PRIVACY POLICY: CAST, CREW AND TALENT
Updated 7 June 2018
1. Introduction
At Avalon Entertainment and its associated group of companies, we hold and process a wide range of information. This Privacy Policy focuses on individuals who we contract to work on our productions (in both production and performance roles as well as talent working on and off screen) and explains the type of information we process, why we are processing it, how that processing may affect you and your rights in relation to the information we process. This policy also covers information on those who have carried out these roles previously.
2. Your information: what do we hold?
The personal information we hold may include, but is not limited to: name, work and home contact details (email, phone numbers, physical address), language(s) spoken, gender, date and place of birth, national insurance number, driving licence information, marital/civil partnership status, domestic partners, dependents, emergency contact information, your CV/career history, bank details, pay data, tax or employment status information, photographs, recordings, citizenship documentation, passport data, details of residency or any work permit, pay frequency, working time records (including holiday, leave and other absence records, and hours worked)and information about your health, ethnicity and criminal convictions.
We process information for the purposes of our business including for production, broadcasting, distribution, marketing, and management, administrative and legal purposes. For example we may need to take a copy of your passport (to prove your right to work), information about your health (to obtain and administer insurance), ethnicity (for diversity monitoring), information about any criminal convictions (for example if the programme you are engaged on involves working with children or if otherwise relevant or requested by the programme’s commissioning broadcaster) and information about you that is relevant for inclusion in publicity material. Please see section 4 below for further details.
3. Your information: Where does the information come from, who may see it and why?
Most of the information that we process about you comes from you or your agent on your behalf (if applicable). For example, if we pay you directly into a bank account, you tell us your contact and banking details. Other personal information 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 information may be seen internally by the relevant managers for that production, our management, finance and legal teams, and, in some circumstances, other employees of ours. We may also pass your information outside the organisation, for example to programme financiers, accountants, auditors, lawyers, insurers, bankers, other professional advisors and public, judicial, governmental authorities and litigants, and third partiesor (where applicable) for distribution and marketing purposes.We may share your personal information with companies that provide products and services to us (or to you in relation to your engagement by us) such as payroll, pension schemes, benefits, expense management, IT systems supply and support, credit cards, medical or health services, trade bodies and associations services, insurers, travel services and others.
Our legal basis for collecting and using this information is that it is necessary for the performance of our agreements with you, to comply with our legal and regulatory obligations and to pursue our legitimate business interests. It may also be information that you have made public as part of your contribution and/or is for the purpose of public interest. Please also see Section 4 below
4. Your information: How do we use it?
We will process your personal data in compliance with applicable laws, including for the following purposes:
HR/Workforce Purposes
HR administration and managing work activities and personnel generally, including recruitment, absence, performance management, right to work checks, rehiring, salary and payment administration, pension and benefits administration, managing business expenses and reimbursements, training requirements, activities and skills.
Communications and Emergencies
Facilitating communication with you, ensuring business continuity and protecting the health and safety of employees and others.
Business Operations and Security
Operating and managing IT and communications systems, managing product and service development and improvement, managing and allocating company assets and human resources, strategic planning, project management, business continuity, compilation of audit trails and other reporting tools, maintaining records relating to business activities, budgeting, financial management and reporting, communications, managing mergers, acquisitions, sales, re-organizations or disposals and integrations, building security and crime prevention.
Compliance
Complying with legal and other requirements, including audits, inspections and other requests from government or other public authorities.
Dispute resolution
Responding to legal process such as subpoenas, pursuing legal rights and remedies.
Health and safety
Complying with legal obligations on occupational safety and health.
Corporate and commercial matters
If the Company is involved in a merger or transfer of all or a material part of its business, the Company may transfer your information to the party or parties involved in the transaction.
6. Your information: How long do we keep it for and where?
We will retain your personal information for the duration of your engagement, for a period of seven years thereafter and will not keep it for longer than is necessary for our purposes. We may occasionally need to keep some of your other personal information for longer than the stated retention period to comply with our legal obligations and perform our obligations under our contract with you, as well as to pursue our legitimate interests.The majority of the personal information in our possession is stored on our centralised computer system.
7. Your information: please keep us updated
Please make sure the personal information we have for you is current and please inform us of any significant changes.
8. Your information: Will it ever be transferred outside the EEA?
We may transfer your personal data outside the EEA to members of our group and processors in the United States of America. For example if you are featured in a production, the data constituting your performance may be transferred out of the EEA for distribution and marketing purposes.
9. Your information: what are your rights?
You have a right to make a subject access request to receive information about the data that we process about you. You have certain other rights in respect of your personal information such as:
- having incomplete or inaccurate personal information corrected;
- accessing and reviewing a copy of that personal information;
- asking for deletion of that personal information (in certain circumstances);
- objecting to the use of that personal information (in certain circumstances where it is based on our legitimate interests);
- to be provided with a copy of that personal information (in certain circumstances) and;
- the right to lodge a complaint with your national data protection supervisory authority. For more information visit ico.org.uk.
You can read more about these rights here – https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
10. 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.
