Data Governance Policy - Mediafilm - Panoscope

Policy Goals and Context

The main purpose of the Panoscope.ca (hereinafter referred to as "PANOSCOPE") data governance policy (hereinafter referred to as the "Policy") is to facilitate the exchange of data, both internally and externally, between PANOSCOPE stakeholders, in order to ensure the quality, availability and integrity of the data, while respecting the privacy of PANOSCOPE users. This Policy explains Mediafilm's processes for data governance.

PANOSCOPE data, whether managed or hosted on Mediafilm's IT resources, stored on personal devices, managed by a third party or business partner, or outsourced to a service provider, are important assets that must be appropriately governed, protected and safeguarded.

Inappropriate use of PANOSCOPE data can be detrimental to Mediafilm, its staff, its users and its partners. It also exposes Mediafilm and its partners to criminal, financial and reputational risks. The various PANOSCOPE stakeholders are therefore responsible for the appropriate use, storage and protection of data.

In the context of PANOSCOPE, the various PANOSCOPE stakeholders are specifically required to:
• Collect descriptive data on films, screenings and venues in Canada (through ouvoir.ca and where2watch.ca);
• Manage a repository of trailers in MP4 and DCP formats;
• Collect information on user actions on various digital platforms, such as Google Analytics, in addition to PANOSCOPE;
• Valorize and securely transmit the collected information between the different stakeholders;
• Valuing and transmitting personalized information to PANOSCOPE users.

Definitions

In this Policy, the following terms are defined as: • DCP: A file format known as the "Digital Cinema Package" which includes a set of standardized files for projecting audiovisual content onto a large screen.
• Data Management: Concrete actions involving the handling and hosting of data as specified by data governance.
• Data Governance: The set of practices and rules, processes, roles, standards and metrics put in place to ensure the proper use of data. It includes roles and responsibilities, formalized policies, processes and procedures, and detailed objectives, values and means to enable strategic and informed decision-making on data collection, use, sharing and archiving, among other things.
• Interoperability: A principle involving the ability of a platform to operate or collaborate with other independent platforms, including without access or implementation restrictions and facilitating the transfer of data with minimal loss of available content and functionality.
• Data Products: Analyses, dashboards, and other results of the data enhancement entrusted to PANOSCOPE.
• Personal information: All personal information of clients and viewers of each of the organizations involved in PANOSCOPE, as defined in the applicable laws regarding the protection of personal information, which may include, but is not limited to, their first name, last name, address, postal code, city, province, country, telephone number(s), email address, language, age range, gender or greeting, generated, collected or transmitted to PANOSCOPE.
• PANOSCOPE Users: All persons and organizations that use the PANOSCOPE website or other platform.

Principles

This policy is guided by the principles and values derived from PANOSCOPE's mission to provide members of the Canadian film and media industry with a business intelligence platform on the distribution of feature films in Canada.

The policy is also guided by the following data governance principles, based on compliance with applicable laws and the FAIR Principles:

• Ethical use of personal information and respect for privacy.
Data protection, which is the responsibility of all PANOSCOPE stakeholders, begins with the collection of data and continues through its use and recovery. PANOSCOPE also uses a risk management approach and follows best practices in data management and security.
• Data interoperability and interconnection between different film databases.
The collaborative approach is central to PANOSCOPE and to make it effective, this approach requires that all PANOSCOPE stakeholders employ effective strategies and methods for collecting (capturing) and sharing film data. These methods rely on a high level of transparency between the different PANOSCOPE stakeholders as well as the use of recognized standards.
• Valuation of data
PANOSCOPE must ensure that it has the necessary latitude to valorize the data, i.e. to have permission to reuse, re-publish, modify, enhance and classify the descriptive and usage data without restriction.
• Transparency
PANOSCOPE and all its stakeholders are committed to documenting their data governance and management practices. PANOSCOPE users are kept informed of any changes to existing policies.

Scope and limitations

This policy applies to Mediafilm, its staff and all other PANOSCOPE stakeholders who create, modify or use PANOSCOPE data, including users who create an account on the PANOSCOPE website.

It applies to all PANOSCOPE descriptive and usage data, regardless of where it is hosted (within Mediafilm or at a partner's site), where it is accessed from, and whether the data is in raw, derived, summarized or aggregated form. It does not, however, apply to how PANOSCOPE partners collect, generate and use data relevant to their own activities.

The policy was developed in the context of, and is designed to complement, Mediafilm/PANOSCOPE's policies and regulations such as the Privacy Policy and the Cookie Policy, which are themselves aligned with the Privacy Act and its recent modernizations (Act 25). This policy is also conceived in the context of the various agreements and contracts that bind Mediafilm with its partners, sponsors and funders.

Roles and Responsibilities

Mediafilm
- Mediafilm is the prime contractor for PANOSCOPE;
- Mediafilm is responsible for the day-to-day governance and management of PANOSCOPE data;
- Mediafilm is responsible for forming a data governance committee within its team. The committee:
- Ensures good data governance and management;
- Reviews this policy periodically;
- Processes requests for the removal of personal information;
- Deals with ethical breaches in accordance with the Non-Compliance Procedures below;
- Mediafilm ensures that users comply with the policies, standards and protocols in place;
- Mediafilm ensures that it applies security protocols appropriate to the sensitivity of the data being held.

User - The user participates in feeding PANOSCOPE by uploading data agreed upon with Mediafilm;
- The user is responsible for the origin, quality, validity and integrity of the data he/she uploads to PANOSCOPE;
- The user ensures that he/she has the legal right to deposit his/her data in PANOSCOPE;
- The user is aware of the policies, protocols and data management mechanisms in force and complies with them.

Data ownership, Licenses and Copyrights

This policy does not attribute ownership of the data collected to any specific stakeholder. The data therefore remains the property of the producer.

The trailers, images and posters uploaded to PANOSCOPE belong to their producer and the terms of their use are subject to the Creative Commons CC BY 04 license.

The data products developed by PANOSCOPE are the property of Mediafilm if they respect the licenses and copyrights, in compliance with the federal, provincial and municipal laws and regulations in force. The reproduction, modification, publication and communication of PANOSCOPE data products is prohibited unless explicitly authorized by Mediafilm/PANOSCOPE.

Unless otherwise indicated, synopses are produced by Mediafilm and are its exclusive property. Trailers, posters and images remain the exclusive property of the distributor.

Policy Enforcement

Data Collection

Mediafilm's database, known as MFI, aggregates descriptive data on feature films for use on all of its sites (mediafilm.ca, ouvoir.ca, where2watch.ca, panoscope.ca, mediafilmvip.ca), as well as those of external clients (Aime ton cinéma, the Coopérative nationale de l'information indépendante, TVA Publications, etc.). MFI also collects the schedule and release data for feature films in Canada (theatrical, platform, television), which is kept for future reference/analysis.

Data Collection The data stored and tagged in MFI is manually collected by the Mediafilm team from knowledgeable sources and authoritative film databases such as • the distributor
• the producer
• the exhibitor (theaters, streaming or video-on-demand platforms)
• Funding institutions that support the film [for Canadian films].
• Internet Movie DataBase (imdb.com)
• The Movie DataBase (tmdb.com)
• AlloCiné (allocine.fr)
• wikidata.org

The trailers in DCP format are uploaded to the PANOSCOPE database by the distributor.

Aggregated theatrical and television broadcast data, as well as data from certain streaming and video-on-demand platforms (iTunes, Illico, Netflix, etc.), are harvested daily through APIs by reputable aggregators:
• TV Media (for broadcast coordinates of TV shows)
• International Showtime (for Canadian theatrical release information)

Usage data

PANOSCOPE collects certain usage data on its website by means of browser cookies (see our Cookie Policy). Usage data is also collected, via Google Analytics, for statistical purposes and to inform certain business intelligence reports published on PANOSCOPE. PANOSCOPE's privacy practices are governed by the Communications & Company Privacy Policy.

Retention and Disposal

All data is stored on Mediafilm's computer servers.

Descriptive film data or other data considered non-sensitive is retained according to Mediafilm's document retention rules or according to special arrangements with the data providers.

In accordance with applicable laws, personal information is destroyed once the purpose for which it was collected has been fulfilled.

Access to data deemed sensitive such as personal information is limited to the analyst responsible for anonymizing or pseudonymizing the data. PANOSCOPE's Data Governance Committee is responsible for approving access and terms of access to data by any individual or third party organization in compliance with this Policy and applicable laws. Access to data will only be granted to the strict minimum necessary in terms of quantity and richness of data, and will be limited in the number of authorized persons.

PANOSCOPE users will however have access to data products elaborated with their film activity data as well as to data products made from the shared film activity data of all PANOSCOPE users.

Protection of personal information

PANOSCOPE is committed to protecting personal information by respecting the laws in force, notably by implementing the following mechanisms
• Designation of a person responsible for the protection of personal information;
• Anonymization and/or pseudonymization of personal data;
• Destruction of personal information once the purpose for which it was collected has been fulfilled.
• Informed and dynamic consent: PANOSCOPE users are informed of the different uses of the data as well as the measures taken for their protection by the present policy and are informed of any change to the said policy;
• Right of withdrawal: PANOSCOPE users may contact the person responsible for the protection of personal information (identified below) if they wish to withdraw data concerning them from PANOSCOPE databases;

Terms of use

Any person who contributes data or uses PANOSCOPE consents to the provisions set out in this policy and undertakes to respect them.

Procedures in case of non-compliance

In the event that non-compliance with the provisions of this policy is demonstrated, Mediafilm/PANOSCOPE reserves the right to prohibit the offending person from using the platform.

Review of the Governance Policy

The present policy is implemented by Mediafilm, which is the prime contractor of PANOSCOPE. It may be revised unilaterally by Mediafilm, without prior notice.

Mediafilm is responsible for updating the Policy, but partners and users may request a revision of the Policy if they feel it is no longer appropriate. The Data Governance Committee will then evaluate the request and decide whether to grant the request to revise the Policy.

Users will be notified each time the policy is updated and may choose to withdraw their consent.

Person responsible for the protection of personal information

Martin Bilodeau General Manager [email protected]