Data Protection Policy and Procedures

The Cornwall Film Festival is committed to a policy of protecting the rights and privacy of individuals, the Cornwall Film Festival needs to collect and use certain types of Data in order to carry on our work. This personal information must be collected and dealt with appropriately.

The Data Protection Act 1998 (DPA) governs the use of information about people (personal data). Personal data can be held on computer or in a manual file, and includes email, minutes of meetings, and photographs. The Cornwall Film Festival will remain the data controller for the information held. The Cornwall Film Festival and volunteers will be personally responsible for processing and using personal information in accordance with the Data Protection Act.    

Management committee members and volunteers running the Cornwall Film Festival who have access to personal information, will be expected to read and comply with this policy.

The purpose of this policy is to set out the Cornwall Film Festival commitment and procedures for protecting personal data. The Cornwall Film Festival regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal with.

The Data Protection Act Legislation
This contains 8 principles for processing personal data with which Cornwall Film Festival will comply. Personal data:

  1. Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
  2. Shall be obtained only for one or more of the purposes specified in the Act, and shall not be processed in any manner incompatible with that purpose or those purposes,
  3. Shall be adequate, relevant and not excessive in relation to those purpose(s)
  4. Shall be accurate and, where necessary, kept up to date,
  5. Shall not be kept for longer than is necessary
  6. Shall be processed in accordance with the rights of data subjects under the Act,
  7. Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorised or unlawful processing or accidental loss or destruction of, or damage to, personal information,
  8. Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal information.

The following list contains definitions of the technical terms we have used and is intended to aid understanding of this policy:

Data Controller – The person who (either alone or with others) decides what personal information Cornwall Film Festival will hold and how it will be held or used.

Data Protection Act 1998 – The UK legislation that provides a framework for responsible behaviour by those using personal information.

Data Protection Officer – The person on the management committee who is responsible for ensuring that it follows its data protection policy and complies with the Data Protection Act 1998

Data Subject/Service User – The individual whose personal information is being held or processed by Cornwall Film Festival (for example: a service user or a supporter)

‘Explicit’ consent – is a freely given, specific and informed agreement by a Data Subject (see definition) to the processing of personal information about her/him.   

Explicit consent is needed for processing sensitive data this includes the following:

(a) racial or ethnic origin of the data subject

(b) political opinions

(c ) religious beliefs or other beliefs of a similar nature

(d) trade union membership

(e) physical or mental health or condition

(f)  sexual orientation

(g) criminal record

(h) proceedings for any offence committed or alleged to have been committed

Notification – Notifying the Information Commissioner’s Office (ICO)  about the data processing activities of the Cornwall Film Festival. Note: Not-for-profit organisations are exempt from notification.

Information Commissioner – The UK Information Commissioner responsible for implementing and overseeing the Data Protection Act 1998.

Processing – means collecting, amending, handling, storing or disclosing personal information

Personal Information – Information about living individuals that enables them to be identified – e.g. names, addresses, telephone numbers and email addresses. It does not apply to information about organisations, companies and agencies but applies to named persons, such as individual volunteers of the Cornwall Film Festival.

Applying the Data Protection Act within the Cornwall Film Festival
Whilst access to personal information is limited to the staff and volunteers at the Cornwall Film Festival Volunteers at the Cornwall Film Festival may undertake additional tasks which involve the collection of personal details from members of the public.

In such circumstances we will let people know why we are collecting their data and it is our responsibility to ensure the data is only used for this purpose.

Correcting data
Individuals have a right to have data corrected if it is wrong, to prevent use which is causing them damage or distress or to stop marketing information being sent to them.

The Cornwall Film Festival is the Data Controller under the Act, and is legally responsible for complying with Act, which means that it determines what purposes personal information held will be used for.

The management committee will take into account legal requirements and ensure that it is properly implemented, and will through appropriate management, strict application of criteria and controls:

The Data Protection Officer on the management committee is:

Name: Louise Fox

Contact Details:
01326 618115 / 07814 906420
G19 Tremough Innovation Centre, Penryn, Cornwall, TR10 9TA

The Data Protection Officer will be responsible for ensuring that the policy is implemented and will have overall responsibility for:



This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

In case of any queries or questions in relation to this policy please contact the Data Protection Officer.

Data collection

Informed consent
Informed consent is when

Cornwall Film Festival will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.

When collecting data, Cornwall Film Festival will ensure that the Data Subject:

Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised volunteers.

Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.

It is Cornwall Film Festival responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.

This policy will be updated as necessary to reflect best practice in data management, security and control and to ensure compliance with any changes or amendments made to the Data Protection Act 1998.

Data Subject Access Requests
Members of the public may request certain information from the Local Authority under the Freedom of Information Act 2000. The Act does not apply to Cornwall Film Festival. However if at anytime we undertake the delivery of services under contracts with the Local Authority we may be required to assist them to meet the Freedom of Information Act request where we hold information on their behalf.

The Cornwall Film Festival may need to share data with other agencies such as the local authority, funding bodies and other voluntary agencies.

The Data Subject will be made aware in most circumstances how and with whom their information will be shared.  There are circumstances where the law allows Cornwall Film Festival to disclose data (including sensitive data) without the data subject’s consent.   

These are:

  1. Carrying out a legal duty or as authorised by the Secretary of State
  2. Protecting vital interests of a Data Subject or other person
  3. The Data Subject has already made the information public
  4. Conducting any legal proceedings, obtaining legal advice or defending any legal rights  
  5. Monitoring for equal opportunities purposes – i.e. race, disability or religion
  6. Providing a confidential service where the Data Subject’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Data Subjects to provide consent signatures.

Cornwall Film Festival regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.  

Cornwall Film Festival intends to ensure that personal information is treated lawfully and correctly.

Risk Management  

The consequences of breaching Data Protection can cause harm or distress to service users if their information is released to inappropriate people, or they could be denied a service to which they are entitled. Volunteers should be aware that they can be personally liable if they use customers’ personal data inappropriately.  This policy is designed to minimise the risks and to ensure that the reputation of the Cornwall Film Festival is not damaged through inappropriate or unauthorised access and sharing.

Destroying personal data.

Personal data should only be kept for as long as it is needed i.e. only keep that data for the duration of administering the campaign/project and securely dispose of once the promotion and monitoring period is complete.   If a customer is housebound and receives regular visits from a volunteer – ensure the list is securely stored and remove customer details when they change or the customer no longer receives the service. Review the list annually. We will ensure that this information is confidentially destroyed at the end of the relevant retention period.

Further information  

If members of the public/or stakeholders have specific questions about information security and data protection in relation to the Cornwall Film Festival please contact the Data Protection Officer:

The Information Commissioner’s website ( is another source of useful information.  

Signed: Louise Fox
Dated: 13th March 2019
Review Date: 1st March 2019