Privacy Policy


This policy will be continuously assessed against changes in regulation, business practices and our audiences’ needs so please check this page occasionally to ensure that you’re happy with any changes. 


Privacy Policy

Keeping your data safe

At Chocolate Films we are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think is important for you to know.

Who are we?

Chocolate Films is an independent video production company. `We use our profits to offer disadvantaged people the opportunity to engage with filmmaking. We are a social enterprise that regularly seeks grant funding to enable us to offer a range of filmmaking workshops to young people and vulnerable adults. At Chocolate Films we produce videos for clients and partner with organisations to make video content for broadcast, online, exhibition and for social media purposes and similar and other similar purposes. When engaging with people on our filmmaking workshops we enable participants to create their own content supported, trained and encouraged by our professional facilitators.

This policy applies to any personal information handled by Chocolate Films Commercial Production, Chocolate Films Workshops and Chocolate Films Ltd, collectively Chocolate Films. The websites produced and operated by us are, and

Who’s in control?

Chocolate Films asks for contributors and participants consent for all services we provide. When working with contributors and participants to produce films we ask for consent to be freely given, specific, informed and unambiguous. Each individual must provide “clear affirmative action” that they consent to the video content, materials being created for the specific purpose. Chocolate Films will expressly obtain active consent from an individual that the footage is to be used for each specific purpose. Further, at the time of obtaining consent, Chocolate Films will explain to individuals that they are able to withdraw consent at any time but also that this would not render processing on the basis of consent prior to withdrawal to be unlawful. Individuals must also be able to easily and freely withdraw consent at any time and use their right to be forgotten. If consent is withdrawn, Chocolate Films will be able to provide a legitimate interest statement for its own requirements for Chocolate Films led projects eg. 1000 Londoners. For all client-led projects, commissions and corporate work where Chocolate Films Workshops, Chocolate Films Commercial Productions and Chocolate Films is being paid to create a film for another party/client/ business we ask that clients offer a legitimate interest statement to Chocolate Films on request. In this respect, the legitimate interest is held by our client the onus will be on our client to offer transparency and action to participants and contributors associated with the films we make for this purpose. Clients will offer Chocolate Films an indemnity for this purpose.

Legitimate Interest for Businesses

When providing services to a client, Chocolate Films will ask that they require the necessary consent and offer all and every needed indemnity and protection to Chocolate Films in respect to all contributors, participants and subjects , in the instance where  consent is subsequently withdrawn from the individual.

The client/commissioner of Chocolate Films will have lawful ground for processing of a business having a “legitimate interest” in the video content even when individuals might withdraw their consent. Chocolate Films will rely on the onus for the legitimate interest to be solely with the business/ client/ commissioner that employs, instructs/partners with Chocolate Films. For all purposes aforementioned, Chocolate Films will have a legitimate interest in the video content created as they have been expressly commissioned to create this content for the business or client.

On commission of work, Chocolate Films will confirm that the business/client/commissioner commissioning Chocolate Films for any and all of its services have a “legitimate interest” in continuing to process personal data.

For Chocolate Films led productions, projects and work Chocolate Films, Chocolate Films Commercial Production and Chocolate Films Workshops for any and all of its services have a “legitimate interest” in continuing to process personal data where:

i) there is a real business interest being pursued in continuing to process the personal data;

ii) the processing is absolutely necessary in order for the business to pursue that interest (i.e. the interest cannot be pursued in another way which is proportionate); and

iii) the processing is balanced against the impact such processing will have on the fundamental rights and freedoms of data subjects.

Chocolate Films requires that under the GDPR, the commissioners/ business/ organisation commissioning the services and work of Chocolate Films show that they have considered the impact their control or processing will have on individuals, and that they have put preventative measures in place to limit such impact.

It is important that you understand who is responsible for keeping your data safe. We collect your personal data with your express consent for purposes set out in this Privacy Policy.

We have appointed a Data Protection Officer (DPO) who has ultimate responsibility within Chocolate Films for making sure your data is treated in accordance with this Privacy Policy and the law. Our DPO can be contacted by emailing

What data do we collect and where from?

We collect some data directly from you when you register for the Chocolate Films newsletter, become a participant on a Chocolate Films workshop, become a contributor on one of our client commissions or our flagship project 1000 Londoners . This data includes the following:

– Your full name;

– Your email address;

– Your Company/organisation/trading name

Landline and mobile numbers

– Mailing and billing addresses

– Social media handles

– Titles

– PA contact details (name, email, landline)

– Short biography

– Photos

– Testimonials

– Payment methods (encrypted)

– Forms and survey responses

– Fax

– Your date of birth; (if you choose to provide it)

– Your gender (if you choose to provide it);

– Your postcode and address (if you choose to provide them); 

– Your interests in filmmaking workshops

– Ethnicity and cultural background – grant funders often us us to collect this information for evaluation purposes (if you choose to provide it)

– Borough where you live (if you choose to provide it)

– School, college or university – grant funders often us us to collect this information for evaluation purpose(if you choose to provide it)

– Place of employment (if you choose to provide it)

– Whether you have a disability – we ask this for our workshop programmes and productions to we are able to ensure that we can offer the most appropriate workshop or method of filming to suit your needs (if you choose to provide it)

– Whether you have a mental health issue – we ask this for our workshop programmes and productions to we are able to ensure that we can offer the most appropriate workshop or method of filming to suit your needs (if you choose to provide it)

We collect information about how you use Chocolate Films website and social media and similar technology. This includes your viewing history, IP addresses, device identifiers and information about how long you have stayed on certain pages or what pages you have clicked on (Behavioural Data).

We collect information from you on your consent forms to be filmed or recorded on video, film and audio visual for the purposes of a specific project, film, production, programme, online content and also for a specific workshop, educational programme, seminar, course or masterclass where the production or creation of a video or film materials is part of the process.

We collect information about you when you participate in competition, such as your contact information. This data is only used for the purposes of the relevant competition and will be subject to the terms and conditions of that competition, which will be notified to you when you enter the competition.

We will collect personal information from job applications (such as, your CV, the application form itself, cover letter and interview notes and recordings).

We also collect anonymised publicly available information from social networking sites such as Facebook, Youtube, Instagram and Twitter and others similar, for example likes, shares, tweets and posts about Chocolate Films, Chocolate Films Commercial Production, Chocolate Films Workshops and 1000 Londoners. This information is provided to us by a third party and is fully anonymised so we cannot see who has posted the information. This information is used for internal analysis purposes.

Other means of processing information:

Social Media:

We collect publicly available information from Twitter, Youtube, Facebook, Instagram, Snapchat and LinkedIn profiles, when users  mention our Twitter handle/Facebook, Youtube, Instagram, Snapchat and LinkedIn address, comment on or retweet our posts. We collect posts, handles, names and follower count.

We process this information, under the lawful basis of Legitimate Interest – tracking engagement.

We will use this information to manage our Twitter,Youtube, Facebook, Instagram, Snapchat and LinkedIn profiles, asses impact and recognise potential collaborators and prospects.


We collect information from emails sent to our team members. We collect names, job titles and contact details of contacts that may qualify as leads or can contribute to our policy work.

For clarity and transparency we refer to Data as information on an individual and footage, photography, audio and/ or visual recordings with the individual featured directly and in the forefront in this Data.

What do we use your data for?

It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.

Providing you with our services

We use your Data to confirm that we have received express consent from you to be the subject in the video content we create.

We use your Data to to provide you with Chocolate Films services that you request from us.

We use your Data to contact you occasionally with messages about services you have that you may be interested in.

We use your Voluntary Data to enable us to respond to queries, or comments that you have and to make sure that these are appropriately dealt with. If Voluntary Data you provide includes any special categories of personal data (such as information about your health, race or religion), you must make sure before you provide this that you are happy for us to use that Voluntary Data for the purposes set out in this Privacy Policy.

Competitions and surveys

We use Competition Data for the purposes of allowing you to participate in competitions and to carry out any activities required in relation to those competitions, for example contacting you to let you know you have won a prize and using your address to send your prize to you.

We use Survey Data for the purposes of analysing insights and information to enable us to improve our services.

Improving our services

We use Data to help us monitor, analyse and improve Chocolate Films services. We use this data to help us understand  and make sure that we are providing you with the best possible services.

Marketing and advertising

We use Data for marketing and advertising purposes.


We use and combine all the data that we hold about you in order to build up a picture of you and the types of products and services which might be of interest to you (your Profile).

We use the data to:

– enable us to assess our performance and to improve our products and services

– inform our marketing and promotional activities;

– enable us to notify you within information about workshops, screenings and productions that might be of interest to you

– provide you with any prizes you have won if you enter any prize draws.


Chocolate Films captures footage and expressly asks its clients, commissioners whether they need us to store this footage and archive it for future client specific purposes. At Chocolate Films we understand how valuable your footage can be, not just for this project but also for future projects. We therefore archive all of our projects and footage using a long-term data storage system. Many organisations store footage on hard drives, which are liable to fail after 3-5 year. We archive projects on a LT07 system is far more reliable, and will safely store footage for 15-30 years. However please note, we cannot guarantee your footage, so if you’d like to keep a back-up, please do send over a hard drive. Unless otherwise instructed by our clients, we archive projects on LT07 data tapes, which have an estimated life-span of between 15 and 30 years. We will work with our partners and clients to comply with their own specific GDPR policies and will observe these in order to remain consistent with their obligations to individuals.

We keep consent forms on file as evidence of receipt of active consent from all participants and contributors. These are kept during the course of the project that they relate to and for up to two years after this time, depending on whether they are still relevant to showing that Chocolate Films have asked for active consent.

We archive all release forms to use for a social enterprise impact reports and evaluation for workshop programmes, projects and educational learning purposes. We will delete or anonymise your data held in the archive where we consider it is no longer of value or interest.

How do we use your data for marketing and advertising purposes?

At Chocolate Films, our services are entirely funded by commissions from clients. Marketing and advertising are therefore key parts of our activities. This section sets out the various different types of marketing and advertising that we carry out and how your data is used for each type of activity.

Email marketing

We will use your email address to send you email marketing (including our newsletter, information about services, events and screenings) where you have signed up to receive this from us.

You can opt out of receiving marketing emails at any time by either following the instructions to unsubscribe in any of our email marketing communications or by changing your preferences. It may take up to 48 hours for your change in preference to take effect and the change will not affect any marketing emails which have already been scheduled to be sent in the future.

If you opt out of email marketing, we will still need to send you service communications by email from time to time, such as information about changes to our services.

Personalised advertising

We sometimes use your name or the name of your organisation to personalise advertisements. This means that you may hear your first name in an audio/video advertisement or see your name in a text advertisement.

If you have opted out of targeted advertising the advertisements you see will not be tailored to you, but they may still be personalised with your name.

You can opt out of personalised advertising at any time by changing your preferences . It can take up to 72 hours for the change to take effect. Some advertising campaigns are also set up to run for a particular time and we are unable to change these settings once they are set up.

If you opt out of personalised advertisements without opting out of targeted advertising, you will still see targeted advertisements from Chocolate FIlms but they will not be personalised with your name.

Promoting our own services on other platforms

We also promote our own content and features via third party platforms, such as social media sites.

Our content might appear on third party sites based solely on your behaviours on these sites (for example, after liking our brand or its content on Facebook), or the behaviours of those within your networks (for example, a friend within your Facebook network likes our brand or its content on Facebook, so it appears in your News Feed). These branded messages are controlled by the third party site, but you may be able to update your preferences to stop these messages appearing in future (for example, you can

Third party service providers

We use third party processors to collect, export, process and store personal data on our behalf. All our processors are compliant with the General Data Protection Regulations and you can view their websites for further detail:

Basecamp and Highrise (Basecamp – Illinois, US)

– Google LLC (California, US)

Mailchimp (The Rocket Science Group LLC, Georgia, US)

Hootsuite (Vancouver, Canada)

Xero (Wellington, New Zealand)

HubSpot (Massachusetts, US)

Cascadego (Leeds, UK)

Frame io (New York, US)

What is our legal basis for using your data?

Data protection law says that we have to tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.

With the exception of email marketing, we process your personal data for all of the purposes identified under and above on the basis that it is in our legitimate interests, or the legitimate interests of third parties with whom we share your data, to carry out these activities. Further information about what those interests are is set out below.

Chocolate Films Purpose:

We are providing you with our video services

– We are producing video content for your organisation

– We are engaging all communities in filmmaking skills

– We re training young people and disadvantaged adults in media skills and offering practical training and facilitation to empower and inspire people through film.

Legitimate interests: To ensure that Chocolate Films complies with the law and its policies of consent, to ensure we can create films and videos for our clients and devise and deliver workshops for participants and organisations and to help us deliver our remit to provide the best video content and filmmaking workshops to clients and participants .

Purpose: Improving our services

Legitimate interests: To make sure that we continue to improve our service and provide our clients and participants with the best and most effective service possible.

Purpose: Advertising

Legitimate interests: To provide advertising that is relevant to you to ensure that you have the best experience possible of using Chocolate Films, as well as to generate more commissions for Chocolate Films so that we can growth and expand this independent production company and as a social enterprise offer more workshops and engage with more young people and vulnerable adults in filmmaking skills.

Purpose: Profiling

Legitimate interests: To provide a customised experience of Chocolate Films to ensure you have the best experience possible of using our services as well as to generate more commissions which in turn allows us to put more back into the filmmaking workshops we offer to young people and vulnerable adults for free.

You have the right to object to us processing your personal data for the purposes set out above. Unless we can show that we have a compelling legitimate reason to continue processing your personal data, we will stop processing it.

In respect of the use of your email address for email marketing purposes, we process this on the basis that we have your consent to do so. You can withdraw your consent at any time by following the instructions to “unsubscribe” in any email marketing communications.

Freedom of information

We are required under the Freedom of Information Act 2000 to provide certain information in response to Freedom of Information requests. In order to respond to requests, we will need to collect your name, address, email address, phone number and information about your request, including any additional personal data you choose to share with us when you make your request. We will use this personal data to respond to your request and will retain it for administrative purposes in line with the section headed below.

For more information about Freedom of Information, please see here.

How long do we keep your data for?

We will keep all your personal data for retained for a period of two years from submission, after which it is anonymised. You can close your subscription to our newsletter and remove your consent to be in one of our films at any time. If you do this, we will anonymise all your Account Data as soon as we can after you have closed your account. All other information about you, such as Behavioural Data, will also be fully anonymised.

We may need to keep your data after account closure for limited purposes, for example if we need your data in order to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need to in order to fulfil those purposes.

We keep information relating to any service errors or interruptions you have experienced for between 15-30 days.

Any Voluntary Data you submit will be retained for a period of two years from submission, after which it is anonymised. Once anonymised, we will destroy all paper copies of your data.

Data retention

We will retain some personal data categories in order to comply with legal requirements. Otherwise, we will remove information that is not required for our processes.

What rights do you have?

You have a number of rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.

We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to two months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.

A right to access your information

You can access all of your Data by emailing

You also have a right to ask us to send you a copy of your Data and all other personal data that we hold about you (subject to some exceptions). A request to exercise this right is called a “subject access request” and must be made in writing to:

A right to object to us processing your information

You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing. This includes all of your personal data that we process for all of the purposes set out in this Privacy Policy, with the exception of our use of your email address to send you marketing communications with your consent (but you can withdraw your consent to this at any time). Chocolate Films will keep a log book of any complaints or breaches of data.

If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.

You can exercise this right by emailing

Remember that you can always delete your account to receive our newsletter at any time.

A right to ask us not to market to you

You can ask us not to send you direct marketing or advertising. You can do this by opting out of the advertising you no longer want to receive. In relation to email marketing, you can also opt out by using the “unsubscribe” option in any of our email marketing communications.

Please note that it can take a short time for opt-out requests to take effect. The time taken to opt out of each type of marketing and advertising is detailed at above.

More information about opting out of marketing and advertising is provided at above.

A right to have inaccurate data corrected

You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.

You can update your own personal data at any time.

A right to have your data erased

You have a right to ask us to delete your personal data in certain circumstances, for example if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy.

We will fully anonymise any personal data we hold about you when you close your account, as set out under above. This means that it will no longer identify you and ceases to be “personal data”.

If you ask us to delete your personal data we will fully anonymise your personal data as set out above.

If you would like to make a request to exercise this right, please email If we are required by law to comply with your request, we will fully anonymise your data it so that it is no longer personal data and cannot be used to identify you.

A right to have processing of your data restricted

You can ask us to restrict processing of your personal data in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights.

Restricting your personal data means that we only store your personal data and don’t carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.

How can you contact us?

If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can get in touch with our Data Protection Officer using:


What if you have a complaint?

You have a right to complain to the Information Commissioner’s Officer (ICO), which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data. Chocolate Films will keep a log book of any complaints or breaches of data

What if this policy changes?

We may make changes to this Privacy Policy from time to time. Any changes we make will be posted on this page.

Aged 16 or under

We collect and process information in a number of areas to promote the welfare of our participants on our workshop and education programmes and creative engagement projects, we endeavour to help every participant fulfil her potential and manage our workshops and education programmes and projects effectively. We use personal data:

– To safeguard and promote the welfare of our participants

– To support our participants’ learning and help every participant fulfil their potential during the workshop or course we offer

– To support participants with Special Educational Needs or Disability (SEND) on our workshops and programmes

– To communicate with our network of Chocolate Films alumnae ( participants that have been on our workshops)

– To manage our workshops and engagement programmes effectively

– For the employment and management of our staff

– For development and fundraising for Chocolate Films Workshops as a social enterprise

Please note that you need to be 18 or over to receive services from Chocolate Films. As we regularly engage and work with young people that are under 18 we ask for parents/ guardians to provide consent for their dependents to receive workshops, courses, training and mentoring workshops and classes from us. In these cases, if you are aged 16 or under, please speak to your parent/guardian to get their permission before you provide any personal information to Chocolate Films because without this consent, you are not allowed to provide us with personal information. We may also ask for your parent/guardian’s contact details so that we can check they are happy for you to engage with Chocolate Films.

Parents provide information about themselves and their dependent when completing our release forms in order for their dependent to be involved with our workshops, as well as related documents such as registration forms and health record forms. Personal information is also collected directly from participants and parents by direct means such as meetings, discussions, through schools, colleges, community groups and other organisations and in general correspondence.

Whilst we collect most of our personal information from participants and parents directly, in some cases personal data may be supplied to us by third parties, for example another school, a local authority, or other professionals.

If we have been commissioned by a school, college or community group, we will ask for them to provide us with all consents for participants to be involved in our workshops and productions. The onus of responsibility will be on our client to provide these to us before we are able to commence our services.

We keep consent forms on file as evidence of receipt of active consent from all participants and contributors. These are kept during the course of the project that they relate to and for up to two years after this time, depending on whether they are still relevant to showing that Chocolate Films have asked for active consent.

Does Chocolate Films privacy policy apply to third party websites or social networking sites?

This policy only applies to our use of your information via Chocolate Films only. Therefore, it does not apply to third party websites to which Chocolate Films or might provide links or on which Chocolate Films content is embedded.

Equally, it is important to note that when you access Chocolate Films via a social networking site, such as Facebook or Twitter, that site may also collect and use your information. So, we would advise you to check the privacy policies for those social networking sites and applications to see how your information is being used.

Security Measures

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Unfortunately, the sending of information via the internet is not completely secure. Although we will do our utmost to protect your information, we cannot guarantee the security of your data sent to the digital products and services within Chocolate Films; any sending of information is therefore at your own risk.

How do I contact Chocolate Films if have a question about privacy issues?

If you have any questions or concerns about privacy issues, you can use the form on our ‘Contact us’ page on

Access to your information

If you would like to know what personal information Chocolate Films holds about you, you may make a request to Chocolate Films for copies of this information. You should be aware that we will need to see proof of identity before processing any such request (known as a ‘subject access request’) and may charge an administration fee of up to £10 to cover our costs in providing you with this information.

All subject access requests should be made in writing and addressed to Chocolate Films, Battersea Studios, 80-82 Silverthorne Road, Battersea SW8 3HE.

Changes to this policy

Our privacy policy may change from time to time. Any changes we may make to our privacy policy in the future will be posted on this page, and, where appropriate, notified to you by email.

Policy updated on 25 May 2018

What is this privacy policy for?

Chocolate Films is committed to protecting your personal information, being transparent about what data we hold and giving you control over how we use it.

The purpose of this privacy policy is to give you a clear explanation about how Chocolate Films uses personal and behavioural information we collect from you when you use our services.

This is the main privacy policy for Chocolate Films.