1. Overview & Scope
Welcome to LocalFilm Ireland (localfilm.online and localfilm.ie), the dedicated digital infrastructure and professional ecosystem connecting filmmakers, crew, heads of department (HODs), line producers, and studios across all 32 Irish County Hubs and partner international production nodes.
We are deeply committed to safeguarding the personal data, intellectual property, and logistical confidentiality of our community. This Privacy Policy sets out how LocalFilm processes, secures, and respects personal data in full compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Irish Data Protection Act 2018, the Children First Act 2015, and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No. 336/2011).
Core Privacy Principle: LocalFilm operates on a strict Privacy-by-Design architecture. We never sell your personal information, never train artificial intelligence or large language models on your private scripts or call sheets, and strictly prohibit automated data scraping across all hubs.
2. Data Controller & Supervisory Authority
For the purposes of the General Data Protection Regulation and Irish Data Protection legislation, the Data Controller responsible for your personal data is:
| Data Controller | LocalFilm Ireland (Film & Creative Media Network) |
|---|---|
| Registered Operations | Wicklow / Dublin Production Hub, Ireland |
| Data Protection Desk & DPO | [email protected] / [email protected] |
| Lead Supervisory Authority |
Data Protection Commission (DPC) Ireland 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland Website: www.dataprotection.ie · Tel: +353 (0)57 868 4800 |
3. Categories of Data We Collect
We process the following categories of data strictly necessary for our filmmaking directory, digital call sheet, and production logistics services:
- Account & Professional Identity Data: Full name, verified email address, encrypted password hash (via bcrypt), selected County Hub (e.g., Wicklow, Galway, Cork, Belfast), professional bio, department specialities (e.g., Camera, Grip, Art Dept, Post-Production, Sound), IMDb Pro link, and profile headshots.
-
Federated Single Sign-On (SSO): When authenticating via Google OAuth or Apple Sign-In, we receive your verified email and unique subject identifier (
sub) to provision your account without storing your external passwords. - Production & Call Sheet Data: Information entered by Line Producers and HODs into the Call Sheet Builder, including shoot dates, daily call times, set basecamps, Google Maps directions, nearest A&E hospital medical safety briefings, walkie-talkie channels, and cast/crew roster lists.
- Communication & Interaction Data: Real-time WebSocket messages, noticeboard postings, survey pulse responses, peer endorsements (Vouching), and WebRTC video room signaling metadata.
-
Technical & Telemetry Data: IP address (utilized strictly for security, rate limiting, and fraud prevention), browser user-agent, session cookies, and client-side offline storage keys (
localfilm_active_callsheet_cache).
4. Legal Bases for Processing (Article 6 GDPR)
We process personal data strictly under valid lawful bases specified in Article 6 of the GDPR:
| Purpose of Processing | Legal Basis (GDPR Art. 6) |
|---|---|
| Managing member accounts, verified talent directory profiles, and production radar mapping. | Contractual Performance (Art. 6(1)(b)) — Necessary to deliver LocalFilm services. |
| Digital Call Sheet creation, multi-day scheduling, and WhatsApp/SMS call time dispatches. | Contractual Performance (Art. 6(1)(b)) — Requested by Line Producers & Crew. |
| Public Digital Visibility switch, allowing members to toggle visibility on/off the grid. | Consent (Art. 6(1)(a)) — Fully controlled by the member in Dashboard. |
| Security monitoring, anti-spam heuristics, 1-click IP ban/purge, and infrastructure protection. | Legitimate Interests (Art. 6(1)(f)) — Protecting community integrity and safety. |
| Weekly Hub Production Digest emails (opt-out available at any time). | Legitimate Interests / Consent (Art. 6(1)(a)(f)) — Keeping filmmakers informed. |
5. Protection of Minors & Child Performers
LocalFilm Ireland enforces strict, zero-tolerance child safeguarding policies in full alignment with GDPR Article 8, the Irish Data Protection Act 2018 (Section 31 - Age of Digital Consent), the Children First Act 2015, and the Protection of Young Persons (Employment) Act 1996:
Minor Data Removal Hotline: If a parent or guardian becomes aware that personal data relating to a minor has been uploaded without proper authorization, please email [email protected]. We will immediately purge the record within 24 hours.
6. Intellectual Property, Script NDA & Zero-AI Training Guarantee
LocalFilm Ireland was founded by and for filmmakers. We recognize that scripts, treatments, concept lookbooks, pitch decks, and call sheets represent highly valuable intellectual property and confidential trade secrets:
7. Digital Call Sheets & Production Confidentiality
Film and television production involves highly confidential logistical and personal information (including actors' personal mobile numbers, unreleased script details, confidential shoot locations, and emergency medical contacts). LocalFilm enforces strict industry confidentiality standards:
- Production Data Isolation: Call sheets and rosters generated inside LocalFilm belong exclusively to the creating production team. They are never published to public search engines or indexed by external web crawlers.
- Tokenized Direct Links: 1-Click WhatsApp and SMS call time links utilize private cryptographic tokens, ensuring that only the intended crew member receives their specific call times and directions.
-
Offline Resilience & Local Encryption: On-set caching for remote shoot locations (e.g. Kerry, Connemara, Wicklow) stores draft data locally on your device in
localStorage, minimizing unnecessary cloud transmission until reconnection occurs.
8. SOC 2 Type II Alignment & Enterprise Security
While LocalFilm is actively preparing for formal third-party SOC 2 Type II attestation, our core platform architecture has been engineered from the ground up to align directly with the American Institute of Certified Public Accountants (AICPA) SOC 2 Trust Services Criteria and ISO/IEC 27001 standards:
req.user.id against database record owners before any edit or delete mutation, eliminating Insecure Direct Object References (IDOR).SOC 2 Audit Readiness Roadmap: Formal third-party SOC 2 Type II examination and annual penetration testing are currently tracked under our enterprise compliance milestones.
9. Your Data Subject Rights (Chapter III GDPR)
Under EU and Irish data protection law, you hold statutory rights over your personal data. LocalFilm provides self-service in-app tools to exercise these rights immediately:
🛡️ Mandatory 2-Step Verification & Multiple Warning Gates for Data Erasure
To prevent accidental deletion or unauthorized account sabotage, LocalFilm enforces a strict 2-Step Cryptographic Email Verification Protocol whenever an account deletion request is triggered from the Personal Dashboard:
- In-App Multi-Warning Modal: When you click "Request Deletion", the dashboard alerts you that the action is permanent, irreversible, and cannot be undone, and prompts for your explicit confirmation.
- Cryptographic Email Verification Link: An automated confirmation email is immediately dispatched to your verified registered email address with a single-use, 24-hour cryptographic token.
- Irreversible Execution Gate: The email clearly reiterates multiple warnings that confirming will permanently wipe all your profile credits, headshots, messages, and call sheet connections. Data erasure executes only when you click the confirmation button in your email. If the link is ignored, it expires automatically after 24 hours and your account remains active and secure.
To exercise any rights via formal inquiry, contact our Data Protection Officer at [email protected]. We will respond within 30 days in accordance with GDPR Article 12(3).
10. German Cloud Infrastructure & Third-Party Sub-Processors
To deliver frictionless authentication, geolocation mapping, and critical on-set communication, LocalFilm partners with vetted enterprise infrastructure providers under Article 28 (Data Processing Agreements) and Chapter V (Articles 44–49) of the GDPR.
Where personal data is transferred outside the European Economic Area (EEA), such transfers are strictly executed under European Commission Adequacy Decisions (such as the EU-U.S. Data Privacy Framework) or Standard Contractual Clauses (SCCs):
Core Database & Media Sovereignty: LocalFilm's entire production platform, PostgreSQL databases, Redis real-time caches, media uploads, and secure authentication gateways are hosted on enterprise dedicated cloud nodes physically situated in Germany (Falkenstein / Nuremberg).
Zero Third-Country Storage Transfers: Because our primary infrastructure is 100% EU-hosted in Germany, all member accounts, film credits, call sheet rosters, and chat logs are governed strictly by the German Federal Data Protection Act (BDSG) and European GDPR, with zero mandatory data export to non-EU jurisdictions.
Purpose & Privacy Protections: When you choose to sign in with Google, authentication is handled directly on Google's encrypted servers. LocalFilm receives only your verified email address, display name, and a cryptographic subject ID token (sub) to safely create or link your account.
Zero Password Access: LocalFilm never sees, processes, or stores your Google password. We do not request access to your Google Drive, Gmail, contacts, or calendar. For European users, the contracting controller is Google Ireland Ltd, with global backup transfers safeguarded by the official EU-U.S. Data Privacy Framework.
Purpose & Privacy Protections: Apple Sign-In enables seamless Face ID / Touch ID biometric authentication. Apple gives you the option to use Hide My Email, generating a random, privacy-preserving relay address (e.g. [email protected]) so your real personal email is never shared.
Zero Password Access: LocalFilm never receives your Apple ID password or biometric credentials. Apple Distribution International Ltd in Cork, Ireland acts as the EEA entity, and all operations adhere strictly to Irish Data Protection Law and European Commission Standard Contractual Clauses.
Dynamic Hub & Network Scalability: The 3D Orbit Globe and 2D Production Radar dynamically scale to render new Irish County Hubs and verified international production nodes as new filmmakers and studios join the network across Ireland, the UK, Europe, and global co-production territories.
Privacy Guardrails & Off-Grid Control: Talent and studio pins are mapped to regional County Hub centroids to safeguard private residential addresses. Furthermore, members who toggle Digital Visibility off in their dashboard vanish immediately from all 3D Orbit and 2D Radar visualizations in real time. Map tile queries contain zero personal identity data.
11. Beta Telemetry, UX Diagnostics & Privacy Masking
Building the Future of Irish Film Production — Fast, Safe & Intuitive
LocalFilm is currently operating in active Beta. Because our mission is to build the definitive digital infrastructure for Ireland's film and television industry, we must ensure our platform is lighting-fast, easy to navigate, and free from frustrating obstacles for filmmakers, Line Producers, and Heads of Department working on set.
We use Microsoft Clarity as a behavioral diagnostic tool to identify where users encounter friction, confusing layouts, or dead clicks. This telemetry allows our team to iterate rapidly and pivot features directly around how our members actually want to use the platform.
Privacy-by-Design Sensitive Data Masking: Microsoft Clarity operates with strict, automated client-side data masking enabled. Before any diagnostic data leaves your browser, sensitive inputs (including form fields, names, email addresses, phone numbers, passwords, call sheet cast lists, and confidential script notes) are masked locally with asterisks (***).
Zero Keystroke / Password Logging: Keystrokes inside sensitive text fields and passwords are never captured or stored. Clarity does not record video of your physical screen; it only reproduces an abstracted, masked visual layout of user interface interactions (such as scroll depth and navigation clicks).
No Cross-Site Profiling & No Data Brokering: Microsoft Clarity does not track you across third-party websites and does not sell telemetry data to behavioral advertisers. Microsoft Ireland Operations Ltd is certified under the EU-U.S. Data Privacy Framework and adheres to strict ISO/IEC 27001 and ISO/IEC 27018 cloud privacy standards.
Strict Prior Consent Gating (ePrivacy S.I. No. 336/2011): In compliance with Irish and EU ePrivacy rules, Microsoft Clarity is completely disabled and blocked from loading until you explicitly grant consent via our Cookie Preferences or floating shield. You can revoke consent at any time in 1 click.
12. WebRTC Video Rooms & Ephemeral Media Privacy
LocalFilm features integrated real-time video conferencing for auditions, table reads, production meetings, and remote casting calls powered by a dedicated LiveKit Selective Forwarding Unit (SFU):
- Ephemeral Media Routing: Video and audio streams are forwarded ephemerally through our dedicated server memory. LocalFilm does not record, analyze, or archive any live video or audio streams by default.
- Zero Covert Recording: Background recording is strictly disabled. If a production team enables an explicit on-screen audition recording feature in the future, all participants will receive mandatory on-screen visual banners and audio prompts before any recording begins.
- Encrypted In-Transit Streaming: All WebRTC media packets are secured via DTLS-SRTP end-to-middle encryption, preventing eavesdropping on public networks and mobile cellular connections.
13. 72-Hour Incident Response & Data Breach Notification
In strict compliance with Articles 33 and 34 of the GDPR, LocalFilm maintains a formal Security Incident Response Protocol to detect, contain, and remediate any potential data security incidents:
72-Hour Supervisory Authority Notification: In the event of a personal data breach posing a risk to the rights and freedoms of individuals, LocalFilm will notify the Data Protection Commission (DPC) of Ireland without undue delay and, where feasible, not later than 72 hours after becoming aware of it.
Where a breach is likely to result in a high risk to your rights (e.g. unreleased production scripts, sensitive payment information, or identification credentials), LocalFilm will directly communicate the nature of the breach, the affected categories of data, and recommended mitigation steps to affected data subjects without undue delay.
14. Prohibition of Automated Decision-Making & Profiling
In accordance with GDPR Article 22:
- No Algorithmic Blacklisting or Automated Rejection: LocalFilm does not employ automated algorithms, predictive profiling, or artificial intelligence to make hiring decisions, evaluate actor auditions, or disqualify crew members from call sheets.
- Human-Led Curation: All talent discovery, casting selections, and vouching reviews remain 100% human-directed by verified directors, Line Producers, and Heads of Department.
15. Data Retention & Storage Maintenance
We retain your data only for as long as necessary to provide our services or comply with legal requirements:
- Active Profiles: Retained while your account remains active or until you complete the 2-step verified erasure process.
- User-Initiated 2-Step Erasure: Upon clicking the 24-hour verification link sent to your registered email, your profile, contact numbers, headshots, bio, and credentials are permanently purged and unlinked from the database. A one-way cryptographic SHA-256 hash of your email is placed into
deleted_users_logstrictly to honor communication suppression and prevent subsequent unsolicited emails. - Automated 24h Nightly Storage Cleaner: Unverified registration attempts are permanently deleted from the database after 7 days. Unattached temporary media uploads in
/uploads/are unlinked after 48 hours. - Security Audit Logs & IP Bans: Banned IP records in
ip_bansare retained to preserve platform safety and prevent repeat spam attacks.