STUDIO 71 UK LTD CONTRIBUTOR PRIVACY NOTICE

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 when you provide contributions to us.

This Privacy Notice is for individuals who contribute to on-air talent providing contributions to our productions (such as actors, musicians, presenters, writers and composers) and other contributors providing contributions to us (such as interviewees or those providing material like photos or the use of their property as a filming location). It also applies to individuals who have previously contributed to our productions.

1.Who collects information about you?

Studio 71 UK Ltd, for Studio71 GmbH (‘Company’) is a ‘data controller’. This means that we are responsible for deciding how we hold and use certain information about you.

2.What information do we collect about you?

You provide certain information to us as part of your contribution. This could be your image, voice, photos of yourself, views of your property and other information contained in your contribution that identifies you.

You also provide information in your contract with us and any other correspondence with us concerning your contribution, including your name, email address and address. If we pay you for your contribution, you may provide us with your banking details.

3.How do we use your information?

We process your information for the purposes of our business, including for production, broadcasting, distribution and marketing.

As a ‘data controller’, we are required to have a legal basis for processing your personal data. We will use the information we collect about you for:

The performance of the contract and relationship between you and us.

This includes processing of information concerning your taking part in our productions and our assessment of it, the duration of your contract, your remuneration, your bank details, your references, any checks we may make to verify information provided or background checks. If relevant, we may also process information concerning your health, any disability and 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.

Financial planning and budgeting

This includes processing of information connected with your remuneration.

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.

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

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

Enabling the creation, sale and distribution/broadcast of a production you are taking part in.

This includes processing of information connected with your contribution, 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 for purposes of exploitation of your contribution, including the relevant commissioning party (‘Commissioner’), Soundmouse (the rights management platform) and distribution agents.

Legal basis for processing: Necessary for our legitimate interests or those of a third party to publish your contribution 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, where we consider that our or a third party’s legitimate interests do not override your own interests, rights and freedoms.

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, we 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.

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.

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.

Disputes and legal proceedings.

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

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.

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

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

Who will you share my information with?

We may share your information internally within our group to those employees working on your production. 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.

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.

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. Some of our systems are hosted outside of the EEA. Whenever we transfer your information outside the EE, 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.

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.

7. 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 for a period afterwards. In considering how long to keep it, we will take into account its relevance to our business and your contribution either as a record or in the event of a legal claim.

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

8.Your rights

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

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.
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.
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).
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.
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 Tom Payne, Director of Content in writing at tom.payne@studio71uk.com

Please note that if your request is about your contribution itself, we (or third parties, such as the Commissioner for our production) may rely on 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 EU General Data Protection Regulation and in various national laws, including for example in Schedule 2 Part 5 of the UK’s Data Protection Act 2018.

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

Our Data Controller 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[Data Controller at datenschutz@studio71.com. 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.

10.Changes to this Privacy Notice

This Privacy Notice does not form part of your contract and we may amend it at any time.