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PRIVACY NOTICE FOR CONTRIBUTORS

1. WHAT IS “PERSONAL DATA” AND “PROCESSING”?

  • “Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.

  • Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device.  It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV. It also covers video, audio and images captured as part of a production.

  • “Processing” means doing anything with the data, for example collecting it, holding it, disclosing it and deleting it.

  • Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data”.

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References in the Contributor Privacy Notice to work or services (and similar expressions) include any arrangement we may have under which an individual provides us services in relation to a production. We use the word “you” to refer to anyone within the scope of the notice.

2. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA:

Under data protection law, there are various grounds on which we can rely when processing your personal data. 

  • Legal Obligation: to ensure we perform our regulatory obligations and avoid unlawful actions, such as discrimination.

  • Legitimate Interests: we or a third party have legitimate interests in managing our business effectively, in connection with processing your data. Data will not be processed on this basis if overridden by your own interests / rights / freedoms.

  • Consent: there may be exceptions when the processing of your date is conditional on your consent.

3. PROCESSING SENSITIVE PERSONAL DATA :                        

If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the following applies:

  • Processing is necessary for the purposes of your / our obligations and rights in so far as is authorised by law or contract

  • Processing relates to data about you that you have made public

  • Processing is necessary for the purpose of establishing, making, defending legal claims

  • Processing is necessary for the provision of health care, medical diagnosis, assessment of working capacity

  • Processing for equality and diversity legal purposes

4. FURTHER INFORMATION ON THE DATA WE PROCESS AND PURPOSES: 

Specific information on the processing of data, and examples of it are presented below in a non-exhaustive list. The format shows: purpose, examples of personal data that might be processed, and an explanation of its use. We have not mentioned criminal offences, although if we were to discover that someone working for us was suspected of criminal involvement, we might process any relevant information. We may also require criminal background checks for certain roles – for example those working with minors.

  • Engagement: information concerning your partaking in our productions and our assessment of it, any references or checks we may make to verify information provided. If relevant, we may also process information concerning your health, any disability and in connection with any adjustments to filming arrangements. Legal obligation, legitimate interests.

  • Contacting you or others on your behalf: your address and phone number, emergency contact information and information on your next of kin. Legitimate interests.

  • Enabling the creation, sale and distribution /  broadcast of a production you are in: information connected with your participation including, the processing of images/ video/ audio of you. Legal obligation, legitimate interests.

  • Physical and system security: CCTV images. Records of use of swipe and similar entry cards. Legal obligation, legitimate interests.

  • Providing details in connection with your seeking to participate on other productions: information on your taking part in one of our productions. Consent, legitimate interests.

  • Monitoring of diversity and equal opportunities: information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age as part of diversity monitoring initiatives. Such data will be aggregated and used for equality of opportunity monitoring purposes. Please note we may share aggregated and anonymised diversity statistics with regulators if formally required / requested. Legitimate interests.

  • Disputes and legal proceedings: any information relevant or potentially relevant to a dispute or legal proceeding affecting us. Legal obligation, legitimate interests.

  • Day to day business operations including marketing and travel on our behalf: information relating to your participation in a programme (this may include a picture or profile), information regarding your travel and location. Legitimate interests.

  • Maintaining appropriate business records during and after your participation in a programme: information relating to your participation in one of our productions. Legal obligation, legitimate interests.

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Please note that owing to the fact that you are appearing in one of our programmes, on some occasions we or third parties will rely upon exemptions to data protection rules in relation to journalistic freedom, the right to artistic expression, or more generally the right to freedom of expression (as mentioned in article 85 of the General Data Protection Regulation and in various jurisdiction' data protection rules, e.g. in the UK's  Data Protection Bill section on the exemption for 'journalistic, academic, artistic or literary purposes'. 

5. WHERE DATA COMES FROM  

  • Initial data is likely to come from you (such as contact details)    

6. WHO GETS TO SEE YOUR DATA?     

  • Internal use: personal data may be disclosed within Particle Productions Ltd  to our employees working on your production.

  • External use: your personal data will only be disclosed outside of Particle Productions Ltd if consistent with a ground for processing on which we rely, and if it is lawful and fair to you. This may be for legitimate interests (providing there are not overridden by your interests and privacy rights).

 

Specific circumstances in which your personal data may be disclosed include:

  • Disclosure to external recipients of electronic communications which contains your personal data (such as emails)

  • Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request

  • If you have an on-screen route, disclosure of footage, images, or audio recordings of you as part of the broadcasting, distribution and marketing of the production. Or, whether you have an on-screen or off-screen role, to allow us to credit your role.

7. RETAINING YOUR PERSONAL DATA- MORE INFORMATION                                

Although there is no specific period for which we will keep your personal data, we will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data until the show has been produced and for a period afterwards. In considering how long to keep it, we will take into account its relevance to our business and your participation either as a record or in the event of a legal claim.

If your data is only useful for a short period (for example, CCTV), we may delete it. Some data, such as production footage itself and credit information, will be kept indefinitely as we have an ongoing legitimate interest in retaining the product.

 

8. TRANSFERS OF PERSONAL DATA OUTSIDE OF THE EEA- MORE INFORMATION                   

In connection with our business and for production, broadcasting, distribution, administrative, management, marketing and legal purposes, we may transfer your personal data outside the EEA.  We will ensure that any transfer is lawful and that there are appropriate security arrangements.

 

9. ACCESS TO YOUR PERSONAL DATA AND OTHER RIGHTS

We try to be as open as we reasonably can about personal data that we process.  If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”.  If you exercise this right and we hold personal data about you, we are required to provide you with the following information on it:

  • -A description and copy of the personal data

  • -An explanation as to why we are processing it

 

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted.  If you have provided us with data about yourself, for example your address, you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the ground for processing is Consent.

If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

 

10.  COMPLAINTS

If you have complaints relating to our processing of your personal data, you should raise these with your key contact at the production in the first instance. You may also raise complaints with your statutory regulator.  For contact and other details ask your key contact at the production.

 

11.  STATUS OF THIS NOTICE

This notice does not form part of your contract and does not create contractual rights or obligations. It may be amended by us at any time.

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