PRIVACY NOTICE
INTRODUCTION
Full Fat Television Ltd (‘Full Fat’,‘we’, ‘us’ or ‘our’) is a factual entertainment tv company based in Birmingham. We are an English company (company number 09680953) and our registered office is Foyagh, Chapel Lane Exfords Green, Longden, Shrewsbury, SY5 8HG.
We process personal information in relation to contributors or prospective contributors on a programme, as employers or prospective employers, in the performance of a supplier contract and, if we have your permission, or where otherwise allowed by law, to tell you about our products and services.
We process your personal information in accordance with this privacy notice and in compliance with the relevant data protection laws. This notice provides you with information regarding your rights and our obligations, and explains how, why and when we process your personal data.
If you have any queries relating to this notice, please contact us at the email or phone number below and we will get back to you to you as soon as we can:
T: +44 (0) 121 796 5655
E:
production@fullfattv.co.uk
You can also write to us at our registered office, marked for the attention of our privacy officer.
CONTRIBUTORS
This section includes people who are contributors on our programmes, potential contributors and others who contribute to our programmes, such as interviewees or people who allow us to use their materials.
If you are applying to take part in one of our programmes (for example by using the listed email address for that programme), or, if we approach you about taking part in one of our programmes, you may be asked to submit personal information as part of an application form. You may also be asked to provide special category data such as medical details.
This information will be used to evaluate whether you would be a suitable contributor for one of our programmes. All information submitted through applications will be kept in the strictest confidence and will not be disclosed to any third party for any purpose other than for the purposes stated here.
Unsuccessful applicants
If your application to take part in one of our programmes is unsuccessful we will delete all your data, or, if you have agreed that we can do so, we will keep it for twelve months in order to contact you about future programmes you may wish to take part in.
Successful applicants/contributors
If you are successful in your application and/or you agree to be on one of our programmes, we will continue to process such information as is necessary for the production and exploitation of that programme. This will always comprise contact information and may include, but is not limited to, information contained in your programme release form, special category data (such as health and medical data) and criminal offence data.
Where the information comes from
Some of the information comes from you. For example your contact details, on application forms, on the programme release form or in discussions with you.
Some information comes from third parties. For example publicly available sources, from your friends or family members, social media platforms, or background check service providers.
Other information is generated in the course of you taking part in the programme. For example recorded footage of you.
Lawful basis
Our lawful basis for processing your personal information is one of the following, as permitted by data protection law:
contract: the processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests.
In relation to the special category data we hold about you we will process this in accordance with one of the grounds set out above and we will also ensure that one of the following applies:
(i) we have your explicit consent to the processing of such data.
(ii) You have knowingly and willingly made the data public.
(iii) Where it is necessary to establish, exercise or defend legal claims.
(iv) Where it is necessary for medical purposes.
(v) Where necessary or allowed under employment, social security or social protection law.
(vi) When in the substantial public interest, such as for journalistic/artistic purposes in connection with unlawful acts or dishonesty.
In certain circumstances we may hold information about criminal convictions or offences which you may have incurred. If this is the case we will process this data where we have your consent to do so or where it is necessary or allowed under employment, social security or social protection law. We do not keep a comprehensive register of our contributors’ criminal convictions.
Children
From time to time we may make programmes with child contributors. We will process the data of the child contributor as it is in our legitimate interests to do so. Where a parent or guardian has signed our mutually agreed contract it will be necessary to process their data alongside this (as above). We will not send marketing information to our child contributors but to their parent or guardian.
With whom we share your data
We may share your data (including your special category and criminal offence data) with broadcasters, programme distributors, co-producers, insurers, health and safety advisors, regulatory authorities, external suppliers and viewers.
Where we store your data
The majority of our contributor data is stored on our computer system and/or kept in a file in a locked cabinet. Designated members of staff have access to this system and/or cabinet to enable them to assess your suitability for a programme and to produce and exploit the programme to which you are a contributor. Where there is special category data or information relating to criminal convictions this will be kept in a secure place where access is restricted to designated members of staff.
How long we retain your data
We do not keep contributor data for longer than is necessary, bearing in mind the purpose for which we collected that information and any applicable legal or regulatory requirements.
Transfers of data outside the UK and the EEA
Your personal information is mainly used in the UK. However sometimes we need to share your personal information with third parties outside the UK and EEA. Where we do so we will ensure that any transfer of data is lawful and that there are appropriate security arrangements in place.
Please note that any programme in which you appear is likely to be distributed internationally.
Exemptions
There are certain circumstances where data protection law allows us and relevant third parties (such as the commissioning broadcaster of the programme that you have contributed to) not to comply with the obligations explained in this notice. An example of where the exemption applies is where such obligations and your rights are incompatible with the artistic purposes of the programme and there is a public interest in its broadcast.
JOB APPLICANTS, CURRENT AND FORMER FULL FAT EMPLOYEES, FREELANCERS AND CONTRACTORS
This section applies if you are working for us, applying to work with us, or have worked with us, in any capacity, for example as an employee, freelancer, contractor or through a personal services company. It includes those working on our productions, both on-screen and off-screen.
This privacy notice does not form part of your contract of employment or other contract to provide services.
Information that we collect
We collect and use different types of personal data about you before you start working with us (during the application process) and in the course of your employment or engagement.
You may be asked to provide the following at the application stage:
Proof of your identity. Proof of your qualifications. A criminal records declaration to declare any unspent convictions. We may contact your referees directly to obtain references. We may ask you to complete a questionnaire about your health. This is to establish your fitness to work as well as for your well-being whilst on our premises and may be required by insurers.
If we employ or engage you we may ask you to provide the following:
Bank details – to process salary or other payments. Emergency contact details – so we know who to contact in case you have an emergency at work. Information for your inclusion in our auto-enrolment pension scheme. We use a data processor for this scheme.
We may ask you to provide special category data, for example information on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability and age.
What we do with the information and how long we retain it for
When individuals apply to work at Full Fat, we will only use the information they supply to us to process their application or to fulfil legal or regulatory requirements if necessary.
Personal information about unsuccessful candidates will be held for 12 months after the recruitment exercise has been completed, or, where an individual has applied on a speculative basis, for 12 months from receipt of the CV. It will then be destroyed or deleted.
Once a person has taken up either fixed term or full-time employment with Full Fat, we will compile a file relating to their employment. The information contained in this will be kept secure and will be used for a number of reasons such as for administration and management purposes, to manage salaries and to manage health and wellbeing. Where you are working on a specific programme we may also use your personal data to enable us to produce, broadcast and distribute that programme. We may also process your personal data for monitoring of diversity and equal opportunities, for monitoring and investigating compliance with policies and rules and in relation to disputes and legal proceedings.
The information will be retained for the duration of your employment/engagement plus 6 years following the end of your employment/engagement. This includes your criminal records declaration, fitness to work, records of any security checks and references.
Where the information comes from
Some of the information comes from you. For example your contact details, bank details and information on whether you can lawfully work in the UK.
Some information comes from third parties. For example we may require references and information to carry out background checks.
In the course of your work we may receive personal data relating to you from others, such as your managers and colleagues or those with whom you communicate electronically. We may also have CCTV footage of you. If you are working on a specific programme personal data may be generated in the course of you taking part in the programme. For example recorded footage of you.
Lawful basis
Our lawful basis for processing your personal information is one of the following, as permitted by data protection law:
contract: the processing is necessary for the performance of the contract we have with you, or because you have asked us to take specific steps before entering into a contract.
legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect your personal data which overrides those legitimate interests. We or the third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in processing your data in connection with those interests.
legal obligation: the processing is necessary to comply with our legal obligations, for example providing a safe place of work and avoiding unlawful discrimination.
In relation to the special category data we hold about you we will process this in accordance with one of the grounds set out above and we will also ensure that one of the following applies:
(i) we have your explicit consent to the processing of such data.
(ii) You have knowingly and willingly made the data public.
(iii) Where it is necessary to establish, exercise or defend legal claims.
(iv) Where it is necessary for medical purposes.
(v) Where necessary or allowed under employment, social security or social protection law.
(vi) Where it is permitted for equality and diversity purposes.
In relation to personal data relating to criminal records, we will process this data where we have your consent to do so or where it is necessary or allowed under employment, social security or social protection law.
Who we share your data with
We will only share your data with third parties if we have a ground for processing on which we can rely and doing so is lawful. Examples of third parties that we may share your data with are as follows:
Payroll and benefits providers, professional advisors, IT suppliers, broadcasters, programme distributors, co-producers, insurers, health and safety advisors, regulatory authorities, external suppliers and, where you appear on-screen, viewers.
Transfers of data outside the UK and the EEA
Your personal information is mainly used in the UK. However sometimes we need to share your personal information with third parties outside the UK and EEA. Where we do so we will ensure that any transfer of data is lawful and that there are appropriate security arrangements in place.
Exemptions
Where you appear in a programme there are certain circumstances where data protection law allows us and relevant third parties (such as the commissioning broadcaster of the programme that you have contributed to) not to comply with the obligations explained in this notice. An example of where the exemption applies is where such obligations and your rights are incompatible with the artistic purposes of the programme and there is a public interest in its broadcast.
How we keep your data safe
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Personal data where possible will be saved in restricted access folders and password protected when appropriate.
WEBSITE USE
Our website and Use of Cookies
A ‘cookie’ is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. When you visit a site that uses cookies for the first time, a cookie is downloaded onto your computer/mobile device so that the next time you visit that site, your device will remember useful information such as items added in the shopping cart, visited pages or logging in options.
Cookies are widely used in order to make websites work, or to work more efficiently, and our site relies on cookies to optimise user experience and for features and services to function properly.
USE OF DATA PROCESSORS
Data processors are third parties who necessarily provide elements of our internal practices, such as IT providers. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
USE OF OTHER THIRD PARTIES
Some third parties with whom we share your data, for example for recruitment or casting purposes, are data controllers in their own right in which case they will have their own retention periods.
We have contracts with all third parties to ensure the security of your data that we share with them.
If you are applying to participate in one of our programmes or to work with us via a third party you should check that third party’s privacy notice too.
YOUR RIGHTS & ACCESS TO PERSONAL INFORMATION
Access: You have the right to access any personal information that Full Fat processes about you by making a ‘subject access request’. You can request information about: –
• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source
Once we have identified the person requesting the information the request will be carried out within one calendar month. There are numerous and various exemptions to this right and each request will be dealt with on a case by case basis.
Rectification: If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
Erasure and Restriction: You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us.
Portability and automated decision making: Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.
Withdrawing consent: If we rely on consent to process your personal information, you can withdraw that consent. We will then no longer process your information unless we have another legitimate legal basis for doing so or we rely on one of the exemptions.
To make a request about or for any personal information we may hold you need to put the request in writing to contact address or email address at the top of this privacy notice.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Complaints: You may complain to
ico.org.uk if you are not satisfied with our use of your data.
For further information about your rights under the General Data Protection Regulations (GDPR), please go to the Information Commissioner’s Office website –
https://ico.org.uk
Changes to this privacy notice
We reserve the right to update and alter this privacy notice. This privacy notice was last updated on 12 June 2024.