Privacy Notice 

COLLECTIVE MEDIA GROUP LIMITED 

Last updated 15th December 2022 

This Privacy Notice explains what personal data (information) we will hold about you, how we collect it, and how we will use and may share information about you, and your rights as a data subject. 

Your information is very important to us and we will look after it in line with privacy and data protection laws, including the EU General Data Protection Regulation and UK Data Protection Act 2018. 

This Privacy Notice is for  

1. people who provide on screen and off screen contributions to our productions such as interviewees, actors, experts, musicians, presenters, writers, composers, and other people who attend recordings or filming, or who provide materials or filming locations for our productions; 

1. people who have applied to contribute to our programming or who we are considering as potential contributors; 

1. people who are the subject of our programming; 

1. our employees and freelancers; 

1. individuals who supply us with services or who we have a commercial or business relationship with. 

This Privacy Notice is not part of any contract you may have with us. It may be updated at any time and must read in conjunction with any additional privacy notices or processing notices we may give you and is not intended to override them. 

Note regarding Children – This Privacy Notice applies adults and to children aged under 18 years old and we may lawfully process the personal data of under 18’s provided we carefully protect the interests of the child. Unless necessary in certain cases of journalism or otherwise where parental consent is not required in accordance with the Ofcom Broadcasting Code, we ask children to get their parents or guardians’ permission before you provide us with personal data. 

 

1. Who collects information about you? 

We are Collective Media Group Limited (company number 13501972) (CMG) and where we collect your personal data we are a ‘data controller’. This means that we are responsible for deciding how we hold and use certain information about you. You can contact us regarding this privacy policy at [email protected]  or write to us at CMG Privacy Team, 1 Butterwick, London, W6 8DL 

  

1. What is personal data? 

Personal data (also referred to as information in this privacy notice) is information that relates to an identified or identifiable individual  

Where we refer to “Special Category Data” this means data concerning racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); health; sex life; sexual orientation. 

 

 

1. How do we collect personal data and what personal data may we collect?  

 We may collect information about you from you or your agent directly, and we may also collect information ourselves from third parties and other sources, and this information may include the following. 

1. Information collected from you directly: 

You may provide certain personal data to us as part of your contribution. This could be your image, name, voice, photos of yourself, views of your property and other information contained in your contribution that identifies you. You may also provide us with “Special Category Data” in this process. 

You also provide information in your contract with us and any other conversations, interviews, or correspondence with,  questionnaires and forms you or your representative or agent may complete concerning your contribution or relationship with us, which may include details such as your name, email address, postal address, phone number, and may include further information such passport details or other national identifier, driving licence, your national insurance or social security number and income, employment information and details about your previous roles and personal history. If we pay you for your contribution, you may provide us with your banking details. We may also collect “Special Category Data” – for example information about your physical or mental health to assess your suitability to contribute to one of our productions, or to make adaptations to accommodate you and ensure your welfare; to obtain and administer insurance, and to arrange and administer any medical treatment you may need or to ensure your mental and physical wellbeing. 

(ii) We may also collect data from other sources, e.g.  

• publicly available and accessible directories and sources 
• social media platforms, including Facebook, Instagram, Twitter, Linkedin
• subscription only databases such as Factiva, Lexis Nexis and Reuters 
• tax authorities, including those that are based outside the UK and the EEA if you are subject to tax in another jurisdiction 
• governmental and competent regulatory authorities to whom we have regulatory obligations 
• agents and production companies 
• fraud prevention and detection agencies and organisations 
• where we need to do so for regulatory purposes, and this is in the public interest, crime enforcement and criminal records agencies such as Disclosure Scotland and uCheck
• where we gather information by virtue of our filming, journalism and/or research, including if you are in a public place or involved in a story, where we exercise our right to include you in stories we will be broadcasting.

The information we collect will depend on the nature of the production or other relationship we have with you. In the case of special category data, we will explain what information we need and we may issue you with a supplemental privacy notice. 

 

1. How do we use your information? 

We process your information for the purposes of running our business, including for production, broadcasting, distribution and marketing, and for the day to management of staff, freelancers and suppliers. 

As a ‘data controller’, we are required to have a legal basis for processing your personal data.  

Below we set out the most common reasons why we will process your information and the principal legal basis in each case.  In certain circumstances different legal bases will apply, and we may need to process information for other reasons, but we will always process in accordance with the law. 

  

(i) The performance of contracts between us and you; 

This includes the processing of information we consider necessary to perform the contract such as your name, contact details and address, your remuneration, your bank details, your references, any checks we may make to verify information provided or background checks. Such processing shall include, where necessary sharing your contact information and bank details with third parties for the purposes of enabling payment of any residuals or other fees to the extent that these are payable to you in accordance with the terms of our agreement. 

If relevant, we may also process information concerning your health and any disability in connection with any adjustments to filming arrangements. 

Legal basis for processing: To perform our contract with you and to comply with our legal obligations.  

  

(ii) Financial planning and budgeting 

This includes processing of information connected with your services. 

Legal basis for processing: Necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms.  

  

1. Contacting you (or others on your behalf, such as your agent) in connection with your contribution or potential in our productions. 

This includes processing any contact information you have provided to us or which we have obtained independently, including your address and phone number, emergency contact or next of kin information. 

Legal basis for processing: Necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms.  

  

1. When considering your suitability as a potential contributor or service provider for one of our productions and to determine necessary provisions for your and others’  welfare. 

This includes information which we consider is likely to be relevant in assessing whether you’ll be a suitable contributor, or subject of the programme, which may include your date of birth, information about your work; your life experience, home and family life; your interests and personality; any previous TV appearances; connection to the production subject matter as well as other information relevant to the production and may include (if we deem necessary for the purposes of the production and our commercial and reputational interests)  matters relating to your reputation and past, financial situation and social media presence. If relevant, we may also process information concerning your physical and mental health and/or any disability in order to determine the impact the programme may have on you and to safeguard your welfare and the welfare of other participants, and also to understand what adjustments to filming or interviewing arrangements may be necessary to accommodate your contribution. 

Legal Basis for Processing: Necessary for our legitimate interests to arrange the involvement of individuals to contribute to or assist in our business of developing and producing television programming,  journalistic, artistic or literary material which we believe is in the public interest and to manage and administer our respective businesses effectively and properly, and to ensure the welfare of yourself and others,  where we consider that our or a third party’s legitimate interests do not override your own interests, rights and freedoms 

 

 

1.  Enabling the creation, sale, marketing, promotion and distribution/broadcast of a production you contribute to, participate in or are the subject of. 

This includes processing of information connected with your contribution or portrayal, such as the processing of images, video and/or audio relating to you. Such processing shall include, where necessary, sharing your information with third parties, including the relevant commissioning party (‘Commissioner’), Silvermouse and Soundmouse and distribution businesses. 

As a producer for television we consider we have a legitimate interest in processing your information as follows: 

 

1. to produce, market and exploit programming and individual contributions therein, and associated material e.g. clips, promotional material and material which is filmed or collected by us but not used in the finished programme;  

1. to assess your involvement and continuing involvement in the programme that you are contributing to and potential involvement in subsequent  programmes.;  

1. to verify your age, identity and other information if necessary and as we may require for the production and exploitation of the programme we are producing;  

1. to include it in programming in the public interest of journalism and otherwise keeping the public informed and producing relevant and entertaining programming for the public consumption;  

1. to license the programme to UK broadcasters and exhibitors and platforms in any media and location and technologies around the world to enable the programme and excerpts to be made available to the public, and to retain a copy of the programme and your contribution within the programme, for the purpose of making the programme available for distribution on an ongoing basis and as source of archive material in the public interest.  

1. to comply with applicable regulatory obligations relating to the programme;  

1. to respond to inquiries or complaints or other communications from third parties arising in relation to your participation or involvement;  

1. to deal with your representatives or agents;  

1. to share with our professional advisors, co-producers, broadcasters and distributors;   

1. in the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers In such circumstances the acquirer of the information will become the new data controller;  

1. to pass on to a competent regulator, prosecutor or competent authority or law enforcement authorities including without limitation the UK Information Commissioner and/or the Office for Communications (OFCOM) should it be requested from us;  

1. to comply with our auditing, accounting and tax reporting requirements;  

Legal basis for processing: (i) Necessary for our legitimate interests or those of a third party to use and publish your contribution and personal information as journalistic, artistic or literary material which we believe is in the public interest and to manage and administer our respective businesses effectively and properly (as examples set out above), where we consider that our or a third party’s legitimate interests do not override your own interests, rights and freedoms (ii) where we have a contract with you, the performance of the contract (iii) in respect of certain programme (for example, journalistic programming, we may process you data for the purposes of journalism and archiving material in the public interest. 

  

1. Contacting you in relation to opportunities to contribute on further productions we may be working on. 

This includes processing of your contact information. 

Legal basis for processing: Consent, where we have asked for your consent to contact you for such purposes. Where we do not have your consent or you have withdrawn your consent, we may consider it is necessary for our legitimate interests to manage and administer our business effectively, including for marketing purposes, where our legitimate interests do not override your own interests, rights and freedoms.  

 

1. Monitoring of diversity and equal opportunities. 

This may include 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.  

Legal basis for processing: (i) Necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms. 

Major UK broadcasters participate in an industry-wide diversity monitoring initiative called Diamond which uses personal information of on and off screen contributors to report on diversity in UK TV production. If you have provided us with your email address we will share this with Creative Diversity Network Limited (CDN), SoundMouse and Silvermouse. CDN will contact you to ask whether you are willing to contribute to the project by providing certain information regarding your diversity characteristics such as; gender, ethnicity, disability, age, gender identity and sexual orientation. This information is collected, processed and stored anonymously on the Diamond system, with the relevant data being jointly controlled by CDN and the main UK broadcasters including the BBC, ITV, C4, C5, and Sky.   If you provide CDN with your diversity data, they will issue you with a separate privacy notice. 

 

1. Physical and system security 

This includes any CCTV footage and records of use of swipe cards and similar entry cards. 

Legal basis for processing: To comply with our legal obligations and where it is necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms. 

  

(viii) Disputes and legal proceedings. 

This includes any information relevant or potentially relevant to a dispute or legal proceeding affecting us. 

Legal basis for processing: To comply with our legal obligations and where it is necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms. 

  

(ix) Day to day business operations including marketing and travel on our behalf (where relevant). 

This includes information relating to your contribution in a production and may include a photograph or profile of you as well as details of travel arrangements and location. 

Legal basis for processing: Necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms. 

 (x) Maintaining appropriate business records during and after your participation in a programme. 

This includes information relating to your contribution in one of our productions. 

Legal basis for processing: To comply with our legal obligations and where it is necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms. 

Note regarding Special Category Data and Criminal Convictions 

Where we process your Special Category Data or details of your criminal convictions one of the following grounds will also apply: 

1. You have provided us with explicit consent (i.e. you have affirmed your consent in a clear statement whether oral or written). 

1. We need to fulfil our legal and regulatory obligations and exercise our obligations  and rights conferred by law on us as an employer and we have an appropriate policy document in place– e.g. for the health and safety of our crew, programme contributors, and others. 

1. You have manifestly made the information public (including where you have done so when participating in one of our productions). 

1. We need to process the data for the establishment, exercise or defence of legal claims 

1. The processing is necessary for reasons of substantial public interest based on the law (e.g. where necessary for reviewing equality of opportunity, our health and safety obligations, in connection with journalism in connection with unlawful acts or dishonesty or for insurance purposes). 

1. Where necessary for you to receive medical treatment from a medical professional. 

1. Where we have reasonably determined that compliance with any of the lawful conditions for processing Special Category Data is incompatible with the journalistic and/or artistic and/or literary purposes of the production in question, and we believe that publication and exploitation of the production is in the public interest. 

 

Where we are relying on explicit consent and we do not consider we are able to rely on any of the other grounds above, we may not be able to continue with your involvement in the production or engagement. 

Note regarding Special exemptions under the Data Protection Act 2018 

We may rely on legal exemptions to certain data protection rules in relation to journalistic or artistic purposes or, more generally, the right to freedom of expression (as mentioned in Article 85 of the EU General Data Protection Regulation and in Schedule 2 Part 5 of the Data Protection Act 2018), where we  

1) process data with a view to publishing journalistic or artistic material;  

2) reasonably believe publication is in the public interest; 

3) believe that compliance with the particular data protection rule is incompatible with our journalistic purposes.  

 

1. Who will you share my information with? 

We may share your information internally within our business to those employees and freelancers working on your production or who otherwise need to know the information in order to perform their duties. Your information may also be seen by managers and administrators (including, for example, our finance team) for purposes of production, broadcasting, distribution, marketing, administration and management. 

We will only share your information with third parties outside our group where disclosure is consistent with a legal basis for processing on which we rely and where this is lawful and fair to you. We may disclose your information if it is necessary for our legitimate interests or the interests of a third party but will not do this if these interests are overridden by your interests and rights in particular to privacy. 

We may also share your data with third party data processors who we have instructed to carry out services and who will process your data only as instructed by us. 

Specific circumstances in which your information may be disclosed include: 

 

• Disclosure to external recipients of electronic communications (such as emails) which contain your information; 
• 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. 

  

1. Transfers of information outside the EEA 

In connection with our business and for production, broadcasting, distribution, administrative, management, marketing and legal purposes, we may transfer your information outside the EEA to members of our group and data processors in the US and on occasion other jurisdictions in which we are established.  Whenever we transfer your information outside the  EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented. Please contact us if you want further information about the specific mechanism used by us when transferring your personal information outside the EEA. 

 

1. Keeping your personal information secure 

We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. 

We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

  

1. How long with you keep my information for? 

We will keep the information we obtain about you when you provide contributions to us for no longer than is necessary for the purposes for which it is processed. In general, we will keep your information until the production has been produced and whilst it is still being actively distributed. In considering how long to keep it, we will consider its relevance to our business and your contribution either as a record or in the event of a legal claim. 

 We will retain contracts for a minimum of 6 years from the date of the contract. 

Some information, such as production footage of your contribution will be held indefinitely as we have an ongoing legitimate interest in retaining this. 

  

1. Your rights 

Under certain circumstances, by law you have the right to: 

1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. 

1. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. 

1. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

1. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. 

1. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we restrict processing your personal information, please contact Liz Knowles in writing at liz.knowles@collectivemedia.group. 

 

1. Who to contact with queries or if you have a complaint 

Our Production Executive is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Production Executive at liz.knowles@collectivemedia . We hope that any query or concern you raise about our use of your information can be resolved but if not, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.  

See https://ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.