Effective Date: 24th of April 2025
Applies to: The Video News Factory Limited and its internal divisions, including Mirror Me AI.
1. Purpose
This policy outlines the data processing responsibilities and structure of The Video News Factory Limited (“TVNF”) and its internal divisions, including MirrorMe AI Ltd (“MirrorMe AI”], to ensure compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
2. Organisational Structure
· MirrorMe AI Ltd is a non-trading company setup as a brand functioning as a commercial division by The Video News Factory Limited which is the sole legal entity responsible for all data processing activities.
· MirrorMe AI Ltd is operated as an internal division of TVNF and does not function as a separate data controller.
· All personal data processed by MirrorMe AI Ltd is done under the authority, policies, and registration of TVNF.
3. Data Controller
· TVNF is the registered data controller with the Information Commissioner’s Office (ICO).
· ICO Registration Number: A8158167
· No separate ICO registration is required for MirrorMe AI Ltd as it does not independently process personal data and has no staff or systems to capable to do so.
4. Data Processing Activities
All data processing activities conducted by MirrorMe AI are:
· Managed and overseen by TVNF’s Data Protection Officer (DPO) or designated compliance lead.
· Conducted using systems, infrastructure, and policies owned and maintained by TVNF.
· Logged and documented as part of TVNF’s central data processing records on systems owned and operated at all times by TVNF with clear indication of the source whether it be related to TVNF or the MirrorMe AI brand name.
5. Data Subject Rights
Any data subject requests (e.g., access, rectification, erasure) related to processing by MirrorMe AI Ltd will be handled by TVNF in accordance with its established procedures.
6. Data Sharing and Transfers
· No personal data is shared externally by MirrorMe AI without TVNF’s authorisation. It should be noted that no staff, temporary or otherwise, are employed in MirrorMe AI, and this company is merely a vehicle to protect the brand name and provide a readymade vehicle for any future investment.
· Any data transfers are conducted under TVNF’s data protection agreements and safeguards.
7. Review and Updates
This policy will be reviewed annually or upon significant organisational changes. Updates will be approved by TVNF’s senior management. If and when MirrorMe AI begins to trade separately, it will operate with it’s own ICO registration and this policy amended accordingly.
8. Contact
For any data protection queries, please contact: datacontroller@thevideonewsfactory.com
Or fill out our contact us form - https://www.thevideonewsfactory.com/contact-us/
Data Protection Lead
The Video News Factory Limited
Email: JP Allard
Phone: 07403 901384