HT Global Ltd General Data Protection Regulation
Privacy Policy, May 2018 This policy details the nature of personal data stored by the above named company in relation to affiliates, musicians, performers and sub contractors (or ancillary contracted staff i.e. technical production companies) who we employ in the capacity of booking agent, and to our company employees. For the purposes of this document we will refer to the former category, i.e. personnel booked by us for performances on a freelance/ad hoc basis, as ‘performers’. Our legal justification under Article 6 of the GDPR for collecting this data is Legitimate Interests. Processing of this data is necessary in our capacity as a bookings agent to secure and administrate paid bookings on our performers’ behalf. We process this data in ways that our performers would reasonably expect, as detailed below, and which we believe to have a minimal privacy impact on them. It is in both our performers’ and our own commercial interests to collect and process this data. Data is obtained directly from our performers on request as and when it is needed, and is stored on our secure internal cloud based file share systems to facilitate future bookings requiring the same information. For this reason we do not intend to obtain individual written Consent to retain personal data already held on our system or to retain newly obtained data from this point onwards.
If at any stage any person for whom we hold personal data records has any questions or concerns regarding our methods or reasons for holding this data, we would encourage them to contact HT Global Ltd Data Protection Officer, Heshima Thompson at Heshima@htgentertainment.co.uk
What personal information do we collect and store? Why is it being collected?
Below is a breakdown of performers’ and employees’ personal data categories collected by HT Global Ltd, and our reasons for collecting and storing this information.
­ Contact details, i.e. mobile phone numbers and email addresses: held for the purpose of contacting performers regarding arrangements for professional engagements.
­ Passport scans: held for the purpose of booking flights (or other international travel) for professional engagements.
­ Home addresses as included on performers’ invoices: HMRC requires us to store our last 10 years of invoices for our tax records.
­ Bank account details as included on performers’ invoices: HMRC requires us to store our last 10 years of invoices for our tax records. Bank details are also saved on our Barclays online banking system in order to process payments.
­ Car registration numbers, makes and models: held for the purpose of arranging parking or access to site for performances.
­ Dietary requirements: held for the purpose of ensuring performers are properly catered for on performances.

Who is collecting this information?
This information is being collected by employees HT Global Ltd under the supervision of Heshima Thompson, Data Protection Officer.
How is this data being collected?
Data is collected directly from the person to whom the data relates via email or occasionally via telephone, on request. For acts where we communicate with a designated band leader or coordinator, that person will collect and pass on their band members’ personal data to us via email or shared Google documents.
How will this data be used?
We will use performers’ contact details to communicate with them regarding professional engagements.
We will use performers’ passport scans to arrange flight/(other international transport) bookings for overseas performances. Passport details are usually required by airlines to complete these bookings.
We will use performers’ car registration details to arrange on site access or parking for performances that require driving.
We will use performers’ dietary requirements to ensure they are suitably catered for on performances.
We will use performers’ bank account details to process payments. Home addresses are a required component of purchase invoices under HMRC guidelines.
Who will this data be shared with?
For the purposes of this document, the term ‘client’ is used to refer to an individual or entity with which HT Global Ltd. has entered or is in the process of entering into an agreement to provide musical entertainment services. Our client contracts are being updated to protect our performers’ privacy, to include a clause stipulating that in cases where their personal data is shared with our client this must be treated as strictly confidential, must be deleted immediately upon completion of the contracted engagement, and may not be shared with any third parties.
HT Global Ltd clients typically fall into (but are not limited to) the following categories: wedding/event planners; corporate event bookers; private individuals organising events.
Your bank account details and home address will only be accessible to HT Global Ltd employees, including our accredited accountant, and will not be shared with our clients or third parties.
Your invoices will be shared with HMRC (via our accountant) for tax purposes.
Your passport details may be shared on an individual basis with clients or travel agents in cases where flight/(transport) bookings are being arranged directly by that client or agency.
Your car registration details and dietary requirements will be shared with clients in order for them to implement necessary arrangements on your behalf.

Your contact details (phone numbers and email addresses) may occasionally be shared with clients in circumstances where that client requires a point of contact for a performance and no HT Global Ltd representative is in attendance; you will be informed if you have been designated as the client’s point of contact for a given performance. On occasion HT Global Ltd employees may be in a position to recommend you to third parties for paid work; where we believe such opportunities to be genuine and the third party is known to us, we may share your contact details with such a person in your own legitimate interests unless you specifically request otherwise. On occasion we may deem it suitable to put performers directly in touch with each other to facilitate arrangements for performances (e.g. arranging lift shares). Should you wish for HT Global Ltd to keep your contact details restricted to use by our employees and that they not be shared with clients or third parties, please inform us and we will make a note on your contact record.
How is this data stored?
This data is stored across 2 emailing platforms:
Hotmail and Gmail/(Google docs), are our emailing platforms. In cases where data has been shared with us via email, i.e. passport scans sent to us as attachments, that data will remain in our Gmail accounts unless/until deleted on request. Each employee’s Gmail account is accessible via individual logins known only to that employee and to the HT Global Data Protection Officer (Heshima Thompson). As an added layer of security for our email accounts to control sign ins on unknown devices we use two factor authentication. Personal data such as passport details are also occasionally shared with us via Google Docs/Spreadsheet/Drive, which are subject to the same logins and security measures as Gmail.
How long will this data be stored? The only data type listed above which is subject to expiry is passport details, which will be deleted from our system either on expiry or when we are notified that a passport has been updated/replaced – whichever happens first. All other data types will be stored for as long as there is a possibility of future bookings being offered to that performer, unless that performer requests their data to be updated/removed. We commit to immediately update or delete any incorrect or out of date records relating to any of the above categories if a performer advises us that their data has changed or is inaccurate. HT Global Ltd formally recognise the existence of each of data subject’s rights, including the right to request the updating or removal of data records at anytime, where relevant, and the right to lodge a complaint with a supervisory authority.
Right to be forgotten: An individual may request that an organisation delete all data on that individual without undue delay.
Right to object: An individual may prohibit certain data uses.
Right to rectification: Individuals may request that incomplete data be completed or that incorrect data be corrected.