Rap Club Productions C.I.C & The Spit Game UK Privacy Policy

Last updated: 22 July 2026

1. Who we arE

Rap Club Productions C.I.C., trading as The Spit Game UK, is a community interest company registered in England and Wales under company number 11904686.

In this Privacy Policy, “we”, “us” and “our” refer to Rap Club Productions C.I.C. and The Spit Game UK.

We are the data controller responsible for deciding how and why personal information is used.

Address:
706 Bale House
Connington Road
Lewisham
London
SE13 7GX

Email: info@thespitgameuk.com

Website:https://www.thespitgameuk.com

2. Who this Privacy Policy applies to

This Privacy Policy applies to personal information relating to:

• young people participating in our programmes, projects and events;

• parents, guardians and emergency contacts;

• people applying for or taking part in casting, auditions, films, music, digital content and other creative productions;

• artists and clients receiving management or professional-development services;

• actors, contributors, crew members, freelancers, employees and volunteers;

• schools, youth organisations, funders, commissioners, partners and professional contacts;

• people who contact us, submit material or visit our website; and

• people whose image, voice, performance or creative work is recorded or used by us.

3. Personal information we may collect

Depending on your relationship with us, we may collect:

Identity and contact information

This may include:

• your name;

• address;

• email address;

• telephone number;

• date of birth or age;

• pronouns;

• professional or stage name;

• parent or guardian details;

• agent or representative details; and

• emergency-contact information.

Programme and participation information

This may include:

• the school, youth organisation or programme you attend;

• attendance and engagement records;

• permissions and consent information;

• interests, skills, goals and creative work;

• feedback, evaluation responses and outcomes;

• support, access or participation requirements; and

• information needed to plan activities safely.

Casting and production information

This may include:

• applications, self-tapes, auditions, photographs, showreels and CVs;

• casting notes and decisions;

• scripts, performances and rehearsals;

• availability and scheduling information;

• contracts, releases and permissions;

• production stills and behind-the-scenes material;

• audio and audiovisual recordings;

• credits, biographies and publicity information;

• call sheets, risk assessments and production records; and

• details of an agent, parent, guardian or chaperone.

Financial and contractual information

This may include:

• fees, invoices and payment records;

• bank or payment details;

• tax or National Insurance information where required;

• contractual terms;

• expenses and receipts; and

• records needed for accounting, audit, insurance or funding purposes.

Health, access and safeguarding information

Where necessary, we may collect limited information relating to:

• health conditions;

• disabilities or access requirements;

• allergies or medication relevant to safe participation;

• injuries or incidents;

• emotional or welfare support;

• safeguarding concerns;

• risk assessments;

• child-performance licences and chaperone arrangements; and

• criminal-record or DBS information where legally permitted and relevant to a role.

We only collect sensitive information where it is relevant and proportionate to the activity, support or legal responsibility involved.

Website and communications information

This may include:

• messages and correspondence;

• enquiry and submission information;

• IP address, device and browser information;

• website usage and technical information;

• cookie preferences; and

• interactions with our email, website and social-media content.

4. How we obtain personal information

We may receive personal information:

• directly from you;

• from your parent, guardian, agent or representative;

• through casting forms, auditions, applications, contracts or releases;

• from schools, youth organisations or referral partners;

• from funders, commissioners or project partners;

• from casting platforms and professional networks;

• from staff members, freelancers or safeguarding professionals;

• from publicly available professional sources; and

• through our website, email and social-media platforms.

Where information is provided to us by another organisation, that organisation is responsible for ensuring it has a lawful basis for sharing it with us.

5. How and why we use personal information

We use personal information only where we have a valid reason under data-protection law.

Enquiries, applications and casting

We use information to:

• respond to enquiries;

• assess applications and submissions;

• arrange auditions and meetings;

• make casting, recruitment or participation decisions;

• communicate outcomes; and

• take steps requested before entering into an agreement.

Our lawful bases are generally:

• taking steps before entering into a contract;

• performing a contract; and

• our legitimate interests in selecting suitable participants, performers, workers and collaborators.

Programmes, youth work and events

We use information to:

• enrol and support participants;

• plan and deliver sessions, events and opportunities;

• communicate with participants, parents, guardians and partner organisations;

• manage attendance, access and wellbeing;

• evaluate our work;

• meet funding and reporting requirements; and

• protect participants, staff and the public.

Our lawful bases are generally:

• performing a contract or arrangement;

• complying with legal obligations;

• our legitimate interests in delivering and improving our charitable and community activities; and

• consent where it is specifically required and appropriate.

Film, music and digital productions

We use information to:

• develop, produce, edit, distribute and promote creative work;

• record performances and contributions;

• manage cast, crew, contributors and schedules;

• provide credits;

• create promotional and behind-the-scenes material;

• submit work to festivals, broadcasters, distributors and platforms;

• maintain evidence of permissions, releases and ownership; and

• protect and enforce our legal and creative rights.

Our lawful bases are generally:

• performing a contract;

• our legitimate interests in creating, distributing, promoting and preserving our work;

• compliance with legal obligations; and

• consent where no other appropriate basis applies.

Where an agreement, release or contract grants us rights to record or use a performance, image, voice or creative contribution, those rights are governed by that agreement. Withdrawing data-protection consent does not automatically cancel rights granted under a separate contract or release.

Management and professional opportunities

Where we provide management, representation or professional-development support, we may use personal information to:

• identify and apply for opportunities;

• communicate with casting directors, production companies, labels, venues and other industry professionals;

• negotiate and administer professional arrangements;

• promote an artist’s work and skills; and

• manage payments, commissions and contractual obligations.

Our lawful bases are generally:

• performing a contract;

• taking steps before entering into a contract;

• complying with legal obligations; and

• our legitimate interests in delivering effective management and professional support.

Payments, accounting and administration

We use information to:

• make and receive payments;

• process invoices and expenses;

• maintain accounting and tax records;

• meet audit and funding requirements;

• administer insurance; and

• establish, exercise or defend legal rights.

Our lawful bases are generally:

• performing a contract;

• complying with legal obligations; and

• our legitimate interests in managing our organisation responsibly.

Safeguarding, welfare and safety

We may use or share information where necessary to:

• protect a child, young person or adult at risk;

• assess or respond to a safeguarding concern;

• manage health and safety risks;

• investigate an incident or complaint;

• obtain urgent support;

• comply with child-performance, employment or safeguarding requirements; or

• report concerns to an appropriate authority.

Depending on the circumstances, our lawful bases may include:

• compliance with a legal obligation;

• our legitimate interests in safeguarding people and preventing harm;

• recognised safeguarding interests;

• protection of someone’s vital interests; and

• the establishment, exercise or defence of legal claims.

We do not normally rely on consent where information must be used or shared to protect someone from serious harm. Data-protection law does not prevent necessary and proportionate safeguarding information from being shared.

Monitoring, evaluation and funder reporting

We use information to:

• understand who participates in our work;

• assess programme quality, reach and impact;

• improve our activities;

• report to funders and commissioners; and

• conduct research and evaluation.

Where reasonably possible, reporting information is aggregated or anonymised.

Our lawful bases are generally:

• our legitimate interests in evaluating and improving our work;

• contractual requirements connected to funding or commissioning; and

• consent where identifiable case studies, testimonials or optional research require it.

Communications and promotion

We may use contact information to:

• send information connected to an existing project, contract or programme;

• share relevant opportunities;

• invite people to events;

• publish agreed credits, biographies or promotional content; and

• send newsletters or marketing communications where permission has been given or another lawful basis applies.

You can unsubscribe from optional marketing communications at any time.

6. Sensitive or special-category information

Some information receives additional protection under data-protection law. This includes information about:

• health or disability;

• racial or ethnic origin;

• religion or beliefs;

• political opinions;

• trade-union membership;

• sexual orientation or sex life;

• genetic information; and

• biometric information used to identify someone.

Where we use this information, we must have both an ordinary lawful basis and an additional legal condition.

Depending on the circumstances, we may rely on:

• explicit consent;

• employment, social-security or social-protection law;

• vital interests;

• the establishment, exercise or defence of legal claims;

• substantial public interest, including safeguarding children and individuals at risk; or

• another condition permitted by the Data Protection Act 2018.

Health or access information voluntarily provided to help us make adjustments or support participation will usually be processed with the person’s explicit consent unless another lawful condition is more appropriate.

7. Criminal-offence and DBS information

We only process criminal-offence or DBS information where it is necessary, proportionate and legally permitted.

This may be required when assessing whether a person is suitable to work with children or adults at risk, managing safeguarding responsibilities or complying with legal or contractual requirements.

Access to this information is restricted, and it is retained only for as long as necessary under applicable requirements and our retention procedures.

8. Children and young people

Much of our work involves children and young people. We take particular care when handling their information.

We aim to:

• collect only the information genuinely needed;

• explain how information will be used in accessible language;

• consider the child or young person’s age, understanding and best interests;

• involve a parent or guardian where appropriate or legally required;

• restrict access to sensitive information;

• share information only where there is a clear and proportionate reason; and

• respect the child or young person’s own views wherever possible.

Data-protection rights belong to the child or young person, although a parent or guardian may sometimes exercise those rights on their behalf where appropriate.

We may use or share information without parental or participant consent where this is necessary to protect someone from harm, meet a legal obligation or respond to a safeguarding concern.

9. Who we may share information with

We do not sell personal information.

Where necessary and lawful, we may share information with:

• our employees, freelancers, volunteers and authorised project workers;

• parents, guardians, agents and professional representatives;

• schools, colleges, youth organisations and referral partners;

• funders, commissioners, evaluators and auditors;

• production companies, co-producers and production partners;

• casting directors, agents, labels and other industry professionals;

• venues, festivals, cinemas, broadcasters, distributors and streaming or social-media platforms;

• chaperones, licence authorities and local authorities;

• accountants, payroll providers, insurers, legal advisers and professional consultants;

• website, email, cloud-storage, communications and information-technology providers;

• regulators, courts, law-enforcement bodies and government authorities; and

• safeguarding services, social care, medical services or emergency services.

We share only the information reasonably necessary for the relevant purpose.

Funders and commissioners will ordinarily receive anonymised or aggregated information unless identifiable information is genuinely required and there is a lawful basis for providing it.

When creative content is distributed publicly through cinemas, festivals, broadcasters, websites, social-media platforms or streaming services, those organisations may process information under their own privacy policies.

10. International transfers

Some of our service providers, production partners, platforms or professional contacts may process personal information outside the United Kingdom.

Where personal information is transferred internationally, we take reasonable steps to ensure that the transfer is lawful. This may include relying on:

• UK adequacy regulations;

• approved contractual safeguards, such as the UK International Data Transfer Agreement or UK Addendum; or

• another lawful transfer mechanism or exception.

You may contact us for further information about safeguards applying to a particular transfer.

11. How long we keep personal information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including legal, safeguarding, funding, contractual, insurance, accounting and rights-management requirements.

Our usual retention approach is:

General enquiries and correspondence

Normally retained for up to 12 months after the last meaningful contact, unless the information becomes part of an ongoing project, contract, complaint or legal matter.

Unsuccessful casting, recruitment and programme applications

Normally retained for up to 12 months after the relevant decision, unless:

• a shorter period is appropriate;

• the applicant asks us to delete it sooner and no lawful reason requires retention; or

• the applicant agrees that we may retain it for consideration for future opportunities.

Participant and programme records

Normally retained for up to six years after the programme or funding relationship ends, where needed for evaluation, funding, audit, insurance, complaints or legal accountability.

Information that is no longer needed in identifiable form may be deleted or anonymised earlier.

Contracts, releases and rights-management records

Contracts, contributor agreements, releases, licences, permissions and related evidence may be retained for as long as reasonably necessary to:

• demonstrate ownership or permission;

• distribute or preserve a production;

• respond to claims;

• enforce contractual rights; and

• protect the integrity of our creative archive.

This may extend for the duration of the relevant intellectual-property or performer’s rights and any applicable legal limitation period.

Financial and accounting records

Normally retained for at least six years after the end of the relevant financial year, or longer where legally required, connected to an investigation or necessary for an outstanding matter.

Staff, freelancer and volunteer records

Normally retained for up to six years after the working relationship ends, subject to shorter or longer periods for particular records.

Unsuccessful recruitment records are normally retained for up to six months, unless there is a legitimate reason or agreement to retain them longer.

Health and access information

Normally retained only for the relevant programme, engagement or production and a reasonable period afterwards.

It may be retained longer where it relates to an accident, safeguarding matter, legal claim, insurance requirement or continuing support need.

Safeguarding and incident records

Safeguarding records may need to be kept for a significantly longer period after someone’s participation ends.

The period depends on:

• the age of the individual;

• the nature and seriousness of the concern;

• whether another organisation is responsible for retaining the principal record;

• possible legal or regulatory action;

• insurance requirements; and

• applicable safeguarding and records-management guidance.

These records are securely restricted and reviewed in accordance with our safeguarding retention procedures.

Published creative work and organisational archives

Completed films, recordings, photographs, credits, promotional material and other published creative work may be retained for as long as the production, publication or archive continues to be used or held for legitimate creative, historical, evidential or rights-management purposes.

Removing personal information from our internal systems may not remove material already lawfully published, distributed or copied by third parties.

Website information

Cookie and analytics information is retained for the periods identified by the relevant cookie settings and service providers.

At the end of the relevant retention period, information is securely deleted, destroyed or anonymised unless continued retention is justified.

12. How we protect personal information

We use appropriate technical and organisational measures designed to protect personal information.

These may include:

• access controls;

• password-protected and secure cloud systems;

• limiting sensitive information to people who genuinely need it;

• confidentiality requirements;

• secure sharing methods;

• staff and freelancer guidance;

• backups and system-security measures; and

• procedures for responding to suspected data breaches.

No storage or communication system can be guaranteed to be completely secure, but we take proportionate steps based on the nature and sensitivity of the information involved.

13. Automated decision-making

We do not ordinarily make decisions about individuals solely through automated processing where those decisions produce legal or similarly significant effects.

Casting, participation, safeguarding and employment decisions involve human consideration.

14. Cookies and website information

Our website uses cookies and similar technologies.

Essential cookies may be used where necessary for the website to function, remain secure and remember basic preferences.

Where required by law, we will ask for consent before placing non-essential analytics, advertising or similar cookies.

You can manage cookies through our website cookie controls and your browser settings. Blocking some cookies may affect how the website functions.

15. Your data-protection rights

Depending on the circumstances and the lawful basis used, you may have the right to:

• ask for access to your personal information;

• ask us to correct inaccurate or incomplete information;

• ask us to delete information in certain circumstances;

• ask us to restrict how information is used;

• object to particular uses of your information;

• receive information you provided in a portable format in certain circumstances;

• withdraw consent where consent is the basis for processing; and

• complain about how your information has been handled.

These rights are not absolute. For example, we may need to retain information to meet legal, safeguarding, accounting or contractual obligations, establish or defend legal claims or demonstrate rights in a production.

Withdrawing consent does not affect processing already carried out lawfully before withdrawal. It also does not prevent processing based on another lawful basis or automatically cancel rights granted under a separate contract or release.

We will not normally charge for responding to a rights request. We aim to respond within one month, although data-protection law allows additional time in some complex circumstances.

To exercise your rights, contact:

Email: info@thespitgameuk.com

We may need to verify your identity before acting on a request.

Your right to object

You may object where we process personal information based on legitimate interests.

You also have an absolute right to object to the use of your personal information for direct marketing.

To object, email info@thespitgameuk.com and explain which use of your information concerns you.

16. Complaints

Please contact us first if you have concerns about how we use personal information:

Email: info@thespitgameuk.com

Address:
Rap Club Productions C.I.C.
706 Bale House
Connington Road
Lewisham
London
SE13 7GX

You also have the right to complain to the Information Commissioner’s Office.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website:https://www.ico.org.uk

17. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our activities, systems, legal obligations or guidance.

The latest version will be published on our website with its revision date.

Where a change materially affects how we use information already collected, we will take reasonable steps to bring that change to the attention of the people affected.