NEWS UK AND WIRELESS CONTRIBUTOR PRIVACY NOTICE: HOW WE USE YOUR INFORMATION

The privacy and security of your information is very important to you and to us. We want you to trust that the information we hold about you is properly managed and protected. This Privacy Notice lets you know what information we may collect about you, what we use your information for, who we may disclose it to, and how you may raise concerns or complaints.

This Privacy Notice covers how we process information relating to “contributors” to or for our editorial, digital and television content. The term “contributor” covers:

on-screen talent, such as actors, musicians, performers, presenters, journalists, hosts, experts and celebrities who participate in programmes for broadcast by News UK or a third party or who produce or are involved in the production of content for publication by News UK or a third party;

off-screen talent, such as voiceover artists, writers, musicians and other experts;

individuals that apply, are put forward to take part in/nominated to be in, and/or audition for our programmes;

online and social media personalities or ‘influencers’ or ‘content creators’;

individuals that provide contributions for broadcast or publication, or contribute to, take part and/or feature in one of our programmes, such as those that are interviewed, submit comments or images to us, those who regularly write/supply content, or grant us access to their properties for filming purposes; and

agents and others representing contributors.

The News UK group company that engages you and News UK & Ireland Limited (together “News UK”) are the data controllers for the information you provide and we collect during your engagement or consideration for engagement with us, and what we retain after the engagement.

If the contributor is a child, then the person with the parental responsibility for or the legal guardianship of the child must ensure that they have explained to the child how the child’s information will be used.

WHAT INFORMATION DO WE PROCESS?

The information that we process about you may include (depending on your type of engagement):

Your contribution: The information that you provide and that we gather in relation to any articles, interviews, commissions or submissions that result from your contribution or engagement or any consideration of an engagement with us, whether such contributions are used by us or others or not. We may process your personal information (which may include Special Categories of Personal Information – see below) as part of the content of a programme (for example, footage, recordings, images, audio of you and/or about you) and/or other materials created/used during the production of a programme (for example, scripts and/or research notes) or pre-production (for example before or during the application process). This could include details about your background, interests, activities (including on social media), general knowledge, opinions and/or family and friends;

Personal Details: Your name, maiden name and surname, e-mail and telephone details, home address, date and place of birth, government-issued identifiers, gender, marital status, photograph, driver’s licence, as well as emergency contacts;

Residence Status: Nationality and passport information, details of residency or work permit;

Payment Information: Banking details, payments made, and start of engagement and end-dates;

Details of your engagement: Description of role or services provided and details about your previous roles and experience;

Compliance: Acknowledgements regarding applicable policies and records of completion of compliance and other training; information required to comply with laws and regulations and requests or directions of law enforcement agencies or court orders;

Technology Systems and Application Access Data: Information required to access News UK systems and applications such as System ID, LAN ID, email account, instant messaging account, mainframe ID, previous company-assigned personnel number or ID, system passwords, worker status and country code;

Technology Usage Data: Voicemails, emails, correspondence and documents and other work product and communications created, stored or transmitted by you using News UK’s information technology or communications equipment, or received by you through such equipment;

CCTV and Security: information captured on security systems, including CCTV and key card entry systems and other security and technology systems;

Special Categories of Personal Information: Some of your personal information may be

more sensitive and fall within the ‘Special Categories’. This is personal information that reveals an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership; is genetic or biometric data used for identification purposes; or data concerning health, sexual life or sexual orientation. Such data is afforded extra protection. We may use certain types Special Category personal information as permitted by law, for example, data that identifies health-related conditions, such as where required for making an accommodation if you need to attend one of our offices, studios or sites or in undertaking psychological assessments and providing support or managing insurance for productions, and diversity-related data (such as sex and racial or ethnic origin) to comply with our legal obligations and internal policies relating to diversity and anti-discrimination. We may also process Special Categories of Personal Information where this is provided or collected as part of, or in relation to, your contribution;

Criminal Convictions and Offences: Information concerning the commission or alleged commission of a criminal offence, convictions, sentences and penalties may be collected and used by the company in limited circumstances. We only do this with your consent or when we have another legal basis to do so.

Much of the personal information we process is information that you provide to us, for example through applications or expressions of interest to us, pre-filming questionnaires, contracts, consent forms, release forms, correspondence with us and any other documentation that you (or an agent on your behalf) complete. We may also process information about you from discussions, interviews, audition footage, programme footage or other programme contributions.

However, in other instances, we process personal information that we may infer about you based on other information you provide to us or during our interactions with you, or personal information about you that we obtain from third parties, publicly available sources (such as social media platforms) or industry directories or subscription databases. This may include information from interviews and correspondence with your family, friends and other people that are connected to you or information from agents, production companies, audience ticketing companies and other broadcasters. We may obtain information from tax authorities, governmental and competent regulatory authorities where required under laws, insurance companies, fraud prevention and detection agencies and organisations and, where authorised by applicable laws, background check organisations and registered health professionals.

2. HOW DO WE USE YOUR INFORMATION?

We may use your information for the following purposes (where relevant to your type of employment or engagement):

Production Management: Producing, selling, distributing and broadcasting programmes, articles, interviews, commissions or submissions (“Editorial Materials”) for commercial exploitation (including researching and contacting potential contributors for programmes and assessing their interest in and suitability for a programme) and using any footage, images, audio and/or information contained in or related to the Editorial Materials.

Contributor Management: Managing activities generally, including without limitation negotiation of any engagement or contributions, assessing performance, suitability and quality in relation to the engagement or contribution, payments or benefits, data analysis and planning, managing questions or complaints, contract termination, occupational health matters, references and nominations, and emergency contact details;

Communications and Emergencies: Facilitating communication at company premises and outside (including when individuals are traveling), ensuring business continuity, protecting the health, safety and security of our workforce, contributors, visitors or property, facilitating communication in an emergency (including controlling and facilitating access to and monitoring activity in secured premises and activity using News UK information technology, communications and other resources);

Business Operations: Operating and managing News UK’s information technology and communications systems, managing product and service development, improving our products and services, managing News UK assets and human resources, strategic planning, project management, business continuity, crisis management, compilation of audit trails and other reporting tools, maintaining records relating to manufacturing and other business activities, budgeting, financial management and reporting and communications within and outside News UK, managing acquisitions, mergers and reorganisations or sale of News UK in whole or in part;

Compliance: Complying with News UK’s policies, agreements, and legal requirements applicable to our businesses in all countries in which News UK operates, such as taxation, record-keeping and reporting obligations, conducting audits, compliance with inspections and other requests from government, regulators or other public authorities, compliance with legal process such as court orders, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims arising out of or relating to your relationship with News UK, or other claims against News UK, its workforce, contributors and visitors;

Security and Safety: There are Closed Circuit Television (CCTV) cameras in operation within and around our offices and sites, which, are used for the following purposes:

to prevent and detect crime;

to protect the health and safety of our workforce, contributors and visitors;

to manage and protect News UK’s property and the property of News UK’s workforce, contributors and visitors; and

to investigate complaints and allegations of breaches of company policy

We may monitor internet use and communications in accordance with applicable laws and News UK’s Acceptable Technology Usage Policy for information technology resources and any other acceptable use policies that may replace, amend or supplement that policy from time to time.

Unless otherwise stated, all personal information we request from you is obligatory. If you do not provide and/or allow us to process all obligatory personal information as requested, we will not be able to keep complete information about you, thus affecting our ability to accomplish the purposes set out above.

3. WHO DO WE DISCLOSE YOUR INFORMATION TO?

Internal Disclosures: Information about you may be disclosed for the purposes set out above to management, consultants, advisers and other appropriate persons employed or engaged by News UK which may also include health professionals and psychologists.

Viewers and others: If your personal information is included in a programme, this information will be shared with anyone who views the programmes. We may also need to share your information with other broadcasters or production or post-production companies, studio venues, ticket providers or consultants, presenters, experts or other professionals (including health professionals) working with us on the programme or licensing content from us.

Your agent or other representative: Information regarding your potential, current or past engagement.

Professional Advisors: We may disclose your information to our accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries in which News UK and associated group companies operate.

Outsourcing: Like many businesses, from time to time, we outsource the processing of certain functions and/or information to third parties – these are known as processors. Processors provide services on our behalf, including contributor management, managing payments, IT systems suppliers and support; medical advice and insurance administration, trade bodies and associations, and other services. These processors can only use your information in accordance with our instructions and for no other purpose, and we oblige them to protect your personal information with appropriate security measures.

Mergers and Acquisitions and Corporate Transactions: As we continue to develop and grow our business, we may buy or sell companies and other assets. In such transactions, contributors information may be one of the business assets transferred to a buyer or disclosed (on a confidential basis) to a potential buyer. In the unlikely event that the assets or shares of News UK, or part of the company, are sold, your personal information would be included in the contributor information transferred or disclosed to the buyer.

We may also disclose your information to other third parties (such as professional advisers or consultants) in connection with any proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of News UK’s business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Disclosures required or permitted by law: We will disclose any personal information we have concerning you if we are compelled to do so by a court of law or requested to do so by a governmental entity or regulatory authority or if we determine it is necessary or desirable to comply with the law, regulation, codes of practice or industry guidelines or to protect or defend our rights or property.

News Corporation: News UK is an affiliate of News Corporation, headquartered in the United States of America (https://newscorp.com/). The transfer of personal information to News Corporation is protected by a contract, based on the European Commission Standard Contractual Clauses. This contract requires News Corporation to protect your information to the same high standards required by data protection laws in the United Kingdom. The purposes for which News Corporation will use your information are compatible with the purposes outlined in this Privacy Notice.

Content Licensees: Where your personal information is collected and used by us in connection with editorial contributions across our titles and publications, this information (set out above) may be disclosed to commercial partners as part of licensing deals for our content.

PROTECTING YOUR INFORMATION

The personal information we collect from you is stored by us and/or our service providers on systems protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuses or alteration of personal information, and we will notify you of any material loss, misuse or alteration of personal information that may affect you, so that you can take the appropriate actions for the due protection of your rights.

INTERNATIONAL TRANSFERS OF YOUR INFORMATION

We may transfer your personal information to our News UK group companies, News Corporation affiliates, and our processors outside the UK to countries that may not have data protection rules that provide the same level of protection as required in the United Kingdom. However, where we do this, we only transfer your information where there are appropriate data security and privacy measures and controls in place. If you would like to receive a copy of the applicable data transfer safeguards used when your information is transferred outside the EEA, please contact us at dataprotection@news.co.uk.

4. OUR LEGAL GROUNDS FOR USING YOUR PERSONAL INFORMATION

All organisations need a legal reason to use your personal information. If they don't have one, they can't use it. There are a number of legal grounds that enable News UK to process your personal information. Below are the most relevant grounds you should be aware of.

The purpose of journalism, arts and literature: We may rely on the exemption provided for these purposes where applicable.

Legitimate Interests: We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else. Such interests are to:

produce television programmes for commercial exploitation, including finding suitable contributors, and sell, distribute and broadcast the programme;

run and operate an efficient and sustainable business;

protect the health, safety and welfare of our workforce, contributors and visitors;

protect our rights and the rights of others;

provide general management of all contributor-related matters

We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between legitimate interests and your privacy rights.

With your consent: In some cases, we may need your consent to process your personal information. Where we obtain your consent to process personal information, you have the right to withdraw that consent at any time. If you wish to withdraw your consent, please contact us at dataprotection@news.co.uk with details of your request. However, whilst we respect your wishes, an exemption may apply to continued processing or there may be an important reason why we need to continue to process

that personal information and in such case will inform you of the legal basis on which we rely to continue such processing.

To enter into and fulfil your contract: We also process your personal information in order to perform our contract with you. For example, we use your information to pay you or ensure we uphold our duty of care to you.

To comply with legal obligations: There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims.

Where we process Special Categories of Personal Information, we may process such information on the following grounds:

Substantial public interest: There may be situations where it is necessary to process your information in the substantial public interest, including for the equality of opportunity or treatment, prevention and detection of unlawful acts, insurance purposes, archiving purposes, safeguarding of children and individuals at risk and ‘special purposes’ of journalism, art and literature in connection with unlawful acts and dishonesty.

Employment, social security, and social protection law: Where it is necessary to process your information for the purposes of your or our obligations and rights in relation to your engagement in so far as it is authorised by law or collective agreement (for example, if you are attending any of our premises or filming locations, in compliance with health and safety laws, we may need to ask you about your health or any other requirements you have so we can provide appropriate adjustments).

Vital interests: Where is it necessary to process your information to protect your vital interests or someone else’s and consent cannot be obtained (for example, in a medical emergency).

Explicit consent: We may ask for explicit consent to use your information for a specific purpose (for example, health assessments and/or background checks).

Information that has been manifestly made public: Where you have clearly made your sensitive (including special category) information public (for example, on publicly available social media websites or when speaking in interviews or footage).

Establishment, exercise or defence of legal claims: Where it is necessary to process your information for the purposes of establishing, making and/or defending legal claims.

Applying these legal grounds to your information, in the table below we have listed the main purposes for which we process your information and the relevant legal bases that are available to us. The specific legal basis we use will depend on the activity and circumstances the information is used for. Please keep in mind that while we will usually rely on one legal basis, if that is no longer appropriate, we may be able to rely on another.

Purposes of processing (why we use your information)	Lawful basis for the use of your information - this may depend on the specific activity
Production Management
Producing, selling, distributing, licensing and broadcasting programmes and other editorial content for commercial exploitation, including researching and contacting potential contributors for programmes and assessing their interest in and suitability for a programme and using any footage, images, audio and/or information contained in or related to the programme.The commercial exploitation of editorial content involving the use of personal data of contributors, may include licensing of content to AI systems providers to train their models and for purposes that align with our editorial activities.	Performance of the contract with you. Legitimate interests Your consent Legal obligation Substantial public interests Employment, social security, and social protection law Vital interests Information that has been manifestly made public Explicit consent Reliance on the exemption provided for journalism and artistic purposes under the UK and/or Ireland Data Protection Act 2018.
Contributor Management
Contributor administration, including payment, decisions regarding commencement and termination of engagement.	Performance of the contract with you. Legitimate interests
Occupational health programmes and Health & Wellbeing	Legitimate interests Your consent
Management planning, market research and opinion surveys, performance, payment reviews.	Legitimate interests
Travel administration	Your consent Legitimate interests
Emergency contact details	Legitimate interests Your consent Vital interests
Communications and Emergencies
Protecting the health, safety and security of News UK workers and visitors, and the security of property	Legitimate interests
Maintaining contact during emergencies	Legitimate interests Vital interests
Business Operations
Management of access to and use of News UK information technology and communication systems, including the maintenance of usage logs and conducting audits	Legitimate interests
Monitoring access to and the use of News UK information technology and communication systems, and assessing compliance with News UK policies	Legitimate interests
Compliance
Assessing compliance with News UK policies	Legitimate interests
Tax and other government or regulator mandated activities	Legal obligation
Complaint, litigation and claim investigation and management, and taking or defending legal actions	Legitimate interests
CCTV
Monitoring within News UK properties as well as the exterior for the safety and security of the News UK workforce, contributors and visitors	Legitimate interests
The use of CCTV recordings for complaint investigations, assessing compliance with company policy, to defend against claims, and to defend the rights of News UK and others	Legitimate interests

5. HOW LONG DO WE RETAIN YOUR INFORMATION?

We will retain your information for as long as necessary for the uses set out in this Privacy Notice or while there is a legitimate reason for doing so. We will also retain personal information collected and to process such personal information to comply with accounting and tax rules, regulations and any specific record retention laws.

The contribution through your engagement is intended to be kept in perpetuity, in line with usual journalistic and archival practice.

Any talent contract, consent forms and personal information relating to your contribution will be retained for the duration of copyright in your contribution.

6. KEEPING YOUR INFORMATION UP-TO-DATE

It is your responsibility to provide us with any changes to your personal information, such as when you move home or change bank accounts. You should promptly inform the HR Hub (HRHub@news.co.uk) of any changes. If you notice any errors or omissions in the information we have about you, please let the HR Hub know straight away, so that the information may be corrected.

7. YOUR DATA RIGHTS

You have rights as an individual which you can exercise in relation to the information we hold about you. You have the right to request:

a copy of the information that we hold about you (this is known as a ‘Subject Access Request’ or SAR);

that your information be corrected, if it is incorrect;

that your information be deleted;

that we restrict our processing of your information;

that we cease processing your information; and

that your information be provided in a portable format for another organisation where you may work.

All requests must be submitted in writing by letter or email to the HR Hub. Please be sure to include your full name and nature of your engagement with us and the News UK entity you are or were engaged by. We may ask for a copy of a document evidencing your identity (such as a driving licence or passport) before responding to your request.

If you request that we correct, delete or stop processing your personal information that we hold, please tell us the grounds on which you are making such a request. If we agree that the information is incorrect, or that the processing should be stopped, we will delete or correct the information. If we do not agree that the information is incorrect, we will tell you that we do not agree and record the fact that you consider that information to be incorrect. We carefully consider all requests, as there may be circumstances which require us, or allow us, to continue processing your information. If you ask us to delete your information, we may not be able to do so due to technical, legal, regulatory or contractual constraints.

If you request a copy of information that we hold about you, please provide us with sufficient detail so that we can locate the information you are seeking.

These rights may be restricted by law, for example we may not be able to provide a copy of your information where what we hold is also the information of a third party and it is not reasonable to disclose this information. We may not disclose information that you are not entitled to receive under applicable laws (e.g., information revealing something about another individual).

If you are residing in California, please refer to the section below which covers the specific rights granted to you under Californian legislation.

8. CALIFORNIA RESIDENTS

This section is intended to supplement the rest of this notice, and applies only to News UK Contributors currently residing in California.

California residents are granted certain rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). If you are a resident of California, you may request to access, modify or correct your information. You may also request to erase your personal information, and you have the right to have your personal information ported. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable laws.

You may submit your requests by email or in writing to the Group Data Protection Officer using the contact details provided below. We will respond to your questions or complaints relating to the processing of your personal information.

Our policies protect you from retaliation in connection with the exercise of your rights.

Please also note that California law classifies extra categories of personal information as sensitive. These are additional to the Special Categories of personal information identified above in the section What Information Do We Process and are used in accordance with this Notice.

9. QUERIES AND COMPLAINTS

News UK seeks to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously.

If you have any questions about this Privacy Notice, about our processing or your personal information, or any concerns or complaints regarding our handling of your information, please contact the Data Protection Office (dataprotection@news.co.uk).

If you have a complaint and we cannot resolve the matter, you have the right to complain to the Information Commissioner’s Office in the UK (www.ico.org.uk), the Office of the Data Protection Commissioner in Ireland (www.dataprotection.ie) or the data protection regulator responsible for the country or region where you are based.

NEWS UK DATA PROTECTION OFFICER

If you wish to contact the News UK Group Data Protection Officer, you can send an email to dataprotection@news.co.uk or write to:

Group Data Protection Officer Legal & Compliance Department News UK & Ireland Limited

1 London Bridge Street

London SE1 9GF

United Kingdom

CHANGES TO THIS PRIVACY NOTICE

We keep our privacy notices under regular review. This privacy notice was last reviewed on 15/05/2024.