Spooky Paranormal Investigations Ltd (“SPI”) may take photographs, video or audio recordings at some Events for legitimate event documentation and promotional purposes.
We recognise that guests may have different preferences about appearing in photographs or recordings. This Policy explains when photography or filming may take place, the lawful bases SPI may rely upon, when specific consent will normally be sought, and how guests can raise concerns or objections.
Acceptance of SPI’s Terms & Conditions does not amount to blanket consent to every use of a person’s image or voice.
1. Why SPI may take photographs and recordings
SPI may use photography, video or audio to:
- document investigations and Events;
- create Event recaps;
- show prospective guests what an SPI Event is like;
- promote future Events;
- provide content for SPI’s website and official social-media channels;
- create printed or digital promotional material;
- document Venues, equipment and investigation activities; and
- maintain an appropriate historical record of SPI activities.
SPI will consider the context, purpose and privacy impact before using identifiable material.
2. Ordinary Event and documentary photography
SPI may take ordinary contextual or documentary photographs or video during an Event.
This may include wide shots, group activity, investigation equipment, rooms, Venues or guests naturally participating in the Event.
Where appropriate, SPI may rely on legitimate interests as the lawful basis for this type of processing where the use is necessary and proportionate and the rights and interests of the individual do not override SPI’s interests.
SPI will not rely on legitimate interests simply to avoid obtaining consent where a person is deliberately singled out or made the principal subject of promotional content.
3. Notice that photography or filming may take place
Where SPI expects photography or filming to take place, reasonable notice may be provided through one or more of:
- the Event page;
- the booking process;
- pre-Event information;
- the Event briefing; or
- signage at the Venue where appropriate.
The absence of a universal consent checkbox does not mean SPI may use images without considering an appropriate lawful basis.
Normal photography notice will ordinarily be given in advance through Event or booking information and, where appropriate, reminded at the Event.
4. If you would prefer not to appear
If you would prefer not to appear in ordinary Event photography or filming, you may:
- contact SPI before the Event; or
- tell an SPI representative when you arrive.
You do not need to provide a reason.
Where reasonably practicable, SPI will take appropriate steps which may include:
- avoiding targeted photographs of you;
- positioning you away from photographs where practical;
- avoiding selection of clearly identifiable images of you for promotional use; or
- removing suitable material from SPI-controlled channels where appropriate.
Because Events take place in group environments, SPI cannot guarantee that a person will never appear incidentally or at a distance in the background of a photograph or recording.
5. Arranged or posed promotional photography
Where SPI arranges or poses promotional photography that makes an identifiable person the principal subject of promotional material, SPI will normally seek specific consent.
Examples may include:
- individual or small-group portraits arranged for advertising;
- photographs where a guest is specifically asked to pose for SPI marketing; or
- content centred on an identifiable guest for an advertising or promotional message.
Agreeing to SPI’s Terms & Conditions does not itself provide consent for prominently featured posed promotional material.
6. Interviews and testimonials
SPI will normally obtain specific agreement before recording or publishing:
- a guest interview;
- a video testimonial;
- an audio testimonial;
- a written testimonial linked to an identifiable individual; or
- other deliberately featured personal promotional content.
SPI will explain the intended use where appropriate.
Where processing relies on consent, consent may be withdrawn for future use.
7. Group photographs
SPI may occasionally invite guests to participate in a group photograph.
Participation is optional.
A guest may choose not to take part without disadvantage.
Where a group photograph is intended for promotional use, SPI will make that purpose reasonably clear.
8. Photography involving under-18s
SPI primarily operates adult paranormal investigation Events. Selected suitable Events may occasionally permit guests aged 12–17 to take part in the ordinary mixed-age Event in accordance with Age Requirements at SPI Events. Children under 12 are not permitted at SPI Events.
SPI will exercise additional care when processing photographs or recordings involving an under-18 attendee.
SPI will not intentionally make an identifiable under-18 attendee the principal subject of promotional advertising, an interview or a testimonial without appropriate permission from a parent or another person who has parental responsibility for the child. The young person’s own wishes will also be taken into account.
Contextual or incidental photography involving under-18 attendees will be considered carefully in light of the circumstances, purpose and safeguarding considerations.
9. Sensitive or inappropriate situations
SPI will not intentionally use material for promotional purposes where doing so would be seriously intrusive, humiliating, unfair or inappropriate.
Particular care will be taken in situations involving:
- first aid;
- accidents or emergencies;
- significant distress;
- safeguarding concerns;
- private conversations;
- undress;
- medical or health-related matters;
- sensitive personal information; or
- circumstances where publication would reasonably be expected to cause significant embarrassment or intrusion.
10. Audio recording
Video recordings may also capture voices and environmental audio.
Group investigation recordings, including recordings made for EVP review, may capture participant voices and environmental audio as part of the investigation. Guests must not deliberately record private conversations or misuse an identifiable recording.
Recording material for investigation or documentary review does not by itself authorise later promotional use. Promotional use will be considered separately under the principles in this Policy.
SPI will not deliberately record or publish a private conversation for promotional purposes without an appropriate lawful basis.
Where a person is deliberately interviewed, asked to provide a testimonial or made the principal subject of an audio recording, specific agreement will normally be sought.
11. Where SPI material may appear
SPI photographs, video or recordings may appear on:
- spookypi.co.uk;
- SPI’s official Facebook pages;
- SPI’s official Instagram accounts;
- SPI’s official TikTok or other official social channels;
- paid SPI advertising;
- printed promotional materials;
- Event advertising;
- Event recaps; and
- other genuine SPI promotional or documentary material.
Where SPI proposes a materially different or unexpected use centred on an identifiable person, SPI will consider whether additional information or consent is required.
12. Third parties
SPI will not ordinarily provide an identifiable guest image to an unrelated third party for that third party’s own advertising unless an appropriate lawful basis exists and any required information or consent requirements have been addressed.
Whether a photographer, videographer or other service provider acts as a controller or processor depends on the actual arrangement. A provider commissioned to process material solely on SPI’s instructions may act as SPI’s processor.
Where a Venue, press organisation or another organisation independently decides why and how it takes photographs for its own purposes, that organisation may act as a separate data controller.
Where SPI arranges such third-party activity, SPI will provide reasonable information where appropriate.
13. Venue photography restrictions
Some Venues impose restrictions on photography, flash photography, filming or recording.
Venue rules and lawful restrictions must be followed.
SPI may restrict photography or filming in particular areas or activities where necessary.
14. Photography and filming by guests
Guests may generally take photographs or recordings for personal use where permitted by the Venue and Event rules.
Guests must respect the reasonable privacy wishes of other attendees.
If an identifiable attendee reasonably asks another guest to stop deliberately recording or photographing them, that request should be respected.
Guest photography or recording must not:
- harass or intimidate another person;
- deliberately humiliate another person;
- intrude into a clearly private situation;
- disrupt the investigation;
- compromise safety;
- interfere with equipment or experiments; or
- breach Venue restrictions.
Commercial or professional filming requires prior permission from SPI and may also require permission from the Venue.
15. Social-media sharing
Once content has been published online, other users may screenshot, download, share or repost it.
SPI cannot completely control independent third-party sharing after publication.
SPI remains responsible for material published through its own controlled accounts and will consider reasonable removal or objection requests in accordance with applicable data-protection law.
16. Venue CCTV
A Venue may operate its own CCTV or security recording system.
Such systems are normally operated independently by the Venue and are not controlled by SPI.
Questions concerning Venue CCTV should normally be directed to the relevant Venue.
17. Retention and storage
SPI will not retain personal data for longer than reasonably necessary for the purpose for which it is held.
Raw, duplicate or unused photographs and recordings may be deleted when no longer required.
Selected photographs or recordings may be retained for longer where they continue to have genuine:
- documentary;
- historical;
- evidential; or
- promotional value.
SPI will periodically consider whether continued retention remains appropriate.
Material will be subject to reasonable security and access controls.
Further information about retention is provided in SPI’s Privacy Notice.
18. Objecting to processing based on legitimate interests
Where SPI processes an identifiable image or recording on the basis of legitimate interests, you may object to that processing.
You do not need to use any particular legal wording.
SPI will consider matters including:
- the context in which the material was obtained;
- how prominent or identifiable you are;
- the purpose for which the material is being used;
- your particular circumstances; and
- SPI’s grounds for continuing the processing.
An objection does not always result in automatic deletion, but SPI will stop the relevant processing unless there are compelling legitimate grounds which override the individual’s interests, rights and freedoms or another legal exception applies.
Where an objection is justified and reasonably practicable, SPI may remove relevant material from channels under its control.
19. Withdrawing consent
Where SPI relies specifically on your consent, you may withdraw that consent for future processing.
Withdrawal of consent does not make processing carried out before withdrawal unlawful.
SPI will take reasonable steps to stop future use of material which depends on the withdrawn consent.
It may not always be possible to recall:
- printed material already distributed;
- content already shared or downloaded by third parties; or
- copies outside SPI’s control.
20. Asking about an existing photograph or recording
If you contact SPI about an existing photograph, video or recording, please provide enough information to help us identify it.
Helpful information may include:
- the Event;
- Event date;
- Venue;
- approximate time;
- description of the image or recording;
- screenshot; or
- link to the material.
21. Data protection
Photographs, video and audio containing identifiable individuals may constitute personal data.
SPI processes personal data in accordance with applicable UK data-protection law.
Further information about:
- lawful bases;
- individual rights;
- retention;
- sharing;
- international transfers; and
- how to contact SPI about personal data
is contained in the SPI Privacy Notice.
SPI will respond to a valid data-protection rights request without undue delay and normally within one month, subject to any lawful extension or request for information needed to verify identity.
22. Contact SPI
For questions, objections, consent withdrawals or concerns about photography or filming, contact:
Spooky Paranormal Investigations Ltd
Email:
hello@spookypi.co.uk
Company number:
16540220
Registered office:
71–75 Shelton Street
Covent Garden
London
WC2H 9JQ
Website:
spookypi.co.uk