We are FIRST Model Management Ltd (“we” or “us”), a company registered in England and Wales. Our company registration number is 07151048 and our registered office is at 276 Vauxhall Bridge Road, London, SW1V 1BB. Our registered VAT number is GB 101 1392 77
This privacy policy sets out the basis on which we collect, use and disclose your personal data. Please read this policy carefully alongside any applicable Terms & Conditions to understand our views and practices regarding your personal data and how we will treat it.
More information can be provided on request. Definitions are defined in the Appendix at the end of this privacy policy.
For the purpose of the applicable Data Protection Legislation, we are the data controller of any personal data we process. As a data controller, we are responsible for ensuring our systems, processes, suppliers and People comply with Data Protection Legislation in relation to the personal data we handle.
We require our People to comply with this privacy policy and our Data Protection Policy when dealing with personal data. We have a Data Protection Manager who is responsible for overseeing and enforcing the compliance of our business and People with the Data Protection
Legislation, and for ensuring our People receive regular compliance training.
We take personal data breaches very seriously, and are required to notify the Information Commissioner’s Office in the event of such a breach.
When using, collecting and disclosing personal data, we follow the key data protection principles.
We have policies, procedures and records to demonstrate compliance with the principles, as further detailed in our Data Protection Policy.
How we collect, use and disclose your personal data The following summaries how we collect, use and disclose your personal data.
Information such as :
Your personal data will be collected from various sources including:
Your personal data will be used for the following purposes:
Your personal data may be transferred to:
Model personal data relevant to the purpose shall be kept for 20 years OR for the period specified in our Data Protection Policy and we shall not keep your personal data for longer than is necessary.
We will ensure we keep all personal data up to date and shall immediately and permanently delete any personal data which is not necessary for the purpose.
Information such as your:
Your personal data will be collected for relationship management and file opening is collected from you directly and further information (e.g. to verify your identity) may be collected from third parties, such as publicly available sources.
When you contact us via email or telephone, we may collect any personal data you provide you provide to us.
All additional personal data is collected when supplied to us, or created by us in connection with a particular matter on which we are engaged
Your personal data will be used for relationship management and file opening data is used for providing legal services, administration, commercial purposes (e.g. creditworthiness) and as required by law (e.g. anti-money laundering).
All other personal data will be used for the purposes of providing legal services and to comply with our statutory/ regulatory obligations.
Your personal data may be disclosed to:
Client personal data shall be kept for 6 years OR for the period specified inour Data Protection Policy and we shall not keep your personal data for longer than is necessary.
We will ensure we keep all personal data up to date and shall immediately and permanently delete any personal data which is not necessary for the purpose.
Information such as your name and business information (email address, job title, who you work for).
Additional information may be processed where it is provided by you, for example in correspondence, in connection with a Model, or in letting us know your interests and how/when you wish to be contacted by us.
Your personal data is collected when you register or ‘opt in’ to receive:
Where you have given us your clear, unambiguous consent to do so, your personal data will be used to:
Your personal data may be transferred to our third party service providers who support the operation of our business.
Where you have given us your clear, unambiguous consent to do so, we may pass your personal data to selected third parties to provide you with information about services we feel may interest you.
We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.
Subscriber personal data shall be kept until you request it to be deleted OR for the period specified in our Data Protection Policy and we shall not keep your personal data for longer than is necessary.
We will ensure we keep all personal data up to date and shall immediately and permanently delete any personal data which is not necessary for the purpose.
Information such as :
Your personal data is collected when you
Your personal information is used to
Your personal data may be transferred to our third party service providers who support the operation of our business.
Where you have given us your clear, unambiguous consent to do so, we may pass your personal data to selected third parties to provide you with information about services we feel may interest you.
We shall only transfer personal data to third parties which is limited to the relevant purpose and is adequately protected.
Our Website users’ personal data shall be kept for 6 years OR for the period specified in our Data Protection Policy and we shall not keep your personal data for longer than is necessary.
We will ensure we keep all personal data up to date and shall immediately and permanently delete any personal data which is not necessary for the purpose.
Personal data such as:
Your personal data will be collected from various sources including:
Your personal data will be used for the following purposes:
Your personal data may be transferred to :
We shall only transfer personal data to third parties which has been limited to the relevant purpose.
Our People’s personal data shall be kept until you request it to be deleted OR for the period specified in our Data Protection Policy and we shall not keep your personal data for longer than is necessary.
We will ensure we keep all personal data up to date and shall immediately and permanently delete any personal data which is not necessary for the purpose.
Personal data may be transferred to one of our Mother Agents for the purposes of fulfilling our obligations to our Models, Talent and Clients. We also use a number of suppliers in connection with the operation of our business and they may have access to the personal data we process. For example, an IT supplier may see our personal data when providing software support, or a company which we use for a marketing campaign may process contacts’ personal data for us. When contracting with suppliers and/or transferring personal data to a different jurisdiction, the firm takes appropriate steps to ensure that there is adequate protection in place and that the principles are adhered to.
Personal data must be processed in line with an individual’s rights, including the right to:
Should you wish to make a request in line with your rights as an individual, please forward it to the Data Protection Manager using the contact details provided at the end of this privacy policy.
Our People must notify or inform the Data Protection Manager immediately if they receive a request in relation to personal data which the firm processes.
The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation (as applicable).
Information security is a key element of data protection. We take appropriate measures to secure personal data and protect it from loss or unauthorised disclosure or damage. Our policy and approach to information security is contained within our Data Protection Policy.
Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our GDPR Compliance Team at +44 (0) 207 436 9095 or by writing to us at accounts@firstmodelmanagement.co.uk
You should direct all complaints relating to how the firm has processed your personal data to the Data Protection Manager.
Our People must inform the Data Protection Manager immediately if they receive a complaint relating to how we have processed personal data so our complaints procedure can be followed.
May 2018.
Clients:
any person, business or other organisation who engages, or is looking to engage, the services of our Models & Talent.
Controller:
a personal/organisation who determines the purposes for which, and the manner in which, any personal data is processed.
Data Protection Manager:
an individual who is responsible for ensuring compliance with data protection legislation, including training staff, conducting internal audits, implementing internal policies and being the first point of contact for the Information Commissioner’s Office.
Data Protection Policy:
our internal data protection policy which sets out how we keep personal data secure, including technical measures (e.g. encryption of personal data, restricted access to personal data, monitoring and testing systems for unauthorised access , backups of personal data), roles and responsibilities of individuals and the scope of protection.
Models & Talent:
models & talent who have engaged, or are looking to engage, our modelling agency and/or management services and are, or are considering being, represented by us.
Mother Agencies:
model agencies in jurisdictions outside of the UK who have engaged us to provide modelling agency services on their behalf in the UK.
People:
all people providing services to or working for us, including but not limited to our employees, directors, members, and contractors.
Personal data:
information (including opinions) which relates to an individual and from which he or she can be identified either directly or indirectly through other data which we have or are likely to have in our possession. These individuals are sometimes referred to as data subjects.
Personal Data Breach:
a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed by an organisation electronically. A personal data breach may mean someone outside the organisation gets unauthorised access to personal data, but a breach can occur if there is unauthorised access within the organisation or if an employee accidentally alters or deletes personal data.
Principles:
the core data protection principles underlying the Data Protection Legislation, which specify personal data should be: processed lawfully, fairly and in a transparent manner; collected for specified, explicit and legitimate purposes; adequate, relevant and limited to what is necessary; accurate and, where necessary, kept up to date; kept for no longer than is necessary; processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. Additionally, organisations must adhere to the principal of accountability.
Process:
the ‘processing’ of personal data captures a wide range of activities, and includes obtaining, recording and holding personal data and performing any operation of the personal data (including erasure/destruction).
Processor:
any person (other than an employee of the data controller) who processes the data on behalf of the data controller.
Purpose:
the purposes identified in the “Purpose” column of the tables in section 3 of this privacy policy (How we collect, use and disclose your personal data), as applicable.
Terms and Conditions:
the Terms and Conditions for Booking Models & Talent, the Model & Talent Representation Agreement and the Website Terms of Use.
Third party:
a person, organisation or other body other than the data subject, controller, processorand persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Website:
www.firstmodelmanagement.co.uk