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GDPR

See through Stories is committed to protecting the privacy and security of your personal information.

 

This notice sets out how See through Stories Limited (together “we”, “our”, and “us”) collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR).

 

It applies to all employees, workers and contractors. Please read it carefully, and let Jon Clay know if you have any queries or comments.

 

See through Stories is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time

but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical. It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

 

DATA PROTECTION PRINCIPLES

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.

12. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

3. Relevant to the purposes we have told you about and limited only to those purposes.

4. Accurate and kept up to date.

5. Kept only as long as necessary for the purposes we have told you about.

6. Kept securely.

 

THE KIND OF INFORMATION WE HOLD ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation.

 

 

We will collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.

  • Date of birth, gender, next of kin and emergency contact information.

  • National Insurance number, bank account details, payroll records and tax status information.

  • Salary, annual leave, pension and benefits information.

  • Start date and, if different, the date of your continuous employment and your leaving date and your reason for leaving.

  • Location of employment or workplace.

  • Copy of driving licence and/or passport, and (where applicable) visa applications or granted visas.

  • Recruitment information (including copies of right-to-work documentation, references and other information included in a CV or cover letter or as part of the application process).

  • Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).

  • Compensation history, performance information, disciplinary and grievance information.

  • Photographs.

We may also collect, store and use the following “special categories” of more sensitive personal information:

 

  • Information about your race or ethnicity for employment/workplace equality monitoring purposes.

  • Information about your health, including any medical condition, health and sickness records, including:

  • details of any absences (other than holidays) from work including time on statutory parental leave and sick leave;

  • where necessary for insurance cover and/or when travelling on our behalf;

  • when you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

  • Information about criminal convictions and offences (particularly when working on productions which involve contact with vulnerable individuals, when DBS checks may be required).

 

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

 

We collect personal information about employees, workers and contractors through the application and recruitment process, generally directly from candidates. We may sometimes collect additional information from third parties including former employers or other background check agencies such as the Disclosure and Barring Service. We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

HOW WE WILL USE INFORMATION ABOUT YOU

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we have entered into with you.

2. Where we need to comply with a legal obligation.

3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

 

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).

2. Where it is needed in the public interest or for official purposes.

 

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The main reasons for processing your information are set out below:

  • Making a decision about your recruitment or appointment and determining the terms on which you work for us, or making decisions about your continued employment or engagement.

  • Checking if you are legally entitled to work in the UK, and where applicable, in other territories.

  • Paying you and, if you are an employee or deemed employee for tax purposes, deducting tax and National Insurance contributions (NICs).

  • Providing pension and other company benefits to you, including, if applicable, enrolling you in a company pension or pension arrangement in accordance with our statutory automatic enrolment duties.

  • Administering the contract we have entered into with you.

  • Business management and planning, including accounting and auditing.

  • Conducting performance reviews, managing performance and determining performance requirements.

  • Making decisions about salary reviews and compensation.

  • Assessing qualifications for a particular job or task, including decisions about promotions.

  • Gathering evidence for possible grievance or disciplinary hearings.

  • Education, training and development requirements.

  • Dealing with legal disputes involving you, or other employees, workers and contractors.

  • Managing sickness absence, complying with health and safety obligations, preventing fraud.

  • To monitor network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

  • Equal opportunities monitoring.

 

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

 

If you fail to provide personal information

 

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

 

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION

”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. 

We may process special categories of personal information in the following circumstances:

1. In limited circumstances, with your explicit written consent.

2. Where we need to carry out our legal obligations or exercise rights in connection with employment.

3. Where it is needed in the public interest, such as for equal opportunities monitoring.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

 

Our obligations as an employer

 

We will use your particularly sensitive personal information in the following ways:

  • We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with employment and other laws.

• We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and (if applicable) on location and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and, if applicable, health insurance.

• We may use information about your race or national or ethnic origin to ensure meaningful equal opportunity monitoring and reporting.

• We may use information about your race or national or ethnic origin for the purpose of visa or other equivalent permit applications.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

 

INFORMATION ABOUT CRIMINAL CONVICTIONS

 

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

 

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

 

We may hold information about criminal convictions where necessary to meet our legal obligations or contractual or regulatory requirements in relation to a particular production. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

 

AUTOMATED DECISION-MAKING

 

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes

 

DATA SHARING

 

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU if necessary for the performance of your contract with us.

 

Why might you share my personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

Which third-party service providers process my personal information?

 

”Third parties” includes third-party service providers (including contractors and agents) and other entities within our group. The following activities are carried out by third-party service providers: travel agents or fixers, payroll, pension administration, benefits provision and administration, IT services.

 

What about other third parties?

 

We may share your personal information with other third parties, for example in the context of the providing information to a commissioner or distributor in relation to a production (including for approval or publicity purposes). We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making returns to HMRC and disclosures to shareholders such as directors’ remuneration reporting requirements. If we have to share information in the context of a possible sale or restructuring of the business we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

 

Transferring information outside the EU

 

From time to time we will transfer the personal information we collect about you to countries outside the EU in order to perform our contract with you. To ensure that your personal information receives an adequate level of protection we will where applicable put in place appropriate measures with those third parties to ensure that your data is deal with in a way that is consistent with and which respects the EU and UK laws on data protection, which may include confirming third party compliance with EU recognised data protection security requirements by the use of approved contractual clauses, or a national certification system (such as the US Privacy Shield).

 

DATA SECURITY

 

We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

DATA RETENTION

 

How long will you use my 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, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our data retention policy. For example, some of your personal data may be retained for tax purposes following the delivery of the production, but will then be destroyed when no longer required.

 

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

 

Your duty to inform us of changes

 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

By law, you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). 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 that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

  • Request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.

  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your personal information to another party.

 

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing. Do note that in certain circumstances we may not be required to comply with your request but will discuss this with you if applicable.

 

No fee is usually required

 

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your access request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

 

What we may need from you

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

RIGHT TO WITHDRAW CONSENT

 

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

DATA PROTECTION OFFICER

 

We have appointed a data protection manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

 

CHANGES TO THIS PRIVACY NOTICE

 

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

 

If you have any questions about this privacy notice, please contact us. 

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