Privacy Policy | BBC Studios Productions

PRIVACY POLICY FOR CONTRIBUTORS

Updated 3 August 2022

1. Who We Are

BBC Studios is the commercial production and distribution arm of the British Broadcasting Corporation (the ”BBC”). We are a global business that funds, creates, distributes and commercialises content for the BBC and other companies both in the UK and internationally.

2. Scope of this Privacy Policy

This Privacy Policy applies to the collection of personal data relating to contributors to programmes and content produced by BBC Studios Productions Limited (and/or its subsidiary production companies). BBC Studios Productions or the relevant subsidiary is the “data controller” of such information, meaning we decide what your personal information is used for, and the ways in which it is processed.

By "contributors", we mean:

on-air talent (such as actors, musicians, presenters, writers and composers);
people applying to be in our programmes (such as to appear on an entertainment show);
people submitting stories or content for potential inclusion in our programmes (e.g. stories about their consumer experiences or entries to a photo competition);
other people providing contributions for our programmes (e.g. experts being interviewed or people letting us use their property as a filming location); and
people representing contributors (such as agents).

This policy explains what personal data we collect and how we use it. It supplements (and is consistent with) the BBC Privacy Notice for Contributors , which is linked to from some of our contracts and other documentation for BBC commissioned programmes. If you are engaged on an employment contract then you should instead refer to the BBC People Privacy Notice .

For non-contributors, please refer to the BBC Studios Group Privacy Policy .

3. Information We Collect

As a contributor you provide information about yourself, and sometimes about others (such as your children or members of your household). For example, in an application form, talent contract, contributor release form and correspondence with us about your contribution, you may include information such as (where relevant):

Your name
Contact details (e.g. Email address, home address, phone number)
Date of birth
Gender
Nationality / Residence status
Financial details including bank account information
National Insurance number / US social security number
Passport number
Biographical information
Dietary preferences/allergies
Mental and/or physical health
Background information/references

If applying to be in a programme, providing us with a consumer story for consideration or sending us User Generated Content (“UGC”), you may include biographical information about yourself and others, along with other information which you either choose to provide, or which is requested during the application process.

You also provide personal data 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. This data you provide could also include equivalent information relating to other individuals such as members of your family.

Special Category and Criminal Offence personal data

You might also share with us “Special Category” or “Criminal Offence” personal data relating to your:

race or ethnicity
political opinions
religious or philosophical beliefs
trade union membership
health
sex life or sexual orientation
genetics or biometrics
criminal convictions and offences

You may share such information with us for diversity monitoring purposes or to enable us to assess your suitability to participate as a contributor – further details provided in ‘How we use your personal data’. You may also share this type of information due to the nature of the programme you are participating in. Your personal information will be collected and processed securely with safeguards in place to protect your rights and freedoms.

Socio-economic information

You might also choose to share with us information about:

the type of school you attended
your eligibility to free school meals
occupation of the main earner when you were growing up
your parent’s attendance at university.

This is called socio-economic information.

Information from other sources

We may collect information about you from public sources (such as social media) industry contacts and public opinion through surveys and market research.

4. How we use your personal data

We may use your personal data for the purposes listed below, or as otherwise notified to you at the time we collect your information:

Managing the relationship between you and us

We will use your contact information, release form and/or contract and your onboarding information for rights management purposes, making payments, contacting you or your agent about the engagement and other purposes for the exploitation or use of your contribution. We may also use your information to contact you about future opportunities to contribute to our programmes.

Assessing your medical fitness to participate

We may need to collect information relating to your physical and mental health for the purposes of carrying out health and safety assessments, in accordance with our legal obligations and/or for insurance purposes.

We do this by via fitness to participate forms and during production as necessary. We will only use this information to determine your medical fitness to participate as a contributor. Your information may be shared with medical experts, our insurers and, where relevant, psychologists (e.g. if we decide we need an independent, expert opinion on your medical fitness to participate as a contributor).

Where relevant, we may collect information about your health during a production to enable us to manage your wellbeing and the filming schedule. For example, if you were to become pregnant, we will need to know information such as your due date. If you become ill with a contagious illness such as COVID-19, we will need relevant information about any required self-isolation and who you may have been in close contact with on the production.

If you are taking in part in a production that requires PCR testing as part of its COVID-19 safety protocols, we will need to process certain information in order to manage the testing and to comply with relevant Government guidance. More information is provided in the Privacy Notice for PCR Testing which will be provided to you along with information about testing requirements.

Background Screening

We may carry out background screening of contributors using publicly available sources, including online sources, in order to determine your suitability to act as a contributor and/or for safeguarding purposes. The screening may include information relating to:

Your name, age, address, and employment details;
Criminal convictions and court proceedings;
Your participation in previous television productions;
Information from public registers, such as Companies House or the Insolvency Register;
Information from your social media profiles where publicly available, or with your consent; including Facebook, Twitter, Instagram, TikTok and LinkedIn.

In certain circumstances, we may carry out a Disclosure and Barring Service (DBS) criminal records check or ask you to complete a self-disclosure form. For example, we might do this where we have a legal obligation to do so for child safeguarding purposes, or where we feel it is necessary to protect your safety and wellbeing or that of other contributors. We may also conduct such checks where we consider it is necessary to avoid bringing the programme into disrepute.

Diversity Monitoring

UK broadcasters are researching diversity on their productions. This covers diversity characteristics you choose to tell the broadcasters about and also how viewers might perceive diversity on screen. If you provide us with your e-mail address, we will automatically enter this in a system called Silvermouse. You will be invited to provide your diversity characteristics – gender, ethnicity, disability, age, gender identity and sexual orientation. You can choose whether or not to provide this information.

The broadcaster (i.e. the BBC), as data controller, is responsible for this information and will have access to reports compiled from it for purposes of the research. Further information can be found here: https://creativediversitynetwork.com/diamond/

We may also collect such information about you that is either based on our perception of your diversity characteristics (i.e. how you appear on screen) or information volunteered by you if we send you an invite to participate in a diversity questionnaire. We do this to help us to improve the representation of different groups in the creation of, and appearance in, our content and to effect positive change so that it is truly reflective of our audiences. We may combine your data with that of other contributors and share this aggregated output with the BBC as part of the 50:50 The Equality Project: https://www.bbc.co.uk/5050. We may collect similar equality data on behalf of companies who commission content from us, in connection with their own diversity and inclusion initiatives.

Filming in Public Places

We may carry out filming in public places. In general, there is less of an expectation of privacy in public places therefore we do not usually obtain consent for filming. However, there may be circumstances in which people can reasonably expect privacy in a public place. We will always balance the public interest in freedom of expression with the legitimate expectation of privacy by individuals and we will display clear signage to indicate where filming is taking place, as appropriate, and in line with the relevant editorial guidelines and advice.

When We Use Your Property for Filming

When you allow us to film at your property, we collect your name, address, contact details and the time and date when we will use the property, and information necessary to make payment.

User Generated Content

We collect User Generated Content (UGC) for use in productions and to engage with our audiences. We will generally invite people to share their content through a “call to action”, and do not generally use unsolicited content sent to us by individuals, or content which is publicly available online such as on social media (except where we’ve invited sharing with us via such platforms). Productions invite submission of the following types of UGC:

Images, videos and stories for inclusion in programmes from audience members applying to act as contributors.
Competitions involving submissions from audience members. This will sometimes involve a judging panel to determine the winner. We will only share the minimum personal data necessary with the panel.

If UGC is filmed openly in a public or even semi-public space, then the presumption would generally be that it would be reasonable for us to use. This may still be the case even where the subject is not aware they are being filmed provided there is a public interest. For example, it could be a video of vehicle drivers using their mobile phones or other examples of anti-social or illegal behaviour.

If your content features other people, we may ask you to confirm you have their consent, or we may undertake further checks. We may also ask you to provide your email address to verify your age and that you are the legal parent or guardian of any children who may be featured in the content, as may be applicable under section 5 of this Privacy Policy (“Child Contributors”).

5. Child Contributors

If you are the parent or guardian of a child thirteen years old or under and they are the contributor, please make sure that you discuss the information we provide and where necessary explain to them what will happen to their personal data. Where appropriate, for example if appearing on a show or because they are giving information to us directly, we will normally ask you to provide written consent before we collect personal data about your child.

If you have concerns about your child’s personal data that we have collected and how it will be used, please contact us using the contact details provided in section 12.

To enable the production team to make decisions in respect of whether to cast your child or use their contributions, we will also need to collect specific identifying information about your child, for example, in order to complete contributor release forms.

Child Performance Licences

A child may need a child performance and activities licence if they are acting as a contributor to BBC Studios Productions or its production subsidiary.

As the organisation in charge of running the event or production, we are responsible for applying to the child’s local council for a child performance licence. If you are the child’s parent/legal guardian we will let you know if a license is needed and ask them to complete the application form.

When applying for a child performance license, we will need to collect a range of personal information as part of the application process. This is necessary to comply with our legal obligations under child performance licensing, child protection and child safeguarding legislation.

The personal information we need to collect from you includes the following:

Name, home address and contact details of the child and the child’s school.
Details of medical conditions the production team need to be aware of during filming and rehearsals.
Details of the child’s involvement in the production.
Details relating to any absence from the school and how educational requirements will be met.

The above list is not exhaustive, and full details of the information required will be provided to you. If you have any further questions, please get in touch with your point of contact in the Production Team. Alternatively, you may wish to contact your local council for further information.

6. Our lawful basis for processing your personal data

BBC Studios Productions is required to have a legal basis to process personal data. We are processing your personal data for:

the performance of the contract and relationship between you and us;
our legitimate interest in considering your application to be in a programme and the publication of your contribution as journalistic, artistic or literary material. We consider that, on balance, this processing is not disproportionate to your rights and freedoms and any impact this processing may have on you;
our legitimate interest in fulfilling our obligations under our contract with the programme commissioner; and
to comply with our statutory, regulatory or compliance obligations, such as equal pay and treatment, health and safety, safeguarding and HMRC reporting.

Our lawful basis for processing special category personal data

We need to have an additional legal basis to process your Special Category and Criminal Offence personal data. When you share Special Category or Criminal Offence personal data with us, we will explain to you the specific lawful grounds for processing the information. Generally speaking, this will be one of the following:

for the purposes of journalism, arts and literature;
for reasons of substantial public interest, such as for equality of opportunity or treatment or safeguarding of children;
for reasons of employment law, for example for the purposes of health and safety;
where you have made the information public; or
where we have your consent.

7. How long we keep your personal data

We intend to retain your contribution in perpetuity. However, if your contribution is not used in a programme, or is not intended for broadcast, we will delete your contribution much sooner - usually within 12 months of it being filmed or received by us (as applicable).

We will keep your talent contract, consent form and personal data concerning your contribution for the duration of copyright in your contribution (for rights management purposes). All other information will be kept only for as long as necessary and in accordance with our retention schedule. Generally, this will be up to 7 years for insurance and statutory purposes and the defence of legal claims. This could include information such as your application form, contact details, and any relevant information collected in connection with fitness to participate (including medical information). Information about criminal convictions will usually be kept for 6 months after the programme has been broadcast unless we have a lawful reason to retain for longer.

Unsuccessful applications to be in a programme will be kept for up to 12 months until after broadcast of the programme or series. We may sometimes retain your application for longer if we have a valid reason to do so, for example to consider you for a future series of the programme.

Unless you advise us otherwise, we may also store your contact details so we can contact you about contributing to future series or other BBC Studios programmes.

8. How we keep your data secure

We maintain appropriate procedures and technical safeguards within our systems to help protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the information we hold about you. We limit access to personal data and provide training and guidance to our production teams to ensure they understand how to keep your data secure in the course of making programmes.

If you believe that your personal information under our control has been compromised, please contact us immediately using the details in the Contact section below (section 12).

9. Where We Store and Use Your Information

We use external service providers who provide business and production services. For example, storage solution companies, payment providers and post-production specialists. In providing these services to us, they may have access to your personal data. These companies may be located in, or use IT equipment located in, countries outside the UK. For example, many technology services are owned by or use the services of US-based companies.

We will only transfer your personal data to countries outside the UK or European Economic Area (the ‘EEA’) that have been deemed to provide an adequate level of protection for personal data by the UK Government, or by using specific contracts approved by the UK Information Commissioner which give personal data the same protection it has in the UK and Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

10. Sharing your information

We will share your contribution and, as necessary, your personal data with the commissioning broadcaster (the ‘Commissioner’). For example, we will share release forms with them for rights management purposes. We may also, if appropriate in the context of the programme, share with them your application and other information as necessary to assess your application or to manage your participation on the programme. We will only share the minimum information necessary and will usually explain what additional information will be shared before doing so. Once we pass your personal data to the Commissioner, the Commissioner will become a separate controller of the personal data and be responsible for processing and storing it in accordance with data protection law and its own privacy policy.

Where relevant in the context of the programme, we may also share your information with the programme’s external experts and our professional advisers. For example, if you are participating in a consumer affairs show, we may consult with financial experts. Such sharing will be explained to you by the production team.

We may also be required to share certain personal data with unions and industry representative bodies (Equity, Musicians Union, Incorporated Society of Musicians, Writers Guild of Great Britain and Directors UK) or distribution agents nominated by a union, research partners, producers and distributors. Otherwise, we will only share your personal data with our contracted service providers or where we otherwise have an appropriate lawful basis to do so.

11. Your Rights

Data protection law gives you certain rights in relation to your personal data.

You can request access, rectification and erasure of your personal data that we hold or to restrict its uses and, in certain circumstances, you can object to processing of your personal data. Rectification means correcting errors in your personal data.

If your request is about your contribution itself, we will consider the impact of your request on:

our (actual or potential) publication of your contribution as journalistic, artistic or literary material; and
the performance of the contract between you and us.

We are committed to being transparent and fair in our handling of personal information and we will always endeavour to comply with best practice and applicable privacy and data protection laws in all the territories within which we operate. However, as a creator and producer of programmes, we may rely on an exemption from the requirements of data protection law in respect of personal data we process for journalistic and/or artistic purposes.

Right to Complain

If you have a concern about how BBC Studios Productions or its production subsidiaries (as applicable) uses your personal data or how we BBCSP deal with any complaints, you should contact us in the first instance via the contact details below.

If you feel we have not resolved your concern 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 (www.ico.org.uk).

Further details are available at: www.ico.org.uk/concerns.

12. Contact

We have appointed a data protection officer (‘DPO’) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO by email at: dataprotection@bbc.com

While we recommend contacting us by email, alternatively you can write to us by post:

Data Protection Officer

Regulatory Affairs

BBC Studios

1 Television Centre

101 Wood Lane

London

W12 7FA

8 BBC Studios Productions Privacy Policy v1 - Last updated 08 April 22