Privacy Policies

Your information is very important to us and what information we collect about you depends on the way you decide to interact with us.

This page provides links to privacy policies which explain the information we collect about you and how we use that information.

We will collect, process and retain any personal information collected from you in accordance with all applicable data protection and privacy legislation in for from time to time in the United Kingdom.

In all privacy policies any reference to we, us and out is to Spark Media Partners Limited. Spark Media Partners Limited is a company registered in England and Wales (company number 08751333) with its registered office at 1 Church Terrace, Richmond, Surrey, TW10 6SE.

We keep our privacy policies under review so please check this page from time-to-time. These privacy policies were last updated in March 2021.

Participant

Spark Media North (“Spark”) is a company incorporated in England and Wales, with registered number13054978 . Its registered office is office 1, 863 Ecclesall Road, Sheffield, England S11 8TH.

This Privacy Policy explains how Spark uses and protects the information you provide to us at any time in the course of applying to and/or participating in programmes produced by Spark Media North (“Programme(s)”), whether as an applicant or potential contributor (“Applicant”) or once you have been selected or engaged to take part in a Programme and signed a contract and/or release form, as a contributor or other on-screen talent (“Contributor”).

As an Applicant, you may complete an application via the ‘Short Audition’ platform (“Application Website(s)”) and/or you may simply be contacted and/or invited by our casting team to apply, via the Application Website, to participate in a Programme.

If you are selected or engaged as a Contributor for a particular Programme, you will be asked to sign a contract or release form setting out the terms on which you agree to contribute to/ participate in the Programme, together with any other related documents such as Rules and Guidelines, Commercial Protocol and/or Press and Social Guidelines (collectively “Contributor Release”).

In this Privacy Policy “we/us/our/ Spark” refers to Spark Media North and its assignees, licensees and/or affiliates and, where appropriate, to any subcontractor engaged by Spark to build and/or provide services for the Application Websites and their contents. “You/your” refers to Applicants and Contributors.

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY AND YOU DO NOT WISH FOR YOUR PERSONAL INFORMATION TO BE COLLECTED, STORED, USED AND TRANSFERRED IN ACCORDANCE WITH THIS PRIVACY POLICY:

(A) AS AN APPLICANT: IF APPLYING VIA AN APPLICATION FORM, PLEASE DO NOT CONTINUE WITH OR SUBMIT YOUR APPLICATION; IF APPLYING VIA AN APPLICATION WEBSITE, PLEASE EXIT THE APPLICATION WEBSITE IMMEDIATELY AND DO NOT CONTINUE TO USE THE APPLICATION WEBSITE; AND IN EITHER CASE PLEASE EMAIL casting@sparkmedianorth.tv TO REQUEST THAT YOUR APPLICATION BE DELETED WITH SUBJECT HEADING ‘DELETE MY APPLICATION’; OR IF APPLYING BY POST OR BY ANY OTHER MEANS, PLEASE INFORM THE CASTING TEAM USING THE CONTACT DETAILS SUPPLIED AND CONFIRM THAT YOU WISH TO WITHDRAW FROM THE CASTING PROCESS.

(B) AS A CONTRIBUTOR: PLEASE DO NOT SIGN THE CONTRIBUTOR RELEASE; AND INFORM THE PRODUCTION TEAM THAT YOU WISH TO WITHDRAW.

1. INTRODUCTION
1.1 This Privacy Policy should be read:-
(a) by Applicants applying via an Application Form and/or an Application Website: in conjunction with the eligibility for the relevant Programme and the Terms and Conditions and by Applicants applying via an Application Website, in conjunction with the Application Websites policies
(b) by Contributors: in conjunction with the Contributor Release;

1.2 The capture, storage and use of your data is governed by the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland, the Data Protection Act 2018, and any other applicable data protection legislation (the “Data Protection Laws”). We are committed to safeguarding your personal information in a confidential and secure environment. We are registered with the Information Commissioner’s Office (“ICO”) as a data controller, with registration number ZB872777. Our registration can be confirmed by searching the Register of Data Controllers on the ICO website.

1.3 We reserve the right to modify, update or otherwise change this Privacy Notice (or any part of it) at any time without prior notice. Any changes will be posted on the Application Website.

1.4 Applicants who apply via the Application Website should note that the Application Websites may contain links to other Internet websites over which we have no control and/or you may access the Application Websites via links from third party websites or via other platforms (such as X (formerly Twitter), Facebook or Instagram). We are not responsible for privacy and data protection policies on any of those other websites and platforms. We encourage you to review the privacy policies of these websites and platforms so you can understand how they collect, store, use and share your information. Where you access an Application Website via a third-party platform, we encourage you to review the privacy policy on that platform, in conjunction with this Privacy Policy.

2. WHAT PERSONAL INFORMATION DO WE COLLECT AND WHY?
2.1 When applying to a Programme, submitting your application and/or registering on any Application Website, or in the course of our considering you as an Applicant or Contributor to any Programme (for example during an audition or interview, from any emails or letters you may send to us or from any other interaction/ correspondence with our casting team), or otherwise at any time during your participation in the Programme, you may disclose or be asked to provide certain information which is personal to you (“Personal Information”) which may include without limitation:-
(a) contact information such as your name, address, email address and telephone number, and emergency contact details;
(b) other personal information such as your date of birth, copy of your passport, current CV, any photographs of you, and details of your gender, nationality, occupation, living situation, and family members;
(c) information about your background, qualifications, experience and abilities;
(d) Personal Information collected from third parties including reference information, the addresses for and content of your social media profiles, and all online content and/or social media posts created/posted by and/or related to you.
(e) Where you have been engaged to take part in or chosen to be a Contributor to the Programme, we may also, collect, store and use any other Personal Information provided by you and/or collected by us in connection with your participation in the Programme, including without limitation all written and recorded material relating to your participation in the Programme.
(f) if relevant, your/ your agent’s bank details, including your/ your agent’s bank account number, sort code and/or VAT number.
We may also collect information about your application to a Programme and/or usage of any Application Website, such as browsing patterns, but information collected in this way will not identify you personally.

2.2 We may use the Personal Information listed at paragraph 2.1 above for one or more of the following purposes:
(a) to select potential contributors for the relevant Programme for which you have applied or are being considered for and (should you have given your consent in the Application Form) to consider you as a potential contributor for other Programmes produced by us;
(b) to administer and manage your application to the Programme, including without limitation: to send you reminders (if you consent during the application process) asking you to complete and submit your application, to identify when you use the Application Websites or contact us, to contact you for further information, respond to any queries you may have, to interview you by phone or in person and/or invite you to a further interview or audition, to help us operate and improve the application system or the Application Website(s);
(c) to complete background checks and otherwise to assess your suitability to be a Contributor to the Programme;
(d) to administer and manage your participation in the Programme, including without limitation: to identify you, to respond to any queries you might have about the Programme, to contact you in order to advise you of filming/ record dates, interviews, promotional events or other activities relating to the Programme, and if relevant, to pay you/your agent any fees and/or expenses;
(e) to film and/or record you for the Programme, to include your contribution (howsoever created) and details of you, your biography, background and past experiences in the Programme and to store and edit such material as we see fit.
(f) to develop, produce and exploit the Programme for which you have applied/ in which you participate including but not limited to sharing your personal data with members of the production team, broadcasters, financiers, distributors, and insurance brokers and underwriters of the Programme and/or for any of the other business purposes set out in the Terms and Conditions and/or Contributor Release Form;
(g) to transmit the Programme (and any advertisements for the same) to the public;
(h) to compile, aggregate and disclose to third parties general demographic information, including using such information for the purposes of ensuring diversity in the Programme – this information may relate to age, gender, location etc. but will not specifically identify you or your computer personally; and
(i) to make any payments due under the Contributor Release.

2.3 Should we need to carry out any background checks and/or searches to assess your suitability as a Contributor to the Programme, we may also collect, store and use (and you hereby consent to us collecting, storing and using) the following more sensitive Personal Information about you (which includes what is known as “Special Category” information and/or “Criminal Offence Data”):
(a) the results of any background checks (for example searches undertaken by us via online search tools, including Google, Lexis-Nexis, publicly available open source tools, and/or on social media platforms) to ensure you meet our eligibility criteria for the Programme;
(b) any information provided by you in relation to your health and/or your disability status, including the statement of health provided by you;
(c) the contents of any letter or other communication provided by your GP relating to the state of your health and/or the results of any medical examination (if necessary) undertaken to ensure that you are capable of taking part in the Programme;
(d) any declaration provided by you (for example a Self-Declaration relating to any Criminal Offence Data or a declaration of your current commercial interests) if you are chosen to be a Contributor to the Programme
(e) the results of any disclosure from the Disclosure and Barring Service (DBS) or a Disclosure Scotland (or any similar disclosure);
(f) any sensitive Personal Information for example about your background or personal life which you disclose to us during the selection process, or in the course of your participation in or transmission of the Programme.

2.4 We may also collect, store and use (and you hereby consent to us collecting, storing and using) information about your health and/or disability status, to safeguard your health and safety during your involvement with the Programme, to ensure that you are at all times able to participate in the production process and any related publicity for the Programme, and to monitor and manage sickness and/or absence during the production process.

2.5 We may also collect, store and use (and you hereby consent to us collecting, storing and using) information you provide us, including diversity characteristics, to ensure diversity in our Programmes.

2.6 UK broadcasters and Creative Diversity Network (CDN) are monitoring diversity on UK television through “Diamond Diversity”. Information is also collected about how viewers might perceive diversity on screen. There is a legitimate interest to collect diversity information about the television industry. If you participate as a Contributor to any of our Programmes, and you provide us with your name and email address and you do not notify us within 7 days of receipt of your Contributor agreement that you would prefer not to be involved in Diamond Diversity, we will enter your name and email address into a system called Silvermouse. You will then be invited to complete a diversity questionnaire in which you will asked to provide information about your diversity characteristics (including gender, ethnicity, disability, age, gender identity and sexual orientation). This information does not come to us, but is provided straight by you to the broadcaster. The broadcaster and CDN, as data controllers, are responsible for this data and will retain your name and email address for the above purpose in Silvermouse for as long as diversity is monitored by them. Find out further information about Diamond.

3. HOW WILL WE USE YOUR PERSONAL INFORMATION?
3.1 We will only use your Personal Information when we have a valid reason (also known as a ‘lawful basis’) to do so. Which legal basis is applicable will depend on precisely how we are using your Personal Information and for what purpose. Most commonly, we will use your Personal Information:
(a) because it is necessary to pursue our legitimate interests and where there is no undue adverse impact on you;
(b) for the performance of the contract we enter into with you (i.e. a Contributor Release Form) and in order to take steps at your request prior to entering into that contract;
(c) in order to comply with a legal obligation to which we are subject;
(d) because you have consented to us doing so (including pursuant to Clauses 2.3, 2.4 and/or 2.5 above).

3.2 Where we are processing your Personal Information for the purposes of pursuing our legitimate interests, those interests may include:
(a) providing you with information you request;
(b) improving the quality of our application/ selection process, including the Application Website(s);
(c) the development, production, exhibition, exploitation, distribution, advertising, publicity and promotion of the Programme and your contribution to the Programme;
(d) ensuring that all Contributors are suitable for the Programme;
(e) ensuring that the Programme meets our standards and complies with all our legal obligations;
(f) establishing, exercising or defending legal claims;
(g) monitoring and managing access to our systems;
(h) protecting our networks and your Personal Information;
(i) investigating and preventing fraud; and
(j) co-operating with investigations by regulatory bodies and/or the police or other law enforcement agencies and/or governmental agencies.

4. HOW MAY WE SHARE YOUR PERSONAL INFORMATION?
4.1 We may share your Personal Information with third party companies, agents, contractors, service providers or affiliated companies (including without limitation broadcasters, financiers, distributors, and insurance brokers of the relevant Programme for which you are an Applicant or Contributor) but only insofar as is necessary for the purposes described in this Privacy Notice. We may share your Personal Information with law enforcement agencies, other governmental agencies or other third parties if we are required by law to do so. We may also share your Personal Information with our professional advisors.
4.2 Should a third party acquire all or a substantial portion of our business (whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets, or as part of any insolvency of us where such a transaction has been approved by the court) we may include your Personal Information then in our possession as part of the transferred business assets in such sale/ transfer and share the same with our advisors and any prospective purchasers and their advisors.
4.3 Where we transfer your Personal Information outside the EEA we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the Personal Information concerned. This can be done in a number of different ways, for example: the country to which we send the Personal Information may have been assessed by the European Commission as providing an “adequate” level of protection for personal data; the recipient may have signed a contract based on standard contractual clauses approved by the European Commission; where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme. In other circumstances, the law may permit us to otherwise transfer your Personal Information outside the EEA. In all cases, however, any transfer of your Personal Information will be compliant with applicable data protection law.

5. SECURITY AND RETENTION OF PERSONAL INFORMATION
5.1 We have implemented appropriate technical measures designed to secure your Personal Information from accidental loss and from unauthorised access, use, alteration or disclosure, including encryption, firewalls and secure socket layers. Notwithstanding such measures, we cannot guarantee that unauthorised third parties will never be able to defeat those measures or use your Personal Information for improper purposes.
5.2 If you are selected and you agree to take part in the Programme for which you are being considered, we will retain your Personal Information (including your name and contact details and any relevant information relating to your participation in the Programme) for as long as is necessary in order to produce, market, distribute, exhibit, exploit, publicise, promote and/or advertise the Programme and to comply with our obligations to any broadcaster or distributor or other licensee authorised to do the same.
5.3 If for any reason you are not selected or you do not appear in the Programme, and you have consented for us to retain your Personal Information for the purposes of considering you as a potential Contributor for future series of the Programme or other programmes produced by us, then we will retain Personal Information, including any Application Form and contact details (but not the other additional Personal Information collected pursuant to Clause 2.3) for up to 3 (three) years from the first transmission of the final episode of the Programme for which you were considered as a contributor. If you have not consented, we will delete your Personal Information within 60 (sixty) days of first transmission of the final episode of the series of the Programme for which you applied/ were considered as a Contributor (“Transmission Retention Period”). In any event, if you do not take part or do not appear in the Programme, we will delete any additional information collected pursuant to Clause 2.3 prior to or on expiry of the Transmission Retention Period.

6. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
6.1 Under EU data protection laws you have a number of rights in relation to your Personal Information. Those rights include the right to:
(a) access your Personal Information (via what is commonly known as a “data subject access request”);
(b) require us to correct any mistakes in your Personal Information which we hold;
(c) require the erasure of your Personal Information;
(d) require us to restrict processing of your Personal Information, in certain circumstances;
(e) receive the Personal Information you have provided to us, in a structured, commonly used and machine-readable format and/or transmit that information to a third party, in certain situations;
(f) object to our continued processing of your Personal Information if such processing is carried out for the purpose of our legitimate interests; and
(g) withdraw your consent if we are relying on consent as our lawful basis for using your Personal Information.

6.2 Please note that not all of these rights are absolute – in some cases they will not apply to you, or to the particular use that we are making of your Personal Information (for example if we have to process the information to comply with our own legal obligations). For further information on each of these rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. If you wish to access a copy of your Personal Information or exercise any of your other rights, please make your request in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with applicable data protection legislation.

6.3 We are reliant on you to ensure that the Personal Information you provide to us is up to date and accurate and you agree to provide true and accurate information about yourself as requested by us. To assist us in ensuring your Personal Information is up to date, please let us know if any of your personal details change by emailing us at casting@sparkmedianorth.tv.

7. MONITORING
We may monitor and record any communications we receive from you. This may be done to improve the services which we provide or to ensure compliance with our practices and procedures.

8. JURISDICTION
This Privacy Notice is exclusively governed by and construed in accordance with the laws of England and will be subject to the exclusive jurisdiction of the English courts.

9. CONTACT US
If, at any time, you have issues or concerns about this Privacy Notice or believe that we have not adhered it, please email our Data Protection Officer at privacy@sparkmedia.tv. We will use reasonable efforts to answer promptly your question or resolve your problem. You also have the right to lodge a complaint with the ICO if you feel any concern of yours relating to this Privacy Notice has not been dealt with properly. The ICO may be contacted at https://ico.org.uk/concerns.

© Spark Media North
Last updated: March 2025

Employee

1. INTRODUCTION
1.1 This privacy policy focuses on individuals who are employed by us on a permanent or fixed term contract of employment or are applying for an employment position with us. It explains what data we collect and why, how we use it and who we share it with, as well as your rights as a data subject. It does not form part of your contract of employment.

1.2 We are known as the “data controller” of your personal data and you can contact us at privacy@sparkmedia.tv or write to us at 210 High Holborn, London, England WC1V 7HD for more information about how we process your data.

2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
2.1 We will collect and record various types of personal information about you from a variety of sources, but mainly directly from you. You will usually provide this information directly to us during the recruitment process and your period of employment. This information will include:
(a) your name, gender, nationality, marital status, date of birth, age, home address, telephone number, e-mail, national insurance number, eligibility to work data;
(b) qualifications, references, CV and application, interview and assessment data, vetting and verification information;
(c) payment information, such as bank account details;
(d) absence records, holiday dates and information related to family leave;
(e) browsing history, data stored on laptops, and other information collected as a result of you using our technology, equipment and systems; and
(f) equality and diversity data.

2.2 In addition, further information about you may come from:
(a) interviews and assessments;
(b) risk assessments, incident reports, data relating to training or training received, call sheets, contact lists, organised travel and hotel bookings, and insurance cover;
(c) allegations, HR investigations, colleague and manager feedback, appraisals, performance management, flexible working processes, restructure and redundancy plans;
(d) employment based litigation and complaints, or your involvement in incident reporting and disclosures; and
(e) third parties, such as recruitment agencies, references from a previous employer, medical reports from external professionals, tax authorities, or where we employ a third party to carry out a background check.

2.3 In some circumstances, data may be collected indirectly from monitoring devices or by other means, such as building and location access control and monitoring systems, CCTV, telephone logs and recordings, and email and internet access logs.

2.4 We may also collect and process a limited amount of personal information known as “special category data” such as racial or ethnic origin, religious beliefs, physical or mental health, sexual orientation, criminal records and information regarding criminal offences or proceedings.

2.5 You may also provide us with personal information relating to third parties, such as your next-ofkin and family members.

3. HOW AND WHY WE PROCESS YOUR PERSONAL INFORMATION?
3.1 We process your personal information to perform the contract of employment between you and us, and for compliance with legal obligations which we are subject to. This processing also enables us to provide you with various benefits and to manage and administrate your employment.

3.2 The processing of your personal information is also necessary for the purpose of the legitimate interests pursued by us (except where such interests are overridden by your interests or fundamental rights and freedoms), including:
(a) to produce audio-visual programming for commercial purposes, such as processing ‘onscreen’ and ‘off-screen’ contributions from individuals;
(b) for the assessment of applications for employment roles to ensure we identify the right people for our business;
(c) for the retention of your details so that you may be considered for future employment;
(d) to ensure you undergo training so that you can undertake your role correctly and in accordance with appropriate procedures; and
(e) to identify and mitigate risks to your health, safety or welfare and ensuring that where required appropriate adjustments are made to your working environment.

3.3 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.

3.4 We will only process your special category data where explicit consent has been given or where such processing is necessary, for example in a medical emergency involving you or for the establishment, exercise or defence of legal claims.

4. DIVERSITY MONITORING
4.1 We are part of 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.

4.2 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, Soundmouse and Silvermouse and you will be invited to participate in the Diamond project.

4.3 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, C4, C5, CDN and Sky. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice.

4.4 Further information about Diamond can be found here:
https://creativediversitynetwork.com/diamond/diamond-faq/contributors/

5. SHARING YOUR DATA
5.1 Your information will be shared within our organisation with our production, human resources, senior management, finance, technology, insurance, health and safety, and legal and business affairs teams.

5.2 We may pass your information to our third-party service providers such as providers of payroll, auto-enrolment pension, onboarding/offboarding and training services and other third parties
such as our insurers, bankers, IT administrators, lawyers, auditors, investors, consultants and other professional advisors. However, when we use third party service providers, we disclose only those elements of your information that are necessary to deliver the required service.

5.3 Limited personal information about you, such as your name and job title, may also be published on our website.

5.4 Please be reassured that we will not otherwise share your information further, unless:
(a) we are required to do so by law, for example by a court order;
(b) we are asked to by competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
(c) for the purposes of prevention of fraud or other crime.

6. SENDING YOUR PERSONAL INFORMATION INTERNATIONALLY
6.1 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.

6.2 Where we transfer personal data to other members of our group, or our service providers, we have put in place data transfer agreements and safeguards using terms approved by the applicable supervisory authority. Please contact us at privacy@sparkmedia.tv if you would like
to know more about these agreements or receive a copy of them.

6.3 Where this happens, we will ensure that adequate security and safeguards are in place to appropriately protect your information.

7. HOW LONG DO YOU KEEP MY INFORMATION?
7.1 In order to perform our contractual obligations and to comply with the applicable laws, we generally retain your information for the duration of your employment plus a further six (6) years.
Thereafter we will securely destroy your data.

7.2 We may keep some specific types of data, (for example tax records, pensions data) for different periods of time, as required by law.

7.3 Each CV which you send us will be retained by us in order to consider you for future productions.
You have the right to ask for your CV to be deleted from our records and can do so by contacting privacy@sparkmedia.tv.

8. USE OF COOKIES
8.1 Like many other websites, our website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.

8.2 It is possible to switch off cookies by setting your browser preferences, however turning cookies off may result in a loss of functionality when using our website.

9. YOUR RIGHTS AS A DATA SUBJECT
Access to your data
9.1 You can request access to the information we hold on you and we will also tell you:
(a) why we are processing it;
(b) who are we sharing it with and if any information is transferred to a country not deemed to have adequate protections in place for personal data;
(c) how long will we be keeping your data; and
(d) the source of the information, if it was not collected directly from you.

9.2 If you are making a request for a copy of your personal data that we are processing, please be as specific as possible as this will both help us to identify the information more quickly and provide you with a copy without any undue delay.

Rectifying inaccuracies
9.3 If you feel the information we hold on you is inaccurate or incomplete, you can ask us to correct or update it.

Right to be forgotten
9.4 You can also request that we erase your information in certain circumstances, although that might not always be possible if doing so means we cannot perform our contract with you, or we have a legal obligation or legitimate interest to keep the data. We will explain the consequences of erasing your data.

Restrict the processing
9.5 If you feel we are processing your information unlawfully or with inaccurate data, you can ask us to restrict any further processing.

9.6 Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims unless we have your consent. Please note that even if the processing is restricted, we will continue to store the data.

Object to the processing
9.7 If you disagree with any legitimate interest or public interest we have relied upon to process your data, you can object to the processing. We will then stop processing the data unless we can demonstrate a compelling legitimate ground that overrides your rights (e.g. exercising or defend a legal claim).

Data Portability
9.8 You can request to receive personal data that you have provided to us in a commonly used format and request that we transmit it to another data controller where feasible, or to you directly.

10. MAKE A COMPLAINT
10.1 We are committed to safeguarding your data and upholding your rights, but if you feel we have not done that, please contact privacy@sparkmedia.tv or write to Data Protection Officer, 210
High Holborn, London, England WC1V 7HD.

10.2 Additionally, you have the right to complain to the relevant supervisory authority, which in the UK is the Information Commissioner’s Office (ICO).

Freelancer

1. INTRODUCTION
1.1 This privacy policy focuses on individuals who are working for us on a freelance basis or are applying to work for us on a freelance basis. It explains what data we collect and why, how we use it and who we share it with, as well as your rights as a data subject. It does not form part of your contract of engagement.

1.2 We are known as the “data controller” of your personal data and you can contact us at privacy@sparkmedia.tv or write to us at 210 High Holborn, London, England WC1V 7HD for more information about how we process your data.

2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
2.1 We will collect and record various types of personal information about you from a variety of sources, but mainly directly from you. You will usually provide this information directly to us during the recruitment process and your period of engagement. This information will include:
(a) your name, gender, nationality, marital status, date of birth, age, home address, telephone number, e-mail, tax information, and eligibility to work data;
(b) qualifications, references, CV and application, interview and assessment data, vetting and verification information;
(c) payment information, such as bank account details;
(d) browsing history, data stored on laptops, and other information collected as a result of you using our technology, equipment and systems; and
(e) equality and diversity data.

2.2 In addition, further information about you may come from:
(a) risk assessments, incident reports, data relating to training or training received, call sheets, contact lists, organised travel and hotel bookings, and insurance cover;
(b) interviews and assessments; and
(c) third parties, such as recruitment agencies, references from a previous employer, medical reports from external professionals, tax authorities or where we employ a third party to carry out a background check.

2.3 In some circumstances, data may be collected indirectly from monitoring devices or by other means, such as building and location access control and monitoring systems, CCTV, telephone logs and recordings, and email and internet access logs.

2.4 We may also collect and process a limited amount of personal information known as “special category data” such as racial or ethnic origin, religious beliefs, physical or mental health, sexual orientation, criminal records and information regarding criminal offences or proceedings.

2.5 You may also provide us with personal information relating to third parties, such as your next-ofkin and family members.

3. HOW AND WHY WE PROCESS YOUR PERSONAL INFORMATION?
3.1 We process your personal information to perform the contract of engagement between you and us, and for compliance with legal obligations which we are subject to.

3.2 The processing of your personal information is also necessary for the purpose of the legitimate interests pursued by us (except where such interests are overridden by your interests or fundamental rights and freedoms), including:
(a) to produce audio-visual programming for commercial purposes, such as processing ‘onscreen’ and ‘off-screen’ contributions from individuals;
(b) for the assessment of applications for freelance roles to ensure we identify the right people for our business;
(c) for the retention of your details so that you may be considered for future engagements;
(d) to ensure you undergo training so that you can undertake your role correctly and in accordance with appropriate procedures; and
(e) to identify and mitigate risks to your health, safety or welfare and ensuring that where required appropriate adjustments are made to your working environment.

3.3 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.

3.4 We will only process your special category data where explicit consent has been given or where such processing is necessary, for example in a medical emergency involving you or for the establishment, exercise or defence of legal claims.

4. DIVERSITY MONITORING
4.1 We are part of 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.

4.2 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, Soundmouse and Silvermouse and you will be invited to participate in the Diamond project.

4.3 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, C4, C5, CDN and Sky. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice.
Further information about Diamond can be found here:
https://creativediversitynetwork.com/diamond/diamond-faq/contributors/

5. SHARING YOUR DATA
5.1 Your information will be shared within our organisation with our production, human resources, senior management, finance, technology, insurance, health and safety, and legal and business
affairs teams.

5.2 We may pass your information to our third-party service providers such as providers of payroll, auto-enrolment pension, onboarding/offboarding and training services, and other third parties
such as our insurers, bankers, IT administrators, lawyers, auditors, investors, consultants and other professional advisors. However, when we use third party service providers, we disclose only those elements of your information that are necessary to deliver the required service.

5.3 Limited personal information about you, such as your name and job title, may also be published on our website.

5.4 Please be reassured that we will not otherwise share your information further, unless:
(a) we are required to do so by law, for example by a court order;
(b) we are asked to by competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
(c) for the purposes of prevention of fraud or other crime.

6. SENDING YOUR PERSONAL INFORMATION INTERNATIONALLY
6.1 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.

6.2 Where we transfer personal data to other members of our group, or our service providers, we have put in place data transfer agreements and safeguards using terms approved by the applicable supervisory authority. Please contact us at privacy@sparkmedia.tv if you would like
to know more about these agreements or receive a copy of them.

6.3 Where this happens, we will ensure that adequate security and safeguards are in place to appropriately protect your information.

7. HOW LONG DO YOU KEEP MY INFORMATION?
7.1 In order to perform our contractual obligations and to comply with the applicable laws, we generally retain your information for the duration of your engagement plus a further six (6) years.
Thereafter we will securely destroy your data.

7.2 We may keep some specific types of data, (for example tax records, pensions data) for different periods of time, as required by law.

7.3 Each CV which you send us will be retained by us in order to consider you for future productions.
You have the right to ask for your CV to be deleted from our records and can do so by contacting privacy@sparkmedia.tv.

8. USE OF COOKIES
8.1 Like many other websites, our website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.

8.2 It is possible to switch off cookies by setting your browser preferences, however turning cookies off may result in a loss of functionality when using our website.

9. YOUR RIGHTS AS A DATA SUBJECT
Access to your data
9.1 You can request access to the information we hold on you and we will also tell you:
(a) why we are processing it;
(b) who are we sharing it with and if any information is transferred to a country not deemed to have adequate protections in place for personal data;
(c) how long will we be keeping your data; and
(d) the source of the information, if it was not collected directly from you.

9.2 If you are making a request for a copy of your personal data that we are processing, please be as specific as possible as this will both help us to identify the information more quickly and provide you with a copy without any undue delay.

Rectifying inaccuracies
9.3 If you feel the information we hold on you is inaccurate or incomplete, you can ask us to correct or update it.

Right to be forgotten
9.4 You can also request that we erase your information in certain circumstances, although that might not always be possible if doing so means we cannot perform our contract with you, or we have a legal obligation or legitimate interest to keep the data. We will explain the consequences of erasing your data.

Restrict the processing
9.5 If you feel we are processing your information unlawfully or with inaccurate data, you can ask us to restrict any further processing.

9.6 Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims unless we have your consent. Please note that even if the processing is restricted, we will continue to store the data.

Object to the processing
9.7 If you disagree with any legitimate interest or public interest we have relied upon to process your data, you can object to the processing. We will then stop processing the data unless we can
demonstrate a compelling legitimate ground that overrides your rights (e.g. exercising or defend a legal claim).

Data Portability
9.8 You can request to receive personal data that you have provided to us in a commonly used format and request that we transmit it to another data controller where feasible, or to you directly.

10. MAKE A COMPLAINT
10.1 We are committed to safeguarding your data and upholding your rights, but if you feel we have not done that, please contact privacy@sparkmedia.tv or write to Data Protection Officer, 210 High Holborn, London, England WC1V 7HD.

10.2 Additionally, you have the right to complain to the relevant supervisory authority, which in the UK is the Information Commissioner’s Office (ICO).