Privacy & Data Protection Policy

Effective Date: 23 July 2025

 

Purpose of this Policy

Fabel Productions takes your privacy seriously where we deal with your personal information.  This Privacy and Data Protection Policy sets out how Fabel Productions (“we”, “our”, or “the Company”) collects, processes, stores, and protects personal data in the course of its work as an independent television, radio, and digital content production company based in Northern Ireland.

Fabel Productions in this policy means Fabel Productions Limited, a company registered in Northern Ireland under number NI675590 whose registered office is at 8 Church Quarter Lane, Carryduff, Belfast BT8 8FW. Fabel Productions Limited is the data controller of information processed under this privacy policy.

We are committed to safeguarding the privacy rights of all individuals whose personal data we hold, including cast, crew, contributors, clients, contractors, and website users.

 

Our Legal Obligations

We are required to process personal data in accordance with the:

  • UK General Data Protection Regulation (UK GDPR)
  • Data Protection Act 2018
  • Privacy and Electronic Communications Regulations (PECR)

We are registered with the Information Commissioner’s Office (ICO) as a data controller. ICO Registration Number: ZB023898

 

What Personal Data We Collect

We may collect and process the following categories of personal data, depending on the nature of your interaction with us:

  • General Personal Data
    • Full name
    • Date of birth
    • Postal and email address
    • Telephone number
    • Employment and work history (CVs)
    • Images and video recordings
    • Nationality and country of residence
  • Special Category Data (where required and with explicit consent):
    • Health and medical information (e.g. risk assessments, COVID declarations)
    • Diversity and inclusion monitoring data (e.g. race, ethnicity, gender)
    • Union membership (if disclosed for collective agreements)
    • Criminal conviction data (for safeguarding and compliance checks)
  • Financial and Contractual Data
    • Bank account details for payments
    • Tax reference numbers
    • Contracts, invoices, and pay records
    • Insurance and pension documentation (where applicable)
  • Website and Communication Data
    • IP address and browser information
    • Usage analytics (via cookies or tracking tools)
    • Contact form submissions and email correspondence

 

How We Collect Personal Data

We may collect your data through:

  • Direct submissions (e.g. CVs, applications, casting calls)
  • Contractual arrangements (e.g. employment or contributor agreements)
  • Filming and production processes
  • Our website and social media channels
  • Third-party referrals (e.g. casting agents, funders, broadcasters)
  • Publicly available sources (e.g. LinkedIn, IMDb)

 

How We Use Personal Data

We use your personal data for the following purposes:

  • To provide a requested service or carry out a contract with you
    • To perform any contract entered into between you and us.
  • Where we have a legitimate interest
    • To investigate and address enquiries, questions and complaints and respond to any feedback.
    • To compile statistics about the behaviour of our website visitors and other users of our services.
    • To assist in the effective resolution of disputes.
    • To develop and improve our engagement with you.
    • To ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
    • To enforce any agreement we have in place with you, or to protect the rights, property, safety, or security of Fabel Productions Ltd, third parties, users of our services or the public
  • Where we have a legal obligation
    • Where we are under a duty to process your information, in order to comply with (and/or where we reasonably believe we are under a duty to comply with) any legal obligation.
  • Where we have your consent
    • For any purpose where we specifically ask for your consent.

Where we rely on legitimate interest for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. You can find out more about the information in these balancing tests by contacting us using the details below.

 

Our Legal Bases for Processing

We process personal data under one or more of the following legal bases:

  • Consent – Where you have given explicit permission
  • Contract – Where processing is necessary for a contract you are party to
  • Legal obligation – For compliance with statutory and regulatory requirements
  • Legitimate interests – For business operations, recruitment, and creative development
  • Public interest / journalistic exemption – For editorial, artistic, or documentary purposes

 

Sharing Personal Data

  • From time to time, it may be necessary for us to share your information with limited categories of third parties. In the business of making and selling content for television, radio and digital series, this may include broadcasters, funder, co-producers and distributors, third party licensees of our content or suppliers working on our shows, as well as professional advisors (including our lawyers, insurance providers and accountants), service providers (including our communications agency, cloud storage, production software providers and website design agency, under data processing agreements), IT consultants carrying out testing and development work on our Website, and analytics and search engine providers that assist us in the improvement and optimisation of our services.
  • Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities (including but not limited to HMRC, ICO and Ofcom) conducting an investigation; to verify or enforce our Website Terms and Conditions or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
  • We share your information where you give us express permission to share your information in the course of your relationship with us from time to time.
  • As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us your personal information will be disclosed to such entity. If any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
  • However, we will never to sell or lease your personal data to third parties.

 

 

Data Transfers Outside the UK and EEA

We will only send data outside of the EEA if we are producing content in a country outside the EEA to which your personal data relates; or, we have licensed a programme in which your personal data appears; or, to comply with a legal duty.

If we do transfer data outside the EEA, we will make sure that it is protected in the same way as if it were being used in the EEA either by transferring the data to a country outside the EEA which has privacy laws at least as protective as those within the EEA; or, contracting the recipient of the data to protect the data to the same standards as required within the EEA.

 

Data Security

We implement appropriate technical and organisational measures to ensure personal data is protected from accidental loss, destruction, or unauthorised access, including:

  • Encrypted storage and transmission
  • Secure cloud services with restricted access
  • Password-protected documents and accounts
  • Physical security measures at our offices

 

Retention of Personal Data

We retain personal data only as long as necessary for the purposes for which it was collected. Typical retention periods:

Data Type

Retention Period

Contributor agreements/releases

7 years post-final use of content

Employment records

6 years after contract end (HMRC requirement)

CVs and applications

12 months (unless permission to retain longer)

Invoices and payments

6 years

Website usage data

12–24 months

 

Your Rights

By law, you have a number of rights when it comes to your personal information. Please contact us using the contact details below to exercise any of your rights. Further information and advice about your rights can be obtained from the data protection regulator in your country.

Under UK GDPR, you have the right to:

  • Access – Request a copy of your personal data
  • Rectification – Request correction of inaccurate or incomplete data
  • Erasure – Request deletion of your data (where applicable)
  • Restriction – Limit the way we use your data
  • Objection – Object to processing in certain circumstances
  • Data portability – Request transfer of your data to another organisation
  • Withdraw consent – At any time, where processing is based on consent
  • Complain – Lodge a complaint with the ICO (www.ico.org.uk)

To exercise any of these rights, contact us at: info@fabelproductions.com

 

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:

  • baseless or excessive/repeated requests, or
  • further copies of the same information.

Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.

 

Use of Cookies

Our website may use cookies to improve user experience and monitor site performance. Cookies may collect anonymous usage data such as IP addresses, device type, and browsing behaviour.

Users can set their browser to refuse or manage cookies. For more information, see our Cookie Policy.

 

Children’s Data

We do not knowingly collect personal data from children under 13 without parental or guardian consent. Where minors are contributors, strict safeguarding and consent procedures are followed.

 

Changes to This Policy

We may update this Privacy and Data Protection Policy periodically to reflect changes in the law or our practices. The latest version will always be available on our website or upon request.

 

Contact Us

If you have any queries or requests concerning this privacy policy or how we handle your information more generally, please get in touch with us using the following details:

Email: info@fabelproductions.com

If you are not satisfied with our response to a complaint you have made, or think we are not complying with data protection law, you can make a complaint to the UK data protection regulator who can be contacted as set out below:

Address: The Information Commissioner’s Office – Northern Ireland, 10th Floor, Causeway Tower, 9 James Street South, Belfast BT2 8DN

Phone number: 0303 123 1114

Email: ni@ico.org.uk

Website: https://ico.org.uk/make-a-complaint/