Privacy Notice for Photography and Filming
This Privacy Notice explains: who we are, the activities of the University Videography and Photography Team, how we use the film and photographs we take, our lawful bases for processing, our relevant retention periods, and how you can exercise your privacy rights.
This notice provides information that is in addition to any photography and film privacy notices, consent forms and signage which may have been in place at the time photography / filming took place. Please do read this notice to understand our practices and if you have any questions, please contact us using the contact details provided below. This privacy notice does not apply if you were a contracted / paid model for University photography / film.
Who we are
Throughout this notice, “University”, “we”, “our” and “us” refer to the Manchester Metropolitan University, an exempt charity under Schedule 2 to the Charities Act 1993 (amended by the Charities Act 2011). The University is the Data Controller in respect of the personal data you provide as part of [activity].
The University is registered as a Data Controller with the Information Commissioner’s Office (ICO). We manage personal data in accordance with the UK General Data Protection Regulation (GDPR) and the University’s Data Protection Policy.
Ensuring you know that photography or videography is taking place
Wherever possible we will ensure you know when photography or videography is taking place in the following ways:
- Advance notice of our intention to photograph / film within event booking forms, event invitations, event information etc.
- Comprehensive signage at prominent locations, entry and exit points to the event.
- Our University photographer / videographer will be clearly identifiable.
- Our University photographer / videographer will approach clearly visible and identifiable individuals to verbally inform that a photograph / film has been taken.
- Photographer / videographer ‘contact cards’ to be issued as applicable.
The personal data we process
- Photographs and filmed footage.
- Where you have given us your consent and as applicable, your name, course of study, country of origin.
Please note that video footage or quotations may be edited to keep them concise. We will not change the meaning of what you have said when editing.
Where any other personal data is collected, you will have been specifically informed of this at the point of photography and filming.
The purposes of our photography and filming
The photographs and film we capture are used for our marketing and promotional purposes; this includes:
- Promoting specific University initiatives explained at the point of photography or filming.
- Promoting the University, our events, our activities, benefits to studying with us, our services, our courses and our research.
to various audiences, including UK and international prospective students, parents, research and other funders, policy-makers, benefactors, the public and other stakeholders.
The recipients or categories of recipients of the personal data
The images and film we take will likely be placed into the public domain. This includes within University publications, printed media, prospectuses, on the University website and other related owned websites, University social media accounts, billboards / hoardings and other public domain advertising, and within adverts placed with specific third parties, (e.g. Google, Facebook and Instagram).
As such, published photographs / film are available to anyone who has access to the website, social media channels or printed materials etc in which the photo or video features.
The original photographs and videos will only be accessible to employees and agents of the University, or third parties that process data on our behalf (e.g. printing providers, digital asset management suppliers).
Our lawful bases for processing
- Legitimate interests – We have a legitimate interest to be able to promote the University using photography / videography, as explained under the Purposes heading. We make every effort to ensure you are aware when photography / filming is taking place and to minimise any privacy impact. You are able to opt out of photography / filming as explained below. Where relying on legitimate interests and as appropriate, we will use ‘depth of field’, and distance/ framing to avoid direct identification to minimise privacy impact.
- Consent – Where appropriate, we may seek your consent to photograph / film you. This will be done with specific written consent forms, either electronic or paper based. Our general electronic consent form for photography / videography can be seen here. We will likely rely upon this lawful basis where you are more prominently featured within the photography / videography.
Withdraw consent or opting out
Prior to or during the event
If you are attending an organised event at which there may be photography or video recording taking place, our event booking form will ask whether you wish to opt out of photography. Please use this option at the point of booking. You can also let us know by contacting: creativeservices@mmu.ac.uk stating what event you will be attending and when. For large events such as Open Days and Graduation etc we may provide you with a badge, armband, lanyard, or other discreet identifier, so our event photographer is aware that you have opted out. We will make every effort not to capture or retain any images or footage of you.
If you have not been able to let us know in advance or have any questions or concerns at an event, please direct these to the photographer or videographer on site. We will ensure that the event photographer will be clearly identifiable.
Post event
If we have collected your consent or you wish to opt out post event, once photography / filming has taken place you can withdraw your consent / opt out by writing to creativeservices@mmu.ac.uk with the subject line: ‘Withdrawal of consent for photography’, stating: your name, the event you attended and date. Where we are unable to identify you, we may have to ask you to provide a recent photograph to assist us to complete the deletion. This will also be securely disposed of once disposal of photography / film has taken place.
Please note: that although we will stop using your image in current publications we continue to control / digital publications and in any future publications, we will not be able to remove any printed copies which have already been published and are out in the public domain. Withdrawing your consent / opting out will not affect the lawfulness of any processing we conducted prior to your withdrawal.
Data retention
We will retain personal data for no longer than is necessary in accordance with the University’s Retention and Disposal Schedule. Where we have collected your consent, the consent form used will have contained a specific retention period after which we will dispose of the photography / videography or seek to refresh your consent. We will seek to refresh your consent using the contact information provided within the consent form.
Where such a consent form has not been used, we will use and retain photography / film for a period of five years from the date of the event, at which point we will dispose of the photography / film. Please note that after deletion the information may still appear in materials already in circulation prior to this date.
Your rights in respect of the processing
The GDPR provides data subjects with the following data subject rights:
- The right to be informed – this privacy notice, event signage and any applicable consent forms / privacy information provided assist with fulfilling these obligations.
- The right to object / withdraw consent, right to restrict processing, right to erasure – please see ‘Withdraw consent or opting out’ above for information about how to exercise these rights.
- The right of access, right to rectification, right to data portability – please contact the University Data Protection Officer using the contact information below to exercise these rights.
Please note, that these rights apply in certain circumstances, for example according to the lawful basis utilised by the University. The right of access to personal information held about you exists in order to be aware of, and verify, the lawfulness of the processing.
Contacting us
For questions or concerns about this Privacy Notice, or our use of photography / film, please contact [specific contact information] in the first instance.
Our Data Protection Officer can also be contacted using dataprotection@mmu.ac.uk, by calling 0161 247 3884 or in writing to: Data Protection Officer, Legal Services, All Saints Building, Manchester Metropolitan University, Manchester, M15 6BH.
Right to lodge a complaint with the supervisory authority
You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) as the supervisory authority in respect of the processing of your personal data. We would encourage you to expend our internal complaints procedure through our initial contact and the University Data Protection Officer, prior to contacting the ICO. Please contact: casework@ico.org.uk or telephone: 0303 123 1113. For any further contact information please see: https://ico.org.uk/global/contact-us/.
Updates to this privacy notice
We may update this privacy notice from time to time in response to changing legal, technical or business developments. When we update our privacy notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.