Data Protection & Privacy

Introduction

The safety of your personal data is extremely important to us, and we take the utmost care and attention to protect it.  We will always treat your personal data in a legal and ethical manner.  The purpose of this Data Protection & Privacy Policy is to set out in a clear manner the information we may collect about you and how we use that information.  We collect, store and use your personal information in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Who We Are 

Bloody Norah TV Ltd (“we”) is a company registered in the UK, with company number 13765538 and whose registered office is at 48 Greys Hill, Henley On Thames, RG9 1SJ, UK.  We are a television production, services and consultancy company that works with a wide variety of different broadcasters, producers, third party suppliers, distributors, financiers, contractors, advisors individuals and other persons and entities.

General Principles

We are required to process your personal data lawfully, fairly and in a transparent manner, and in a manner that ensures appropriate security of the personal data.  Personal data must only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.  The data must be adequate, relevant and limited to what is necessary in relation to those purposes, accurate and, where necessary, kept up to date.  It must be kept in a form which permits identification of data subjects for no longer than is necessary for those purposes. 

Collection of Your Personal Data 

If you are engaged to work for or with us, we will collect various standard information about you, including but not limited to your name, contact details, information from your CV/resume, National Insurance Number, Passport number for purposes of verification of identity and banking details.

If you are an on-screen contributor in any of our programmes we may ask you to provide us with information about you, including your name, address, email address, date of birth and telephone number.  We will also have footage and recordings of you.  In some cases, depending on the nature of the programme, we may also collect your “Special Category Data” (including information regarding your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, and sexual origination/life) and/or your “Criminal Record Data” (including information about criminal allegations, proceedings, convictions and offences or related security information).

Use of Your Personal Data

If we are considering the possibility of you working for or with us, or if you are engaged to work for or with us, we will use your information for the purposes of assessing your skills, qualifications and suitability for the role; communicating with you about the recruitment process; carrying out background and reference checks relating to recruitment; record-keeping; and complying with our legal or regulatory requirements.  If you have consented, we will store your CV and contact details for the purposes of future job opportunities with us. 

If you are an on-screen contributor in any of our programmes, we may use your personal information to complete background checks or otherwise assess your suitability to be a contributor; to administer and manage your participation in the programme; to film and/or record you for the programme and to store and edit such material; to develop, exploit and produce the programme in which you participate; to deliver the programme to a broadcaster for them to exploit; and/or to make any payments due under any contributor release (if applicable).

We will not use your personal information for any marketing or sales purposes. 

Lawful Basis for using Your Personal Data

We will only make use of your personal data if we have a valid reason (known as a “lawful basis”) to do so (or if the limited journalistic exemption applies, which normally relates to investigative-type programming). 

In most cases, we will use your personal information on one or more of the following bases:

1. For the performance of the contract we enter into with you and in order to take steps at your request prior to entering into that contract.

2. In order to comply with a legal obligation to which we are subject (for example, compliance with legal and regulatory requirements and related disclosures; activities in relation to the prevention, detection, and investigation of crime; or verification of your identity).

3. Because it is necessary to pursue our legitimate interests (or the interests of a third party, including broadcasters), always ensuring that your interests and fundamental rights do not override those interests.

  • Legitimate interests may include: the development, production, exploitation, distribution, advertising, publicity and promotion of our programmes and your contribution to them; ensuring the suitability of contributors for programmes; meeting our duty of care obligations to safeguard the welfare of our employees, contractors or programme contributors; ensuring that programmes meet our standards and complies with all legal obligations; establishing, exercising or defending legal claims; protecting your personal information; investigating and preventing fraud; and co-operating with investigations by regulatory bodies and/or law enforcement agencies and/or governmental agencies.

  1. Because you have consented to us doing so.

In addition to having a lawful basis, we will only use your Special Category information if one of the following conditions applies:- 

  • you have given us explicit consent;

  • we need to process such data in order carry out our legal obligations or exercise rights in connection with applicable law;

  • where we need to protect your vital interests;

  • where you have already made the information public;

  • where doing so is necessary for the establishment, exercise or defence of legal claims; or

  • it is necessary for reasons of substantial public interest.

In addition to having a lawful basis, and in the absence of the journalistic exemption, we will only use your Criminal Record data with your consent, where you have already made the information public, or where the law otherwise allows us to do so.

Please note that you are free at any time to change your mind and withdraw your consent. 

Storage of Information

If we collect, process and/or keep any personal information collected from you, we will only do so in accordance with our obligations under the GDPR. 

If you have entered into an agreement with us for us to have your personal information, we will generally keep your personal data until a programme has been produced and for a reasonable period afterwards.  In considering how long to keep it, we will take in to account its relevance to our business and your participation either as a record or in the event of a legal claim.

In certain cases, it may not be physically possible to delete data (for example, where it is stored on a secure external server).  In these cases, we will take appropriate steps to ensure that it is not available for re-use or disclosure to third parties.

Your Rights

You have rights when it comes to how we handle your personal information. These rights include:-

  • The right to be informed about how we are processing your personal data;

  • The right to request access to your personal data and information about how we process it;

  • The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;

  • The right to erasure (also known as the right to be forgotten);

  • The right to restrict processing of your personal data;

  • The right to data portability (i.e., to move, copy and transfer your personal data in an appropriate format); and

  • The right to object and to withdraw your consent to certain processing of your personal data.

Please contact us if you would like to exercise any of these rights.  If we cannot comply with your request to exercise your rights, we will give you a full explanation as to why. 

Sharing Your Personal Information

We may need to share your personal information with third party companies, agents, contractors, service providers or affiliated companies (including without limitation broadcasters, producers, financiers, distributors, and insurance brokers) but only to the extent necessary for the purposes described in this Policy.  We may share your personal information with law enforcement agencies, other governmental agencies or other third parties if we are required by law to do so.  We may also share your personal information with our professional advisors.  Where we share your information with such third parties, we will take all steps necessary under GDPR to ensure that your information is treated securely and in accordance with this Policy.

Your personal data may be transferred outside of the European Economic Area (EEA), including to the USA.  While some countries have adequate protection for personal data under applicable laws, in other countries steps will be necessary to ensure appropriate safeguards to apply to it.  These include imposing contractual obligations.

If we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets which are transferred to the new owner and may be provided to the entities and advisors involved.

No Sale of Personal Information

Under no circumstances will we sell or receive payment for licensing or disclosing your personal information.

Security 

We operate secure data networks that are designed to protect your privacy and security.

Changes to this Policy

We keep this Policy under regular review and we may change it from time to time.  Any updates will be posted on our website or otherwise notified to you. 

Contact Us

If you have any questions about this Policy or the information that we hold about you, please contact: Siangwilliam@bloodynorah.com

Information Commissioner’s Office (ICO)

The ICO is the UK’s independent body set up to uphold information rights.  If you are unhappy about the way in which your information has been handled, you are able to contact the ICO at www.ico.org.uk/concerns.