PRIVACY POLICY

INTRODUCTION

In this privacy policy, any reference to we, us, our and Hall of Mirrors is to Hall of Mirrors Media Ltd. - a company registered in England and Wales (company number 114 89752) with its registered office at W2 Wellington House, Wellington Street, Cardiff CF11 9BE.

 

We are a Wales-based television production company and your personal information is important to us. This privacy policy concerns the personal information of people who are applicants, participants or contributors who we are considering or have decided to include in a programme.

We have set out below the information we collect about you, and how we use that information. We will collect, process and retain any personal information collected from you in accordance with all laws and regulations relating to the protection of personal data, including the General Data Protection Regulation ((EU) 2016/679) (GDPR).

 

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The information we process may include your name, address, email address, IP address, gender, date of birth, age, phone number, passport details or other national identifiers, driving licence, your national insurance or social security number and income, employment information and details about your previous roles and personal history. We collect information about you from a number of sources, including from you directly. See below for more information.

 

Information that you give us:

  • from any documentation that you complete when you apply for a role or part in, or contribute to, a programme when you provide it to us in correspondence and conversations (e.g. application telephone interviews, pre-filming questionnaires and release forms);

  • when you apply, participate or contribute to a Hall of Mirrors programme and you provide information which is relevant to your application or contribution. The information will be dependent on the nature of the programme , but where relevant this could also include special category data such as medical information, political opinions, sexual orientation and where relevant your criminal history. The nature of the programme and the information which we will be asking you for will be explained to you in advance and appropriate; and

  • with your consent, we will pass your email address to Silvermouse and Soundmouse who may contact you as part of the television industry’s commitment to monitoring diversity as part of the Diamond project. This is the diversity monitoring system managed by the Creative Diversity Network (CDN) on behalf of the majority of UK broadcasters such as the BBC, ITV, Channel 4, Channel 5, S4C, UKTV and Sky. You can find out more about Diamond here: http://creativediversitynetwork.com/diamond-contributors/.

 

Information we obtain from others:

  • publicly available and accessible directories and sources;

  • social-media platforms (e.g. Facebook, Instagram, Twitter, Linkedin;)

  • subscription only databases (e.g. Factiva, Lexis Nexis and Reuters;)

  • governmental and competent regulatory authorities to whom we have regulatory obligations;

  • agents and production companies;

  • fraud prevention and detection agencies and organisations; and

  • where we need to do so, for regulatory purposes, and this is in the public interest, crime enforcement and criminal records agencies (e.g. U Check)

 

HOW DO WE USE THIS INFORMATION?

We collect information about you to assess your suitability to contribute and participate in a programme. If you are selected to participate in one of our programmes we will use the personal information you have provided us for the purposes of developing, producing, distributing and administering the programme you have chosen to participate in.

Your personal information will not be used for any marketing or sales purposes. However, we may, subject to your agreement, contact you about other programmes we think you may be interested in.

However we use your information, we will make sure that such use complies with all laws and regulations relating to the protection of personal data. Such laws and regulations allow us to use personal data for a variety of reasons. These include:

  • in order to perform our contractual obligations with our clients, customers and suppliers;

  • where we have obtained your consent;

  • in order to discharge our legal and regulatory obligations;

  • in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

  • as is necessary for our legitimate business interests, such as: allowing us to effectively and efficiently manage and administer the operation of our business (being the development, production and distribution of television programmes); to commercially make full use of either the entire programme or clips from the programme in the UK and around the world, for the period in which we have rights in the programme; to share with our professional advisors and/or the commissioning entity or commissioning broadcaster that we are producing the programme for, any co-producer that we are producing the programme with, and/or any financier of the programme; maintaining compliance with internal policies and procedures; and monitoring the use of our intellectual property.

 

WITH WHOM DO WE SHARE YOUR INFORMATION?

Your information will be used by the relevant production team for the purposes of producing the programme. It may also be shared internally with Hall of Mirrors personnel to prepare contractual documentation or provide legal advice, with the finance team where a payment is required, and any other in-house teams involved in the development, production and distribution of the programme.

We may pass your information to our third-party service providers such as agents, subcontractors and other associated organisations for the purposes of facilitating your application for and inclusion in a programme you are interested in taking part in. However, when we use third party service providers, we disclose only those elements of your information that are necessary to deliver the required service.

We will not share your personal information with any third parties unless you give us your consent to do so or we are authorised to do so by law.

 

DATA STORAGE AND RETENTION

We do not retain your information for longer than necessary for the purpose it was collected.

We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.

In general, we keep your information only for the period we have legal rights to exploit the programme to which your information relates.  We will usually delete your personal information at the end of that period, but it is likely this period will be a minimum of 6 years.

 

DIVERSITY MONITORING

Hall of Mirrors Media Ltd contributes to a television industry-wide diversity monitoring initiative called Diamond. The Diamond project uses personal information regarding on and off-screen contributors to programmes to report on the diversity of TV production in the UK.

If you have provided us with your email address (unless you have asked us not to) we are obliged to share this with Creative Diversity Network Limited (CDN), Silvermouse and Soundmouse and you will be invited to participate in the Diamond project.

The company running the Diamond project will contact you to ask whether you are willing to contribute to the project by providing certain information regarding your diversity, characteristics such as gender, ethnicity, disability, age, gender identity and sexual orientation. This information is collected, processed and stored anonymously on the Diamond system, with the relevant data being jointly controlled by the main UK broadcasters including the BBC, ITV, Channel 4, Channel 5, S4C, UKTV, CDN and Sky. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice.

 

ACCESSING YOUR INFORMATION

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

  • The right to be informed

  • The right of access

  • The right to rectification

  • The right to erasure

  • The right to restrict processing

  • The right to data portability

  • The right to object

  • Rights in relation to automated decision making and profiling

If you would like to exercise any of your rights in relation to your information, please contact us directly using the contact details below. If we cannot comply with your request to exercise your rights we will tell you why.

There will not usually be a charge for handling a request to exercise your rights.

 

CHANGES TO OUR PRIVACY POLICY

We keep our privacy policy under regular review and we may change it from time to time. This policy was last updated in January 2021.

 

HOW TO CONTACT US

If you have any questions about our privacy policy or the information that we hold about you please contact us at:

  • Hall of Mirrors Media Ltd., W2, Wellington House, Wellington Street, CARDIFF CF11 9BE.

 

INFORMATION COMMISSIONER’S OFFICE (ICO)

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

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

 

DIVERSITY & INCLUSION POLICY 

Hall of Mirrors Media Ltd. recognises that diversity and inclusion help to support creativity and innovation and are an essential ingredient in a successful television company. We are committed to encouraging diversity and inclusion and to ensuring there is no discrimination in our company. We want our workforce to be truly representative of all sections of society. We want our company to be one in which every employee and freelancer feels respected and able to give of their best.

To that end, Hall of Mirrors supports equality and fairness for all in our employment. It expresses our commitment not to discriminate on the grounds of age, disability, gender, gender reassignment, marital status (including civil partnerships), race, ethnic origin, colour, nationality, national origin, religion or belief, socio economic background and sexual orientation. We oppose all forms of unlawful and unfair discrimination.

This applies to employed and freelance staff and to those working on and off screen.

All freelancers and employees, whether part-time, full-time or temporary, will be treated fairly and with respect. Selection for employment, whether as a member of staff or on a freelance basis, will be on the sole basis of aptitude and ability. Access to opportunities for promotion, training or any other benefit will also be on the sole basis of aptitude and ability. All employees will be encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the creativity and success of the company.

 

We will:

  • Actively seek to increase the number of people we work with who are from groups/communities that are under-represented in the television industry as a whole, or in particular job roles within the industry.

  • Review all our formal and informal employment/hiring practices and procedures to ensure they are fair and help us to identify the best talent.

  • Identify and take opportunities to increase the diversity of casting decisions.

  • Ensure reasonable adjustments are made to enable disabled people to work in or with our company, both on and off screen.

  • Actively seek to increase the diversity of our talent networks.

  • Create an environment in which individual differences and the contributions of all our staff and freelancers are recognised and valued.

  • Ensure every employee and freelancer is able to work in an environment that promotes dignity and respect for all. We will not tolerate any form of intimidation, bullying or harassment.

  • Ensure training, development and progression opportunities are available to all staff.

  • Acknowledge holidays of all cultures. E.g. help employees be aware of and keep track of multicultural religious or holiday celebrations. Be respectful of these days when scheduling team meetings and understand that employees may have different needs and require flexibility.

 

This is fully supported by the senior management of Hall of Mirrors Media Ltd.