This policy explains what data we collect about you and why, how we use it and who we share it with, as well as your rights as a data subject. Your information is very important to us and we will look after it in line with all laws and regulations relating to the protection of personal data, including the General Data Protection Regulation ((EU) 2016/679).
Who are we?
Any reference to “we“, “us” and “our” is to Twofour Group Limited (company no. 05493388) and its subsidiary companies. We are known as the ‚Äúdata controller‚ÄĚ of your personal data and you can contact us at firstname.lastname@example.org¬†or write to us at Data Protection Officer, Twofour Studios, Estover, Plymouth, Devon, PL6 7RG for more information about how we process your data, including how to exercise your rights as a data subject.
What personal information do we process about you?
The information we process may include your name, address, email address, IP address, gender, date of birth, age, phone number, passport details or other national identifier, driving licence, your national insurance or social security number and income, employment information and details about your previous roles and personal history. We collect information about you from a number of sources, including from you directly. The table below gives more information:
|¬†||WHAT¬†||HOW WE COLLECT THIS INFORMATION / FROM WHERE|
|1||Information that you give us||
|2||Information we obtain from others||
Why do we process your personal information?
We obtain personal information about you when you apply to take part in a programme or are confirmed as a participant or contributor to a programme which we are producing, or apply for tickets to a live recording of one of our programmes.
We need to process this information to consider your application or to make the programme once you have been selected.
We have set out below some more specific information about why we process your personal data:
- Our contracts with you
We consider it necessary to process your personal data to perform our contracts with you in the following circumstances:
(a)¬†¬†¬†¬†¬†¬†¬†to meet the contractual obligations between us;
(b)¬†¬†¬†¬†¬†¬†¬†as part of any legally binding contract which you have entered into with us for your application, contribution and/or participation in a programme; and
(c)¬†¬†¬†¬†¬†¬†¬†if you are due any payment, to provide to our in-house payments team in order for this to be paid.
Contracts are retained for a minimum of six (6) years from the date of signature, or for the period during which we have rights in the programme, whichever is the longest.
- To comply with applicable laws
We process your personal data where it is necessary to do so to comply with applicable laws which apply to us as an organisation, including:
(a)¬†¬†¬†¬†¬†¬†¬†to verify your identity;
(b)¬†¬†¬†¬†¬†¬†¬†to carry out verification and anti-money laundering checks, prevent and detect fraud and carry out other legally mandated checks; and
(c)¬†¬†¬†¬†¬†¬†¬†if we are legally obliged to disclose your personal data.
- ¬†Our legitimate interests
We consider that we have a legitimate interest in producing audio visual programming for commercial exploitation, as such, ‘on-screen’ and ‘off-screen’ contributions from individuals are crucial to this production activity and require the processing of personal information about these individuals.
We consider that it is in our legitimate interests (or those of a third party) to process your personal information, namely:
(a)¬†¬†¬†¬†¬†¬†¬†to produce audio-visual programming for commercial purposes, such as processing ‚Äėon-screen‚Äô and ‚Äėoff-screen‚Äô contributions from individuals. When we refer to a ‚Äúprogramme‚ÄĚ in this policy we mean not just the finished programme but all rushes, clips and unused material;
(b)¬†¬†¬†¬†¬†¬†¬†to assess your continuing involvement for the programme that you are contributing to (if your application to participate in a programme is unsuccessful, your information will be deleted within three (3) months of the programme going into production unless you have agreed you may be contacted about future programmes);
(c)¬†¬†¬†¬†¬†¬†¬†to deal with any questions or complaints arising in relation to your participation in the programme;
(d)¬†¬†¬†¬†¬†¬†¬†to deal with any agents acting on your behalf;
(e)¬†¬†¬†¬†¬†¬†¬†to retain the programme and your personal data in it in our archive, for the purposing of repeating the programme or otherwise using it for commercial purposes;
(f)¬†¬†¬†¬†¬†¬†¬†¬†¬†to commercially make full use of either the entire programme or clips from it in the UK and around the world, for the period in which we have rights in the programme. We also keep an archive copy of the programme after our rights have expired, as a record of programming we have either made and/or broadcast;
(g)¬†¬†¬†¬†¬†¬†¬†if applicable, to provide to any third parties (e.g. travel agencies, airlines, resorts and/or hotels) who require it to supply any prizes and/or benefits to you during your participation in a programme, or to facilitate your participation in the programme;
(h)¬†¬†¬†¬†¬†¬†¬†to share with our professional advisors and/or the commissioning entity or commissioning broadcaster that we are producing the programme for and/or any co-producer that we are producing the programme with;
(i)¬†¬†¬†¬†¬†¬†¬†¬†¬†to verify your age, identity and other information as we may require for the production and exploitation of the programme we are producing;
(j)¬†¬†¬†¬†¬†¬†¬†¬†¬†in the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, along with its professional advisers. If Twofour Group Limited or substantially all of its assets are acquired by a third party, personal information held by Twofour Group Limited about its applicants, entrants or nominee(s) may be one of the transferred assets. In such circumstances the acquirer of the information will become the new data controller;
(k)¬†¬†¬†¬†¬†¬†¬†to comply with applicable regulatory obligations;
(l)¬†¬†¬†¬†¬†¬†¬†¬†¬†to pass on to a competent regulator, prosecutor or competent authority or law enforcement authorities including without limitation the UK Information Commissioner and/or the Office for Communications (OFCOM) should it be requested from us;
(m)¬†¬†¬†¬†¬†¬†to comply with our accounting and tax reporting requirements;
(n)¬†¬†¬†¬†¬†¬†¬†to comply with our audit requirements;
(o)¬†¬†¬†¬†¬†¬†¬†to protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law);
(p)¬†¬†¬†¬†¬†¬†¬†to monitor communications to/from us using our systems;
(q)¬†¬†¬†¬†¬†¬†¬†to protect the security and integrity of our IT systems; and
(r)¬†¬†¬†¬†¬†¬†¬†¬†to arrange for you to attend the live recording of our programmes.
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.
- Monitoring as described at (p) above
We monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with our regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.
- Future participation
Where you have agreed to this, we process your personal data in connection with your consideration for future series of programmes and/or other shows produced by us or by another company within the Twofour Group of companies. This information may be kept by us for period of up to 3 years from date of the applicable agreement, unless you ask us to delete it earlier.
Twofour Group contributes to an industry-wide diversity monitoring initiative called Diamond. The Diamond project uses personal information regarding on and off-screen contributors to programmes to report on the diversity of TV production in the UK.
If you have provided us with your email address (unless you have asked us not to) we will share this with Creative Diversity Network Limited (CDN), Soundmouse and Silvermouse and you will be invited to participate in the Diamond project.
The company running the Diamond project will contact you to ask whether you are willing to contribute to the project by providing 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 being jointly controlled by the main UK broadcasters including the BBC, ITV, Channel 4, Channel 5, CDN and Sky. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice.
What do we do with children’s personal information?
We are committed to protecting the privacy of children aged under 18 years old. If you are aged 17 or under‚Äö please get your parent/guardian’s permission beforehand whenever you provide us with any personal information. We will take reasonable steps to verify this by contacting your parent or guardian to confirm their consent.
Who else do we share your data with?
Your information will be used by the relevant production team for the purposes of making the programme. It may also be shared internally with the Business Affairs team to prepare contractual documentation or provide legal advice, and with any other in-house teams involved in commercial exploitation such as the finance teams where a payment is required, the distribution team, and the health and safety and insurance teams if their advice is required.
We may pass your information to our third-party service providers such as agents, subcontractors, ticket providers and other associated organisations for the purposes of facilitating your application, entry or enquiry or nomination for the programme you are interested in taking part in. However, when we use third party service providers, we disclose only those elements of your information that are necessary to deliver the required service.
Please be assured that we will not otherwise share your information further, unless:
- we are required to do so by law, for example by a court order or for the purposes of prevention of fraud or other crime
- we are asked to by competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
- for the purposes of prevention of fraud or other crime.
Sending your personal information internationally
We may transfer your personal data to other members of our group, and to third party service providers outside of the European Economic Area, which do not have similarly strict data protection and privacy laws.
Where we transfer personal data to other members of our group, or our service providers, we will put in place data transfer agreements and safeguards. Where this happens, we will ensure that adequate security and safeguards are in place to appropriately protect your information.
How long do you keep my information?
We do not retain your information for longer than necessary for the purpose it was collected.
We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.
In general we keep your information only for the period we have legal rights to exploit the programme that your information relates to, but we have included some exceptions to that rule above. We will usually delete your personal information at the end of that period.
Do you need my consent to include me in a programme?
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.
We do not generally rely on obtaining your consent to process your personal data to make a programme in which you appear. This is something which we do as part of our legitimate business interests, as explained above.
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.
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What are my data subject rights and how can I use them?
In law you are the data subject and you have several rights that you can exercise over your data. These rights include:
- The right to be informed;
- The right of access;
- The right to rectification;
- The right to erasure;
- The right to restrict processing;
- The right to data portability;
- The right to object;
- Rights in relation to automated decision making and profiling.
If you would like a copy of some or all of your personal information, please contact us directly using the contact details below. If we cannot comply with your request to exercise your rights we will usually tell you why.
There will not usually be a charge for handling a request to exercise your rights.
How to contact us
- Data Protection Officer, Twofour Group, Twofour Studios, Estover, Plymouth, PL6 7RG
Information Commissioner‚Äôs Office (ICO)
¬†The ICO is the UK’s independent body set up to uphold information rights.
¬†If you are unhappy about the way in which your information has been handled you are able to contact the ICO at¬†www.ico.org.uk/concerns.