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Privacy Policy


1. Introduction
2. What information do we collect?
3. How do we use your personal information?
4. What is our lawful basis for using your personal information?
5. Data storage and timeframe
6. Your rights
7. Cookies
8. Links to other websites
9. Sharing your personal information
10. Outside Europe
11. Changes to our business
12. Are my details safe
13. Changes to our privacy policy
14. How to contact us
15. Information Commissioner’s Office (ICO)

1. Introduction

Brinkworth Productions Ltd and our umbrella companies Brinkworth Films Ltd and Brinkworth Television Ltd are UK based television production companies that specialise in making documentaries for television. Many of these documentaries are observational documentaries made about matters in the public interest. We work with UK and international broadcasters including the BBC, Channel 4 and Channel 5.

Your information is very important to us. We have set out below the information we collect about you and how we use that information. We collect, store and use your personal information in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

The policy is for Brinkworth Productions Ltd and our umbrella companies Brinkworth Films Ltd and Brinkworth Television Ltd. In this privacy policy any reference to “we”, “us” and “our” is to Brinkworth Films Ltd / Brinkworth Productions Ltd / Brinkworth Television Ltd. Brinkworth Productions Limited is a company registered in England and Wales (registered number is 11030690) with registered offices at 33 Percy Street, London, W1T 2DF. Brinkworth Films Limited is a company registered in England and Wales (registered number is 08784273) with registered offices at 33 Percy Street, London, W1T 2DF. Brinkworth Television Limited is a company registered in England and Wales (registered number is 10278697) with registered offices at 33 Percy Street, London, W1T 2DF.

2. What information do we collect about you?
What information we collect about you depends on your interaction with us.

If you are a contributor in any of our programmes we may ask you to provide us with personal information which may include but is not limited to your name, address, email address, date of birth and telephone number. If you appear in one of our programmes we will also have recordings / footage of you. Depending on the nature of the programme, we may also collect your “Special Category Data”(including information regarding your racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, and sexual origination/life) and/or your “Criminal Record Data” (including information about criminal allegations, proceedings, convictions and offences or related security information).

If you apply for a job at our company, we will collect your name, contact details and professional history together with any other information contained in your CV/you provide us with and would ask that we may store this information securely for not just the role you have applied for, but also for future employment opportunities at our company if you consent to this at the time of application. If no consent is given, we will delete all data once the position for which you applied has been filled.

We may contact you for the purposes of developing a programme idea or including you in a programme. Throughout this process will with gather personal information which may include but is not limited to your name, address, email address, date of birth and telephone number that you provide to us.

If you decided to visit and use our website, www.brinkworthfilms.co.uk , we will collect information via the use of first party or ‘Essential Cookies’ only. These cookies enable the basic functionality of our website on your computer. First party cookies do not collect any personal data and by default, first party cookies are allowed in every web browser.

3. How do we use your personal information?

If you are contributor in any of our programmes we may use your personal information to complete background checks or otherwise assess your suitability to be a contributor; to administer and manage your participation in the programme; to film and/or record you for the programme and to store and edit such material; to develop, exploit and produce the programme in which you participate; to deliver the programme to a broadcaster for them to transmit on television; and/or to make any payments due under any contributor release (if applicable).

If you send us your CV and contact information as part of a job application, we may use your information for the purposes of assessing your skills, qualifications and suitability for the role; carrying out background and reference checks; communicating with you about the recruitment process; keeping records relating to our recruitment processes; complying with our legal or regulatory requirements. At the end of this recruiting process, if you have consented we will hold your CV and contact details securely on our server for the purposes of future job opportunities at our company.

If you provide us with personal information during conversations with us for developing a programme idea or casting for a programme, we will use your data for those purposes. Your personal information will not be used for any marketing or sales purposes. However, we may, subject to your agreement, contact you about other future programmes that we think you may be interested in.

4. What is our lawful basis for using your information?

We will only use your personal information when we have a valid reason (known as a “lawful basis”) to do so, or, if the journalistic exemption applies (see below). Which legal basis is applicable will depend on 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 (or the interests of a third party including broadcasters) ensuring that your interests and fundamental rights do not override those interests;

b) For the performance of the contract we enter into with you (eg. 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.

Where we are using your personal information for the purposes of pursuing our legitimate interests (or the interests of a third party including broadcasters), those interests may include the development, production, exploitation, distribution, advertising, publicity and promotion of our programmes (including public interest programmes) and your contribution to the programme; ensuring all contributors are suitable for the programme; ensuring that the programme meets our standards and complies with all our legal obligations; establishing, exercising or defending legal claims; monitoring and managing access to our systems, protecting our networks and your personal information; investigating and preventing fraud; and, co-operating with investigations by regulatory bodies and/or the police or other law enforcement agencies and/or governmental agencies. We will only process your personal on legitimate interests grounds where our (or a third party’s) legitimate interests are not overridden by your own personal rights and freedoms. This will require us to carry out a balancing exercise to assess any competing rights.

In addition to having a lawful basis, and save where we may process your personal data under the journalistic exemption (see below) we will only use your Special Category information if one of the following conditions applies: you have given us explicit consent; we need to process such data in order carry out our legal obligations or exercise rights in connection with applicable law; where we need to protect your vital interests; where you have already made the information public; where doing so is necessary for the establishment, exercise or defence of legal claims; or it is necessary for reasons of substantial public interest. In addition to having a lawful basis, and save where we may process your personal data under the journalistic exemption (see below), we will only use your Criminal Record data with your consent, where you have already made the information public, or where the law otherwise allows us to do so.

Journalistic exemption

Sometimes, we will not need to have a lawful basis to use your personal information and/or need further justification to use your Special Category and/or Criminal Record information because we are able to rely on the ‘journalistic exemption’ contained in the Data Protection Act 2018. This exemption will apply if we a) reasonably believe that full compliance with the GDPR would be incompatible with our journalistic purposes; b) we are using the information with a view to publication of some journalistic material (e.g. a programme we are making; and c) we reasonably believe that publication of the journalistic material would be in the public interest.

5. Data storage and timeframe

We will collect, process and retain any personal information collected from you in accordance with all laws and regulations relating to the protection of personal data under the GDPR and the DPA 2018.

If you have entered in to an agreement with us for us to have your personal information there is no specific period for which we will keep your personal data. However, we will retain all information collected securely on our servers. In general, we will keep your personal data until a programme has been produced and for a period afterwards. In considering how long to keep it, we will take in to account its relevance to our business and your participation either as a record or in the event of a legal claim.

If you haven’t entered in to an agreement with us and we are processing your information because, for example, it is in our legitimate interests to do so, we will retain information collected about you for as long as is necessary for the purpose of developing, producing, distributing and administering the programme you are in. This includes legal, contractual obligations we have following the transmission of an episode. After this period, or if at any point Brinkworth Films determine they have no intention of broadcasting you in a programme, we will delete your data unless we require it in the event of a legal claim. All this data will always be kept securely on our servers for the period we are processing it. If you have provided us with personal information for the purposes of us developing a programme idea or casting we will hold all information securely on our server. Once the programme development has been completed or casting has been completed we will delete your information.

6. Your rights

You have rights when it comes to how we handle your personal information. These rights include:

• The right to be informed; • The right to access; • The right to rectification; • The right to erasure (also known as the right to be forgotten); • The right to restrict or supress processing; • The right to data portability; • The right to object (including when we are relying on legitimate interests as our lawful basis for using your personal information);

If you would like to exercise any of these rights please contact us (see contact details below). If we cannot comply with your request to exercise your rights, we will give you a full explanation as to why. We will respond to all requests within 1 month.

7. Links to other websites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any other website please note that these websites may have their own privacy policies and we do not accept any responsibility or liability for these policies.

8. Sharing your personal information

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) 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.

9. Outside Europe

We use certain third party companies to distribute our programmes on our behalf. These third party companies are only allowed access to your information as is necessary to perform this function. They are not allowed to use it for any other purpose.

Some of these third party companies are either located and/or operate outside the European Economic Area. Where we share your information with such companies, we will take all steps necessary under GDPR to ensure that your information is treated securely and in accordance with this privacy policy.

10. Changes to our business

If we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our assets, then your information may be included in the assets which are transferred to the new owner and may be provided to the entities and advisors involved.

If there are changes to our business (such as a reorganisation or restructuring), your personal information will remain subject to this privacy policy (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition, it may be subject to a different privacy policy. We, or the new owner, will provide notice to you (where practicable) before any of your personal information becomes subject to a different privacy policy.

11. Are my details safe?

We take the utmost care and attention to protect your personal information. Where reasonably practicable we use industry-standard technology to allow for the encryption of sensitive information.

13. Changes to our privacy policy

We keep our privacy policy under regular review and we may change it from time to time. Any updates will be posted on this webpage. This policy was last updated on 30 April 2019.

14. How to contact us

If you have any questions about our privacy policy or the information that we hold about you please contact us at: • Gail Pinkerton, Brinkworth Productions Limited, 33 Percy Street, London, W1T 2DF; or info@brinkworthproductions.co.uk

15. Information Commissioner’s Office (ICO)

The ICO is the UK’s independent body set up to uphold information rights.

If you are unhappy about the way in which your information has been handled you are able to contact the ICO at www.ico.org.uk/concerns.