Copy of PRIVACY POLICY | A-OK Media House

A-OK MEDIA HOUSE PRIVACY POLICY

1. INTRODUCTION

This Privacy Notice sets out how A-OK Media House (“we”/”us”) uses and protects any information that you give us. We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this Privacy Notice.

2. ABOUT US

Our contact and registration details are as follows:

Company Name: A-OK MEDIA HOUSE LTD.

Country of Registration: England and Wales

Company Number: 10014987

Registered Office: 4B Randolph Gardens, London, NW6 5EH

Email: info@aokmediahouse.com

This Privacy Notice does not apply if you are a current or past employee, worker or contractor of ours. In that case, our Internal Privacy Notice will be applicable.

3. WHAT WE COLLECT

We may collect the following information:

name and job title;
contact information including email address;
demographic information such as postcodes;
details about you, if you are applying to and ultimately taking part in a programme;
details about you, if you have sent us an application for a job or speculative work;
details about you, if you are supplying us with services;
your image;
and/or any other personal information you choose to disclose to us or we capture in the course of our relationship with you.

4. HOW WE USE YOUR INFORMATION

a. Purpose: to answer your queries or complaints.

Personal information used; your name and contact details submitted.

Lawful basis; we have a legitimate interest to answer your query or complaint and improve the services we provide or to otherwise contact you in the course of our relationship with you.

b. Purpose: direct marketing on a specific programme where you have opted to receive communications from us.

Personal information used; your name and email address you have registered on the site with.

Lawful basis; consent. We will always ask you to agree before using this information and you may withdraw your consent at any time by contacting us via our contact details in section 15 below.

c. Purpose: applications for a job or speculative work.

Personal information used; all the CV/career information you have sent or disclosed to us, or we may obtain from other sources (e.g., referees, social media, etc).

Lawful basis; we have a legitimate interest to consider you for work and future opportunities.

d. Purpose: applications to be on a programme, taking part, or contributing to a programme.

Personal information used; this will include contact details, and any information you choose to disclose to us, including information on your race, ethnicity, your physical and mental health, sexual orientation, and information relating to any criminal offences. If you choose to take part in a programme, this may also include other personal information (such as details of your education, employment and lifestyle and information on social media about you). This information may be necessary for research and to decide if you are suitable for the programme. You do not need to provide this information, but please be aware that if you do not, you may be unable to take part in the programme. If the applicant is a child, this will include the contact details of the parent or guardian.

Lawful basis; depending on where we are in the application and production process, this may be based on your consent, the legitimate interests of us or third parties (such as co-producers, the commissioner, broadcasters, distributors of the programme) to make and exploit the programme and keep proper records, for the fulfilment of our contractual obligations to you or so that we and the third parties referred to above can comply with our legal obligations.

e. Purpose: to provide services to us.

Personal information used; this will include your name, contact details, VAT No and bank account details.

Lawful basis; to comply with our obligations under our contract with you (e.g. to make payment to you for your services). We also have a legitimate interest to consider you for further work opportunities.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in section 15 below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent, and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent.

5. CHANGE OF PURPOSE

a. We will only use your personal data 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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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

c. 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.

6. WHERE WE COLLECT YOUR PERSONAL INFORMATION FROM

We will collect personal information from a number of sources. These include the following (list is not exhaustive):

Directly from you, for example, when you contact us, meet us face to face or complete electronic and/or paper forms we provide to you.

From our website (see section 7.e. below).

Where you apply to work or participate on a program: from publicly available sources (e.g., social media platforms); from other sources that you give us permission to access (e.g., medical health checks, criminal offences data) from your referees.

7. WHO WE SHARE YOUR PERSONAL INFORMATION WITH:

a. Where you apply to be on a programme or participate in a programme:

other companies that may be involved in the making of the programme, which will include co-producers, broadcasters and distributors;

if the programme is distributed, then to the extent your personal information is included in a programme, that information will be disclosed worldwide, publicly as part of the programme; and

to the Creative Diversity Network for Diamond diversity research (see section 9.c.).

b. Service providers and advisors such as companies that support our IT, help us analyse the data we hold, provide us with legal or financial advice and generally help us deliver our services.

c. The Government or our regulators where we are required to do so by law or to assist with their investigations.

d. Police and law enforcement to assist with the investigation and prevention of crime.

e. Our website logs various information about visitors, including internet protocol (IP) addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp and we may use this information:

to analyse trends, administer the website, track your movement around the website and gather broad demographic information. However, we do not link this information to personally identifiable information;

for Google Analytics which sets cookies to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. For more information about how we use cookies and tracking information in an anonymous form, please see our Cookie Policy; and

to provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

8. TRANSFERRING YOUR PERSONAL INFORMATION INTERNATIONALLY

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section:

if your personal information is included in a programme, that programme may be made available worldwide;

our directors and/or other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are abroad. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK;

in limited circumstances the people to whom we may disclose personal information as mentioned in section 7 above may be located outside of the UK and European Union. In these cases, we will impose any legally required protections to the personal information as required by law before it is disclosed; and

if you require more details on the arrangements for any of the above then please contact us using the details in section 15 below.

9. RETENTION, UPDATING AND REMOVAL OF YOUR PERSONAL INFORMATION

a. We will not transfer your information to, or store it, outside of the European Economic Area except as expressly stated in this notice.

b. If you are taking part in a programme, to determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means, and the applicable legal requirements. Usually, the personal data will be used for the duration of a programme life cycle – including distribution of the programme to the broadcaster and distributor.

c. If you are taking part in a programme that is commissioned by a UK broadcaster, you may be asked to participate in a diversity initiative ‘Diamond’, via a system called Silvermouse. It is possible to opt out of this at request. For more information on Diamond and Silvermouse and on how your data is managed by Diamond, please visit https://creativediversitynetwork.com/diamond/.

d. If you have applied to work for us, we may keep your CV for approximately 12 months and consider you for future work. We will keep candidate information until the end of the recruitment process or for a further 12 months to consider you for other roles that become available. Those engaged by us will have their personal data kept in accordance with our Internal Privacy Notice.

e. If you have applied to be on a programme, we will keep your application until the end of the casting process. If you are unsuccessful, your application will be securely destroyed unless we have asked for your permission to keep your details to consider you for the next series. If you are selected to contribute on a programme 9.b. above will apply.

f. It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. You can contact us using the details in section 15 and, where appropriate, we will update the relevant personal information for you.

g. We will notify you and any applicable regulator of a breach of our obligations under data protection laws, where we are legally required to do so.

10. SECURITY

We are committed to ensuring that your information is secure and have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

11. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

a. You have the following rights in relation to your personal information:

the right to be informed about how your personal information is being used;

the right to access the personal information we hold about you;

the right to request the correction of inaccurate personal information we hold about you;

the right to request the erasure of your personal data in certain limited circumstances;

the right to restrict processing of your personal information where certain requirements are met;

the right to object to the processing of your personal information;

the right to request that we transfer elements of your data either to you or another service provider; and

the right to object to certain automated decision making processes using your personal information.

b. You should note that some of these rights may not apply as they may have specific requirements and exemptions which apply to them, or they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some rights have no conditions attached, so your right to object to processing for direct marketing are absolute rights. This Privacy Notice sets out a general summary of your legal rights in respect of personal information and you can find more information about your legal rights on the Information Commissioner’s website https://ico.org.uk/your-data-matters/.

c. To exercise any of the above rights, or if you have any questions or concerns relating to your rights, please contact us by using the details set out in section 15 below.

d. If you make a complaint about our handling of your personal information, it will be dealt with in accordance with our complaints handling procedure. In the first instance it will be reviewed by our operations team who will respond to you within 28 days. If you are dissatisfied with this response you may request that your complaint is escalated, in which case it will be passed to a senior person in our business. This senior person will review your complaint and the initial response and provide a further response within 28 days of your request to escalate the matter.

e. If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office. Please see https://ico.org.uk/make-a-complaint/ for more information. We are here to help and encourage you to contact us first to resolve your complaint.

f. 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 if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

g. We may need to request specific 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 any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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

12. DIRECT MARKETING

We will only send you emails on a specific programme where you have opted to receive communications from us. You can let us know at any time that you do not wish to receive these messages by contacting us using the details set out in section 15 below or by clicking on the unsubscribe link in any marketing messages we send to you.

13. LINKS TO THIRD PARTY SITES

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit so that you can understand how they treat your personal data.

14. CHANGES TO THIS PRIVACY NOTICE

We reserve the right to alter this Privacy Notice at any time. Such alterations will be posted on the website by us. Such changes will come into effect three business days after posting. Should you object to any alteration, please contact us as described in section 15.

15. CONTACTING US

If you need to contact us about this Privacy Notice or any matters relating to the personal information we hold on you, you can write to us at A-OK Media House Ltd., 4B Randolph Gardens, London, NW6 5EH or email us at info@aokmediahouse.com.

Last updated November 2024

A-OK MEDIA HOUSE ANTI-BRIBERY & CORRUPTION POLICY

1. POLICY STATEMENT AND PURPOSE

1.1. It is the policy of A-OK Media House to conduct all our business in an honest and ethical way. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate as well as implementing and enforcing effective systems to counter bribery or corruption.

1.2. This policy sets out our responsibilities and how we expect those working for us or with us to observe and uphold this policy, and provides information and guidance to those working for us or with us on how to recognise and deal with bribery and corruption issues.

2. WHO SHOULD COMPLY WITH THIS POLICY

2.1. This policy applies to all individuals working at all levels, including employees (whether permanent, fixed term or temporary), consultants, contractors, trainees, seconded staff, agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, wherever located.

3. DEFINITION OF BRIBERY

3.1. Bribery is a common form of corruption and can be defined as the giving or receiving of anything of value or advantage to try and make someone do something improper or reward them for this. Bribes are illegal, and the giving or receiving of them is a criminal offence. In the UK, the Bribery Act 2010 (Act) came into force on 1 July 2011.

3.2. “Improper” performance is defined as performance which amounts to a breach of an expectation that a person will act in good faith, impartially or in accordance with a position of trust.

3.3. The Act creates four offences:

3.3.1. the offence of offering, promising or giving a bribe;

3.3.2. the offence of requesting, agreeing to receive or accepting a bribe;

3.3.3. the offence of bribing a foreign public official to obtain or retain business; and

3.3.4. A new offence for commercial organisations where they fail to prevent bribery by those acting on their behalf.

4. ASSOCIATED PERSON

4.1. We could also commit an offence if a person associated with the Company bribes another person for our benefit. A person is "associated" with a commercial organisation if it performs services for or on behalf of the organisation, regardless of the capacity in which they do so. This could cover (in the UK or overseas) our agents, employees, subsidiaries, intermediaries, joint venture partners and suppliers, all of whom could render us guilty of an offence.

4.2. For all new associated persons where there is a risk of bribes being paid on our behalf, we will need to carry out pre-contract enquiries to establish the organisation’s approach to compliance and corruption risks and help ascertain:

4.3. the adequacy of its current anti-bribery programmes in place; and

4.4. whether or not any bribery has taken place in the past.

4.5. Initial due diligence will take into consideration (as part of a risk assessment), the associated person’s country of origin and that country’s ranking in the Corrupt Perceptions Index: http://www.transparency.org/research/cpi/overview

4.6. When entering into commercial contracts for the supply of goods or services to the Company, we will request anti-corruption warranties or provisions.

5. SANCTIONS FOR NON-COMPLIANCE

5.1. The potential consequences of being convicted of a bribery offence include criminal penalties for both individuals and companies:

5.2. individuals can be jailed for up to ten years and/or receive an unlimited fine; and

5.3. companies can receive unlimited fines.

5.4. "Senior officers" (which is broadly defined, and includes directors) can also be convicted of an offence where they are deemed to have given their consent to giving or receiving a bribe or bribing a foreign public official. Importantly, it is possible that omitting to act might be regarded as consent and lead to prosecutions, fines and/or imprisonment.

6. GIFTS AND HOSPITALITY

6.1. This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable and not linked in any way to an improper act. The intention behind the gift should always be considered.

6.2. The giving or receipt of gifts should be acceptable, if the following requirements are met:

6.2.1. it is not made with the intention of influencing us or a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;

6.2.2. the gift is given in the Company’s name, not in your name;

6.2.3. it does not include cash;

6.2.4. it is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time;

6.2.5. taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time. For example, receiving a gift from a supplier at the time that we are conducting a review process is not appropriate;

6.2.6. it is given openly, not secretly; and/or

6.2.7. it is not offered to, or accepted from, government officials or representatives, or politicians or political parties.

7. FACILITATION PAYMENTS

7.1. Our policy is that we will not make, and will not accept, facilitation payments of any kind. Facilitation payments are typically small, unofficial payments made to secure or speed up a routine government action by a government official. They are not commonly paid in the UK, but are common in some other jurisdictions in which we may operate.

7.2. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment.

7.3. It is also our policy to prohibit all individuals working under our direction or control from accepting any consideration or gratuity, other than consideration paid by us for their services, for the inclusion of material in our programming.

8. DONATIONS

8.1. A vital part of the Company’s reputation as a leading television producer is our impartiality and freedom from bias. We therefore ensure that our dealings with political parties, organisations and candidates are not perceived as favouring one group or cause above any other.

8.2. We will only make charitable donations that are legal and ethical under local laws and practices.

9. YOUR RESPONSIBILITIES

9.1. You must ensure that you read, understand and comply with this policy.

9.2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us, with us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.

9.3. You must notify the Company as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future. We have a Whistleblowing Policy to help you raise any such concerns in the right way. You can find our Whistleblowing policy in the Company Handbook. We reserve our right to terminate our contractual relationship with any third parties if they breach this policy.

10. RECORD KEEPING

10.1. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

10.2. All accounts, invoices, memoranda and other documents and records relating to dealings with the Company should be prepared and maintained with strict accuracy and completeness.

11. TRAINING AND COMMUNICATION

11.1. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

12. MONITORING AND REVIEW

12.1. We will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. We may request any associated party to confirm compliance with this anti-bribery policy on an annual basis. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.

13. QUESTIONS

13.1. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries relating to this policy, please contact your line manager.

Last updated November 2024