FILMING & TALENT PRIVACY POLICY

Objekt Ltd (the “Company”) is committed to protecting the privacy and security of your personal information.

This Privacy Policy is for individuals who are applying and/or being considered for any of our Productions (as further described below) or who otherwise feature in our footage or submit footage to us. This Privacy Policy describes the way that we will use your Information, in accordance with the Data Protection Act 2018 or any successor legislation, as well as the General Data Protection Regulation (EU) 2016/679 (for so long as and to the extent that the law of the European Union has legal effect in the UK).

Please read this Privacy Policy and any additional disclosures carefully to understand our policies and practices regarding your Information and how we will treat it. This Privacy Policy does not apply when you interact with us as a consumer.

If you have any further questions, or if you aren't sure about anything, please feel free to get in touch with us using the contact details set out at the end of this Privacy Policy and we will be happy to help.

Some defined terms:

• “Content”: we mean a piece of creative content that you have either applied for, are being considered for or have been approached to appear in or to work on as a contributor or in which you have otherwise featured, and which is intended to be made publicly available (including online on social media channels).
• "Information": we mean the information, materials and/or documents about you that you may share with us or that we collect or infer, including our footage.
• "Marketing Communications": we mean offers, promotions, publicity, information, news and/or updates, job/casting opportunities and/or other marketing communications.
• "Privacy Policy": we mean this privacy policy.
• "Process" or "Processing": we mean operation or set of operations which is performed on Information or on sets of Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• "Production": we mean a Film, or a Programme or Content.
• "Programme": we mean the development, programme and/or series, whether a scripted or non-scripted production or documentary (including any other versions that we might create) that you have either applied for, are being considered for or have been approached to appear in or to work on as a contributor, actor or talent or in which you otherwise feature.
• "Special categories of data": we mean data revealing racial or ethnic origin, political opinions or membership, religious or philosophical beliefs or affiliations, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, biometric templates, data concerning health or data concerning a natural person's sex life or sexual orientation as well as information about criminal conviction and offences or related security measures, or any other data types designated special/sensitive under applicable law.

What personal information might we collect, store and process?

When applying for one of our Productions, we will Process: (i) Information you provide us as part of your application or as part of any other communication or form you may provide to us; (ii) where applicable, additional Information from third parties or public sources (e.g. casting agencies/talent managers, health/benefit providers, insurance companies, co-production companies, online news stories,  social media profiles through which we may contact you and/or any references you provide us with) and/or (iii) inferred Information (e.g. assessment of your application, notes taken during the interview/casting process etc.).

This Information may include for example:

• Your personal contact details, such as name, title, address, telephone number and personal email address;
• Date of birth;
• Marital status and dependants;
• Next of kin and emergency contact information;
• Casting information, including your application and imgaes/videos

In certain circumstances, in particular if you are applying for one of our Productions, this information may also include your interests, audition materials and casting notes as well as Special categories of data such as:

• your race or ethnicity, religious beliefs, sexual orientation and political opinions;
• information about your health, including any medical condition, health and sickness records; and
• information collected about criminal convictions and offences.

We will tell you where Information collection is required by us – this will include Information that is necessary for us to perform any contract with you, or as otherwise indicated as mandatory on an application form. You should be aware that a failure to provide Information in these circumstances may be a breach of your agreement with us. Where Information is optionally provided, for example details of an emergency contact, there may be some adverse consequences if you refuse to provide this (for example, we would be unable to contact your next-of-kin if you suffered a medical event).

When your application is successful as reasonably required by us, we collect additional Information about you, for example financial details, tax/identity information and your inclusion in our footage. If you do not apply, but otherwise feature in one of our Productions (for example, if you feature in the background of one of our films or participate in user-generated Content submitted by another individual) then we will only Process Information that appears in our footage, or that you otherwise supply to us on any relevant release form or in any communication you send to us.

If you are under the age of consent in the relevant jurisdiction, your parent or guardian will be required to submit your information on your behalf and agree to our collection of your Information as set out in this Privacy Policy.

If you are providing the Information of someone else to us, they must agree to this, and be aware of this Privacy Policy.

How is your information collected?

Much of the information we hold has been provided by you, but some may come from other internal sources, such as your social media or portfolio, or in some cases, external sources, such as a casting agent or background check provider.

How your information will be used?

The information we hold and process will be used where necessary for our legitimate interests where our interests are not overridden by your data protection and privacy rights. Including:

• commission, develop, produce, publish, distribute and promote our Productions, including arranging finance, incentives, or subsidies for any of our Productions;
• make a decision as to whether you are the right person for the position you have applied for or to take part in the Production, or whether to accept and make use of Content that features you;
• contact you about your application, and/or casting process and/or your involvement in the Production as well as to respond to any of your communications, complaints or requests;
• investigate and resolve any concerns or other matters that may arise from your involvement with us and/or our Productions;
• consider you for any other Productions intended to be produced by us or our affiliate companies;  and
• protect our legitimate business interests and legal rights. This includes but is not limited to, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with any legal process or litigation or where requested by law enforcement or other relevant third parties).  

Where necessary to comply with a legal obligation, such as:

• carrying out necessary occupational health and safety and/or medical assessments; and
• administration of accounts and providing any information to tax and social security authorities as required by law.

Where necessary to prevent or detect unlawful acts, such as when carrying out background checks (e.g., checking your references and/or criminal record): such background checks will be carried out only to the extent permitted by and in accordance with applicable law and at different stages of the application process depending on the type of application you’ve made (e.g. it may apply only to the successful or shortlisted applicants).

Where necessary to protect the vital interests relating to you or another person (for example, avoiding serious risk of harm to you or others).

Where otherwise permitted or required under applicable law.

We may process your personal information in the following situations:

• Making a decision about your casting or contribution;
• Determining the terms on which you work for us;
• Checking you are legally entitled to work in the UK;
• Paying you and contracting you;
• Administering the contract we have with you;
• Complying with health and safety obligations;
• Equal opportunities monitoring.

Who will we share your information with?

We may also share your Information with other companies, organisations and/or individuals with whom we work and/or who provide services to us. As a result of this, and where applicable, we may share your Information with: (i) our service providers; (ii) the organisation that operates our website; (iii) casting agency, the production team, co-producers, the relevant broadcasters, distributors, licensees and/or exhibitors, investors, insurers, distributors, unions and/or industry representatives, background check providers, IT system suppliers and/or travel and medical service providers of Productions; and/or (iv) where we have to, in order to comply with laws, as required by a court; and/or (v) in the event of an actual or potential merger, acquisition, or business transaction.

In respect of Marketing Communications:

• if you have indicated that you wish to receive Marketing Communications from us, then we will share certain Information, such as your name, email address and/or any other chosen method of communication with the organisations that help us send you Marketing Communications; and
• if you have indicated that you wish to receive Marketing Communications from someone else, then we will share certain parts of your Information, such as your name and contact details with that other organisation who will use it to send you the Marketing Communications that you have requested.

We will share certain Information such as your name, email address and/or such other chosen method of communication with development and/or production teams, commissioning broadcasters and/or distributors to contact you about potential opportunities with other productions, unless you have told us that you don't want us to.

Change of Control

In the event we go through a business transition such as a merger, acquisition, bankruptcy, reorganisation, or sale of all or a portion of our assets, or a diligence process in connection with a potential business transaction, the information we collect and maintain may be disclosed, sold, or transferred as part of that transaction. If such transfer is subject to additional restrictions under applicable laws, we will comply with such restrictions.

Transferring Information Internationally

We may transfer your personal information to third-party service providers outside the country where you are located.  We have put in place appropriate security measure, such as the adoption of standard contractual clauses approved by the European Commission and, if the transfer is to the United States of America, we will verify that recipient is certified under the EU-US Privacy Shield framework.

How long will we retain your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting,  reporting requirements, or further disclosed to you as part of the application process.

This means that the retention periods will vary according to the type of Information and the reason for which we need to process it (e.g. recruitment, Marketing Communication, establishment, exercise or defence of legal claims, applicable legal or regulatory obligations etc.). Please be aware that if you are a successful applicant or if you are otherwise featured in final footage, your Information will be kept for a longer period (i.e. your Information will be kept for at least as long as the Production is being broadcast, distributed and/or exploited).

After the relevant retention period has elapsed, where permitted under applicable law, the Information is securely deleted. For more information about our retention policy, please submit a request by emailing makenoise@objekt.co.uk

Changes to this Privacy Policy

This Privacy Policy was last updated in July 2022. We may need to make changes to this Privacy Policy from time to time and if the changes are important, we will let you know about it. We encourage you to come back and review this policy every now and again so that you don't miss out on any updates.

You have the right to:

• Request access to your personal information.  This enables you to receive a copy of the personal information we hold about you, and to check that we are lawfully processing it.
• Request correction of the personal information we hold about you.
• Request erasure of your personal information where there is no good reason for us to continue to process it.
• Object to processing of your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing.
• Request the transfer of your personal information to another party.
• Lodge a complaint with the Information Commissioner’s Office if you believe that we have not complied with the requirements of data processing legislation.

You will not have to pay a fee to exercise any of your rights detailed above, however we retain the right to charge a reasonable fee if your request for access is deemed unfounded or excessive. We may also need to request specific information from you to help us to confirm your identity for security purposes.

Please contact Alex Kempner (alex@objekt.co.uk) if you have any questions.