Collecting Personal Data

In?Diamond, Personal Data is collected on the?Diversity Self-declaration Form (DSF)?that each?contributor(anyone working on a production, on- or off-screen) completes. This form includes a Privacy Notice that explains who is collecting the information, what it will be used for and how long their Personal Data will be held (this is a requirement under the DPA). By completing their declaration, the contributor confirms that they have read and understood the Privacy Notice and gives their consent for their Personal Data to be processed as set out in the Notice. You can read the Privacy Notice used on the Diversity Self-declaration Form in Appendix 1. The DSF additionally includes a link to a (more detailed) Diamond Privacy Policy, which contributors have the option to view.

In the case of a child or vulnerable adult this consent can be given by the guardian or authorised representative who will be completing the form.

The?Perceived diversity data?(that you complete) does not generally count as Personal Data on scripted programmes because the data relates to a role, rather than a living individual. However, where Perceived data is connected to the name of an actor in their role, the information may become Personal Data if the actor can be identified from the characteristics. On non-scripted programmes the information you collect will always be classified as Personal Data because it is based on a living person and the information is linked to a contributor name. In order to best protect information held on those working with us and minimise the possibility of identifying contributors from any data held, Diamond has put in place a number of safeguards:

  • The?Diversity Perceived Form?only displays roles, and not?contributor?details.
  • Perceived diversity data is encrypted when stored.
  • Perceived data is hidden from view after it is entered. That means you can?t view or edit individuals? data once it?s submitted, but if necessary you can re-submit data, which will overwrite the previous entry.

Contributors should also be notified within the contractual documentation and on release forms that you will be collecting and holding Perceived data on their diversity characteristics. Broadcasters and/or Pact can provide you with wording that can be included in relevant documentation, which includes a link to the Diamond Contributors page on the CDN website containing a Diamond Perceived Privacy Notice (which you can read in Appendix 2).

For programmes that include live audiences, Perceived data may be recorded for some audience members (e.g. if the camera focuses on them, see section 5). You should notify audiences that production teams may record their Perceived data. Broadcasters and/or Pact can provide you with notification wording that can be included in audience service suppliers? Codes of Conduct, and also wording that can be made available on the day when programmes with live audiences are being filmed (e.g. as notices to be attached to walls).