Contributor Privacy Notice
1. WHAT IS THE PURPOSE OF THIS DOCUMENT?
STV Productions Limited is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are applying to appear on a television show being produced by us for broadcast by Channel Four Television Corporation (the "Programme"). It makes you aware of how and why your personal data will be used, namely for the purposes of the application exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
2. DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.
3. THE KIND OF INFORMATION WE HOLD ABOUT YOU
We will collect, store, and use the following categories of personal information about you:
• The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, gender, your relationship status, employment history and qualifications.
• Any information you provide to us during an interview.
Due to the nature of the Programme and our obligations under broadcasting codes, we will also collect, store and use the following "special categories" of more sensitive personal information:
• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records.
• Information about criminal convictions and offences.
4. HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
• You, the candidate.
• LexisNexis background check provider, from which we collect the following categories of data: any mention of your name in news reports.
• Disclosure and Barring Service and/or Disclosure Scotland in respect of criminal convictions.
• Publicly available sources including search engine results (such as Google) and social media (such as Twitter, Facebook, Instagram).
5. HOW WE WILL USE INFORMATION ABOUT YOU
We need all the categories of information in the list above in order to pursue our legitimate interests as a television production company [*],exercise our rights under any contributor release by you [**], and to enable us to comply with legal obligations [***]. The situations in which we will process your personal information are listed below. We have indicated by asterisks the purpose or purposes for which we are processing or will process your personal information, as well as indicating which categories of data are involved.
We will use the personal information we collect about you to:
• Assess your suitability for Programme. *
• Carry out background and reference checks, where applicable. *
• Communicate with you about the application process. *
• Keep records related to our application processes. *
• Comply with OFCOM requirements. ***
• To film you and to incorporate your contribution in the Programme. **
• Where applicable, to broadcast and distribute the Programme including your contribution. *
• To collect data for an ongoing broadcast diversity project known as Diamond. This data will be used to create statistical reports tracking diversity across the industry. The data will be retained in an anonymous format and will not name or otherwise identify specific individuals. The data collected will relate to the following characteristics: gender; gender identity; age; ethnicity; disability; sexual orientation. *
We also need to process your personal information to decide whether to enter into a contributor contract with you.
6. HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
• Due to the nature of the Programme, we will, where applicable, use information about your home life, relationships, sexual life or sexual orientation, your disability, any health problems, any criminal convictions in our selection process for the Programme.
7. INFORMATION ABOUT CRIMINAL CONVICTIONS
We envisage that we will process information about criminal convictions.
We will collect information about your criminal convictions history if we would like to offer to include you in the Programme. We are entitled to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the Programme. In particular, participation in the Programme requires a high degree of trust and integrity since it involves dealing with sensitive information including sexual life, sexual orientation, personal relationships and relationship counselling and so we would like to ask you to seek a basic disclosure of your criminal records history.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
8. AUTOMATED DECISION-MAKING
You will not be subject to any automated decisions.
9. DATA SHARING
Why might you share my personal information with third parties?
STV Productions Limited is part of the STV Group plc group of companies. We may share your personal information with any member of our group, which means our subsidiaries, and our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We will only share your personal information with the following categories of third parties for the purposes of considering whether to include you as a contributor to the Programme, and producing and distributing the Programme:
• Professional psychiatrists, psychologists and counsellors, who are advising us on contributor suitability for the Programme.
• TV broadcasters who are, or are interested in, broadcasting the Programme in the UK and worldwide;
• Programme distributor(s) who are marketing and selling the Programme on our behalf to international TV broadcasters;
• Pursuant to the Diamond project referred to above, we will share your email address with Creative Diversity Network;
• Where requested to do so, we will share information with the Crown Office and Procurator Fiscal Service, Scottish Prison Service, Crown Prosecution Service, or their equivalents in other jurisdictions;
• In the event that STV Productions Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our company policies or any contributor contract/release entered into by you or to protect the rights, property, or safety of STV Productions Limited, our customers, or others.
10. DATA SECURITY
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal 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 place upon all external data processors, processing data on our behalf to comply with their obligations under UK data protection legislation.
Whilst the Programme may be distributed for broadcast internationally, other than your programme contribution and copies of your contributor contract, we do not transfer any of personal data outside the EEA.
11. DATA RETENTION
How long will you use my information for?
We will retain your personal information for a period of twenty-four months after we have communicated to you our decision about whether to offer to include you in the Programme. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the application exercise in a fair and transparent way. We also retain your information in order to consider you as a prospective participant in the event that last minute or additional vacancies in the Programme or subsequent series of the Programme within the twenty-four month period becomes available. After this period, we will securely destroy your personal information in accordance with our data retention policy.
Where you are included as a contributor to the Programme, the Programme may be distributed indefinitely to broadcasters, and as such your information will be retained indefinitely in order to demonstrate your agreement to be included in the Programme. Where the information is no longer required, we will limit our retention of data to the extent possible while retaining sufficient data in order to enable the continued distribution and sale of the Programme.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future in connection with the Programme and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
12. YOUR RIGHTS
By law you have the right to:
• Request access to a copy of the personal information we hold about you (commonly known as a "data subject access request").
• Request correction of the personal information that we hold about you.
• Request erasure of your personal information where there is no good reason for us continuing to process it..
• 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. If you have given us permission to hold onto your details for marketing purposes (for other programmes), you can instruct to stop sending marketing communications at any time.
• Request the restriction or suspension of processing personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
• Make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would of course appreciate being given the opportunity to resolve any complaint you may have directly with you in the first instance.
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 transfer a copy of your personal information to another party, please contact us via email@example.com.
If you have any questions about this privacy notice or how we handle your personal information, please contact us via firstname.lastname@example.org.
Created: 10 May 2018