Comuniqé Policies

Comuniqé embraces equal employment opportunity (EEO) and inclusiveness and maintains a model work environment that is free of discrimination. No employee, former employee, or applicant for employment at Comuniqé will be denied equal opportunity because of race, color, sex, national origin, religion, age, disability, pregnancy, sexual orientation, gender identity, genetic information, retaliation, or any other non-merit-based factor. This not only is the law; it is an essential component of the Comuniqe mission for a work place built on humanity, humility and honesty.

Comuniqé will:

● only undertake work for which it has been adequately funded;
● produce a written health and safety policy statement, including an organization section detailing who is responsible for what, and an arrangements section, including the procedures for risk assessment and monitoring 
● clearly identify who has control of the premises, location and facilities;
● use only competent staff, freelances and contractors 
● ensure that contractors and freelances are formally appointed and that company standards are clearly communicated to them (eg terms of trades, contractor rules, health and safety procedures);
● identify any additional training needs of staff and freelances and ensure these are met before production; 
● ensure that contractors are provided with adequate information about the planned production activity so that they in turn can establish safe systems of work based on risk assessment (they may need to be invited along to any recces and production meetings as required);
● ensure that specialist advice is taken and implemented where necessary;
● ensure that a full risk assessment is undertaken for all activities under the control of the production, the appropriate controls are implemented for all risks and the significant findings of the assessment are recorded; 

Comuniqé recognizes our responsibility to: 

● ensure appropriate exchange of information regarding risk assessments between production and all affected parties (this might include local authorities, police or residents);
● ensure adequate co-ordination and communication between the various parties involved in the production;
● ensure that work begins only when adequate preparations have been made, including full assessment of all risks, selection of competent contractors and other production crew, clear assignment of responsibilities;
● ensure that all work throughout the life of a production is undertaken safely, in line with any company standards and/or the standards established by risk assessments (including those from contractors);
● ensure that staff and freelance employees are adequately informed and supervised throughout the production;
● report all accidents and reportable incidents, in line with company/production policy and legal requirements;
● communicate any changes that are likely to affect health and safety standards in the production clearly;
● monitor health and safety performance throughout the production;
● implement effective remedial action for any shortcomings in performance;
● ensure that any concerns with the health and safety performance of employees, freelance staff and contractors are addressed and communicated as appropriate;
● consult and involve employees in health and safety matters;
● ensure that working hours are managed effectively throughout all production activities. Everyone involved with the production is responsible for ensuring heath

Individual workers/production crew Individual workers, location managers and production crew have key health and safety responsibilities:

● to take reasonable care of themselves and others who may be affected by what they do or fail to do
● to co-operate with the employer in carrying out activities intended to meet the employer’s health and safety responsibilities, eg by following instructions, using personal protective equipment, reporting accidents
● to work within the limits of their competence
● to attend training as required by the employer
● to raise any health and safety concerns with their head of department, line manager or producer;
● co-operate with the producer or a nominated person in all matters relating to health and safety. Contractors Contractors are jointly responsible, with the production company, for working in a safe manner in accordance with relevant legal requirements
● our employees and subcontractors will be competent to carry out the work activity and monitored accordingly
● site rules or production safety procedures are followed;
● risk assessments are carried out for their activities and the necessary control measures are implemented;
● significant findings of any risk assessments and the necessary control measures are adopted and communicated to everyone who may be affected;
● health and safety concerns are raised at the earliest possible occasion with production;
● a system of communication and co-ordination is set up between any subcontractors;
● recces are attended as required;
● the production company is informed promptly of any accidents and incidents.

1. Data protection principles

Comuniqe LLC is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

1. processed lawfully, fairly and in a transparent manner in relation to individuals;

2. collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

4. accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

5. kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and

6. processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”

2. General provisions

1. This policy applies to all personal data processed by Comuniqe LLC.

2. The Responsible Person shall take responsibility for Comuniqe LLC’s ongoing compliance with this policy.

3. This policy shall be reviewed at least annually.

4. Comuniqe LLC shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing

1. To ensure its processing of data is lawful, fair and transparent, Comuniqe LLC shall maintain a Register of Systems.

2. The Register of Systems shall be reviewed at least annually.

3. Individuals have the right to access their personal data and any such requests made to Comuniqe LLCshall be dealt with in a timely manner.

4. 4. Lawful purposes

5. All data processed by the Comuniqe LLC must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).

6. Comuniqe LLC shall note the appropriate lawful basis in the Register of Systems.

7. Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.

8. Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in Comuniqe LLC systems.

9. 5. Data minimisation

10. Comuniqe LLC shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

11. 6. Accuracy

12. The Charity shall take reasonable steps to ensure personal data is accurate.

13. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

14. 7. Archiving / removal

15. To ensure that personal data is kept for no longer than necessary, Comuniqe LLC shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

16. The archiving policy shall consider what data should/must be retained, for how long, and why.

17. 8. Security

18. Comuniqe LLC shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

19. Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

20. When personal data is deleted this should be done safely such that the data is irrecoverable.

21. Appropriate back-up and disaster recovery solutions shall be in place.

22. 9. Breach

23. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Comuniqe LLC shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).