We are Spotlight (a trading name of Talent Systems Europe Limited) (Spotlight, we, us and our). We are a company registered in England and Wales with company number 07664065. Our registered office is at 16 Garrick Street, London WC2E 9BA.
We provide services to connect performers with casting professionals of roles in theatre, television and film productions (Services) via our website which can be located at www.spotlight.com (Site) and any associate mobile apps (together, the Platform).
You can contact us by email at firstname.lastname@example.org if you have any questions about data protection or other legal matters.
This policy was last updated on 25 September 2023. We will periodically update the policy so please check back for updates.
Talent Systems Europe Limited is a controller of your data where we determine the purposes for the processing of your information. We have a Data Protection Officer who can be contacted via email@example.com or by writing to Data Protection Officer, 7 Leicester Place, London WC2H 7RJ.
We fully endorse and adhere to data protection law across Europe in the form of the General Data Protection Regulation (GDPR), the gold standard of data protection legislation, and the equivalent data protection laws in the UK. We have registered as a data controller under the UK Data Protection Act, and can be found in the Data Protection Public Register. We also work in accordance with relevant standards including the UK’s Age Appropriate Design framework.
Relationships when we are not your Data Controller
If you are a performer, young performer or graduate who has purchased or subscribed to Spotlight’s Services (Spotlight Member) please note that your authorised agent (Agent) (if you are represented) or training establishment may also act as your Data Controller both for the supply of your information to Spotlight and its use in submissions made by your Agent on your behalf via one of our Services, The Spotlight Link, and additionally for any third party tools your Agent or training establishment may employ to administer your data. It is your responsibility to ensure that your Agent or training establishment only processes your personal information in accordance with your wishes. Casting professionals that have purchased or subscribed to Spotlight’s Services (Casting Subscribers) also act as your Data Controller where they determine the purposes for the administration of personal information in finding and hiring professional performers, working with agents, and collaborating with other project members. Please do contact them with any queries you have in respect of their processing of your personal information.
How do we make sure your data is used lawfully?
We will only collect, use, store, share (and any other of the defined uses of processing data) where we have a lawful basis to so do, as defined by data protection legislation, and do not collect more information than we need to fulfil the specific purpose. We document which lawful bases are relied upon for our processing activities. Lawful bases include where you have given consent, where processing is necessary for the performance of a contract with you, when complying with law and where there we have legitimate interests to do so. More information on how we apply these lawful bases is provided below:
- Consent – In certain situations we process your data with your consent. Where we process data based on your consent, we will ask you for your explicit consent (you have to take an action) which you can withdraw at any time, but it will not affect the lawfulness of processing before then. If you are under 16, consent will be obtained from your parent or guardian.
- For example, you tick a box to receive email marketing communication from us.
- Contract – In certain situations, we need your personal information to comply with our contractual obligations.
- For example, if you become a Spotlight Member we will collect and process your information so we can deliver Services to you.
- Complying with law – we may need to process your personal information if the law requires us to.
- For example, we may have to pass on information of people in fraud or other criminal activity to law enforcement.
- Legitimate interest – We will only rely on legitimate interests where the processing of your data is not overridden by your interests or rights and freedoms. This means that we may need your information and use in a way that can reasonably be expected as part of us running Spotlight and does not materially impact your rights, freedoms or interests.
- For example, we may use your information to build a more accurate picture of you to better inform our business decisions, or to provide you with relevant product or service offerings.
When do we collect your personal information?
We will collect personal information from you when you:
- Visit and/or use our Platform and/or Services;
- Sign up to or use Platform and/or Services (e.g. as a Spotlight Member);
- Purchase or subscribe to a product or Service from us (e.g. a room bookings or editing sessions);
- Book to attend an event;
- Complete a survey or feedback form;
- Provide feedback or review our Platform and/or Services;
- Correspond with us on social media;
- Contact us with a form of query, compliment or complaint (plus other types of enquiries) via phone, email, post or otherwise; or
- Enter a competition or prize draw.
What personal information do we collect?
We will only ever ask you for the necessary information needed to process your data. We may process your data including the following personal information:
- Name and previous names;
- Date of birth;
- Address(es) or location data;
- Telephone number(s);
- Information pertaining to disability, ethnicity and heritage;
- Physical details such as height;
- Training and skills;
- Information/ documents to enable us to vet an application;
- Information/ documents you provide to prove age, identity or other requirement where the law requires this to confirm discount eligibility;
- Technical information such as your browser or device type, or your IP address;
- Telephone call recordings (for training and monitoring purposes);
- Photographs, video and audio clips, and metadata relating to this such as copyright information;
- Career history;
- URLs and links to social media;
- Bank and payment data;
- Closed Circuit Television (CCTV) footage in accordance with Spotlight’s CCTV Policy;
- For security, a robustly-asymmetrically encrypted record of your login password.
Please note, that as many of our Services are primarily promotional tools, personal information included in these public profiles may be accessible by other Spotlight users and/or the public via wide circulation or redistribution, and via our historical archives. Therefore you should never include any personal information on your profile that you would wish to remain private.
How will we use your personal information?
We (or third-party data processors acting on our behalf) may collect, store, use and share your personal information for the following purposes:
- To provide you with the Spotlight Services, including making your public profile information available (including via our third-party partners if you have requested that we do so), and searchable where applicable, to other users of the Services;
- To fulfil orders for products or Services (including recognising returning members, returning customers and previous member applicants);
- To keep your details and records up-to-date and accurate;
- To provide you with important service communications relating to our products or Services;
- To provide you with alerts and notifications to you based on your preferences including via email and push notifications;
- To communicate with you regarding professional industry enquiries;
- To invite you to and manage your attendance at Spotlight and our partner events;
- To answer/respond to your enquiries and complaints or otherwise communicate with you;
- To process and share audio and visual content including self-tape and audition videos;
- To vet your professional background when you are joining as a Spotlight Member/Agent/Casting Subscriber or purchasing a restricted access product;
- To enable agents to find performers seeking representation;
- Internal record keeping;
- To notify you of other products and/or services that we think will be of interest to you (you can unsubscribe from these communications at any time by managing your notifications within your account or by submitting a request to our Support team);
- To inform you of latest developments within Talent Systems companies and the wider industry (provided that we have your consent to do so);
- To contact you as an expired member or subscriber about how you can rejoin Spotlight (provided that you have not indicated that you no longer wish to receive communications from us);
- To assist in the creation and editing of audio and visual content;
- To improve our products and Services;
- To understand information which may better inform business decisions;
- To verify your identity;
- For market research and analysis, such as receiving opinions and feedback on our products and Services;
- To administer prize draws or competitions where you have entered into;
- To process payments and identify or prevent fraudulent transactions;
- To develop, test and improve our Platforms, Services and products that we provide to you;
- For training and monitoring purposes;
- To provide you with access to specific search facilities;
- To provide you with useful information and statistics about your and other users of the Platforms’ activities;
- To comply with any legal obligation such as to share data with law enforcement;
- To ensure the safety of staff, visitors and Spotlight’s buildings and offices;
- To improve and personalise our Platform and Services to you; and
- To facilitate the historical archiving of information, including Spotlight public profiles/titles both in print and digital formats and media footage.
What personal information do we share?
We share personal information with carefully selected and trusted third parties when required. Wherever possible only information contained within your public profile would be released to such third parties. To keep your data safe and maintain your privacy we have the following approach:
- We implement appropriate legal, procedural and technical controls;
- We only provide the information they need to undertake that service;
- We ensure that they can only use the information for that specific purpose;
- We maintain a close relationship to make sure that your data is protected and your privacy maintained;
- We mandate that if or when the service stops, they must return or delete any information held.
Here are the examples of the types of trusted third parties we work with:
- Within the Talent Systems Group;
- Spotlight network partners who may, for example, circulate breakdown information via their casting platforms in other territories or provide the opportunity for Spotlight Members’ profiles to be made available on the partner’s own website;
- Subcontractors assisting us in providing our service to our users;
- IT companies who help us deliver our Platforms and services;
- Third parties who provide service enhancements or additional functionality to our users related to how they use our services;
- More information: In order to facilitate certain users of Spotlight with their workflow management processes or other functionality, Spotlight may from time to time provide or authorise the use of certain third-party software or applications to facilitate additional off-site access to the professional materials and content otherwise available via the Services. An example of this would be third party tools used by Agents to administer their client submissions to casting services alongside diary management etc, or software used by casting directors during the audition process. Such third-party packages or systems should only be used subject to the written approval of Spotlight. You acknowledge that your personal information may be used in this way. Please note however that Spotlight does not endorse and is therefore not responsible for any such third-party packages or systems, and Spotlight will not be liable for any loss of information, materials, data or otherwise that may occur due to the use of your information within them.
- Third parties who are involved in furthering research and technology in areas connected with our service;
- More information: We are constantly looking for new ways to change and upgrade our Services and functionality. This may involve partnering with selected and trusted research organisations and technology providers to contribute to their research and innovation projects. Often the most innovative developments come from other industries or fields of research outside of our own, and the outputs of the research may have a broader application beyond the improvements from which we directly benefit. As part of this research our trusted partners may be given access to our systems and data and/or be provided with copies of our data, including member photos, video and audio clips, and other professional information from their public profile. In all such circumstances our partners’ access to and use of this information will be comprehensively documented and strictly limited to specific research projects that may include benefits for Spotlight and our Services to you, and will be under secure, confidential, temporary conditions, and closed testing environments. Under no circumstances will this information be used for any commercial or live operational activity, other than to develop and test the specific technology and functionality, without your prior consent.
- Marketing and advertiser partners to improve and personalise our Platform and Services to you.
- Law enforcement in complying with the law, or to enforce our Terms and Conditions or to protect the rights, property, or safety of ourselves, our customers or other third parties.
- If we acquire any new business, and/or sell all or part of our business;
- Third party payment service providers; and
- Third parties as detailed within your specific Membership Terms.
How long do we keep your information?
We will not keep personal information for longer than it is necessary, and will only retain information for as long as needed to carry out our functions and that purpose. Personal information is retained in line with our retention schedule.
Where your information is processed
We will retain payment details briefly (the duration of time it takes to complete each transaction) whilst purchases are made through our online shop. Payment card details are not stored on our servers beyond this.
Our secure socket layer software (SSL) is the industry standard and among the best software available today for secure commerce transactions. It encrypts all personal information including credit card numbers, names and addresses. This encryption has the objective of ensuring that nothing can be read as it travels over the Internet to our chosen fully PCI DSS compliant payment service providers www.sagepay.com and https://worldpay.com/ for processing.
If you experience any payment problems when placing an order via our Platform, we advise you to resubmit your payment details. If your payment still fails, please contact your card issuer, to ensure there are no problems with your account, before contacting our customer services team.
Keeping your personal information up-to-date
Spotlight provides you with access to your personal information and tools to manage this. If you have provided us with personal information, it is your responsibility to ensure that it is correct and up to date. This will enable us to provide you with the best service possible. Please contact us as soon as possible if you believe that any information we are holding on you is incorrect or incomplete.
You have a number of rights in relation to your personal information that can be exercised by contacting the Data Protection Officer at firstname.lastname@example.org.
To make sure we protect you and your information, we will need to verify your identity for any requests we receive from you before we begin to process your request.
If you are based in the EU/EEA
If you are based in the European Union/European Economic Area, you can exercise your rights by contacting Spotlight’s EU data protection representative at email@example.com.
As a Parent or Guardian representing a child, you are a third party acting on behalf of your child and it is your responsibility to inform the child of their rights, and to act solely in your child’s best interests. Parents or guardians have the right to exercise the below rights on behalf of the child that they represent.
In respect of any third party acting on your behalf, we will request that they provide proof that they have your consent to represent you.
If we decide not to action your request we will explain our justification for refusal.
Rights available to you
There are circumstances in which your rights not apply but generally, you have the right to:
- Access your information – you can request access to or a copy of your personal information and check what information we hold about you.
- Change or correct your information – if you wish to have any errors corrected, you can request this – although this is not an absolute right and we may request for further information.
- Take your information – you can ask for a copy of your personal information to be provided in a reusable and machine-readable form.
- Object to, limit or restrict the use of your information – you can ask that we stop using parts or all of your personal information or limit its use if you believe that this personal information is unlawfully held.
- Direct marketing – you can ask that we stop using your personal information for direct marketing. This can be by managing your privacy settings within your account; by clicking on an ‘unsubscribe’ link in an email or writing to the Data Protection Officer.
- Delete your information – you can ask that your personal information is deleted if you believe it is no longer necessary for the purposes it was collected.
- Legitimate interest – if we are processing your information on the grounds of legitimate interest, you can ask us to stop this if there are reasons related to your individual circumstances. We have to do this unless we believe we still have an overriding legitimate reason.
If you are unhappy
If you are unsatisfied with our response to any data protection issues you raise with us, you have the right to complain to your supervisory authority, which within the UK is the Information Commissioner’s Office (ICO) who can be contacted by calling 0303 123 1113 or by visiting www.ico.org.uk.
If you are based in the European Union (EU) or European Economic Area (EEA) you may complain to Spotlight’s appointed lead European supervisory authority by contacting the Irish Data Protection Commissioner (DPC) by visiting this webpage (https://www.dataprotection.ie/en/contact/how-contact-us).
What is a cookie?
A cookie is a piece of information that is stored on your computer’s hard drive by your web browser. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Most web browsers allow control over these cookies through the browser settings. If you are a Spotlight Member, Agent or Spotlight Casting Subscriber some cookies are vital to your effective usage of our Services; we use these to identify Spotlight Members/Agents/Spotlight Casting Subscribers, manage secure logins and authentication status, remember website preferences and also to ensure secure renewals and payments can be made. Therefore if you choose to disable these cookies you will not be able to use the Spotlight website.
Third party cookies
Cookies from third parties including our Analytics and Advertising partners may also be used by us to help us understand how our visitors engage with our Platform and Services, to analyse how effective our Platform and Services are, or to ensure that our visitors and customers are provided with relevant product and service offerings. If you access our Platforms and Services through a mobile device, we might also collect additional information such as a unique device identifier and location information. When you use our Platform and Services, other parties such as third-party advertising partners and analytics providers may also collect information about your online activity.
To see a comprehensive list of the cookies used on the Spotlight Platform, and their purpose, please click here.
You can also see a full list of all third party cookies on your web browser by visiting Your Choices Online.
For more information about cookies, including if you have concerns, and to find out how to remove and disable them, visit http://www.allaboutcookies.org/.
How we use IP addresses
An IP address is a number which is automatically assigned to your computer whenever you access the internet. When you access the Spotlight Platform we will log your IP address. Third parties we work with such as our Payment Service Providers may also capture this information from you. We generally only use IP addresses to analyse trends, administer our Platform, track general user movements and gather broad demographic information for aggregate use, or where investigating possible criminal activity. However, we do link IP addresses to other information which could identify the user, for instance when assessing applications from new, re-joining and renewing members to ensure that they are provided with legal ‘cooling off periods’ where necessary. They will also be used to ascertain where members may be attempting to seek extended free periods on the Spotlight Platform by the misuse of our ‘cooling off periods’ or refund policy (see Terms & Conditions), or to identify potentially inappropriate or fraudulent membership applications. The IP information gathered for this purpose will only be used to ‘flag up’ possible misuse to Spotlight staff members.
More information and information in an accessible format