Privacy & Data Protection Policy

1. Who we are

The Right to Write European Observatory is an initiative of the Federation of Screenwriters in Europe (FSE), a European organisation representing screenwriters' guilds and associations across Europe.

The Federation of Screenwriters in Europe (FSE) acts as the data controller for all personal data processed through this Observatory.

FSE – Federation of Screenwriters in Europe (AISBL)
c/o UNI-Europa
Rue Joseph II, 40
B-1000 Brussels
Belgium

Contact: observatory@righttowrite.eu

2. What data we collect and why

The data collected through the Observatory is used for the purpose of documenting, analysing and reporting on patterns that may affect artistic freedom across Europe.

2.1 Submit evidence (URL-based submissions)

When you submit a URL pointing to a press article or public document, we may collect:

• The URL and publicly accessible content of the article — required for analysis
• Country of origin — required for geographic classification
• First name, last name, email address — optional. Contact details are never published and are stored separately from the analytical data.

2.2 Personal testimony (incident or chilling effect)

When you submit a personal testimony via the Share your experience form — whether describing an overt incident or a chilling effect — we may collect:

• Your written description of the situation — required for analysis and documentation
• Country of origin — optional. You may choose "I prefer not to say", in which case your report is routed directly to FSE without involvement of any national guild.
• First name, last name, email address — entirely optional. Providing contact details allows FSE or your national guild to follow up for verification or additional context. Contact details are never published.
• Your consent choice — you choose explicitly whether your anonymised summary may be published on the public Observatory ("Say it loud") or kept confidential for FSE's internal monitoring only ("Keep it quiet").

Personal contact details (name, email) are stored separately from the analytical and descriptive data. This means that testimony records can be retained for monitoring purposes without retaining personal identifiers.

2.3 Technical data

Standard web server logs (such as IP address, browser type and pages visited) are collected for security and diagnostic purposes only and are retained for a maximum of 30 days.

3. Legal basis for processing

• URL-based evidence submissions: legitimate interest (FSE's mission to document and analyse patterns affecting artistic freedom), and, where personal contact details are provided, your consent
• Personal testimony (incident or chilling effect): your explicit consent, expressed through your choice between confidential recording and public publication at the time of submission; and legitimate interest for the underlying confidential monitoring record
• Technical logs: legitimate interest (security and system integrity)

FSE ensures that its legitimate interest is balanced against the rights and freedoms of data subjects, in particular given the optional nature of personal data submission and the separation of personal identifiers from analytical data.

Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. How long we keep your data

• Analytical data (incident content, country, patterns): retained for the duration of the Observatory's operation
• Personal contact details (name, email): retained for a maximum of 2 years, or until you request erasure
• Technical logs: retained for a maximum of 30 days

Where possible, analytical data may be retained in anonymised form where it no longer allows identification of individuals.

5. Where your data is stored

All data is hosted on secure servers located in Switzerland, operated by Infomaniak Network SA (Geneva).

Switzerland is recognised by the European Commission as providing an adequate level of data protection.

6. Who has access to your data

FSE staff and authorised representatives of member guilds may access submissions for review and validation purposes. Personal contact details are never published and are not shared with third parties.

The Observatory uses an AI-assisted analysis tool — Claude, an AI system provided by Anthropic — to support the initial classification of submissions. This tool is used solely as an analytical support instrument; all classifications are reviewed and validated by an authorised FSE expert before any publication.

Sub-processor. For the purposes of this processing, Anthropic Ireland, Limited (6th Floor, South Bank House, Barrow Street, Dublin 4, D04 TR29, Ireland) acts as a data processor on behalf of FSE, which remains the data controller. The relationship is governed by Anthropic's Data Processing Addendum and Commercial Terms of Service.

No model training. Pursuant to Section B of Anthropic's Commercial Terms of Service (effective 17 June 2025), Anthropic is contractually prohibited from training its models on content submitted through the API. Submission content is not used by Anthropic for any purpose other than generating the analytical classification requested by FSE, in accordance with its contractual commitments.

Data retention by Anthropic. API inputs and outputs are retained by Anthropic for a maximum period of 30 days for security and operational purposes, after which they are deleted from Anthropic's systems.

International data transfers. Processing by Anthropic may involve transfers of data to servers located outside the European Economic Area (EEA), including in the United States. Such transfers are carried out in accordance with Article 46 of the GDPR, on the basis of Standard Contractual Clauses approved by the European Commission. Anthropic's contracting entity for customers in the EEA is Anthropic Ireland, Limited, whose operations are subject to Irish law.

No automated decision-making. In accordance with Article 22 of the GDPR, no decision producing legal effects or significantly affecting individuals is made solely on the basis of automated processing. The AI system provides an analytical indication only; all final determinations are made by a human expert.

7. Your rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request erasure of your personal data
• Object to processing
• Request restriction of processing
• Withdraw your consent at any time (where applicable)
• Lodge a complaint with your national data protection authority

To exercise any of these rights, please contact: observatory@righttowrite.eu

8. Cookies

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