Proper Content Limited is an independent television production company based in London, producing quality programmes and other content for worldwide distribution.We are a company incorporated in England under company number 10369370and our registered office is at 6th Floor Charlotte Building, 17 Gresse Street, London W1T 1QL.Proper Content’s main office is at 44-48 Bloomsbury Street, London WC1B 3QJ.
We are committed to protecting the privacy of others and complying with all relevant data protection laws and regulations.This Privacy Notice explains how we collect, store, use and transfer information about individuals, including those who are involved in the programmes we make, whether in hard copy or digitally on any of our servers or computers.
In this Privacy Notice ‘Proper Content’, ‘we’, ‘us’, ‘our’ refers to Proper Content Limited and ‘you’, ‘your’ refers to potential contributors to our programming.
1. Why do we collect personal information
We collect and process personal information for a number of reasons including:
producing, exhibiting, exploiting, distributing, publicising, advertising and promoting our programmes by any media (now known or hereafter invented) throughout the world;
operating and managing our business effectively and lawfully;
as part of and in connection with our programme-making and other activities;
responding to queries from members of the public;
contacting individuals about taking part in our programmes and assessing individuals’ suitability to take part in our programmes;
making payments to individuals.
2. What personal information do we collect
Contacting us: you may provide your personal information (e.g. name, postal address, email address, telephone number, other contact information) when you contact us by phone, e-mail or otherwise in writing, or where you contact us online.This may be in connection with you participating in one of our productions, or for some other reason.
Participating in programmes: if you are applying or being considered to take part in one of our programmes it will be necessary for us to collect certain basic information about you including your full name, date of birth, gender, postal address, email address, telephone number and other contact details.We may also need to carry out identity checks and background checks.This will be in order to contact you and to assess your suitability for taking part in our programmes.
We may also collect, store, process and transfer personal information about you that is publicly available e.g. press articles, your social media profiles, online searches.
Special Category personal information: Data protection legislation recognises certain “special categories” of personal information, which is information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information for uniquely identifying a person, information concerning health, and information concerning a person’s sex life or sexual orientation.Information relating to criminal offences and convictions is treated in a similar way.
In order for us to be able to (i) assess your suitability as a contributor to a programme; and (ii) produce, exploit and publicise our programmes; and (iii) ensure your health and safety during your participation in a programme, ensure that you are at all times able to participate in a programme and related publicity, and monitor and manage sickness and/or absence during the production process; we may (should we require or should you provide all or some of the following) collect, store and use the following special categories of personal information about you:
the results of any background checks (for example searches undertaken by us via Google, Lexis-Nexis and/or on social media platforms);
a statement of health form provided by you;
the contents of any letter or other communication provided by your GP relating to the state of your health and/or the results of any medical examination (if necessary);
information provided by you about your past convictions;
any other sensitive personal information, for example about your racial or ethnic origin, political opinions, religious beliefs, or your personal life and sexual orientation which you disclose to us at any time or in the course of your participation in a programme.
3. Sharing your personal information
Your personal information is processed by our employees and staff.Sometimes we use third parties who are contractually engaged to provide services to us that may involve the sharing of personal information e.g. IT services, health and safety services, insurance brokers and underwriters, legal and accountancy services.We also may need to share your personal information with other organisations from time to time including with:
companies involved with our business activities e.g. broadcasters, post-production houses, sales agents, distributors, financiers;
broadcasting regulators e.g. Ofcom;
the police or other regulatory bodies as required by law in connection with the investigation of crimes.
Although based in the UK, our business is global which means that we may need to transfer your personal information to organisations outside the European Economic Area (EEA).Where that is the case, we will ensure that adequate safeguards are in place to ensure the safety and security of your personal information and that it is processed in accordance with this Privacy Notice.
We may share special category personal information about you with members of the production team, and with the parties set out above, and (to the extent you provide such information as part of your contribution to a programme and the same is incorporated in a programme and/or we include details of your biography background and past experiences ina programme) with the public on transmission of the programme in which you appear.
4 The bases for collecting and processing your information
There are a number of lawful bases upon which we may collect and process your personal information including the following:
if you have entered into a contract with us, we may need to use your information to fulfil the contract and our obligations to you;
we may be under a legal obligation to process your personal information;
we may process your personal information with your consent.Where that is the case, we will tell you and seek your explicit consent before processing your information;
it may be necessary for us to process your personal information for our own legitimate interests.Note that we will only do so where our legitimate interests do not override your own legitimate rights and interests.
In respect of special category personal information (defined above) and criminal convictions and offences information concerning you, in addition to one or more of the above lawful bases for the general processing of your personal information, we will only process special category and criminal convictions/offences information in one or more the following circumstances:
with your express consent;
where the special category personal information in question has been made public by you (including without limitation as part of your contribution to the programme you intend to take part in);
as necessary to establish, exercise or defend our legal rights and interests;
as necessary for reasons of substantial public interest;
as necessary for archiving purposes.
5. How we store your personal information
We have implemented appropriate measures and safeguards to ensure that your personal information is kept safe and secure e.g. by storing it securely, and by keeping electronic data on secure servers and hard drives with appropriate levels of security including encryption and firewalls.However the internet is an open system and we cannot guarantee that unauthorised third parties will never be able to defeat those measures.
We will only keep your personal information for as long as we need to.For those participating in our programmes, we are likely to retain your personal information for as long as is necessary in order to produce, exhibit, exploit, distribute, advertise, publicise and promote the programme in accordance with our legitimate interests and legal obligations.Personal information that is no longer required will be deleted/destroyed.
6. Your rights
You have a number of rights in respect of your personal information, including the right:
to request access to the personal information that we hold about you;
to request that we do not process your personal information for direct marketing purposes;
to request that inaccurate personal information we hold about you is corrected;
to request that personal information is deleted;
to request that your personal information is provided to you in a portable format
to withdraw your consent to processing where we are relying on your consent as the lawful basis for processing your personal information including special category and criminal convictions/offence data.
Note that most of these rights are not absolute and are limited to certain defined circumstances.Accordingly, we may not be able to comply with any such request.
If the basis of our processing of your personal information is ‘consent’ you have the right to withdraw your consent at any time.
7. Getting in touch
If you have any questions or concerns regarding this Privacy Notice please contact Proper Content’s data protection manager at: firstname.lastname@example.org.We will use reasonable efforts to answer your question or address your concerns promptly.
Please note that you are also entitled to make a complaint to the Information Commissioner’s Office if you feel any concern of yours relating to the Privacy Notice has not been dealt with properly: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.https://ico.org.uk/make-a-complaint/
8. Changes to this Privacy Notice
We may update or amend this Privacy Notice from time to time.