

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If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

Permissions

 

CTA may use images taken as part of any employment found for you or by the agents for its advertising in flyers, on social media or on the CTA website. Permission for this is given by clients / parents in the registration form.

Your rights

 

The GDPR legislation conveys various individual rights. These include the following:

 

• The right to be informed
• The right of access
• The right to rectification
• The right to be erased and / or forgotten
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

 

You therefore have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about CTA event and services, then you can select your choices by ticking the relevant boxes on our website contact form / registration form on which we collect your information.

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You can change your preferences at any time by contacting us by using the details provided below.

Complaints or queries

 

CTA tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

 

If you want to make a complaint about the way we have processed your personal information, please contact us in writing to the address provided below.

Access to information about you

 

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold is inaccurate or out of date, please let us know and we will correct our records.

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You have the right to ask for a copy of the information CTA holds about you. This is formally known as a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:

 

• give you a description of it.
• tell you why we are holding it.
• tell you who it could be disclosed to.
• let you have a copy of the information in an intelligible form.

 

To make a request to CTA for any personal information we may hold you need to put the request in writing to the address provided below.

 

Disclosure of personal information

 

Except as described in this Privacy Policy we will not disclose personal data without consent.

 

Legal obligations

 

We may disclose your information to governmental agencies or entities, regulatory authorities, or other persons in line with any applicable law, regulations, court order or official request. In this case CTA will rely on consent and/or legal and/or legitimate interest as the legal basis for holding and sharing this information

 

How to contact us

 

Frances Cooper Ltd trading as Cooper’s Talent acts as the data controller for the purposes of data protection.

 

Contact us in writing at: Data Protection, Frances Cooper Ltd trading as Cooper’s Talent Agency, 24 Cherry Orchard Road, Bromley, Kent BR2 8NE

 

Or by email at:                 admin@cooperstalent.com

 

Or by telephone at:         07940 335588

 

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Review of these policies: CTA keep this policy under regular review.  This Policy was last updated in May 2019.