Contributor Privacy Notice
PRIVACY NOTICE – CONTRIBUTOR & TALENT
In accordance with UK data protection law, CTVC Limited, whose registered office is at 5th Floor, 16 – 18 Kirby Street, London, England, EC1N 8TS, has prepared this privacy notice for individuals who participate or appear in our media productions as contributors or talent.
This may include presenters, performers, interviewees, experts, participants, members of the public and other on-screen or recorded contributors.
This privacy notice explains:
- what personal data we process;
- why we process it;
- the lawful bases on which we rely;
- how long we retain it;
- who we share it with; and
- your rights.
Scope
This notice applies to current and former Contributors and Talent engaged or considered for engagement in connection with CTVC productions.
It does not apply to CTVC employees, workers, production crew, freelancers or job applicants, who are covered by separate privacy information where applicable.
Data Protection Principles
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles.
In accordance with these principles, we will ensure that:
- processing is fair, lawful and transparent;
- data is collected for specific, explicit, and legitimate purposes;
- data collected is adequate, relevant and limited to what is necessary for the purposes of processing;
- data is kept accurate and up to date;
- data which is found to be inaccurate will be rectified or erased without delay;
- data is not kept for longer than is necessary for its given purpose;
- data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures; and
- we comply with the relevant GDPR procedures for international transferring of personal data.
Types of Data We Hold
Personal data is any information about an individual from which that person can be identified. It does not include anonymous data which does not identify the individual.
We collect, store and use several categories of personal data on our Contributors and Talent to carry out effective and efficient processes. We keep this data in files relating to each individual and we also hold the data within our computer systems.
It is your responsibility to keep us up to date with any changes to your personal details so that we can make sure that your personal data is accurate.
We may collect, store and use personal data about Contributors and Talent where relevant to a production. This may include:
- identification and contact details;
- biographical and professional information;
- photographs, voice recordings, video footage, audition or casting material;
- contribution forms, release forms and contracts;
- payment, tax and bank details;
- travel and accommodation information;
- emergency contact details;
- accessibility, dietary, medical or welfare information needed to support participation safely;
- right to work or identity documentation where required;
- information relevant to safeguarding, insurance, compliance or production risk assessments;
- correspondence with you or your agent or representative; and
- information created through your participation in the production.
Collecting Your Data
In addition to administrative records, we may record, edit, reproduce, distribute, broadcast, stream, promote, archive and otherwise use your name, image, likeness, voice, performance, contribution and biographical information in connection with the relevant production and its exploitation, publicity and promotion, subject to the terms of any agreement or release applying to your participation.
You may provide personal data to us directly when you:
- make an enquiry;
- take part in casting or research;
- complete a contributor or talent form;
- enter into an agreement;
- attend a production; or
- communicate with us.
We may also receive information from:
- your agent or representative;
- a casting agency;
- production partners;
- broadcasters;
- commissioners;
- publicly available sources;
- people who nominate or refer you; or
- other individuals involved in researching and producing the programme.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers when gathering references or credit reference agencies.
Personal data may be held in production files, contributor or talent records, contracts, release forms, correspondence, audio-visual production material and CTVC’s secure IT systems.
Lawful Basis for Processing
Data protection law permits us to process personal data only where we have a lawful basis.
Depending on the circumstances, we may process your data because:
- it is necessary to take steps at your request before entering into an agreement or to perform our agreement with you;
- to comply with a legal obligation;
- for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests; or
- because you have given consent.
The applicable basis will depend on the particular processing activity.
Principal Processing Activities and Lawful Bases
The table below summarises the principal ways in which we process personal data about Contributors and Talent and the lawful bases on which we rely. The applicable basis will depend on the circumstances and the type of data involved.
| Activity requiring your data | Lawful basis |
|---|---|
| Researching and assessing potential Contributors and Talent | Our legitimate interests in researching, developing and casting suitable participants for productions; consent where required. This may include the results of any background checks undertaken using third party search tools, and/ or on social media platforms to ensure you meet our eligibility criteria for a programme. |
| Communicating with you or your agent or representative and arranging your participation | Taking steps at your request before entering into an agreement; performance of an agreement; our legitimate interests in managing productions effectively |
| Entering into and administering contributor releases, appearance agreements or talent agreements | Taking steps at your request before entering into an agreement and performance of an agreement |
| Making payments and meeting tax, accounting and reporting obligations | Performance of an agreement and compliance with legal obligations |
| Recording and editing your contribution, image, likeness, voice or performance | Performance of an agreement; our legitimate interests in producing editorial content including for journalistic purposes where applicable; consent where applicable |
| Producing, distributing, broadcasting, streaming, promoting and archiving the production | Performance of an agreement; our legitimate interests and those of production partners in exploiting, promoting and preserving the production; consent where applicable |
| Arranging travel, accommodation, access requirements and welfare support | Performance of an agreement; compliance with legal obligations; our legitimate interests in supporting safe and effective participation; explicit consent where required for special category data |
| Managing health and safety, safeguarding, insurance and production security | Compliance with legal obligations; our legitimate interests in protecting participants, personnel and productions; an applicable condition for special category or criminal offence data |
| Responding to complaints, disputes or legal claims | Our legitimate interests in protecting our legal position and managing disputes; compliance with legal obligations |
| Complying with legal, regulatory, court or law-enforcement requirements | Compliance with legal obligations |
| Maintaining secure IT systems and production records | Our legitimate interests in ensuring the security, integrity and availability of our systems and personal data; compliance with legal obligations |
Special Categories of Data
Special categories of data are data relating to your:
- health;
- sex life;
- sexual orientation;
- race;
- ethnic origin;
- political opinion;
- religion;
- trade union membership; and
- genetic and biometric data.
We may process special category data where it is relevant and necessary for a production. This may include:
- health or disability information needed for access, welfare, insurance, safeguarding or health and safety;
- racial or ethnic origin, religious or philosophical beliefs, political opinions, sexual orientation or other sensitive information where it forms part of your contribution or the subject matter of the production; and
- diversity information collected for monitoring purposes.
We will identify an appropriate condition for processing this data and apply additional safeguards.
Special category data may also be processed, where applicable:
- for the purposes of equal opportunities monitoring;
- in our sickness absence management procedures; or
- to determine reasonable adjustments.
Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing; or
- we must process the data to carry out our legal obligations; or
- we must process data for reasons of substantial public interest; or
- you have already made the data public.
Failure to Provide Data
If you do not provide personal data that we reasonably require, we may be unable to:
- assess or arrange your participation;
- enter into or perform an agreement with you;
- make a payment;
- meet legal or safety requirements; or
- include your contribution in the production.
Criminal Conviction Data
We will collect information about criminal convictions or offences only where this is relevant to the production or your proposed participation and where the law permits us to do so.
This may arise, for example, where safeguarding, access to vulnerable individuals, insurance, security or regulatory requirements make such information necessary.
We will identify both a lawful basis and an additional legal condition for processing this information and will apply appropriate safeguards.
Who We Share Your Data With
Access to your personal data will be limited to CTVC personnel who need it for research, casting, editorial, legal, compliance, safeguarding, production management, finance, distribution, publicity or other relevant production functions.
We may share relevant personal data with:
- your agent or representative;
- production crew and production companies;
- broadcasters, commissioners, distributors, streaming platforms and exhibitors;
- post-production, subtitling, dubbing, access-services and archiving providers;
- publicity, marketing and press agencies;
- travel, accommodation, security, medical, welfare and safeguarding providers;
- insurers;
- payment, accounting and tax advisers;
- IT and hosting providers;
- professional advisers;
- regulators, law-enforcement bodies or courts; and
- other recipients where sharing is necessary for the production, its distribution and promotion, or compliance with legal obligations.
We may also share your data with third parties as part of an Organisation sale or restructure, or for other reasons to comply with a legal obligation upon us.
We have a data processing agreement in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
International Transfers
We may share your personal data with recipients located outside of the United Kingdom and European Economic Area (EEA), including countries where we engage freelancers, contractors, or production partners.
These may include countries in which our production activities take place or where our service providers are based.
The reason for these transfers is to:
- support the development, production, post-production, distribution, broadcast, streaming, promotion and archiving of our productions;
- manage your participation and any associated travel or payment arrangements; and
- obtain IT, hosting and professional support services.
Where we transfer personal data outside of the UK/EEA, we ensure that appropriate safeguards are in place in accordance with UK data protection laws.
These safeguards may include the use of International Data Transfer Agreements (IDTAs) or other legally approved mechanisms to ensure your data is protected to an equivalent standard.
Protecting Your Data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
Retention Periods
We retain personal data only for as long as required for the purpose for which it was collected and to meet legal, regulatory, accounting, reporting, insurance, safeguarding and contractual requirements.
Contributor and Talent agreements, releases, payment and tax records, editorial records and records evidencing permissions may be retained for the period during which the production is exploited and for an appropriate period afterwards.
Recorded contributions and completed production material may be retained for archive, editorial, evidential and exploitation purposes.
Casting or research information relating to individuals who do not participate will normally be deleted or anonymised after an appropriate period, unless there is a lawful reason to retain it for longer.
More sensitive production welfare, medical or safeguarding information will be retained only for as long as necessary for the relevant purpose.
In some cases, we may retain your personal data for longer where necessary to comply with legal obligations, resolve disputes, or defend legal claims.
Automated Decision-Making
Automated decision-making means making decisions about you using no human involvement, eg using computerised filtering equipment.
No decision will be made about you solely based on automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Your Data Protection Rights
You have the following rights in relation to the personal data we hold on you:
- Right to be informed: the right to be informed about the data we hold on you and what we do with it.
- Right of access: the right of access to the data we hold on you. More information on this can be found in our separate policy on subject access requests.
- Right to rectification: the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected.
- Right to erasure: the right to have data deleted in certain circumstances.
- Right to restriction: the right to restrict the processing of the data.
- Right to data portability: the right to transfer the data we hold on you to another party.
- Right to object: the right to object to the inclusion of any information.
- Rights relating to automated decision-making and profiling: the right to regulate any automated decision-making and profiling of personal data.
Further information about these rights and how to exercise them is available from our data protection contact using the details below.
Consent
Where we rely on consent to process your personal data, you may withdraw that consent at any time by contacting us.
Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.
It may not require us to stop processing where another lawful basis applies or where continued retention or use is required or permitted by law.
Making a Complaint
If you consider that your data protection rights have been breached, you may contact CTVC’s data protection contact using the email address, postal address or telephone number stated at the end of this notice.
Email: officeadmin@ctvc.co.uk
Post: 5th Floor, 16 – 18 Kirby Street, London, England, EC1N 8TS
Telephone: 020 7940 8480
More information is available in our separate Data Protection Policy.
Complaining to the ICO
You can also raise a complaint with the Information Commissioner (ICO). You can contact the ICO at:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Alternatively, you can contact the ICO by telephone on 0303 123 1113 (local rate) or 01625 545 745.
Data Protection Compliance
Our appointed compliance officer in respect of our data protection activities is:
Rebecca Porter