Privacy Policy of Outline Productions

Introduction

In this privacy statement, any reference to we, us, our and Outline is to Outline Productions Limited. Outline Productions Limited is a company registered in England and Wales (company number 03687838) with its registered office at Bankstock Building 2nd Floor, 42-44 De Beauvoir Crescent, London, N1 5SB.

We are a UK-based television production company and your personal information is very important to us. This privacy statement concerns the personal information (meaning any information relating to an identified or identifiable living person) of people who are applicants, participants or contributors who we are considering, or have decided, to include in a programme which is obtained by us or provided to us by the individuals themselves or by others or from other sources. When collecting and using personal data, our policy is to be transparent about why and how we collect, process, store and transfer personal data.

We have set out below the information we collect about you, the means of collection, how we use that information, and the lawful bases of use. We will collect, process and retain any personal information collected from you in accordance with all laws and regulations relating to the protection of personal data, including the Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) (GDPR).

1. What Information Do We Collect About You And Why Do We Process Data?

‍The personal data that is obtained by us or provided to us is either provided directly by the individual concerned (and in the case of Special Category Data this includes the completion by you of self-declaration forms, statement of health forms, application forms or similar) or by a third party acting on behalf of an individual (and in the case of Special Category Data this includes letters or other communications about your health from a medical professional or the results of any medical examinations or test) or obtained from a publicly available source e.g. press articles, social media profiles, online searches, database searches (and in the case of Special Category Data this includes publicly available information such as articles, social media posts and accounts) about your political or religious views, sexual orientation, ethnicity. Where we receive personal data that relates to an individual from a third party acting on behalf of an individual, we request that this third party informs the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

We may process personal data for various purposes, including:

• responding to queries from members of the public
• considering the suitability of individuals to take part in our programmes and in connection with contributions they then make to our programmes;
• as part of and in connection with our programme-making and other activities 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; and
• making payments to individuals.

The information we collect and process will depend on the nature of our interaction with you, more detail is given in section 2 below. We only collect personal data that is necessary for the purposes of interaction with you.

Your personal information will not be used for any marketing or sales purposes. However, we may, subject to your agreement, contact you about other programmes we think you may be interested in. Information we collect about you when you visit and use our website will be used by us to ensure our website is presented in the most effective way for you and your computer, and for internal record keeping. For more information see COOKIES below.

2. What Data Is Processed By Us And On What Basis?

The data that is processed by us and the lawful bases for that processing includes:

Members of the public, who contact us by phone, email, or otherwise in writing or online:

• this may include your name, address, email address, IP address, phone number and handwriting – to correspond with you and for administrative purposes (with such processing being necessary for the purposes of our legitimate interests);

Contributors;

• this may include your name, address, email address, IP address, phone number and handwriting – to correspond with you and for administrative purposes (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it);
• your image, passport details or another national identifier, driving licence, your national insurance or social security number and other official documents – to verify your identity and to ensure compliance with relevant laws (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it);
• your employment information, qualifications and experiences – to assess your suitability to take part in our programmes and/or to comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests);
• information about your personal, home and family life – to assess your suitability to take part in our programmes and/or to comply with our contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests);
• information about you on social media and the internet including images of you and other information – to verify your identity and to assess your suitability to take part in our programmes (with such processing being necessary for the purposes of our legitimate interests);
• and/or information about your physical and mental health – to assess your suitability to take part in our programmes and/or to comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it – and undertaken with your consent or if made publicly available by you) (see Special Category Data below);
• information about any criminal convictions or cautions you have or any criminal activity or proceedings you have been involved in – to assess your suitability to take part in our programmes and/or to comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests and/or for the performance of our contract with you or steps taken prior to entering into it – and if made publicly available by you or undertaken with your consent or) (see Special Category Data below);
• your financial details including your bank details – to pay or reimburse pre-approved costs or expenses (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it); and
• your age, gender, gender identity, ethnicity, disability and sexual orientation – for diversity analysis monitoring (with such processing being necessary for the purposes of our legitimate interests – and if made publicly available by you or undertaken with your explicit consent) (see Special Category Data below);
• information contained in footage filmed for our programmes or provided to us including a very wide range of personal information about you including:

1. your image, your age; date of birth; handwriting; information about your personal, home and family life and your work history, qualifications and experiences (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you);
2. information about your racial and ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, health, sex life or sexual orientation (with such processing being necessary for the purposes of our legitimate interests and/or the performance of our contract with you – and if made publicly available by you or undertaken with your explicit consent and/or in connection with public interest journalism) (see Special Category Data below); and
3. information about any criminal convictions or cautions you have or any criminal activity or proceedings you have been involved in (so-called ‘criminal convictions and offences data’) (with such processing being necessary for the purposes of our legitimate interests and/or the performance of our contract with you – and if made publicly available by you or undertaken with your explicit consent and/or in connection with public interest journalism) (see Special Category Data below).

We need the information in such footage for editorial reasons and for the production of our programmes, for contractual reasons and obligations we have to third parties, and/or to comply with our obligations to you pursuant to our contract with you.

If we intend to process your personal information with your consent, we will seek your explicit consent.

We will only process your personal information for our legitimate interests where our legitimate interests do not override your own legitimate rights and interests.

Following the exploitation of our programmes, any information about you in them will have been manifestly made public by you and we may also continue to process it on that basis.

Special Category Data: 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.

3. Who Do We Share Your Information With?

We will only share personal data with others where we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Your information (including special category data) will be used by the relevant production team for the purposes of producing the programme. It may also be shared internally with the business affairs team to prepare contractual documentation or provide legal advice, with the finance team where a payment is required, and any other in-house teams involved in the development, production and distribution of the programme.

We may pass your information (including special category data) to our third-party service providers such as agents, subcontractors and other associated organisations for the purposes of facilitating your application for and inclusion in a programme you are interested in taking part in. This may include third parties who are contractually engaged to provide services to us, e.g. IT services, health and safety advisors, insurance brokers and underwriters, legal advisors and accountancy services. However, when we use third party service providers, we disclose only those elements of your information that are necessary to deliver the required service.

We may share your 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 or to establish, exercise or defend legal rights.

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.

If there are changes to our business (such as a reorganisation or restructuring), your personal information will remain subject to this privacy statement. However, where your personal information is transferred to a new owner following a merger or acquisition, it may be subject to a different privacy statement. We, or the new owner, will provide notice to you (where practicable) before any of your personal information becomes subject to a different privacy statement. We may share your information with other third parties on an ad-hoc basis, however we will inform you if and when this happens.

We may share Special Category Data 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.

4. Security

We take the security of all the data we hold seriously. We have implemented appropriate measures and safeguards to ensure that your personal information is kept safe and secure including the following:

• staff are trained on data protection, confidentiality and security;
• we have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure;
• all information you provide to us is stored in a secure way.

The transmission of information via the internet is not completely 100% secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted by this means; any transmission is at your own risk. Once we have received your information, we will use our procedures and security measures to try to prevent unauthorised access.

5. Data Storage And Retention

We do not retain your information for longer than is considered necessary for the purpose it was collected.

We keep your personal data for as long as it is required by us for our legitimate interests, to perform our contractual obligations, or as is required by law or regulatory obligations which apply to us. Personal data that is no longer required will be deleted/destroyed.

In general, for those participating in our programmes, we are likely to keep your information for as long as necessary to produce, exhibit, exploit, distribute, advertise, publicise and promote the programme that your information relates to in accordance with our legitimate interests and legal obligations.

6. Diversity Monitoring

‍Outline contributes to a television industry-wide diversity monitoring initiative called Diamond. The Diamond project uses personal information regarding on and off-screen contributors to programmes to monitor the diversity of TV production in the UK and how viewers might perceive diversity on screen. There is a legitimate interest to collect diversity information about our industry. If you have provided us with your name and email address (and unless you have asked us not to) we will share this with Creative Diversity Network Limited (CDN) and the broadcaster of the programme you have participated in via Soundmouse and Silvermouse online systems, and you will be invited to participate in the Diamond project and to provide certain information regarding your diversity characteristics, such as gender, ethnicity, disability, age, gender identity and sexual orientation. This information is collected, processed and stored anonymously on the Diamond system, with the relevant data held by CDN and the applicable broadcaster as data controllers, and CDN and the applicable broadcaster will retain your name and email address for this purpose in Silvermouse for as long as diversity is monitored by them. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice.

Further information about Diamond can be found here:

http://creativediversitynetwork.com/diamond-contributors/

7. Individual’s Rights

You have certain rights over your personal data including the following:

• individuals may request access to their personal data held by us;
• individuals may request that we rectify any inaccurate personal data that we hold about them;
• individuals may request that we erase their personal data;
• where we process personal data based on consent, individuals may withdraw their consent at any time;
• individuals may have other rights to restrict or object to our processing of personal data and the right to data portability; and
• individuals may request information about any automated data processing that we may undertake.

If you would like to exercise any of your rights in relation to your information, please contact us directly using the contact details below.

There will not usually be a charge for handling a request to exercise your rights.

Please 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.

8. Cookies

A cookie is a small file of letters and numbers that we put on your computer when you access our website. We use cookies to identify which pages of our website are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to our visitors’ needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our website.

9. Links To Other Websites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any other website please note that these websites may have their own privacy policies and we do not accept any responsibility or liability for these policies or any of their content.

10. Locations Of Processing

Although based in the UK, our business is global which means that the data that we collect from you may be transferred to and stored at a destination 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 statement.‍

11. Changes To Our Privacy Statement

We keep this privacy statement under regular review and we may update or change it from time to time. Any updates or changes will appear on this website.

This privacy statement was last updated in July 2020.

12. How To Contact Us and Complaints

If you have any questions about our privacy statement or the information that we hold about you, or you want to complain about your use of personal data, please contact us at:

Data Protection Officer, Outline Productions Limited, Bankstock Building (2nd Floor), 42-44 De Beauvoir Crescent, London, N1 5SB; or

mail@outlineproductions.co.uk with “FAO the Data Protection Officer” in the subject heading.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO) is the UK’s data protection regulator.

For further information on your rights and how to complain to ICO, please refer to the ICO website:

https://www.ico.org.uk/concerns.