Proper Privacy
Proper Content Limited
Privacy Notice
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 10369370 and 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.
Your information is important to us and we will look after it in line with UK data protection law including the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).
This notice explains what data we collect and why, how we use it and who we share it with, as well as your rights as a data subject. If we process your personal information, we will only do so in accordance with this Privacy Notice and data protection law.
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
We process a lot of information in the course of our business. Depending on our interaction with you, we may process the following information about you which we may obtain from you or from others:
- your name, your gender, your age and date of birth, your address and contact details such as your email address and telephone number, your handwriting as well as other basic details about you. We need this information to correspond with you and to contract with you and for administrative and other purposes.
- your name, image, your gender, your age and birth date, information contained within your passport, your driving licence and possibly other official documents which identify you. We need this information to check your identity and to ensure compliance with relevant laws and regulations.
- information about your past and present personal, home and family life. We need this information to be able to assess your suitability to take part in our programmes and to comply with our contractual and regulatory obligations.
- information about your past and present professional life including information about your current role and schedule, your previous work history, your qualifications and your experiences. We need this information for administrative purposes, to be able to assess your suitability to take part in our programmes and to comply with our contractual and regulatory obligations.
- whether you consent or object to being identified in our programmes and if you object, the basis of your objection. We need this information to assess your suitability to take part in our programmes and to comply with our contractual and regulatory obligations.
- information about you that is on social media and the internet including images of you and other personal information that is contained there. We need to process this information in order to verify your identity and to assess your suitability to take part in our programmes.
- financial information e.g. your bank details and the details of any payments made to you. We may need this information in order to make payments to you and/or to comply with accounting and tax reporting requirements.
- information concerning your physical and mental health, including information set out in any statement of health form you give us, the contents of any communication from your GP regarding your health and the results of any medical tests. We need this information in order to assess your suitability for participation in our programmes, and for compliance with contractual obligations we have to third parties, who are subject to statutory regulation.
- information concerning any criminal convictions or cautions you may have, any criminal activity you may have been involved in and any current criminal proceedings or criminal allegations that relate to you or in which you are involved. We need this information in order to assess your suitability for participation in our programmes; and for compliance with contractual obligations we have to third parties, who are subject to statutory regulation.
- your age, gender, gender identity, ethnicity, religion, disability and sexual orientation. We will use this information for diversity analysis monitoring.
- any personal information revealed on camera and contained in footage filmed for our programmes (collected by us or provided to us by a third party in connection with our programmes) including your image and voice and potentially a very wide range of personal information relating to you revealed by you and others including without limitation:
11.1 your name; your gender; your age and date of birth; your address and contact details; information about your past and present personal, home and family life and professional life including information about your current role such as your position and work schedule, your previous work history, your qualifications and your experiences;
11.2 information concerning your racial and ethnic origin, political opinions, religious or philosophical beliefs, your membership of a trade union, your health and any medical treatment you receive, your sex life or your sexual orientation (“special category data”); and
11.3 information concerning any criminal convictions or cautions you may have and any other criminal activity you may have been suspected of or involved in; information concerning the nature and status of any arrests, charges, prosecutions, court proceedings or other interactions between you and the authorities; and information about any criminal behaviour you have witnessed or which has affected you and any related police investigation or prosecution (“criminal convictions and offences data”).
- your name and contact details for marketing purposes where you have opted to receive communications from us or from third parties that we believe may offer services/events or products that are of interest to you.
3. What are the lawful bases for processing?
The first column of the following table refers to the types of data set out in the numbered paragraphs above. The second column lists the lawful bases we rely upon in order to process these types of data.
| Para | Lawful Basis |
| 1 | Processing is:
|
| 2 | Processing is:
|
| 3 | Processing is necessary for the purposes of our legitimate interests and others e.g. the commissioning broadcaster of our programmes |
| 4 | Processing is necessary for the purposes of our legitimate interests and others e.g. the commissioning broadcaster of our programmes |
| 5 | Processing is:
|
| 6 | Processing is necessary for the purposes of our legitimate interests and others e.g. the commissioning broadcaster of our programmes |
| 7 | Processing is:
|
| 8 | Processing is:
|
| 9 | Processing is:
|
| 10 | Processing is:
|
| 11 | Processing is:
|
| 11.1 | Processing is:
|
| 11.2 | Processing is:
|
| 11.3 | Processing is:
|
| 12 | Processing is undertaken with your explicit consent, which you may revoke at any point by clicking the unsubscribe link at the bottom of each email sent to you. |
3.1 Legitimate Interests
Where we rely on ‘legitimate interests’ as the lawful basis for processing, such legitimate interests include our legitimate interests in making and exploiting television programmes for worldwide distribution. We only process data on this legal basis where we have considered that, on balance, our legitimate interests are not overridden by your interests, fundamental rights or freedoms.
3.2 The Special Purposes – public interest journalism
Please note that the UK GDPR and DPA 2018 state that in certain circumstances we do not have to comply with some aspects of data protection law (including this Privacy Notice) if we believe that doing so would be ‘incompatible’ with journalism and/or artistic purposes (i.e. it would stop us from doing our job as a producer), data is being held with a view to publication, and there is a public interest in broadcasting the programme. This is known as the ‘special purposes exemption’
Where we are producing certain programmes, we may process your personal data under the special purposes exemption. References in the above table to ‘processing undertaken in connection with public interest journalism’ includes processing where we rely upon the special purposes exemption.
3.3 Consent
Generally, individuals give their informed consent to take part in our programmes but there are circumstances in which we can make programmes about an individual without their consent provided we comply with the relevant laws and regulatory codes, such as the Ofcom Broadcasting Code.
Where you have entered into a contract with us to participate in our programmes, we may be entitled to show the programme whether or not you later change your mind about participation.
Consenting to take part in a programme, and our reliance on your consent to process your personal data are two distinct, different things. We do not generally rely on your consent if you appear in one of our programmes. This is something which we normally do as part of our legitimate business interests, for contract purposes and/or, in connection with public interest journalism.
Where we do rely upon ‘consent’ to process your personal information, you have the right to withdraw your consent at any time although we may be relying on other lawful bases at the same time.
4. Sharing your personal information
Your personal information is processed by our employees, staff and contractors. 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 where we are required to do so by law or to assist with their investigations;
- the police or other law enforcement or 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 UK. Where that is the case, we will ensure that adequacy regulations or adequate safeguards are in place to ensure the safety and security of your personal information – or an exemption applies e.g. you have given us your explicit consent to the transfer or we have a contract with you and the transfer is necessary for the performance of the contract – 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 in a programme) with the public on transmission of the programme in which you appear.
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;
- the right to object to our processing of your personal data; and
- the right to request the restriction of our processing of your personal 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 by email at: samantha.chambers@propercontent.com or by post at: 44-48 Bloomsbury Street, London WC1B 3QJ. 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.
Proper Content Limited
May 2021