Filmed Child Policy

This Filmed Child Policy explains how Siren Films Ltd (“Siren Films”, “we”, “us”, “our”) approaches the filming of children under the age of 16 (“Filmed Children”) as part of our commercial activities, and how we protect their personal data and wellbeing.

Who we are

Siren Films Ltd is a limited company registered in England (company number: 04546211) with its registered office at John Marley Centre, Muscott Grove, Newcastle upon Tyne, NE15 6TT.

Definitions

  • Filmed Child / Filmed Children means any individual under the age of 16 who we film as part of our commercial activities.
  • Filmed Adult / Filmed Adults means any individual over the age of 16 who we film as part of our commercial activities.
  • Customer / Customers means any entity or individual buying or enquiring about the films and services we produce or sell.
  • Commissioned Film means a film that has been specifically commissioned for a Customer for their sole use and acquisition.
  • Data protection law means the Data Protection Act 2018 and the UK GDPR (and, where applicable, the General Data Protection Regulation (EU) 2016/679).

Scope

This policy applies when we film a child in any setting, including when we visit a workplace or educational setting to make a film, and where a child may appear in footage used within our films and related materials.

Our website is not intended for children and we do not knowingly collect personal data from individuals under the age of 16 through their use of our website.

Our role

For the purposes of data protection law, Siren Films is the data controller in relation to personal data we collect and use when we film a Filmed Child (including footage and related information we hold).

Lawful basis and consent

We will only film a child where we have a proper legal basis under data protection law. In practice, this means:

  • We will obtain explicit consent before filming a Filmed Child.
  • Consent must be provided by an adult with parental authority or legal guardianship over the child.

By providing consent, the adult with parental authority or legal guardianship confirms they are permitted to consent on the child’s behalf and that no additional parental authority is required.

What information we collect about filmed children

The personal data we may collect in relation to a Filmed Child includes:

  • Footage and images captured during filming (including audio where relevant).
  • Contextual information necessary to produce and manage the film (for example, filming dates, location, and scene descriptions).

Sensitive personal data

In some cases, footage may reveal information that could be considered special category (sensitive) personal data (for example, a child’s disability, medical condition, race, ethnicity, or religion) because it may be discernible from the images captured.

Where we process special category personal data, we will rely on explicit consent obtained from the adult with parental authority or legal guardianship before filming takes place.

How we use filmed children’s personal data

We use filmed children’s personal data for the following purposes:

  • To produce films and associated educational materials.
  • To make films available to Customers and other authorised viewers via our platforms and licensing arrangements.
  • To manage and administer our film production and licensing operations.
  • To comply with applicable legal and regulatory obligations.

Where filmed children’s data may be shared

Films we produce may be licensed to Customers and may be made available through streaming or publishing partners in various jurisdictions. We only share the minimum personal data necessary for our operations.

We may also disclose personal data where required to comply with legal obligations, enforce our legal rights, or in connection with a sale, acquisition, or reorganisation of our business (where personal data, including films we have produced, may be a transferred asset).

For a full list of third parties with whom personal data may be shared, please contact us using the details set out in the Contact section below.

International transfers

We may process personal data in the UK and worldwide, including in Australia, Canada, Ireland, Japan, India, New Zealand and the United States, because we have licensing agreements with publishing organisations in these jurisdictions that provide streaming video services of our films.

When we transfer personal data outside the UK and the European Economic Area, we implement appropriate safeguards as required by data protection law, which may include anonymisation where possible, reliance on adequacy decisions, and/or the use of approved standard contractual clauses.

Retention and review

We retain filmed children’s personal data only for as long as necessary for the purposes for which it is collected and processed. In particular:

  • Films we produce and license may retain filmed children’s personal data for as long as we consider the film reasonably relevant to our business operations (including how often it is licensed and requested). These films are reviewed annually by our Board of Directors to determine whether they should continue to be offered.
  • Commissioned Films: where a film is commissioned for a Customer for their sole use and acquisition, personal data in that film may fall under the control of a separate controller once rights transfer to the Customer, and we will have no jurisdiction over personal data in the Commissioned Film from that point.
  • Unedited footage and outtakes (including footage cut from a film that we have retained) will be held for a maximum period of ten (10) years before being destroyed in a GDPR-compliant way.

Security

We implement appropriate technical and organisational security measures to protect personal data against accidental loss, unauthorised access, alteration or disclosure. Access is limited to employees, agents, contractors and other third parties who have a business need to know, and they are subject to confidentiality obligations.

We also maintain procedures for suspected personal data breaches and will notify affected individuals and regulators where we are legally required to do so.

Rights and requests

Individuals (and, where applicable, those with parental authority or legal guardianship) may have rights under data protection law in relation to personal data, including rights to access, correction, deletion, restriction, objection, and data portability, and the right to withdraw consent in certain circumstances.

To make a request, contact us using the details below.

How to complain

If you believe there is a problem with how personal data is handled, please contact us. You also have the right to complain to the Information Commissioner’s Office (ICO): telephone 0303 123 1113 or via the ICO website.

Changes to this policy

We may update this policy from time to time. Any changes will be posted on this page and, where appropriate, we will give reasonable notice of significant changes.

Contact

If you have any questions about this Filmed Child Policy or how we handle personal data, you can contact us by:

  • Telephone: 0191 2327900
  • Email: info@sirenfilms.co.uk
  • Post: Siren Films Ltd, John Marley Centre, Muscott Grove, Newcastle upon Tyne, NE15 6TT

Please ask for Katrina McEvoy.