This notice is directed at professional football managers and coaching staff whose pre-match press conference footage is analysed by EchoDepth Sport. It is published in accordance with Article 14 UK GDPR, which requires us to provide transparency information when we process personal data obtained from a source other than the individual directly.

Who is processing your data

Controller: Cavefish Ltd, 15 Neptune Court, Vanguard Way, Cardiff CF24 5PJ

ICO registration: ZB915633

Contact: hello@cavefish.co.uk

What data we process and where we get it

We analyse publicly broadcast pre-match press conference footage — footage distributed intentionally by clubs, the Premier League, and broadcasters for public consumption.

From this footage we derive three composite scores per press conference:

Genuine Confidence score (0–1)
Instability Index (0–1)
Net Confidence score (−1 to 1)

These scores are derived from Facial Action Coding System (FACS) analysis — mapping 44 facial muscle movements to emotional state indicators. We do not create a biometric identification profile. The processing measures emotional state; you are identified by the event context, not by the processing.

We do not retain raw video footage after processing is complete.

Why we process this data and our legal basis

Lawful basis: Article 6(1)(f) UK GDPR — Legitimate Interests.

We have assessed that you, as a professional public figure whose press conference appearances are a contractual requirement of your role and are intentionally broadcast for public consumption, have a reduced privacy expectation in this specific professional context. Our commercial and editorial interest in analysing this publicly available content does not override your fundamental rights, given the mitigation measures we apply.

This assessment is documented in our Legitimate Interests Assessment (LIA-ED-SPORT-001).

Outputs are used for:

Editorial and analytical content published on echodepthsports.com
Commercial data feed supplied to sports analytics and alternative data subscribers under a Data Subscriber Agreement

Who receives your data

Data feed subscribers — trading desks, quant funds, and alternative data aggregators operating under a signed Data Subscriber Agreement. Subscribers are prohibited from using outputs for automated decisions affecting individuals and must maintain their own lawful basis for any downstream processing.
Readers of editorial content published on echodepthsports.com

We do not sell your data to advertisers. We do not share data with social media platforms.

How long we keep your data

Composite scores are retained as part of our analytical and backtesting dataset for the duration of our commercial operation of the Manager Intelligence product. Raw footage is not retained. No biometric identification profile is created or retained.

Your rights

Right to access (Article 15)

You can request a copy of the scores we hold about you.

Right to object (Article 21)

You have the right to object to processing based on legitimate interests. We will assess your objection against the compelling legitimate grounds documented in our LIA. Where your objection is upheld, we will cease processing your footage.

Right to erasure (Article 17)

You can request deletion of your scores. We will comply unless we have compelling legitimate grounds to retain, or unless the data is part of published editorial content protected under the journalism exemption.

Right to rectification (Article 16)

If you believe a score is the result of a processing error, you can request investigation and correction.

Right to restriction (Article 18)

You can request that we restrict processing while an objection or rectification request is assessed.

To exercise any right, contact hello@cavefish.co.uk. We will respond within one calendar month.

Right to complain

You have the right to lodge a complaint with the Information Commissioner's Office:

ico.org.uk/make-a-complaint · 0303 123 1113

Information for Data Subjects