INTRODUCTION
Please read this Privacy Policy which demonstrates how Genesis Media Productions use and protect the information you provide to us.
Like most businesses, we hold and process a wide range of information, some of which relates to individuals who we engage to work on our productions. This Privacy Notice explains the type of information we process, why we are processing it and how that processing may affect you.
The notice focuses on individuals who we contract to work on our productions. This includes those in production roles, such as designers, production assistants, camera crew etc. and also those working on-screen be it as extras or featured performers, as well as our voiceover artists. It also covers information on those who have carried out these roles previously.
This Privacy Notice is set out in this document (the Core Notice) and the Supplementary Information in the Annex to this document. In the Supplementary Information, we explain what we mean by “personal data”, “processing”, “sensitive personal data” and other terms used in the notice.
In processing your personal data, we act as a data controller. Our contact details are: dataprotection@genesismedia.productions or our privacy policy can be found here https://genesismedia.productions/privacy-policy/
PERSONAL DATA
We process data for the purposes of our business including for production, broadcasting, distribution, marketing, management, administrative and legal purposes. The Supplementary Information provides more specific information on these purposes, on the type of data that may be processed and on the grounds on which we process data.
“Personal data” is information relating to you (or from which you may be identified) which is processed by automatic means or which is (or is intended to be) part of a structured manual filing system. It includes not only facts about you, but also intentions and opinions about you.
Data “processed automatically” includes information held on, or relating to use of, a computer, laptop, mobile phone or similar device. It covers data derived from equipment such as access passes within a building, data on use of vehicles and sound and image data such as CCTV. It also covers video, audio and images captured as part of a production.
“Processing” means doing anything with the data, for example, it includes collecting it, holding it, disclosing it and deleting it.
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership and genetic and biometric data are subject to special protection and considered by EU privacy law to be “sensitive personal data”.
References in the Cast, Crew and Talent Privacy Notice to work or services (and similar expressions) include any arrangement we may have under which an individual provides us services in relation to a production. We use the word “you” to refer to anyone within the scope of the notice.
WHERE THE DATA COMES FROM AND WHO SEES IT
Some of the personal data that we process about you comes from you. For example, if we pay you directly into a bank account, you tell us your contact and banking details. Other personal data about you is generated in the course of your work, for example from other contractors working on your production, or from our employees.
Your personal data may be seen internally by the relevant mangers for that production, our finance teams, in some circumstances, other employees of ours. We may also pass your data outside the organisation, for example to people you are dealing with and payroll agencies or (where applicable) for distribution and marketing purposes.
In relation to infectious disease control and national health emergencies, including but not limited to Covid-19 and / or other pandemics or epidemics, you may be required to provide us with information or a self-certification which includes sensitive personal data relating to your health and fitness to work on a regular basis as requested by us. In addition, we may require you to undertake testing such as temperature checks and / or antibody or disease tests either at work or any other place we designate during or outside working hours. We shall either receive the results directly or require you to inform us of the results, and shall treat and process the information as sensitive personal data.
WHO GETS TO SEE YOUR DATA
Internal use: Your personal data may be disclosed to our employees working on your production, as well as to our managers and administrators for production, broadcasting, distribution, marketing, administrative and management purposes as mentioned in this document. We may also disclose this to other members of our group including in response to infectious disease prevention and / or health emergencies (including, but not limited to Covid-19) where your personal data and / or test results may need to be disclosed in specific circumstances for the health and safety of the wider workforce and the group as a whole.
External use: We will only disclose your personal data outside the group if disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you. We may disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are over-ridden by your interests and rights in particular to privacy). We may also disclose your personal data if you consent, where we are required to do so by law and in connection with criminal or regulatory investigations or where it is mandated by government regulation or legislation in response to infectious disease control and / or public health emergency (including, but not limited to, Covid-19).
Specific circumstances in which your personal data may be disclosed include:
- disclosure to organisations that process data on our behalf such as our payroll service, insurers, our bank and organisations that host our IT systems and data;
- disclosure to external recipients of electronic communications (such as emails) which contain your personal data;
- 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.
HOW LONG DO WE KEEP YOUR DATA
Although there is no specific period for which we will keep your personal data, we will not keep it for longer than is necessary for our purposes. In general, we will keep your personal data for the duration of your contract and for a period afterwards. In considering how long to keep it, we will take into account its relevance to our business and your engagement either as a record or in the event of a legal claim.
If your data is only useful for a short period (for example, CCTV), we may delete it. Personal data relating to job applicants (other than the person who is successful) will normally be deleted after 12 months.
Some data, such as production footage itself and credit information, will be kept indefinitely as we have an ongoing legitimate interest in retaining the product.
TRANSFER OF PERSONAL DATA OUTSIDE THE UK AND THE EEA
In connection with our business and for production, broadcasting, distribution, administrative, management, marketing, legal purposes or your performance if featured in a programme, we may transfer your personal data outside the UK and the EEA to members of our group and data processors in other jurisdictions in which we are established. Some of our systems are hosted outside of the UK and the EEA. We will ensure that any transfer is lawful and that there are appropriate security arrangements.
LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
Under data protection law, there are various grounds on which we can rely when processing your personal data. In some contexts more than one ground applies. We have summarised these grounds as Contract, Legal obligation, Legitimate Interests and Consent and outline what those terms mean in the following table.
TERM | GROUND FOR PROCESSING | EXPLANATION |
Contract | Processing necessary for performance of a contract with you or to take steps at your request to enter a contract | This covers carrying out our contractual duties and exercising our contractual rights. |
Legal obligation | Processing necessary to comply with our legal obligations | Ensuring we perform our legal and regulatory obligations. For example, providing a safe place of work and avoiding unlawful discrimination. |
Legitimate Interests | Processing necessary for our or a third party’s legitimate interests | We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your data. Your data will not be processed on this basis if our or a third party’s interests are overridden by your own interests, rights and freedoms. |
Consent | You have given specific consent to processing your data | In general processing of your data in connection with the services you provide is not conditional on your consent, although there may be general exceptions to this. |
PROCESSING SENSITIVE PERSONAL DATA
If we process sensitive personal data about you, as well as ensuring that one of the grounds for processing mentioned above applies, we will make sure that one or more of the grounds for processing sensitive personal data applies. In outline, these include:
- processing being necessary for the purposes of your or our obligations and rights in relation to your engagement in so far as it is authorised by law or collective agreement;
- processing relating to data about you that you have made public (e.g. if you tell us you are ill);
- processing being necessary for the purpose of establishing, making or defending legal claims;
- processing being necessary for provision of health care or treatment, medical diagnosis, and assessment of your working capacity (including (but not limited to) for infectious disease control and / or health emergencies such as Covid-19 or any other pandemic / epidemic); and
- processing for equality and diversity purposes to the extent permitted by law.
ACCESS TO YOUR PERSONAL DATA AND OTHER RIGHTS
We try to be as open as we reasonably can about personal data that we process. If you would like specific information, just ask us.
You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:
- giving you a description and copy of the personal data; and
- telling you why we are processing it
If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.
As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing or to have its processing restricted. If you have provided us with data about yourself (for example your address or bank details), you have the right to be given the data in machine readable format for transmitting to another data controller. This only applies if the ground for processing is Consent or Contract.
If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.
YOUR DATA RIGHTS & COMPLAINTS
You have a right to make a subject access request to receive information about the data that we process about you.
If you have complaints relating to our processing of your personal data, you should raise these with your key contact at the production in the first instance or with the Information Officer. You may also raise complaints with your statutory regulator. For contact and other details ask your key contact at the production.
STATUS OF THIS NOTICE
This notice does not form part of your contract and does not create contractual rights or obligations. It may be amended by us at any time.