SCHEDULE 1 – PRIVACY NOTICE
This notice explains how we handle your personal data. It includes the additional
information at the end of the document (“Additional Information”) where we explain what
we mean by “personal data”, “processing”, “special category data” and other terms
specifically used in this privacy notice. This notice does not create contractual rights or
obligations and may be amended by us at any time.
1. The data we hold and why we process it
We process data for the purposes of running our business including for production,
broadcasting, distribution and marketing. The Additional Information section provides more
specific information on these purposes, on the type of data that may be processed and on
the grounds on which we process data.
2. Where the data comes from and who we share it with
The personal data that we process about you comes from you, which can include your
name, age and email address or, for example, your bank details which are required in order
to make payments to you. It may be seen by our staff and contractors who are working on
the production and we may also pass your data outside the organisation, if applicable (eg
third party payroll agencies).
3. How long do we keep your personal data for? PLEASE ASK TO SEE OUR RECORD
RETENTION SCHEDULE IN SCHEDULE 2 - DATA PROTECTION
4. Transferring data outside the EEA
We may transfer your personal data outside the EEA where we have a foreign server
storage provider. If you featured in a production, the data constituting your performance
may be transferred out of the EEA for programme broadcast, distribution and marketing
5. Your rights
You have a right to make a subject access request to receive information about the data
that we process about you, as set out in the Additional Information.
In processing your personal data, we act as a data controller and our main point of
contact for data-related matters is the DPO.
“personal data” is information relating to you that identifies you and includes not only facts
about you, but also intentions and opinions about you.
Personal Data 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.
“special category data” is 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 “special category data”.
References in the Crew 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 for legitimately processing personal
data. In some contexts more than one ground applies which are summarised below as Legal
obligation, Legitimate Interests and Consent and outline what those terms mean in the
3. Processing Special category data
If we process special category data about you, we will only carry this out for one of the
permitted reasons under Schedule 8 of the Data Protection Act 2018, including where it is
necessary at law or where there is substantial public interest in doing so.
4. Further information on data we process
The following is a short list of examples of what kind of personal data we may process and
the grounds for doing so. We may also require criminal background checks for certain roles
– for example those working with minors.
If you are appearing in one of programmes (in the background or in the ‘behind scenes’
versions of the Programme), 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- as above
6. Who gets to see your data
Internal use: Your personal data may be disclosed to our employees working on your
External use: We will only disclose your personal data outside our company 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 (including any appearance in a ‘behind the scenes’ or
‘making of’ documentary for the Programme), 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
7. Retaining your Personal Data- PLEASE SEE RECORDS RETENTION SCHEDULE 2 - DATA
8. 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,
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.