Personnel Privacy Notice

LAST UPDATED OCTOBER 2022

  1. Introduction

1.1 Humble Pie Productions Limited, trading as Studio Ramsay (“we”, “us” or “our”), is a company registered in the United Kingdom under company number 09909641, with its offices at 539-547 Wandsworth Road, London SW8 3JD

1.2 Like most businesses, we hold and process a wide range of information, some of which relates to the individuals we employ, engage on our productions or who otherwise contribute to our productions. This privacy notice (the “Notice”) explains the type of information we process relating to you (i.e. your “personal data”), why we process it and how that processing may affect you. This Notice applies to you if you are employed by us, or are engaged by us to work on one of our productions, for example in:

1.2.1 production roles, such as series producer, production coordinator, 1st AD;

1.2.2 craft roles, such as set designers, camera and sound crew;

1.2.3 on-screen roles, such as extras, featured performers, contributors, as well as our voiceover artists; and

1.2.4 other cast, crew and contributors to our productions

(“personnel”).

1.3 Where we decide the purpose or means for which your personal data is processed, we are the “data controller” for the purposes of the General Data Protection Regulation 2016/679 and the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European union (Withdrawal) Act 2018.

1.4 We work with a range of third party suppliers who help us find and recruit our personnel. One of the most important of such suppliers is a third party platform called The Talent Manager through which we are able to find and recruit a large number of our personnel and manage a large portion of our CV database. Where you submit your personal data (including CV) to The Talent Manager, The Talent Manager will independently make use of that personal data, such as to facilitate your application to Studio Ramsay, or other third party productions, on your request. Please refer to The Talent Manager’s privacy notice for further information regarding its processing of your personal data.

If you have questions or concerns relating to this Notice or our processing of personal data, please contact: Eleanor@studioramsay.com.

2. What Personal Information Do We PROCESS And How Do We Use It?

This section sets out the different types of personal data we process about you, the purposes for which we use it and where we obtain the information. For further information on the purposes for which this personal data is used, please refer to section 3.

Your data

Purposes of processing

Sources

Contact Data

  • Name
  • Address, telephone, email and other contact (personal and work) details
  • Age, date of birth, gender, marital status, location
  • Driving status
  • Recruitment
  • Right to Work
  • Employment or Engagement
  • Leave Administration
  • Finance & Accounting
  • Benefit Administration
  • Health & Safety
  • Crime & Fraud
  • Production Distribution
  • Insurance

We collect this information from you directly, from our / your recruitment / casting consultants or platforms (such as The Talent Manager), or from your agent.

Recruitment Data

  • CV, portfolios, showreels, professional and academic qualifications and experience
  • Skills and language capabilities
  • Social media accounts
  • Professional licences, certifications, accreditations or memberships
  • Information supplied in interview or through assessments
  • References (including both those we collect, and those we provide to others where you request we do so) and background checks (see further at ‘Vetting Data’ below)
  • Offer letters and associated correspondence
  • Personal data in your CV or provided in relation to your recruitment.
  • Inferences and opinions drawn from Recruitment Data.
  • Recruitment
  • Right to Work
  • Employment or Engagement
  • Health & Safety
  • Crime & Fraud

We collect most of this information directly from you.

We may also receive information from our/your recruitment / casting consultants or platforms (such as The Talent Manager), or from your agent.

We may also obtain some of this from your public social media profiles (such as Linked:In), and other public sources, and from your referees.

Right to Work Data

  • ID and right to work documentation (e.g. driving licence, work permits, residency status, passport, visas, citizenship documentation)
  • Recruitment
  • Right to Work
  • Employment or Engagement
  • Crime & Fraud

We generally collect this information from you, but may compare it with information held by us or available on public records.

Key Contact Data

  • Spouse, partner, next of kin and emergency contact details including date of birth, address, telephone number.
  • Benefit Administration
  • Health & Safety
  • Crime & Fraud

We collect this information from you.

Please ensure that, where you provide us with this sort of information, the individuals concerned receive a copy of this policy and are happy for you to provide their information.

HR Data

  • Role, contract, date of hire, start, promotion, resignation, termination
  • Pension and benefits (e.g. medical, dental, retirement, life insurance) information
  • Remuneration, bonuses, rewards, sick pay, compensation history, student loan, and bank details
  • National Insurance, PAYE, tax, social security, residency, payroll and P45 information
  • Location of production / workplace
  • Information relating to your compliance with our policies
  • Working hours, time records, flexible working requests, work history, training (including health and safety training) records
  • Performance history, achievements, complaints and awards
  • Performance and appraisal review records, hearing, investigation, warning, disciplinary and grievance records
  • Absence and leave data (including sickness, paternity/maternity, annual and other leave, and associated forms, certificates and other related documentation)
  • Payment information for business credit or debit cards, limits, account details, how and where they are used or authorised for use.
  • Recruitment
  • Right to Work
  • Employment or Engagement
  • Leave Administration
  • Finance & Accounting
  • Benefit Administration
  • Health & Safety
  • Diversity Monitoring
  • Crime & Fraud
  • Production Distribution

We collect much of this information from you directly.

Some of this information is generated by you or us in the course of your work with us.

Certain other information, for example relating to your performance, may be collected from colleagues and others you work with.

We may also receive some of this information from HMRC or other authorities, or from benefit providers, or corporate credit or debit card providers and other suppliers we work with.

Work Data

  • Information produced during your engagement or employment, including any of your contributions recorded as part of a production (such as video, audio or images), email, voicemail, correspondence, calendar items, usernames, paper and electronic documents, and other work product and communications created, stored, transmitted or accessed via our networks, software, devices, or systems.
  • Content you produce for use on our website or social media, such as photographs, audio, videos, blog posts.
  • Information relating to your travel arrangements where relevant for a production.
  • Information relevant to a dispute or legal proceedings, or potential dispute or legal proceedings affecting us.
  • Recruitment
  • Right to Work
  • Employment or Engagement
  • Leave Administration
  • Finance & Accounting
  • Benefit Administration
  • Diversity Monitoring
  • Health & Safety
  • Crime & Fraud
  • Production Distribution
  • Insurance

We collect much of this information from you directly.

Some of this information is generated by you or us in the course of your work with us.

Certain other information, for example relating to your performance, may be collected from colleagues and others you work with.

We may also receive information from other entities we work with to produce or distribute a production.

Health Data

  • Information regarding your health, including any disability or medical conditions, covid vaccination status, covid testing results, workplace (or filming arrangement) adjustments required, and other of your health and sickness records.

  • Benefit Administration
  • Health & Safety
  • Leave Administration
  • Insurance
  • Employment or Engagement

We collect this from you directly. We may also work with third party health assessment or covid testing providers who will share, with your permission, the results of your health tests with us.

Vetting Data

  • Information regarding criminal convictions & offences, inc. criminal record checks through DBS
  • Financial background checks through government websites
  • Drug and alcohol testing (for specific programming only)
  • Credit reference agency checks (for specific programming only)
  • Employment or Engagement
  • Right to Work
  • Health & Safety
  • Crime & Fraud

We collect this from you directly, from public authorities, or credit reference agencies.

IT & Security Data

  • CCTV footage
  • Key card and security pass identifiers, photographs and ID
  • Sign in activity (date, time, location) for specific Microsoft applications (Microsoft SharePoint, OneDrive and Office 365) and audit logs showing activity within such applications.
  • Details of phone, laptop, computer and other devices used to connect to our systems or otherwise in the course of your work
  • Certain usernames and passwords used during on our systems, name and email address

Purposes

  • Employment or Engagement
  • Health & Safety
  • Crime & Fraud

We collect some of this information from you directly, and some of it is collected through our systems as you use them.

3. HOW DO WE USE YOUR PERSONAL INFORMATION AND ON WHICH LEGAL BASIS?

This table sets out in more detail the purposes for which we process personal data. It also explains the legal basis for that processing.

Purpose

Our legal basis for this processing

Recruitment

We use this information to make a decision about your recruitment or appointment and to determine the terms on which you work for us, and whether you are suitable for the role or production you are applying for.

Our and your legitimate interests in ensuring that you are the right candidate for the role, suitably qualified and experienced, and that the terms of your prospective engagement meet our mutual expectations and our business objectives.

Right to Work

We use this information to ensure you have a right to work in the role on the production you have applied for.

Our legal obligation to ensure you are entitled to work for us in the country where you are engaged.

Employment or Engagement (inc. contractor and contributor engagement)

We use this information to:

  • administer the contract we have entered (or will enter) into with you;
  • provide access (local or remote) to systems, services, premises & facilities;
  • arrange travel, visas & accommodation;
  • manage HR processes e.g. performance, disciplinary and grievance procedures;
  • enable you to discharge your duties;
  • promote our business and personnel, for example by providing personnel bios to our business partners, on our website or in press releases;
  • maintain a profile for our personnel which is available to all employees internally in our directory, which includes information such as your name, telephone number, email, job role and title.

We process personal data for this purpose in order to:

  • perform our agreement with you, or to take steps prior to entering into such agreement;
  • pursue our and your legitimate interests, being our mutual legitimate interests in ensuring that our business and your contribution to it are successful, that you are able to, and do, discharge your duties, that your performance is recognised or rewarded appropriately, that developmental needs are understood and met and that disciplinary matters and concerns are understood and addressed correctly; and
  • comply with our legal obligations.

Leave Administration

We use this information to administer statutory and contractual leave entitlements including sickness and other absences.

Our respective legitimate interests in ensuring absence and cover are dealt with appropriately.

To perform our contractual obligations to you and to comply with our legal obligations.

Finance & Accounting

We use this information to pay you and, if you are an employee, deduct tax and National Insurance contributions, and for the purpose of maintaining our accounts.

To perform our contract with you, or take steps requested by you prior to entering a contract, and to comply with our legal obligations.

Benefit Administration

We use this information to administer and provide pension contributions, medical, dental or life insurance, childcare and similar support, and any other memberships or benefits we may agree with you from time to time, and to liaise with associated benefit providers.

To perform our contract with you, or take steps requested by you prior to entering a contract, and to comply with our legal obligations.

For healthcare and associated insurance purposes, with their consent, we may also process and share (with benefit providers) information about your spouse, partner or dependents (including birthdate, phone number, social security number, and tax identification number).

Health & Safety

We use this information to assess fitness to work, carry out desk audits, assess needs and reasonable adjustments, to ensure the health and safety of our personnel, applicants and participants, and to record accidents at work. We may also use Key Contact Data to communicate with a designated third party in the event of a medical emergency, disaster or similar.

To meet our legal obligations, to perform our contractual obligations, and to pursue our and your mutual interests in ensuring health and safety in the workplace.

Crime & Fraud

We use this information to detect and prevent fraud and other crime.

To meet our legal obligations, and pursue our legitimate interest in detecting and preventing crime, and harm to our property or personnel.

Production Distribution

We use this information to enable the creation, sale, marketing and distribution or broadcast of a production you are taking part in, and (in certain circumstances) to credit your role.

To pursue our and your legitimate interests, being our mutual legitimate interests in ensuring that our production and your contribution to it are successful.

Insurance

We use this information in order to obtain insurance for our business and productions.

To meet our legal obligations and pursue our (and your) legitimate interest in ensuring we are adequately covered and able to meet any financial liabilities arising out of accidents and incidents.

4. FURTHER INFORMATION REGARDING SPECIAL CATEGORIES OF PERSONAL DATA

4.1 ‘Special categories’ of personal data such as (without limitation) certain of the data listed under ‘Equalities Data’ and ‘Health Data’ at section 2 above, are granted higher levels of protection by data protection laws. We will only process special categories of personal data if it is appropriate given the nature of the circumstances of your engagement with us and where we are legally able to do so.

4.2 We are only able to legally process your special category personal data where we have identified both a lawful basis (as identified in section 3) and a 'special condition' for such processing. We have therefore identified the following special conditions for our regular processing of your special category data:

4.2.1Health Data: employment, social security and social protection, to ensure health, safety and welfare of personnel, obtain relevant workplace insurance, provide appropriate workplace adjustments, monitor and manage sickness absence, maintain records of statutory sick pay and maternity pay and to administer personnel benefits.

4.2.2 Equality Data: equality of opportunity or treatment, for the purposes of monitoring and reporting equality of opportunity or treatment at the workplace with a view to enabling such equality to be promoted or maintained.

5. FURTHER INFORMATION REGARDING CRIMINAL CONVICTIONS DATA

5.1 Similar to special category data, we also need to have an additional special condition in order to process criminal convictions data. Our background checks may involve DBS checks in some cases or voluntary disclosure by you. Our special condition for processing your criminal convictions data as part of DBS checks is that it is necessary to establish whether a member of personnel has previous convictions for crimes for the purposes of carrying out our employment law obligation to take reasonable care for the safety of our personnel.

5.2 Where a background check is a voluntary disclosure by you of criminal records our special condition will be your consent, which we will make clear to you at the time. Where we rely on your consent in this way, you can withdraw your consent at any time.

6. Who Do We Share Your Personal Information With For Such Purposes?

6.1 If you have an on-screen role, your personal data (such as video, images or audio of you, to the extent it is part of the production we are creating) will likely be broadcast publicly as part of our sale, distribution and marketing of the production.

6.2 Similarly, if you have an off-screen role, your personal data (namely, your name and contribution to the production) may be broadcast publicly where necessary to credit your role.

6.3 Further, we may share your personal information with third parties as specifically approved by you or under the circumstances described below.

6.3.1 Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006, and which includes Studio Ramsay Global and XOF Productions, LLC), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Notice. However, this is on the basis that they have agreed to safeguard the information.

6.3.2 Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may be required to share your personal data with the buyer.

6.3.3 Required by law: In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

6.3.4 Enforcement: We may also disclose your personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel, or others.

6.3.5 Professional services (suppliers): We may also share your personal information with our service providers and subcontractors, provided they use that personal data on our instructions and not for their own independent purposes. The categories of supplier who may receive your personal data include:

a)recruiters and recruitment / casting consultants and platforms such as ETribz, We do Talent, Independent Post, Satusfaction, In Crowd, Talent Manager, Facebook, Talented People, Production Hive, Production Base, Tovs, Blueberry Creatives, Soho Editor, The Camera Crew, The Firm – camera crew, Impact Recruitment and Handle Recruitment, who identify candidates for our open positions;

b)The Talent Manager through which we obtain information regarding your CV and application to our roles;

c) third party suppliers to administer payroll, benefits and other human resource functions;

d) third party travel agents to arrange travel for personnel to productions or other engagements taking place abroad;

e) a range of other suppliers to provide our business infrastructure, including email service providers, web hosts, IT support consultants, and suppliers of security technology (e.g. key-card access systems);

f) health and safety advisors who advise on the health and safety considerations for our workplaces and productions; and

g) specialist consultants or advisors where required for a particular production, such as for psychological assessment.

Please note that for benefits such as medical insurance, your personal information may be provided directly by you to the third party service provider.

7. How Long Do We Keep Your Personal Information For?

We will only keep your personal data for as long as it is reasonably necessary to do so bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.

8. Confidentiality And Security Of Your Personal Information

8.1 We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration by implementing information security policies, rules and technical measures to protect the personal information that we have under our control from:

8.1.1 unauthorised access;

8.1.2 improper use or disclosure;

8.1.3 unauthorised modification; and

8.1.4 unlawful destruction or accidental loss.

8.2 All of our employees and data processors (i.e. the suppliers who may process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users.

9. Your Rights

  • You have the following rights in relation to your personal data, although these rights may be limited in some circumstances:
  • Request access. You have the right to ask for a copy of personal data we are processing about you.
  • Request correction. You have the right to request correction of the personal data we hold about you, such as if it is incomplete or inaccurate.
  • Request erasure. You have the right to request erasure of your personal data, where there is no legitimate reason for us to continue to process it, or where you have exercised your right to object to the processing (see below).
  • Object to processing. You have the right to object to the processing of your personal data where we rely upon the legal basis of our (or a third party’s) legitimate interests for that processing.
  • Request processing restriction. You have the right to ask us to suspend processing of your personal data, such as if you want to establish its accuracy or the reasons for it being processed.
  • Request machine-readable copy and transfer. You have the right to request a machine-readable copy of your personal data, which you can use with another data controller. Where it is technically feasible, you can also ask us to send this information directly to another data controller if you prefer.
  • Right to make a complaint. You have the right to make a complaint to a data protection supervisory authority. In the UK, the relevant supervisory authority would be the Information Commissioner’s Office. Please refer to section 13 of this policy for further information.
  • Right to withdraw consent. In the limited circumstances for any processing by us of your personal data for which we rely upon the legal basis of your consent, you have the right to withdraw your consent at any time upon notice to us. If you do, we will no longer process the relevant personal data.

9.2 To make a request, please let us know by sending an email to eleanor@studioramsay.com. We aim to comply with any request without undue delay, and within one month at the latest.

10. INTERNATIONAL TRANSFERS

10.1 We may transfer your personal data to location outside of the UK, for example to members of our corporate group or to providers who deliver services to us.

10.2 Where we transfer your data outside of the UK, we will have appropriate safeguards in place to protect your personal data, an example of which may include standard data protection clauses adopted by a data protection regulator and / or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about the safeguards we use for these purposes, please let us know by writing to eleanor@studioramsay.com.

11. How To Contact Us

If you have any questions about this Policy or want to exercise your rights set out in this Policy, please contact us by sending an email to Eleanor@studioramsay.com.

12. Complaints

If you have complaints relating to our processing of your personal data, you should raise these with your key contact at the production in the first instance or contact: eleanor@studioramsay.com. If we can’t resolve your issue, you can also get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns (or if you live in a European country, you can submit a complaint to the supervisory authority in your country).

13. changes To This NOTICE

To ensure that you are always aware of how we use your personal information we will update this Notice from time to time to reflect any changes to our use of your personal information and as required to comply with changes in applicable law or regulatory requirements. However, we encourage you to review this Notice periodically to be informed of how we use your personal information.