INTRODUCTION
Hardcash Productions Limited is an independent production company that
creates and produces documentaries and investigative films for all
platforms internationally.
Hardcash Productions Limited is a company registered in the United
Kingdom under company number 02695415 and our registered office is at
4th Floor 399-401 Strand, London, WC2R 0LT.
Here at Hardcash Productions we process personal data for 4 main
reasons:
1. In relation to potential contributors, and actual contributors, on a
programme in order to develop and produce content and programmes;
2. As employers;
3. In the performance of a supplier contract;
4. If we have permission from the user, or where otherwise allowed by law,
to market to them.
We are the data controller responsible for your personal data. This notice
explains what we do with your personal data.
If you have any questions about this privacy notice or how we handle your
data please email us at hardcash@hardcashproductions.com or write to us
at our registered office address marked for the attention of the privacy
officer.
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CONTRIBUTORS
In this privacy notice “contributors” means people who are participants or
who approach us to be in our programmes and other people who contribute
to our programmes (for example interviewees or people who allow us to use
their materials).
Information that we collect
When you approach us to be on a specific programme or if we approach you
or your representatives about being on a specific programme we will collect
sufficient information to determine your suitability for that programme.
When you approach us to be on any of our future programmes we will
collect sufficient information to determine whether to contact you about
such programmes as and when we are carrying out research for them.
1. Contributors of interest
If we meet and/or film with you we will continue to process such information
as is necessary for the production and exploitation of that programme. This
will always comprise contact information and may include, but is not limited
to, information contained in an application form, a programme release form,
special category data such as health and medical data and criminal offence
data.
In addition we may process sufficient data so as to remunerate a
contributor, where appropriate.
2. Prospective contributors
As with those we meet and/or film with we may process data as above. If
you do not appear in a particular programme we may keep your details and
contact you about Hardcash Productions programming and products unless
you ask us not to.
3. Unsuitable contributors
If we deem that you are unsuitable to appear in any programme we will
delete the majority of your data and retain sufficient contact data to send
you information about Hardcash Productions programming and products
unless you ask us not to.
Where the information comes from
Some of the information comes from you. For example your contact details,
on application forms, on the programme release form, or in discussions with
you.
Some information comes from third parties. For example publicly available
sources, from your friends or family members, social media platforms, or
background check service providers.
Other information is generated in the course of you taking part in the
programme. For example recorded footage of you.
Lawful Basis
Our lawful basis for processing your personal information is one of the
following, as permitted by data protection law:
contract: the processing is necessary for a contract we have with you, or
because you have asked us to take specific steps before entering into a
contract.
legitimate interests: the processing is necessary for Hardcash
Production’s legitimate interests or the legitimate interests of a third party
unless there is a good reason to protect your personal data which overrides
those legitimate interests.
In relation to the special category data we hold about you we will process
this in accordance with one of the grounds set out above and we will also
ensure that one of the following applies:
We have your explicit consent to the processing of such data.
You have knowingly and willingly made the data public.
Where it is necessary to establish, exercise or defend legal claims.
Where it is necessary for medical purposes
Where necessary or allowed under employment, social security or
social protection law
When in the substantial public interest, such as for journalistic/artistic
purposes in connection with unlawful acts or dishonesty
In certain circumstances we may hold information about criminal convictions
or offences which you may have incurred. If this is the case we will process
this data where we have your consent to do so or where it is necessary or
allowed under employment, social security or social protection law.
We do not keep a comprehensive register of our contributors’ criminal
convictions.
Children
From time to time we may make programmes with child contributors. We will
process the data of the child contributor as it is in our legitimate
interests. Where a parent or guardian has signed our mutually agreed
contract it will be necessary to process their data alongside this (as
above). We will not send marketing information to our child contributors but
to their parent or guardian.
Who we share contributor data with
We may share contributor data (including your special category and criminal
offence data) with broadcasters, programme distributors, co-producers,
insurers, health and safety advisors, professional advisors, regulatory
authorities, external suppliers and viewers.
How long we retain contributor data
We do not keep contributor data for longer than is necessary, bearing in
mind the purpose for which we collected that information and any applicable
legal or regulatory requirements.
Transfers of data outside the UK and the EEA
Your personal information is mainly used in the UK. However sometimes we
need to share your personal information with third parties outside the UK
and EEA. Where we do so we will ensure that any transfer of data is lawful
and that there are appropriate security arrangements in place.
Please note that any programme in which you appear is likely to be
distributed internationally.
Exemptions
There are certain circumstances where data protection law allows us and
relevant third parties (such as the commissioning broadcaster of the
programme that you have contributed to) not to comply with the obligations
explained in this notice. Examples of where the exemption applies is where
such obligations and your rights are incompatible with the artistic purposes
of the programme, processing for the purpose of journalism, and there is a
public interest in its broadcast.
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EMPLOYEES, FREELANCERS AND CONTRACTORS
This section of the privacy notice applies if you are working for us in any
capacity, for example as an employee, freelancer, contractor, through a
personal services company, or if you are applying to do so. It includes
those working on our productions, both on-screen (e.g. presenter, voice-
over artist) and off-screen (e.g. productions staff, crew).
This notice does not form part of your contract of employment or other
contract to provide services.
Information that we collect
We collect and use different types of personal data about you before you
start working with us (during the application process) and in the course of
your employment or engagement.
You may be asked to provide the following at the application stage:
Proof of your identity.
Proof of your qualifications.
A criminal records declaration to declare any unspent convictions.
We may contact your referees directly to obtain references.
We may ask you to complete a questionnaire about your health. This is to
establish your fitness to work as well as for your well-being whilst on our
premises.
If we employ or engage you we may ask you to provide the following:
Bank details – to process salary or other payments.
Emergency contact details – so we know who to contact in case you have
an emergency at work.
Information for your inclusion in our pension scheme (if applicable). We
use a data processor for this scheme.
We may ask you to provide special category data, for example information
on your nationality, racial and ethnic origin, gender, sexual orientation,
religion, disability and age,
What will we do with the information you provide to
us?
At the application stage:
The information you provide will be used for the purpose of progressing
your application, or to fulfil legal or regulatory requirements if necessary.
The information you provide will be held securely by us and/or our data
processors.
Where you have sent us a speculative application, if there is no suitable
vacancy at that time we keep them in our system for 24 months at which point we will redact the information but keep the contact information on our
database until such time as you opt out.
If you are unsuccessful following an application to work with us, we may ask
if you would like your details to be retained in our talent pool for a period of
24 months. If you say yes, we will proactively contact you should any
further suitable vacancies arise.
If you work with us we will use your personal data for a number of reasons
such as for administration and management purposes, to manage salaries
and pensions and to manage health and wellbeing. Where you are working
on a specific programme we may also use your personal data to enable us
to produce, broadcast and distribute that programme. We may also process
your personal data for monitoring of diversity and equal opportunities, for
monitoring and investigating compliance with policies and rules and in
relation to disputes and legal proceedings.
Where the information comes from
Some of the information comes from you. For example your contact details,
bank details and information on whether you can lawfully work in the UK.
Some information comes from third parties. For example we may require
references and information to carry out background checks.
In the course of your work we may receive personal data relating to you
from others, such as your managers and colleagues or those with whom you
communicate electronically. We may also have CCTV footage of you. If
you are working on a specific programme personal data may be generated
in the course of you taking part in the programme. For example recorded
footage of you.
Lawful Basis
Our lawful basis for processing your personal information is one of the
following, as permitted by data protection law:
contract: the processing is necessary for the performance of the contract
we have with you, or because you have asked us to take specific steps
before entering into a contract.
legitimate interests: the processing is necessary for Hardcash
Production’s legitimate interests or the legitimate interests of a third party
unless there is a good reason to protect your personal data which overrides
those legitimate interests. We or the third party have legitimate interests in carrying on, managing and administering our respective businesses
effectively and properly and in processing your data in connection with
those interests.
Legal obligation: the processing is necessary to comply with our legal
obligations, for example providing a safe place of work and avoiding
unlawful discrimination.
In relation to the special category data we hold about you we will process
this in accordance with one of the grounds set out above and we will also
ensure that one of the following applies:
We have your explicit consent to the processing of such data
You have knowingly and willingly made the data public
Where it is necessary to establish, exercise or defend legal claims
Where it is necessary for medical purposes
Where necessary or allowed under employment, social security or
social protection law
Where it is permitted for equality and diversity purposes
In relation to personal data relating to criminal records, we will process this
data where we have your consent to do so or where it is necessary or
allowed under employment, social security or social protection law.
Who we share your data with
We will only share your data with third parties if we have a ground for
processing on which we can rely and doing so is lawful. Examples of third
parties that we may share your data with are as follows:
Payroll and benefits providers, professional advisors, IT suppliers,
broadcasters, programme distributors, co-producers, insurers, health and
safety advisors, professional advisers, regulatory authorities, external
suppliers and, where you appear on-scree, viewers.
How long we retain your data
We do not keep your data for longer than is necessary, bearing in mind the
purpose for which we collected that information and any applicable legal or
regulatory requirements.
Transfers of data outside the UK and the EEA
Your personal information is mainly used in the UK. However sometimes we
need to share your personal information with third parties outside the UK and EEA.
Where we do so we will ensure that any transfer of data is lawful
and that there are appropriate security arrangements in place.
Please note that any programme in which you appear is likely to be
distributed internationally.
Exemptions
Where you appear in a programme there are certain circumstances where
data protection law allows us and relevant third parties (such as the
commissioning broadcaster of the programme that you have contributed to)
not to comply with the obligations explained in this notice. Examples of
where the exemption applies is where such obligations and your rights are
incompatible with the artistic purposes of the programme, processing for the
purpose of journalism, and there is a public interest in its broadcast.
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HOW WE KEEP DATA SAFE
We have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Personal data where possible will be saved in restricted access folders and password
protected when appropriate.
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USE OF DATA PROCESSORS
Data processors are third parties who necessarily provide elements of our
internal practices, such as IT providers. We have contracts in place with
our data processors. This means that they cannot do anything with your
personal information unless we have instructed them to do it. They will not
share your personal information with any organisation apart from us. They
will hold it securely and retain it for the period we instruct.
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USE OF OTHER THIRD PARTIES
Some third parties with whom we share your data, for example for
recruitment or casting purposes, are data controllers in their own right in
which case they will have their own retention periods.
We have contracts with all third parties to ensure the security of your data
that we share with them.
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IF OUR BUSINESS IS SOLD
We will transfer your personal information to a third party:
· if we sell or buy any business or assets, we will provide your personal
information to the seller or buyer (but only to the extent we need to, and
always in accordance with data protection legislation); or
· if Hardcash Productions or the majority of its assets are acquired by
somebody else, in which case the personal information held by Hardcash
Productions will be transferred to the buyer.
We process your personal information for this purpose because we have a
legitimate interest to ensure our business can be continued by the buyer. If
you object to our use of your personal information in this way, the relevant
seller or buyer of our business may not be able to provide services to you.
In some circumstances we may also need to share your personal
information if we are under a duty to disclose or share it to comply with a
legal obligation.
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UPDATING YOUR PERSONAL INFORMATION
You can update your personal information at any time and change your
marketing preferences. To do this please email us at
hardcash@hardcashproductions.com
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YOUR RIGHTS
Under UK data protection law, you have rights as an individual which you
can exercise in relation to the information we hold about you.
You have the right to see the personal data held by us (a Subject Access
Request). Once the person requesting the information has been identified
the request will be carried out within one calendar month in a clear and
easy to read way. There are numerous and various exemptions to this right
and each request will be dealt with on a case by case basis.
You have the right to have your data rectified where it is incorrect or out of
date. Where a request for data rectification is made it will be dealt with in a
similar way to a Subject Access Request, i.e. within a strict time frame.
You also have the rights to (i) erasure and (ii) restriction, meaning that you
can request that we remove your data or restrict the processing of it.
You have the right to object to the processing of your data in specific
circumstances. We will them stop doing so unless there are compelling
grounds for us to continue the processing.
If you have provided us with data about yourself you have the right to be
given the data in a machine readable form or to ask for it to be transferred
to another organisation.
If we rely on consent to process your personal information, you can
withdraw that consent.
You can complain to ico.org.uk if you are not satisfied with our use of your
data.
You can read more about these rights here – https://ico.org.uk/for-the-
public/is-my-information-being-handled-correctly/
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This privacy policy was updated on [21 May 2024]. We reserve the right to
update and alter this policy.