Contractor Privacy Notice

We respect your privacy and are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data, and tells you about your privacy rights when you are working with us as a Contractor.

Summary

Where Voice & Script International Limited (“we”, “us” or “VSI”) collects information about you, or information that can be used by us or organisations that we work with, to find out about you, that information is known as “personal data”. In line with the law, this Contractor Privacy Notice explains what types of personal data we collect and hold about Contractors and how we use and look after it, where VSI is responsible for data protection compliance. For example, where we hold your information on our database for our own purposes, or to offer your services to third parties.

By "Contractor", we mean all of the following:

  • Talent (such as actors, subtitlers, expert linguists, directors, dubbing and voice-over artists, production teams, audio-visual technicians and other experts) engaged by VSI directly or by VSI, on behalf of our clients (such as studios) or people applying to be talent
  • Other people providing contributions for use by VSI directly or by VSI, on behalf of VSI’s clients (such as people being interviewed, submitting comments or giving us photos/images to use)

VSI is part of a wider group of companies. You can find details of these companies on our website: www.vsi.tv.

If your interaction with VSI relates to situations where we are acting as a data processor of your personal data, on behalf of VSI’s commissioning clients (such as third-party studios or other VSI Group companies), we may also share your personal data with those data controllers, and they will be responsible for data protection compliance. This means that their privacy notice will also apply to how they process your personal data.

This privacy notice does not apply to you:

  • If you visit our website or our social media pages. In that case, our Website Privacy Notice will apply
  • If you are a sub-contractor/supplier/service provider (Supplier) working with us (or a person representing that Supplier) in a way other than as a Contractor. In that case, our Website Privacy Notice will apply
  • If you work for us as an employee or are applying to work for us in that way. In that case, we will provide separate privacy notices that set out more details of our employment relationship with you.

This privacy notice also tells you about your privacy rights and how the law protects you.

The rules about personal data are complex. If you need help understanding anything in this privacy notice, please contact us at data.privacy@vsi.tv or using our full contact details below.

The simple version is this:

  • We collect information about you, including contact details (like your email address), when you give us that information as part of our relationship with you, and when you call us or communicate with us  
  • We treat the information that we hold about you very carefully. We do our best to make sure that information about you does not go to the wrong people or to people who might not look after that information properly
  • If you ask us to do certain things with the information that we hold about you, we must usually do what you ask, and you do not usually have to pay for this. Those things include:
    • Giving you a copy of the information that we hold about you
    • Putting right any mistakes in the information that we hold about you
    • Putting a stop to using information about you or deleting it where appropriate to do so

If you want to ask us to do any of these things, or you have any questions or concerns, you can contact us at data.privacy@vsi.tv or using our full contact details below. If you still have concerns, you can also contact the Information Commissioner’s Office (“ICO”). This is the organisation in charge of making sure that we do the right things with your personal data.

Background

This privacy notice is addressed to individuals who work as a Contractor with Voice & Script International Limited (VSI, we”, “our” or us”). By "Contractor", we mean all of the following:

  • Talent (such as actors, subtitlers, expert linguists, directors, dubbing and voice-over artists, production teams, audio-visual technicians and other experts) engaged by VSI directly or by VSI, on behalf of our clients (such as studios) or people applying to be talent
  • Other people providing contributions for use by VSI directly or by VSI, on behalf of VSI’s clients (such as people being interviewed, submitting comments or giving us photos/images to use)

In this privacy notice, we refer to these individuals as you” or “Contractor”.

This privacy notice explains what personal data we collect about Contractors and what happens to it, where VSI is acting as a data “controller” under the applicable data protection legislation. For example, where we hold your information on our database so we can contact you regarding future projects.

This privacy notice does not apply to you if you visit our premises, our website or our social media pages, or you are a Supplier working with us (or a person representing that Supplier) in a way other than as a Contractor, or you work for us as an employee or are applying to work for us in that way. In those cases, we have separate, more specific privacy notices that apply, and those are explained in more detail in Section 1 below.

Our privacy notice is split into sections so that you can quickly go to a specific section. Alternatively, if you prefer, you can request a hard copy of the whole Contractor Privacy Notice by contacting us at data.privacy@vsi.tv  or using our full contact details below.

You can check the meaning of some of the terms used in this privacy notice by using the Glossary in the final section.

1. Important information and who we are

(a) Purpose of this privacy notice

This privacy notice is addressed to individuals who work as a Contractor with Voice & Script International Limited (VSI, we”, “our” or us”). In this privacy notice, we refer to these individuals as you”.

This privacy notice details how Voice & Script International Limited collects and processes your personal data when you work with us as a Contractor, including when you call us, write to us or communicate with us in any way in relation to your role as a Contractor.

This privacy notice does not apply to you:

  • If you visit our website or our social media pages. In that case, our Website Privacy Notice will apply.
  • If you are a sub-contractor/supplier/service provider (Supplier) working with us (or a person representing that Supplier) in a way other than as a Contractor. In that case, our Website Privacy Notice will apply.
  • If you work for us as an employee or are applying to work for us in that way. In that case, we will provide separate privacy notices that set out more details of our employment relationship with you

This privacy notice is not intended for children, and we do not knowingly collect data relating to children.

To ensure that you are fully aware of how and why we are using your data as a Contractor, it is important that you read this privacy notice together with any other data protection or privacy notice that we may provide on specific occasions when we are collecting or processing personal data about you. This privacy notice supplements other such statements and privacy policies and is not intended to override them.

(b) Who we are

VSI is a limited company registered in England and Wales with registered company number 03195141 and whose registered head office is at 128-134 Cleveland Street, London, W1T 6AB.

Either VSI or VSI’s clients (such as studios where applicable) is the data “controller" under the applicable data protection legislation and will therefore be responsible for how your personal data is used.

VSI  is part of a wider group of companies. You can find details of these companies by visiting our website.

This privacy notice is issued on behalf of VSI. If your interaction with us relates to:

  • Situations where VSI is providing Services as a data “processor” under the applicable data protection legislation, on behalf of VSI’s clients who are the data “controller" (for example, where VSI acts as a contractor for commissioning third parties such as studios), we will also pass your personal data to them as agreed. This means that the commissioning third party is responsible for data protection compliance, and their privacy notice will also apply to how they process your personal data.
  • VSI’s Group companies who are acting as a data “controller” under the applicable data protection legislation, we will pass your personal data to them. This means that the relevant Group company is responsible for data protection compliance, and their privacy notice will also apply to how they process your personal data.

(c) VSI’s contact details

If you have any questions about VSI’s Contractor Privacy Notice (including any requests to exercise your legal rights), or about VSI’s privacy practices, please contact the VSI Data Privacy Manager in the following ways:

Email address: data.privacy@vsi.tv

Postal address: 128-134 Cleveland Street, London, W1T 6AB

Telephone number: +44 (0) 207 692 7700

You have the right to make a complaint about VSI at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so we would encourage you to contact us first to discuss these.

(d) Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated on 7 December 2021. Historic versions can be obtained by contacting us.

Any changes that we make to this privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.

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

2. The data we collect about you

(a) Types of data

As part of our relationship with you as a Contractor including when you call us, write to us or communicate with us in any way, in relation to your role as a Contractor, you may provide us with personal data about you. You may also provide personal data when you enter into an Assignment of Rights contract with VSI directly or with VSI’s clients, or when you provide application forms or consent forms to VSI directly or to VSI, on behalf of VSI’s clients.

Personal data 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).

We may, on our own behalf, or on behalf of our clients, collect, use, store and transfer the following kinds of personal data about you:

  • Identity data, including your first name, maiden name, last name, username or similar identifier, title, date of birth, gender, sexual orientation, religion, disabilities and ethnicity
  • Contact data, including your billing address, home address, email address and telephone numbers
  • Financial data, including your bank account, payment card details, IBAN number, SWIFT code, sort code, account number and preferred payment methods
  • Transaction data,including details about payments to and from you and other details of the type of services that you have provided us or our clients with and when (such as your services as a Dialogue or Vocal Artist, a Dialogue or Vocal Director, a Writer, Adaptor, Lyricist, Translator/Transcreator, a Subtitler or a Transcriber)
  • Marketing data,including your preferences in receiving marketing from us and where relevant named third parties, and your communication preferences in relation to marketing
  • Communications data, including personal data that is included in your communications with us, or communications from your agents or representatives on your behalf
  • Voice data,including actual voice recordings and samples
  • CCTV data,including any images and/or audio recorded when visiting our premises

(b) Special categories of personal data “SCPD”

SCPD are defined under the applicable data protection legislation as being personal data about your race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, political opinions, trade union membership, health, genetics or biometrics.

When you are acting as a Contractor you may share certain categories of SCPD with us. SCPD are afforded extra protection under the applicable data protection legislation, and so, we have to have an additional legal basis to process SCPD that you share with us. We have set out the purposes for such processing and the legal basis for our processing under Section 4 below.

(c) No criminal offence data or children’s data

We do not collect:

  • Any personal data about children under the age of 13 years old. If you believe your contribution relates to a child under that age, please contact us for a specific privacy notice relating to that child’s contribution
  • Any criminal offence data, such as information about criminal convictions and offences, nor will we request that you carry out or share the results with us of any criminal records check, such as the UK Disclosure and Barring Service (“DBS”) check.

(d) Aggregated data

We also collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered personal data in law, because this data will not directly or indirectly reveal your identity.

However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy notice.

(e) If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract with you, or we are processing your personal data to fulfil a request that you have made, and you fail to provide that data when requested, we may not be able to perform the contract with you, or may not be able to otherwise comply with requests made by you. In this case, we may have to cancel a particular service, but we will notify you at the time if this is the case.

3. How your personal data is collected

We use different methods to collect data from and about you, including through:

  • Direct interactions - you may give us your Identity data, Contact data and Financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data that you provide when you:
  • Enquire about the services we provide to others and how you might engage with us or our clients as a Contractor
  • Provide your services as a Contractor
  • Subscribe to our publications for Contractors
  • Attend an event connected with us as a Contractor
  • Request marketing to be sent to you
  • Complete a survey
  • Give us feedback or contact us
  • From suppliers (such as studios and third-party commissioners - we will receive identity and contact data about you from studios, as set out below
  • From your agents or representatives - we will receive identity, contact and transaction data
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services in relation to your role as a Contractor
  • Identity, Contact and Profile Data from social media sources, the media generally, industry contacts and from public opinion through surveys and market research

4. How we use your personal data

Either VSI or VSI’s clients (such as studios where applicable) is the data “controller" under the applicable data protection legislation and will therefore decide how your personal data is used. This is called "processing data".

The data controller is required to have a legal basis to process personal data. Most commonly, we will process your personal data in the following circumstances:

  • Where the data controller needs to perform the contract that it is about to enter into or has entered into with you. This will include managing that contractual relationship, including assignment of rights, making payments, contacting you or your agent about the Contractor engagement, or for other purposes relating to the exploitation of your contribution/assignment of rights
  • Where it is necessary for the legitimate interests of the data controller (or those of a third party) and your interests and fundamental rights do not override those interests. Where the legitimate interest relates to the consideration of your application as a Contractor and/or the publication of your contribution as journalistic, artistic or literary material, the assessment is that such processing will not be disproportionate to your interests and rights
  • Where we need to comply with a legal or regulatory obligation

To find out more about the types of lawful basis that the data controller will rely on to process your personal data, under the applicable data protection legislation, see the Glossary below.

(a) Purposes for which we will use your personal data as a data processor

We may also process your personal data, where we act as a data “processor” under the applicable data protection legislation. For example, where our commissioning controller, VSI’s clients (such as studios), have asked us to provide services to them which require us to process your personal data as a Contractor.

Where that is the case, we have appropriate contractual arrangements in place to manage the relationship between our controller, VSI’s clients, and us as their data processor. As controller, they are responsible for having a legal basis to process your personal data, and we simply carry out that processing on their behalf. The terms of their appropriate privacy notice, relating to your role as a Contractor will apply to any processing where they are responsible for data protection compliance.

Please contact us if you need confirmation about the specific data controller that relates to your interaction with us as a Contractor.

(b) Purposes for which we will use your personal data as a data controller

i. General purposes

The following table describes all the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so, where we act as a data “controller” under the applicable data protection legislation. Where appropriate, we have also identified what our legitimate interests are.

Generally, we will not rely on consent as a legal basis for processing your personal data. However, if we ever do, we will make you aware of this prior to such consent being given. You have the right to withdraw consent to marketing at any time by contacting us.

Note that we may process your personal data on more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis on which we are relying to process your personal data, where more than one basis has been set out in the table below.

Purpose/activity
Type of data
Legal basis for processing (including the relevant legitimate interest basis where applicable)
If SCPD, additional legal basis for processing
Retention period
To register you as an actual or potential Contractor who could provide services to VSI’s clients or contacts
 
(a) Identity
(b) Contact
(c) Image
(d) Profile
(e) Marketing
(f) Voice
(a) Necessary for our legitimate interests (to hold and use data about different types of Contractors to enable VSI to develop our products and services, to grow and develop our business and to inform our marketing strategy generally)
 
Substantial, public interest legal basis (equality of opportunity or treatment), under the applicable data protection legislation, to allow us to process such data lawfully for these purposes 
For the duration of your contract with VSI, and for 7 years afterwards, otherwise 12 months
To register you as an actual or potential Contractor who could provide services to VSI as a Controller
 
(a) Identity
(b) Contact
(c) Image
(d) Profile
(e) Marketing
(f) Voice
(a) Performance of a contract with you or that we are about to enter into with you
(b) Necessary for our legitimate interests (to hold and use data about different types of Contractors to enable VSI to develop our products and services, to grow and develop our business and to inform our marketing strategy generally)
 
N/A
For the duration of your contract with VSI, and for 7 years afterwards, otherwise twevle months
To process your services to VSI or to VSI’s clients including:
(a) Arranging such services
(b) Managing payments, fees and charges related to those services
(c) Collecting and recovering money owed to you or us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Communications
(a) Performance of a contract with you or that we are about to enter into with you
(b) Necessary for our legitimate interests (in efficiently managing our business and operations, to recover debts due to us)
N/A
For the duration of your contract with VSI, and for 7 years afterwards 
To process your contribution further to the Assignment of Rights (AOR) agreement, where that is entered into by you, with VSI
Where you have entered into that AOR with a third party (such as a studio) as a Controller, the terms of their privacy notice shall apply
 
(a) Identity
 
(b) Contact
 
(c) Voice
 
 
 
(a) Performance of a contract with you or that we are about to enter into with you  
 
(b) Necessary for our legitimate interests (in efficiently managing our business and operations)
(c) Necessary to comply with a legal obligation (such as those related to the coordination of occupational risks)
N/A
We intend to retain your contribution in perpetuity. We will keep your Assignment of Rights contract, along with any relevant  consent forms and personal data concerning your contribution for the duration of copyright in your contribution
To manage our relationship with you, which will include:
(a) Responding to an enquiry or complaint
(b) Notifying you about changes to our terms or privacy notice
(c) Asking you to supply a review, take a survey or provide other feedback
(a) Identity
(b) Contact
(c) Profile
(d) Marketing
(e) Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers/clients use our products and services)
(a) Responding to an enquiry or complaint: N/A
(b) Notifying you about changes to our terms or privacy notice: N/A
(c) Asking you to supply a review, take a survey or provide other feedback:  N/A, except in relation to our Diversity Questionnaire, where we rely upon Explicit Consent (as provided by you in the Diversity Questionnaire), otherwise we will either 1) not have any SCPD data about you and/or 2) not use any SCPD data we hold about you for this purpose
For the duration of your contract with VSI, and for 6 years after, or 6 yeards after the closure if any complaint
To enable you to partake in a competition, or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing
(f) Communications (no SCPD)
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers/ clients use our products and services, or how suppliers provide us with products or services, and to grow our business)
(b) Necessary for our legitimate interests (to study how customers use our products and services, to develop them and to grow our business)
N/A
Two years 
To administer and protect our business (including troubleshooting, data analysis, testing, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Communications
(a) Necessary for our legitimate interests (for running our business, for provision of administration and IT services, to prevent fraud and in the context of a business reorganisation or Group restructuring exercise)
(b) Necessary to comply with a legal obligation
N/A
Two years
To deliver relevant content and marketing to you, and measure or understand the effectiveness of the marketing that we provide
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing
(f) Communications
Necessary for our legitimate interests (to study how Contractors and customers/clients use our products and services, to develop them, to grow our business and to inform our marketing strategy)
N/A
2 years from last contact
To use data analytics to improve our products and services, marketing and Contractor/customer/client relationships and experiences
(a) Usage
 
Necessary for our legitimate interests (to define types of Contractors/customers/clients for our products and services, to keep our contacts database updated and relevant, to develop our business and to inform our marketing strategy)
N/A
2 years from last contact
To make suggestions and recommendations to you about products or services that may be of interest to you
(a) Identity
(b) Contact
(c) Usage
(d) Marketing
(e) Communications
Necessary for our legitimate interests (to develop our products and services, and to grow our business)
Explicit Consent (as provided by you in the Diversity Questionnaire), otherwise we will either 1) not have any SCPD data about you and/or 2) not use any SCPD data we hold about you for this purpose.
Twelve months
Making reasonable adjustments if you need to attend one of our offices, studios or sites
(a) Identity
(b) Contact
(c) SCPD – health, religious, sexual orientation
(a) To comply with our legal obligations
(b) Necessary for our legitimate interests (to grow our business, to ensure fairness, equality and compliance with our internal policies and clients’ policies, relating to such reasonable adjustments)
Substantial, public interest legal basis (equality of opportunity or treatment) under the applicable data protection legislation, to allow us to process such data lawfully for these purposes
Twleve months
Ensuring and monitoring equality of opportunity and diversity
(a) Identity (if relevant only)
(b) Contact (if relevant only)
(c) SCPD - health, religious, sexual orientation
(a) To comply with our legal obligations
(a) Legitimate interests (to grow our business, to ensure fairness, equality and compliance with our internal policies and clients’ policies, relating to equality and diversity)
 Substantial, public interest legal basis (equality of opportunity or treatment) under the applicable data protection legislation,  to allow us to process such data lawfully for these purposes
Twelve months

ii. Journalistic, academic, artistic or literary purposes

Please note that on some occasions, we or third parties will rely upon an exemption under the applicable data protection legislation, in relation to the processing of journalistic, academic, artistic or literary purposes.

iii. Automated decision-making

We do not make any decisions that could have a legal effect, or other significant effect on you, based solely on automated processing of your personal data.

iv. Marketing

We hope that you enjoy and value our newsletter and our marketing material generally. We may send you this information by various means including email, text message, post or telephone. We respect your right to choose what marketing messages you receive, and we will always try to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Third-party marketing

We will always get your opt-in consent before we share your personal data for marketing purposes with any company outside our group of companies.

Opting out

You can ask us to stop sending you marketing messages sent by us as a controller under the applicable data protection legislation, at any time, by selecting or deselecting relevant boxes to adjust your marketing preferences. You can also follow the opt-out links on any marketing message that we email to you or by contacting us at any time.

v. Change of purpose

We will only use your personal data as a controller 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 you would like to understand more about our purposes, or you wish for us to explain how the processing of the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

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

5. Disclosures of your personal data

All of VSI’s contractors, suppliers and staff (including volunteers, agents, temporary workers and casual workers), who process your personal data on our behalf, are subject to strict contractual requirements in relation to processing personal data.

For the purposes set out in the table in the previous section, we may share your personal data with the following parties:

  • Internal third parties as set out in the Glossary
  • External third parties as set out in the Glossary
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party processors to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International DATA transfers

Some of our internal third parties and external third parties may be based outside the United Kingdom (UK) and/or the European Economic Area (EEA) so the processing of your personal data may involve a transfer of data outside the UK and/or the EEA.

Whenever we transfer your personal data out of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a) A transfer of your personal data to countries that the UK government or the European Commission have deemed to provide an adequate level of protection for personal data. For further details, see the information about adequacy decisions on the European Commission’s website and the UK ICO website). Currently, we transfer your personal data to the following jurisdictions on the basis of this safeguard:

i. Our email is hosted and our files are stored using Microsoft 365, which is a cloud service provider based in Ireland. Ireland is considered by the UK as having an adequate level of protection for your personal data.

(b) Where we use certain service providers, we may use specific contracts approved by the UK or by the European Commission that give personal data the same protection that it has in Europe. For further details, see the information about model contracts for the transfer of personal data to third countries on the European Commission’s website and the UK ICO website (model clauses). Currently, we transfer your personal data to the following jurisdictions on the basis of this safeguard:

i. To our Group companies that are based outside the UK or the EEA (see here for details of where our Group companies are located). We have an Intra-Group Data Transfer Agreement in place that contains the model clauses.

Please contact us if you would like further information about the specific mechanism that we use when we transfer your personal data out of the UK or the EEA.

Please note that we have no control over the routes that emails take, and even emails exchanged between two people in the UK could appear on equipment in countries outside the UK or the EEA, where they may not be protected by strong privacy or data protection laws and practices. You will probably not consider this an issue, but if you have any concerns, please raise them with us, and we will make alternative arrangements.

7. Data security

We have a strong commitment to data security.

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.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We take appropriate steps to communicate with and train our staff in relation to applicable data protection law.

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

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or via our website. Any transmission is at your own risk.

If you would like to know more about our data security measures, please contact us.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint. or if we reasonably believe that there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about you for tax purposes (including contact, identity, financial and transaction data) for at least six years after you cease being a Contractor.

Details of other retention periods for different aspects of your personal data are available in our retention policy above.

In some circumstances, you can ask us to delete your data: see the following section for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

(a) Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which we process as a controller. These rights are subject to specific requirements and limitations set out in the applicable data protection legislation and are summarised below (see the Glossary below for more information about these rights):

  • You can request access to the personal data that we hold about you and check that it is being lawfully processed (commonly known as a “data subject access request”)
  • You can request correction of the personal data that we hold about you if it is wrong and ask us to complete it if it is incomplete
  • You can request erasure of your personal data, but we will retain your data for the purposes of dealing with any claims, or where we have another legitimate reason to retain it
  • You can object to the processing of your personal data. For example, if we are processing it on the basis of a legitimate interest and that does not override your individual rights
  • You can request to restrict the processing of your personal data. You may, for example, want to do this while we consider your request to have it corrected
  • You can learn how and why we are processing your personal data, the legal basis for that processing, who we have disclosed it to and who we will disclose it to (which we have provided in this privacy notice)
  • You can receive a copy of your personal data (or have it passed to a third party) in a common and structured electronic format (where the legal basis for our processing is your consent, or the processing is necessary for the performance of our contract with you)
  • You can stop having your personal data used for direct marketing
  • You can withdraw your consent to the processing of your personal data at any time if the lawful basis of the processing is your consent

If you wish to exercise any of the rights set out above, please contact us.

You also have the right to complain to the ICO about our processing or our response to your requests and objections. You can do this by visiting the ICO website or calling 0303 123 1113.

(b) No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, or refuse your request, if your request is clearly unfounded, repetitive or excessive.

(c) What we may need from you

We may need to request proportionate information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to someone who has no right to receive it. To speed up our response, we may also contact you to ask you for further information in relation to your request.

(d) Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, if your request is particularly complex or you have made several requests, it could take us longer than a month. In this case, we will notify you and keep you updated.

10. Glossary

(a) Lawful Basis

i. Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best, most secure experience. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

ii. Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

iii. Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

(b) Third Parties

i. Internal third parties are:

  • other companies in our Group, including those that are based outside the UK or the EEA (see here for details of where our Group companies are located), that provide various products and services to us in their capacity as a data processor, under the applicable data protection legislation, such as internal IT and system administration services and leadership reporting.

ii. External third parties are:

  • Service providers acting as processors based in the UK and EEA who provide IT and system administration services
  • Where you are represented by a third party, we will share personal data with your agent or representative in order to meet the purposes set out in this privacy notice, and for the purpose of allowing your agent or representative to engage services on your behalf
  • Where relevant, unions and industry representative bodies or distribution agents nominated by a union, research partners, producers and distributors
  • Professional advisers including lawyers, bankers, financial and accounting advisors, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services
  • HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances

(c) Your Legal Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data that we hold about you corrected, although we may need to verify the accuracy of the new data that you give us
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data, where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation that makes you want to object to processing on this basis because you feel that it affects your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms
  • Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy
  • Where our use of the data is unlawful, but you do not want us to erase it
  • Where you need us to hold the data, even if we no longer require it because you need it to establish, exercise or defend legal claims
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party whom you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent

If your request is about your contribution itself, we will consider the impact of your request on both:

  • The publication of your contribution as journalistic, artistic or literary material
  • The performance of the contract