Contributor Privacy Notice
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, it includes 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”.
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. In some contexts more than one ground applies. We have summarised these grounds as Legal obligation, Legitimate Interests and Consent and outline what those terms mean in the following table.
|Term||Ground for processing||Explanation|
|Legal obligation||Processing necessary to comply with our legal obligations||Ensuring we perform our legal and regulatory obligations. For example, avoiding unlawful discrimination.|
|Legitimate Interests||Processing necessary for our or a third party’s legitimate interests||We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data.
Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms.
|Consent||You have given specific consent to processing your data||In general processing of your data in connection with the services you provide is not conditional on your consent, although there may be general exceptions to this.|
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 grounds for processing sensitive personal data applies. In outline, these include:
- Processing being necessary for the purposes of your or our obligations and rights in relation to your engagement in so far as it is authorised by law or collective agreement;
- Processing relating to data about you that you have made public (e.g. if you tell us you are ill);
- Processing being necessary for the purpose of establishing, making or defending legal claims;
- Processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity;
- Processing for equality and diversity purposes to the extent permitted by law.
4. Further information on the data we process and purposes
The Core Notice outlines the purposes for which we process your personal data. More specific information on these, examples of the data and the grounds on which we process data are in the table below.
The examples in the table cannot, of course, be exhaustive. For example, although the table does not mention data relating to criminal offences, if we were to find out that someone working for us was suspected of committing a criminal offence, we might process that information if relevant for our purposes. We may also require criminal background checks for certain roles – for example those working with minors.
|Purpose||Examples of personal data that may be processed||Grounds for processing|
|Engagement||Information concerning your taking part in our productions and our assessment of it, your references, any checks we may make to verify information provided or background checks. If relevant, we may also process information concerning your health, any disability and in connection with any adjustments to filming arrangements.||Legal obligation
|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 taking part in||Information connected with your participation including, the processing of images/ video/ audio of you.
|Physical and system security||CCTV images. Records of use of swipe and similar entry cards.
|Providing details in connection with your seeking to participate on other production||Information on your taking part in one of our productions.||Consent
|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.||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 of you.
Information regarding your travel arrangements and location.
|Maintaining appropriate business records during and after your participation in a programme||Information relating to your participation in one of our productions.||Legal obligation
Please note that owing to the fact that you are appearing in one of 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 jurisdictions’ data protection rules, for example in the UK’s Data Protection Bill section on the exemption for ‘journalistic, academic, artistic or literary purposes’.
5. Where data comes from
When you participate in one of our productions, the initial data about you that we process is likely to come from you for example, contact details
6. Who gets to see your data?
Internal use: Your personal data may be disclosed within the Raw TV Limited group to our employees working on your production.
External use: We will only disclose your personal data outside the Raw TV Limited group if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you. We may disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy).
Specific circumstances in which your personal data may be disclosed include:
- Disclosure to external recipients of electronic communications (such as emails) which contain your personal data;
- Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request;
- If you have an on-screen role, 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 to members of our group and data processors in the US and on occasion other jurisdictions in which we are established. Some of our systems are hosted outside of 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 information on it, including:
- Giving you a description and copy of the personal data
- Telling you 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.
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.