PRIVACY NOTICE
HOW YOUR PERSONAL DATA WILL BE USED

This Privacy Notice is for anyone who participates in TV programmes or development projects for STV Studios Limited or one of STV Studios Limited’s subsidiaries and/or production partners/labels (“we”, “us”, “our”). You can find details of our production partners/labels on our website here or as otherwise notified to you.

This policy was last updated in September 2024.

The Data Controller of your personal data is the production company producing the programme and/or development project you are involved in.

We comply with the UK General Data Protection Regulations (GDPR) and UK privacy laws and this Privacy Notice sets out how we process and handle your personal data in relation to the production and development of TV programmes.

What type of personal data do we collect?

Name and Contact Details: e.g. name, address, telephone/mobile number, email address
Biographical Data: e.g. date of birth, gender, nationality
Audiovisual Data: e.g. image, photograph, voice recording, video recording
Background Data: e.g. general information about you
Special Category Data: e.g. gender, racial group, health (incl. access services and/or alternative formats)
Employment/Right to Work Data: e.g. job title, NI number, passport, tax codes
Financial Data: e.g. bank details
Criminal Offence Data: e.g. criminal activity, criminal proceedings
Lexis Nexis Data: e.g. name, address, date of birth
Public Data: e.g. images, opinions, behaviour

How we get your personal data, why we have it and how it will be used

Most of the personal data we process is provided to us directly by you for one of the following reasons:
To assess your application, to learn more about you and/or otherwise consider you as a programme or development project participant;
To ensure we have suitable and eligible participants (including talent, members of the public and production crew) for each of our programmes/development projects;
To make payment, where agreed, for your participation;
To contact you, to keep you informed and updated about production schedules and changes;
Where you have given us your permission, use your personal data to contact you about future series and programmes for which you may be interested in applying;
To ensure we include a diverse range of applicants in our programmes to represent society and our viewing audience
To monitor the effect and impact of our own diversity and inclusion initiatives and assess what other initiatives may be required;
To research development projects and programmes, for which we may also engage experts and other consultants for further relevant information;
To comply with our duty of care, health and safety and/or safeguarding obligations (including production crew, participants, audiences, ourselves, and our partners) and our legal, and insurance obligations which includes background, medical, and other screening checks;
To enable us to film at your property where relevant for the purpose of the programme or development project;
To promote, seek interest and otherwise exploit the programme and/or development project in which you are a participant;

We will also seek personal data about you from the following sources to supplement and/or verify the information you have provided:

• Background check providers: e.g. Lexis Nexis, Disclosure Scotland/DBS (where required);
• Public sources: e.g Google, other internet sources, social media platforms;
• Medical professionals and experts (where we are required to do so by law, or otherwise with your consent);
• Legal professionals and law enforcement (where necessary to do so);
• Family, friends, representatives, associates and anyone else who is responsible for your health and wellbeing; and
• Your employer / agent (where applicable).

In instances where your personal data has been collected through public filming (including interviews), this may be for the purpose of including it in development project materials such as taster tapes and development decks that are not intended to be used for broadcast. In such cases, your personal data will be reviewed regularly until we have a successful commission. We safely dispose of any personal data where it is no longer required. Where we do film in public, we put up filming notices around the areas being filmed with contact details so that you can let us know if you do not wish to be filmed.

SPECIAL CATEGORY DATA AND CRIMINAL OFFENCE DATA

When it is necessary for us to collect and process personal data which is Special Category Data and Criminal Offence Data (as further detailed in this Privacy Notice), we will inform you separately and provide you with more detailed information at the relevant time where it is necessary to do so.

Special Category Data includes information about your physical or mental health or condition, race, ethnic origin, political opinions, religion, trade union membership, genetics, or sexual orientation.

Criminal offence data includes information relating to actual or suspected criminal activity, allegations, investigations and proceedings, as well as information about unproven allegations, penalties, conditions or restrictions or other civil measures which must be adhered to.

We rely on the following lawful bases for processing your personal data:

Contractual: Where processing is necessary for the performance of a contract to which you are party (e.g. contributor agreements, talent agreements, supplier agreements etc.) or in order to take steps at your request prior to entering into the contract.
Legal obligation: Where processing is necessary for compliance with a legal obligation to which we are subject (e.g. right to work checks, health and safety checks, child and vulnerable person protection, duty of care obligations, insurance requirements etc.).
Your consent: Where we need to process sensitive data, such as Special Category Data or Criminal Offence Data (where not required to do so to comply with a legal obligation), or where we want to contact you for future productions or development projects, we will ask your permission to do so. For example, we will ask for your consent before we process any Special Category Data or undertake enquiries and/or basic criminal checks. You are able to withdraw your consent at any time. You can do this by contacting us using the contact details below.
Legitimate Interests: Where the processing is necessary for our legitimate interests or a third party’s legitimate interests (e.g. broadcasters, commissioners, co-producers, distributors, financiers etc.) except where our interests are overridden by your interests or fundamental rights and freedoms. We have a legitimate interest to validate the information uou provide to us to protect ourselves, other participants and viewers.

There are certain circumstances where an exemption for compliance with UK data protection laws applies to us, broadcasters and commissioners for the purposes of journalism, art and literature which is in the public interest.

Sharing your personal data

We share your personal data where we are legally obliged to do so. We also share personal data to comply with contractual purposes and/or where there is a compelling public interest reasoning for doing so.

We share personal data with: broadcasters, verification organisations, regulatory and legal bodies, law enforcement, insurers, third party health practitioners, experts (including legal and medical professionals and advisory service providers), and any other third parties connected to the relevant programme and/development project such as distributors and financiers.

We also use data processors to provide the following services:

Programme production management services (e.g. scheduling and day planning, talent, contributor and similar databases);
Records management services (e.g. document storage);
Finance, accounting and payroll services;
Support services (who help deliver duty of care, welfare, and safeguarding services);
Screening services; and
Communication and transcription services (including audio/video recordings).

We also share your personal data internally within the STV Group of companies, subsidiaries and/or production partners/labels where it is necessary for programme or development project purposes.

Equality, Diversity and inclusivity initiatives (D&I)

STV engages in and participates in a number of D&I initiatives involving production crews and contributors. This involves the processing of Special Category Data. The processing of D&I information is essential to monitor and improve diversity and inclusion across the creative industry. Where requested to do so, we share D&I information in statistical form only, with no personally identifiable detail included (“anonymised data”). However, where there are limited numbers of individuals in a particular production or development project, there is the possibility that individuals may be indirectly identified. We share D&I information as follows:

Project Diamond – the broadcast, production and creative industry diversity monitoring initiative. Diamond uses personal information regarding contributors to programmes to produce reports on the industry. The information is generally anonymised. STV will share your email address with the Creative Diversity Network, unless you have asked us not to. They will contact you directly to ask if you wish to contribute and provide Special Category Data. Your contribution is entirely voluntary.
Ofcom – commissioning broadcasters must provide D&I statistics to Ofcom on an annual basis to comply with their regulatory obligations. Where we receive a commission from a broadcaster, we are required to share the information (in statistical format). Your contribution is entirely voluntary.
Broadcaster/Commissioners/Funders – who are also committed to ensuring the projects they fund reflect society and ensure equality, diversity, and inclusion, seek anonymised information relating to D&I. Your contribution is entirely voluntary.

How we store your personal data and keep it secure

Your personal data is securely stored by us. We use data processors (detailed above) who also store your personal data on our behalf where necessary. Some of these data processors store your personal data in the UK. We also use processors outside the UK. Where your personal data is processed outside the UK, we ensure appropriate safeguards are in place to keep your personal data secure. This includes using data processors in countries where we have assessed their suitability, including where there is a UK ‘adequacy decision’ e.g. EU countries, and others, for example, the US and other countries where we enter into contracts containing standard data protection clauses.

We are committed to keeping your personal data secure with appropriate technical and organisational measures which ensure its confidentiality, integrity and availability. This includes secure systems, operational policies and procedures to prevent your personal data from being accidentally lost, used, accessed, altered by, or disclosed to unauthorised persons (e.g. by using psudonymisation, encryption, restricting access, and retention policies). Our contracts with data processors stipulate that they will only process your personal data on our instructions and that they will comply with confidentiality obligations.

Personal data will only be retained (i) for as long as it is necessary to keep it for the purposes set out in this Privacy Notice, (ii) to enable us to pursue our legitimate business interests, and/or (iii) for as long as necessary to comply with legal or regulatory obligations which apply to us. The personal data will be reviewed regularly and once it is deemed no longer necessary, it will be deleted securely. When determining our retention periods, we think about the amount and nature of the information, the risks posed to you by our use of it, the importance of the reasons we need to use it, whether we can achieve those objections without using it, and other applicable legal or regulatory requirements.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal data.

Your right to rectification - You have the right to ask us to rectify data you think is
inaccurate. You also have the right to ask us to complete data you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal data in certain
circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your data in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances. For example, where our lawful basis for processing is legitimate interests. We must stop processing unless we have a compelling reason to continue. You also have a right to object to your data being processed for direct marketing purposes.

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances (this only applies where we automatically use your data with your consent, or to perform a contract with you). However, it may not be technically possible and/or feasible for us to comply with your request.

Your right to withdraw consent – Where we rely on your consent to process your data, you have a right to withdraw your consent at any time. You do withdraw your consent by contacting us using the contact details below.

Your right to complain – Uou can make a complaint to the UK Regulator (the Information Commissioner’s Office) if you are not satisfied with the use of your personal data. Their contact details are available on their website: https://ico.org.uk/

How to exercise your data protection rights / contact information:

Please contact our privacy team at privacyteam@stv.tv if you wish to make a data rights request or if you have any questions about this Privacy Notice. You can also write to the privacy team at: Privacy Team, STV Compliance, STV, Pacific Quay, Glasgow G51 1PQ.

Applicant/Contributor Privacy Notice