Contributor Privacy Policy
- Introduction & Who this notice is for
This Privacy Notice is for all ‘contributors’ who are involved in making TV programmes for Orchard Studios Media Ltd and any of its subsidiaries (“we”, “our” or “us”).
Contributors include:
- On screen talent (actors, writers, presenters or hosts, composers and musicians and other performers)
- People who are participants or apply to be in our TV programmes or in an audience
- Other people who contribute to our TV programmes (for example, interviewees or people who send us videos, photos or other materials)
This Privacy Notice will also apply to agents or other representatives of the contributors listed above.
This Privacy Notice does not apply if you are employed by us or provide services to us as a freelancer or other contractor - see our separate privacy notice.
This Privacy Notice explains how and why we collect and use your personal information to make our programmes, and sets out your related rights and options.
We are a “controller”, which means they have legal responsibility when using your personal information.
- What personal information do we collect and use?
It depends on the programme you are involved in and nature of your participation, but we commonly collect and use your: name, contact details (usually phone number and/or email address), gender, date of birth, passport details or other national identifier (e.g. driving licence), proof of address, national insurance or social security number, bank details, tax status, details about your previous roles or work, background, interests, general knowledge, preferences, opinions, education details, video footage of you or from which you can otherwise be identified, details of your role in the production, photographic or other still images of you, your professional qualifications or examples of previous work (for example showreel footage).
We may also collect and use types of personal information which are more private and sensitive in nature, such as information about your physical and/or mental health, racial / ethnic origin, political opinions, sex life / sexual orientation, religion, philosophical beliefs, genetics, biometrics, trade union membership and/or information about your criminal record, if any (which may include allegations, proceedings and/or convictions). All these types of information are referred to collectively as “Special Categories of Personal Data” in this Privacy Notice.
- Where do we get your personal information?
We collect your personal information either from you or third party sources. The table below sets this out in more detail:
WHAT
|
OUR SOURCES
|
Personal information that you give to us |
- from emails or other types of correspondence, application forms, pre-filming questionnaires, release forms, payment instructions and any associated documentation that you (or an agent on your behalf) complete; and
- from discussions, conversations, interviews, consultancy, audition footage, footage of the actual programme (live or pre-recorded), behind the scenes material, contributions to the programme and participation in social media chats (including Instagram Stories, Instagram Live and similar on other social media channels).
|
Third parties we obtain personal information from |
- publicly available and accessible reports, directories and sources (such as Companies House and newspaper articles);
- interviews and correspondence with friends, family members, and/or people connected to you;
- social media platforms, including Facebook, Instagram, Twitter, Linkedin, Snapchat and TikTok;
- subscription only databases such as Lexis Nexus and Reuters;
- background check services providers such as People Check;
- tax authorities, including those that are based outside the UK and the EEA if you are subject to tax in another jurisdiction;
- your bank or building society in connection with payments;
- your professional advisers working on a matter which involves or is relevant to you;
- governmental and competent regulatory authorities to whom we have regulatory obligations;
- agents, production companies, audience ticketing companies and other broadcasters;
- recruitment / talent agencies;
- our insurer, and its representatives including brokers, third party claims adjusters, reinsurance companies and insurance regulatory authorities;
- fraud prevention and detection agencies and organisations;
- Information technology and access systems run by others on our behalf, such as CCTV systems and door entry systems / logs
- third parties we work with as part of the production process, such as fixers, editors and individual freelance crew members such as writers and directors;
- where authorised by applicable laws, crime enforcement and authorised criminal records organisations, such as the DBS (sometimes via a DBS-registered organisations such as uCheck), Disclosure Scotland and/or Access NI (depending on where in the world you live / have lived before); and
- registered health professionals.
|
- How and why we use your personal information
To use your personal information we need a “lawful basis”. A lawful basis is a justification for using your personal information which is recognised and permitted by data protection law. Generally, we use your personal information when one of these justifications applies:
- Contract performance: when using your personal information is necessary to perform a contract with you or take steps at your request before entering a contract with you.
- Legal obligations: when using your personal information is necessary for us to comply with applicable law.
- Consent: when you agree in advance that we can use your personal information in a specific way.
- Where using your personal information is necessary to satisfy the TV programme commissioner’s public service broadcasting remit.
- “Legitimate interests”: when using your personal information is necessary for a genuine business, operational or legal reason. We only rely on this justification when we have considered that, on balance, our legitimate interests are not overridden by any potential adverse impact on you. Such interests include:
- Managing and administering contributor work or submissions.
- Ensuring compliance with editorial or quality standards.
- Processing payments, royalties, or financial transactions.
- Maintaining records for operational, or reporting purposes.
- Publishing, distributing, and promoting contributions.
- Preventing fraud, unauthorised access, or security breaches.
- Analysing data to improve processes and offerings.
- Preserving contributions for archiving or research purposes.
- Protecting legal rights and defending against claims.
- Building relationships and engaging with contributors.
- Supporting public interest, transparency, and intellectual property rights.
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
To use your Special Categories of Personal Data, we must rely on both a lawful basis and a “condition”. A condition is another justification for using personal information which is recognised and permitted by data protection law. Generally, we will only use your Special Categories of Personal Data:
- when in the substantial public interest on the basis of section 10(3) and Part 2 of Schedule 1 of the Data Protection Act 2018. In brief, these are situations considered by applicable law to be important enough to our society to justify using Special Categories of Personal Data. The most applicable to Orchard are:
- reviewing / maintaining equality of opportunity or treatment,
- journalistic / artistic purposes including in connection with unlawful acts or dishonesty,
- preventing and detecting unlawful acts,
- safeguarding children and individuals at risk,
- preventing fraud,
- safeguarding of economic well-being of certain individuals; and
- publication of legal judgments.
- Processing is necessary for archiving reasons in the public interest, scientific or historical research purposes or statistical purposes in accordance with Schedule 1, Part 1, Condition 4 of the Data Protection Act 2018. This includes:
- Preservation of Materials: Retain interviews, transcripts, and raw footage for historical or cultural records;
- Future Productions: Keep contributor data for continuity in sequels or follow-up projects;
- Public Interest Archiving: Deposit materials in archives for societal benefit; and
- Statistical/Research Use: Archive anonymised data for future analysis of societal trends or issues.
- Where necessary or allowed under employment, social security or social protection law in accordance with Schedule 1, Part 1, Condition 1 of the Data Protection Act 2018. This includes:
- checking if individuals are entitled to work in the UK;
- ensuring health, safety and welfare of employees;
- maintaining records of statutory sick pay and maternity pay; or
- deducting trade union subscriptions from payroll.
- Where necessary for medical purposes in accordance with Schedule 1, Part 1, Condition 2 of the Data Protection 2018. This includes:
- diagnosis, preventive / occupational medicine;
- assessment of working capacity; and
- providing healthcare / treatment, public health or in medical emergencies.
- Where you knowingly and willingly make / have made your Special Categories of Personal Data available to the public.
- Where necessary to establish, exercise or defend legal claims. This includes:
- protecting the public against dishonesty, malpractice or other improper conduct;
- insurance reasons;
- actual or prospective court proceedings;
- obtaining legal advice; and
- establishing, exercising or defending legal rights in any other way.
- when you provide your explicit consent in advance – such consent can be withdrawn at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- When we use your personal information, and at least one of the conditions apply, examples of how we use your Special Categories of Personal Data include:
- Administering our relationship with you and facilitating your involvement
- For example, communicating with you, managing our legal relationship, using your contribution, onboarding you, booking travel / accommodation, making reasonable adjustments, scheduling, or paying you when you.
- Casting and crewing
- Ensuring that we have appropriate and suitable talent, contributors, audience members and production teams for each of our programmes. We do this by, for example:
- creating, maintaining, updating and selecting from databases,
- receiving applications and considering them on merit,
- auditions, interviews and conversations,
- considering public-facing social media profiles and accounts,
- working with talent and recruitment agencies,
- typecasting, and
- receiving and considering nominations for a person to participate as a contributor.
Depending on your preferences, we may also use your personal information to contact you about future series / programmes for which you may be interested in applying.
In some cases we may work with third party advertisers and platforms, such as Facebook, to advertise our casting flyers to the most relevant audiences. This can involve sharing your personal information (such as name and email address) with third party platforms who will match the personal information we hold about you with the personal information they hold on their platform to either provide you with flyers for relevant future series / programmes or to find and target individuals with similar interests and demographics.
- Research for programmes
- We use personal information when doing both initial and further research for programmes (for example scripted dramas based on real-life circumstances). We do this by using publicly available sources, like books and articles, and by engaging consultants who can provide relevant information.
- Assessing your medical fitness and suitability to participate
- We ask for health information and carry out health assessments (and similar assessments like drug tests and STI screening) so that we can ensure that all participants can be kept healthy and safe during production, for insurance reasons and to offer reasonable adjustments where appropriate.
- Medical problems and emergencies
- If you get ill or injured during your participation in a production, we will share information about your health with either an on-site / attending / emergency medic so that they can give you the right treatment.
- Duty of care background checks and screening
- We carry out background checks and screen contributors using publicly available sources and third parties, for duty of care, health and safety and/or safeguarding purposes. This includes information such as employment / work details, participation in previous / other TV programmes, social media posts or other content published online, information from public registers like Companies House or the Insolvency Register, criminal record and court proceedings.
- Recording, editing and otherwise producing content
- We record and edit footage and audio of you for the purpose of making programmes, which helps us satisfy our remit as a Public Service Broadcaster and fulfil our objective of making television content for commercial use.
- Using your property for filming
- When you allow us to film at your property, we collect your name, address, contact details, bank details and (if relevant) ownership details so that we can arrange filming, logistics and set-up and payment.
- Filming in public places
- We may film in public places (for example as part of an outside broadcast for a news item). While there is less of an expectation of privacy in public places than private places, people are still entitled to expect their privacy to be respected when going about their daily lives. Whenever we film in public we put filming notices up in and around the area being filmed (to notify people in that area in case they prefer to not be filmed). We offer opt-outs to anybody who has been filmed and either did not realise, was unable to use a different route / area or who has changed their mind about being filmed.
- User generated content
- We ask for and collect UGC as required for use in relevant productions and to engage with our viewers. We usually invite you to share UGC through a “call to action” (for example via a flyer issued on social media), and do not generally use unsolicited UGC sent by individuals or which is publicly available online. Productions typically ask for (i) images, videos and stories for inclusion in programmes from contributors or audience members and (ii) competitions involving submissions from viewers.
- Broadcasting content and making it available for video-on-demand services
- If you contribute to a programme and/or are part of a programme’s subject matter, we have a legitimate interest in selling / licensing the programme for use, making it available for broadcast and/or VOD services and distributing it (including repeats and re-edits) around for world for the period in which we have rights in the programme (which may be indefinitely - please see your release form or similar agreement). We also have a legitimate interest in using your personal information to deal with any questions or complaints arising in relation to your contribution.
- Promotion and marketing
- Sometimes we may use your personal information to promote or market a particular programme or product (for example a short clip of video footage of your contribution to a production included in an advert to attract viewers to the programme).
- Relationships with third parties relevant to you
- We provide personal information to third parties who work with us who may require it to, for example, perform their contractual obligations with us or you, supply benefits or services to you and/or help facilitate your participation in the programme or its production (for example transport and accommodation suppliers).
- Diversity and inclusivity initiatives
- Orchard runs and participates in a variety of diversity, equity and inclusion initiatives both in-house and working with key partners. These could include:
- Orchard is part of an industry-wide diversity monitoring initiative called Diamond, which is run alongside Pact, other UK broadcasters and the Creative Diversity Network. Diamond uses personal information regarding on- and off-screen contributors (the vast majority of which is anonymised) to programmes to report on the diversity of TV production in the UK. If you have provided us with your email address, we will share this with the Creative Diversity Network (unless you have asked us not to). They will contact you to ask if you are willing to contribute to the initiative by providing information about characteristics like gender, ethnicity, disability, age and sexual orientation.
- We run initiatives which encourage individuals from diverse and under-represented backgrounds to participate in TV production and consider it as a profession.
- We keep records to create statistics and analysis in order to monitor the effect and impact of our own D&I initiatives and consider what further initiatives are required.
- We provide D&I information to commissioning broadcasters / streamers when they are a condition of the relevant commission.
- Training and education
- Depending on the nature of your relationship with Orchard and the production, we may use your personal information in order to provide you with professional or similar training / education (for example diversity and inclusivity, health and safety, anti-bullying and harassment, first aid and mental health awareness training).
- External disclosure requests
- As set out in more detail in section 5 below, sometimes it may be necessary to share your personal information with third parties who ask us to disclose it to them. We only do this where we are legally obliged to do so or where there are compelling public interest reasons for doing so (for example, providing footage or other information which may assist law enforcement authorities in an investigation).
- Offering you support and assistance
- Depending on the applicable circumstances, we may use your personal information to offer you support or assistance which either you request or we consider would be appropriate and helpful (for example, training and guidance on how to deal with social media and press scrutiny or psychological support after production).
- Facilitating your rights and honouring opt-outs
- We use your personal information in order to help facilitate rights set out in section 8 below or to honour your choice to opt-out of a particular use of your personal information. For example, if you decide you do not want to be included in a production having been filmed in a public place, you can contact us to let us know your preferences. We will locate and delete footage of you and use our contact details to confirm.
- Who uses your personal information and who do we share it with?
We may use, provide and share your personal information as set out below:
- Internally: your personal information will be used by our employees and contractors who are working on relevant projects or others in supporting departments (such as finance and accounting for payroll purposes).
- External suppliers - we use suppliers to help us do our work. Non-exhaustively, those suppliers include:
- Online casting application systems
- Medical service providers such as physiotherapists and psychologists
- Professional advisers such as lawyers, insurers, accountants and auditors
- Suppliers which help with logistics and practicalities, such as accommodation and travel service providers
- External TV studios and post-production houses, transcription service providers
- Audience providers and ticketing companies
- Suppliers helping with our D&I initiatives
- Talent / similar databases
- Recruitment agencies or agents
- Parties helping us with background checks, screening and identity verification
- Document storage
- Payroll
- Property owners / managers
- Hospitals / police etc if we’re working with them
- In-show / after-show care providers / counsellors etc
- Security - threat monitoring, physical
- Commissioning broadcasters / streaming platforms - the companies who buy or licence our programmes and make them available to viewers
- Independent production labels who our labels sometimes work with to co-produce programmes
- Unions and industry representative bodies
- Viewers - personal information included in the content of a programme will be shared with anybody who watches it
- Law enforcement bodies / government bodies - for example if police request footage or information to help with an investigation or to apprehend or prosecute offenders or to protect someone from harm
- Regulators such as Ofcom (the UK broadcasting regulator) or the Information Commissioner’s Office (the UK data protection regulator) may ask us for documents or records including personal information
- Group companies. We work closely with other companies which are part of our group. We may share your personal data with such companies for the purposes of security, optimisation of our production and services, as well as internal reporting.
- Business successors. We may share your personal data with potential partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business.
- We may also share your personal information externally if:
- We are required to do so by law (for example a court order) or a regulator (such as Ofcom or the ICO)
- We are asked by a competent law enforcement or other organisation or body (for example police requesting footage)
- For the purposes of prevention of fraud or other crime
- Sending your personal information internationally
Your personal information is mainly used within the country where the relevant controller operates i.e. in the UK.
However, your personal information may sometimes be transferred to group subsidiaries or third parties in other countries for the purposes described in this Privacy Notice which may have less strict, or no data protection laws, when compared to those in the EEA or the UK.. We will only transfer your personal information to a country outside the UK/EEA if:
- the UK data protection authority or EU has determined that the data protection law of that country offers you a similar standard of protection as under UK / EU law;
- we put the recipient under contractual obligations or organisational rules that mean the standard of protection offered to you in practice is similar to that under UK / EU law - such as the EU Standard Contractual Clauses, UK International Data Transfer Agreement and the UK Addendum to the EU Standard Contractual Clauses;
- you provide your consent; or
- data protection law allows us to (for example where necessary under a contract which benefits you); or
- self-certification mechanisms such as the EU-US Data Privacy Framework and the UK extension to the EU-US Data Privacy Framework.
You may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
- How long do we keep your personal information?
As a general rule, we keep your personal information only as long as required for the relevant purpose set out in this Privacy Notice (or another purpose that has been notified to you) or to enable us to pursue our legitimate business interests or for such longer period as is required by law or regulatory obligations which apply to us.
We do not keep personal information in perpetuity or on a “just in case” basis unless stated in this notice.
When determining our retention periods, we think about the amount and nature of the personal information, the risks posed to you by our use of it, the importance of the reasons we need to use it, whether we can achieve those objectives without using it, and other applicable legal or regulatory requirements.
As general guidance, we will keep your contribution (i.e. footage or other recordings of you), personal information contained within the contract(s) you enter into, personal information required to fulfil any ongoing contractual payment obligations, any records of your participation in the TV programme or project and information contained in any publicity material for as long as necessary – which may be indefinitely for airing and re-airing or other ongoing use or exploitation of the TV programme in any media (whether in whole or in part).
- What are my rights when you use my personal information?
When we use your personal information, you obtain several rights that you can exercise over our use of it. Please note that some of these rights are not absolute or automatic - some can only be exercised in certain circumstances.
- Consent withdrawal: where we have asked for your consent to use your personal information, you can withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.. Please note that withdrawal may preclude or prevent you from participating in a programme. Please also note that consent to use your personal information under applicable data protection law is different from consent obtained in a release form for purposes of compliance with the Ofcom code.
- Access: you can request a copy of our records, files and documents containing your personal information.
- Rectification: you can ask us to correct or update our records of your personal information.
- Erasure: you can ask us to delete your personal information from our records in specific circumstances.
- Restriction: in specific circumstances you can ask us to only use your personal information in certain ways.
- Objection: you can challenge our use of your personal information in specific circumstances. We then have to stop the relevant use(s) unless we have a compelling reason to continue.
- Portability: you can request us to move a copy of your personal information that you provided to us to another provider or to give you a copy (this right may be available when we automatically use your personal information on the legal basis of consent or performance of contract. However, it may not be technically possible and/or feasible for us to comply with your request).
- Complaint: you can make a complaint if you are not satisfied with our use of your personal information. You can lodge a complaint with the relevant data protection authority in your country of work or residence. The UK data protection regulator is the Information Commissioner’s Office: https://ico.org.uk/. For the EU, a list of supervisory authorities and their contact details can be found here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
Please be aware that these rights are not always absolute and there may be some situations in which you cannot exercise them, or they are not relevant. Please also be aware that these rights will not apply to the extent an exemption applies (for example where exercising these rights would undermine or prejudice the public interest value of a production).
If you want to exercise any of these rights or have any questions, please contact info@orchard-studios.com
- What do we do with children's personal information?
As a general rule we take the following approach to children in the UK:
- Applicability of this Privacy Notice
- This Privacy Notice is aimed at individuals aged 13 and above.
- If you are unsure about this Privacy Notice, please contact us know or ask a parent / legal guardian to go through it with you and explain.
- For children 12 and under, we require the parent / legal guardian to explain this Privacy Notice to their child our use of their personal information and its implication, in a way that the child can understand and to the extent the parent / legal guardian considers it appropriate.
- Obtaining consent
- For children 12 and under, we usually rely on parental consent as a lawful basis to use personal information
- For children aged 13-17, we may rely on their own consent where it is appropriate, taking into account the nature of the personal information, , the risks posed by our use and the relevant child’s level of understanding.
- In all cases, we ensure that consent is freely given, informed, and specific, in accordance with UK GDPR requirements.
Otherwise, we take additional precautions when using children’s personal information such as:
- Limiting the collection and use of children’s data to what is strictly necessary.
- Explaining clearly and transparently how we use children’s data, in language they can understand.
- Implementing robust security measures to safeguard children’s data.
- How we keep your personal information secure
We're committed to protecting your personal information and keeping it secure, private and confidential to prevent your personal information from being lost, damaged, compromised or used / accessed unlawfully or without authorisation.. We put in place appropriate technical and organisational measures to help protect the security of your personal information. Unfortunately no measures can ever be completely secure. We have implemented various safeguards to protect against unauthorised access and unnecessary retention of personal information in our systems. These may include pseudonymisation, encryption, restricting access, and retention policies. These measures are chosen and/or designed taking into account the nature, amount and scope of personal information we use.
- Exemptions
There are certain circumstances where the UK GDPR and the Data Protection Act 2018 allows us (and the Programme broadcaster/commissioner) exempts us from having to comply with certain data protection obligations explained in this Privacy Notice, nor with your legal rights. These exemptions may limit obligations such as - transparency (i.e. telling you how and why we use your personal information) or needing to have a lawful basis and a condition (i.e. a justification recognised by law) to use your Special Categories of Personal Data.
The most common circumstances where exemptions may apply are:
- journalistic purposes, artistic purposes or literary purposes as permitted under Schedule 2, Part 5 of the Data Protection Act 2018. This includes making a programme which has public interest value.
- assisting with the prevention or detection of crime,
- protecting the public against dishonesty, malpractice, serious incompetence or other seriously improper conduct,
- protecting the health, safety and welfare of people at work,
- Where legal privilege applies, or
- When negotiations or management forecasting or planning need to be confidential.
- Contact
If you have any queries about this notice, please contact Orchard’s MD, Nicola Hill – NicolaHill@orchard-studios.com If you would prefer, you can write to us at 8-12 Leeke Street, London WC1X 9HT.
- Changes To This Privacy Notice
We reserve the right to update this privacy notice at any time. We will notify you of any changes by e-mail. We may also notify you in other ways from time to time about the processing of your personal information.
Annex – Data Processing Table
Purpose
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Personal Data Used
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Activity
|
Lawful Basis and Condition
|
To produce and broadcast a programme
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Name, contact details, recorded interviews, images, and footage
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Collecting, recording, editing, and broadcasting contributor content
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Lawful Basis: Legitimate interests (producing content); Consent (explicit for special category data)
Condition: Explicit consent (Article 9(2)(a)) or journalistic purposes (DPA 2018, Schedule 2, Part 5)
|
To ensure contributor safety
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Health information, emergency contact details
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Conducting risk assessments, safeguarding health and safety during filming
|
Lawful Basis: Legal obligation (health and safety law)
Condition: Explicit consent (Article 9(2)(a)) or vital interests (Article 9(2)(c)) for health emergencies
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To verify eligibility to participate
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Identification documents (e.g., passport), age, proof of work eligibility
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Verifying identity, confirming age, and ensuring compliance with legal requirements
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Lawful Basis: Legal obligation (right-to-work checks); Legitimate interests (eligibility verification)
|
To manage contributor payments
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Bank details, tax information
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Processing payments, issuing invoices, and maintaining financial records
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Lawful Basis: Contractual necessity (payment processing); Legal obligation (tax compliance)
|
To archive the programme or materials
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Recorded interviews, images, and footage
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Storing programme materials for public interest archiving or future research use
|
Lawful Basis: Legitimate interests (archiving for public interest)
Condition: Archiving in the public interest (Article 9(2)(j))
|
To comply with legal or regulatory requirements
|
Any relevant personal data
|
Responding to legal requests, regulatory investigations, or ensuring compliance with laws
|
Lawful Basis: Legal obligation (e.g., responding to authorities)
Condition: Substantial public interest (Article 9(2)(g), e.g., preventing unlawful acts)
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To address complaints or disputes
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Contact details, correspondence, and relevant contributions
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Investigating and resolving contributor complaints or disputes
|
Lawful Basis: Legitimate interests (complaint resolution); Legal obligation (where required)
Condition: legal claims (Article 9(2)(f))
|
To promote the programme
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Images, footage, and contributions
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Using contributor data for promotional trailers, social media posts, or press activities
|
Lawful Basis: Legitimate interests (promoting content); Consent (for special category data)
Condition: Explicit consent (Article 9(2)(a))
|
To protect legal rights
|
Contract details, correspondence, and relevant personal data
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Defending or exercising legal claims, or protecting against fraud or misconduct
|
Lawful Basis: Legitimate interests (defending legal rights)
Condition: Legal claims (Article 9(2)(f))
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To conduct audience or statistical research
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Demographic data, anonymised or pseudonymised data
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Analysing programme impact or contributor demographics for reporting or improvement purposes
|
Lawful Basis: Legitimate interests (research and analytics)
Condition: Archiving/research purposes (Article 9(2)(j))
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To comply with safeguarding obligations
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Information on vulnerable contributors (e.g., children, health information)
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Implementing safeguarding measures for vulnerable individuals during production
|
Lawful Basis: Legal obligation (child/vulnerable individual protection laws)
Condition: Substantial public interest (Article 9(2)(g))
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To manage contributor contracts
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Contact details, signed agreements
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Preparing, signing, and managing contributor contracts
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Lawful Basis: Contractual necessity (contract performance)
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To handle allegations of misconduct
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Relevant personal data, including sensitive information (e.g., criminal allegations)
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Investigating allegations of dishonesty, malpractice, or improper conduct
|
Lawful Basis: Legitimate interests (investigating misconduct); Legal obligation (where required)
Condition: Substantial public interest (Article 9(2)(g), e.g., protecting the public from improper conduct)
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To facilitate programme insurance
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Personal details, health information (if applicable)
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Sharing necessary contributor data with insurers to arrange production insurance
|
Lawful Basis: Legitimate interests (insurance arrangements); Legal obligation (insurance regulations)
Condition: Explicit consent (Article 9(2)(a))
|
To support marketing and publicity efforts
|
Names, images, recorded contributions, and interviews
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Using contributor data in press releases, trailers, or promotional materials
|
Lawful Basis: Legitimate interests (publicising the programme); Consent (explicit for sensitive data)
Condition: Explicit consent (Article 9(2)(a))
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To handle legal compliance related to minors
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Age, parental consent forms, and identity documents
|
Verifying parental consent and complying with child protection laws
|
Lawful Basis: Legal obligation (child protection laws)
|
To manage audience participation
|
Names, contact details, and recorded contributions
|
Coordinating contributor/audience participation in live or pre-recorded segments
|
Lawful Basis: Legitimate interests (managing participation); Consent (explicit for sensitive data)
Condition: Explicit consent (Article 9(2)(a))
|
To ensure ethical compliance and diversity monitoring
|
Diversity data (e.g., race, ethnicity, sexual orientation)
|
Monitoring diversity for reporting, compliance, and ethical objectives
|
Lawful Basis: Legitimate interests (diversity monitoring and ethical compliance)
Condition: substantial public interest (Article 9(2)(g))
|
To share data with third parties
|
Contact details, recorded contributions, or other relevant data
|
Sharing contributor data with approved third parties (e.g., distributors, broadcasters)
|
Lawful Basis: Legitimate interests (contract fulfilment with third parties)
|
To ensure IT and data security
|
Metadata, access logs, and system usage data
|
Monitoring and protecting IT infrastructure to safeguard contributor data
|
Lawful Basis: Legitimate interests (ensuring data security)
|
Casting and crewing
|
Name, contact details, social media profiles, applications, nominations, health information (if relevant)
|
Recruitment, casting decisions, maintaining databases, contacting about future opportunities
|
Lawful Basis: Legitimate interests (recruitment/casting); Consent (where required)
|
Research for programmes
|
Publicly available information, books, articles, consultant-provided data
|
Researching real-life circumstances for scripted or factual programming
|
Lawful Basis: Legitimate interests (programme research); Substantial public interest (journalistic purposes)
|
Assessing medical fitness
|
Health information, medical assessments, drug tests, STI screenings
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Ensuring participant safety, insurance compliance, offering reasonable adjustments
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Lawful Basis: Legitimate interests (ensuring safety); Legal obligation (insurance)
Condition: Medical purposes (Article 9(2)(h))
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Managing medical problems or emergencies
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Health information
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Sharing health data with medics in case of illness or injury during production
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Lawful Basis: Vital interests (protecting life)
Condition: Medical purposes (Article 9(2)(h))
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Duty of care background checks
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Employment history, social media posts, criminal records, court proceedings
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Conducting checks for safeguarding, health and safety, and duty of care purposes
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Lawful Basis: Legitimate interests (safeguarding); Legal obligation (where applicable)
Condition: Substantial public interest (Article 9(2)(g))
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Recording, editing, and producing content
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Name, image, voice, recorded contributions
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Filming, editing, and producing programmes for broadcast or commercial use
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Lawful Basis: Legitimate interests (programme production); Consent (where required)
Condition: Journalistic purposes (DPA 2018, Schedule 2, Part 5)
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Using your property for filming
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Name, address, contact details, bank details, property ownership details
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Arranging logistics, filming setup, and payments
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Lawful Basis: Contractual necessity (property agreements); Legitimate interests (production logistics)
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Filming in public places
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Images, incidental recordings of individuals
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Recording footage in public areas, offering opt-outs to those filmed
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Lawful Basis: Legitimate interests (journalistic purposes); Public interest (freedom of expression)
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User-generated content (UGC)
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Images, videos, stories submitted by contributors or audience members
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Collecting and using UGC for productions or competitions
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Lawful Basis: Legitimate interests (engaging audiences)
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Broadcasting and VOD
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Name, image, voice, recorded contributions
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Selling/licensing programmes for broadcast, repeats, re-edits, or VOD services
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Lawful Basis: Legitimate interests (distribution);
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Promotion and marketing
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Name, image, footage, contributions
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Using personal data in promotional material or programme advertisements
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Lawful Basis: Legitimate interests (promoting content)
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