Contributor Privacy Policy

  1. 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:

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.

 

  1. 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.

 

  1. 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.

 

  1. 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:

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:

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.

  1. 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:

 

  1. 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:

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.

  1. 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).

  1. 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.

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  

  1. What do we do with children's personal information?

As a general rule we take the following approach to children in the UK:

Otherwise, we take additional precautions when using children’s personal information such as:

  1. 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.

  1. 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:

  1. 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.

  1. 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

Personal Data Used

Activity

Lawful Basis and Condition

To produce and broadcast a programme

Name, contact details, recorded interviews, images, and footage

Collecting, recording, editing, and broadcasting contributor content

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

Health information, emergency contact details

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

To verify eligibility to participate

Identification documents (e.g., passport), age, proof of work eligibility

Verifying identity, confirming age, and ensuring compliance with legal requirements

Lawful Basis: Legal obligation (right-to-work checks); Legitimate interests (eligibility verification) 

To manage contributor payments

Bank details, tax information

Processing payments, issuing invoices, and maintaining financial records

Lawful Basis: Contractual necessity (payment processing); Legal obligation (tax compliance) 

To archive the programme or materials

Recorded interviews, images, and footage

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)

To address complaints or disputes

Contact details, correspondence, and relevant contributions

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

Images, footage, and contributions

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

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))

To conduct audience or statistical research

Demographic data, anonymised or pseudonymised data

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))

To comply with safeguarding obligations

Information on vulnerable contributors (e.g., children, health information)

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))

To manage contributor contracts

Contact details, signed agreements

Preparing, signing, and managing contributor contracts

Lawful Basis: Contractual necessity (contract performance) 

 

To handle allegations of misconduct

Relevant personal data, including sensitive information (e.g., criminal allegations)

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)

To facilitate programme insurance

Personal details, health information (if applicable)

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

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))

To handle legal compliance related to minors

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

Ensuring participant safety, insurance compliance, offering reasonable adjustments

Lawful Basis: Legitimate interests (ensuring safety); Legal obligation (insurance)

Condition: Medical purposes (Article 9(2)(h))

Managing medical problems or emergencies

Health information

Sharing health data with medics in case of illness or injury during production

Lawful Basis: Vital interests (protecting life) 

Condition: Medical purposes (Article 9(2)(h))

Duty of care background checks

Employment history, social media posts, criminal records, court proceedings

Conducting checks for safeguarding, health and safety, and duty of care purposes

Lawful Basis: Legitimate interests (safeguarding); Legal obligation (where applicable) 

Condition: Substantial public interest (Article 9(2)(g))

Recording, editing, and producing content

Name, image, voice, recorded contributions

Filming, editing, and producing programmes for broadcast or commercial use

Lawful Basis: Legitimate interests (programme production); Consent (where required) 

Condition: Journalistic purposes (DPA 2018, Schedule 2, Part 5)

Using your property for filming

Name, address, contact details, bank details, property ownership details

Arranging logistics, filming setup, and payments

Lawful Basis: Contractual necessity (property agreements); Legitimate interests (production logistics)

Filming in public places

Images, incidental recordings of individuals

Recording footage in public areas, offering opt-outs to those filmed

Lawful Basis: Legitimate interests (journalistic purposes); Public interest (freedom of expression)

User-generated content (UGC)

Images, videos, stories submitted by contributors or audience members

Collecting and using UGC for productions or competitions

Lawful Basis: Legitimate interests (engaging audiences)

Broadcasting and VOD

Name, image, voice, recorded contributions

Selling/licensing programmes for broadcast, repeats, re-edits, or VOD services

Lawful Basis: Legitimate interests (distribution);

Promotion and marketing

Name, image, footage, contributions

Using personal data in promotional material or programme advertisements

Lawful Basis: Legitimate interests (promoting content)

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