Last updated: 4 January 2021
This policy has been updated to clarify its scope and to reflect that BBC Global News is now part of the BBC Studios group
You might engage with us as a consumer or in a professional capacity. When you do, we are likely to collect information about you and about your use of our services. We are committed to being transparent and fair in our handling of personal information and we will always endeavour to comply with best practice and applicable privacy and data protection laws in all the countries within which we operate. This policy describes the information we collect, how we use it, the circumstances in which it may be shared, and your rights in relation to the information we hold.
- Scope of this policy
- Information we may collect
- How we use your information
- Sharing and disclosing your information
- Where we will store and use your information
- How long we will keep your information
- Children using our services
- How we secure your information
- Your rights and choices
- Changes to this policy
- Contact Us
If you have any questions or comments about this policy or our approach to privacy please contact us at: email@example.com. We aim to reply to any queries within five working days.
BBC Studios is a global business operating as BBC Studios Productions, BBC Studios Distribution and BBC Global News (also trading as BBC StoryWorks), and through its international subsidiaries. The details of our primary companies and their locations can be found here. Additionally, BBC Global News has subsidiaries in India, Japan, Singapore and the USA.
This policy governs the processing of your information by the relevant BBC Studios company in relation to their distribution and marketing activities.
We will provide additional notices where appropriate, for example, to explain how we use web technologies such as cookies (you can find the link in the footer of the site you are using) or our mobile app notice.
If you are a contributor to one of our programmes, the processing of your personal information by BBC Studios Productions is covered by the notice provided here, unless expressly indicated otherwise.
Other companies using our brands
We license our brands and content to other companies who may produce their own websites, events and digital content. These companies must clearly identify themselves through their website branding and privacy policies and handle your information appropriately. When you use a service operated by another company, the use of your information will be subject to their privacy practices and you should ensure you read their notices. If you wish to raise any concerns with us about the treatment of your information by such companies, please contact us at: firstname.lastname@example.org.
2. INFORMATION WE MAY COLLECT
The information we collect depends on the circumstances and the service you are using. We will only collect and store the information we need to. We may collect information relating to you and/or your use of our services in the following ways:
Personal information provided by you:
When you use our services, attend one of our events or you otherwise interact with us (such as through social media platforms or engaging with our sales teams), we may ask you to provide information relevant to the circumstances. This information could include your email address, which we require to enable you to subscribe to receive news about our content and brands, or your contact details and payment information if you purchase something from us. It should be obvious why we are asking for particular information and if it is not we will provide an explanation. In the next section, we explain in more detail the types of information we might collect.
When you share your comments and content with us (User Generated Content)
We may sometimes invite you to comment or to share your photos and videos with us. If you take part then we may publish or use your content on our services or other platforms. There may also be times when you proactively choose to post content on our social media pages or elsewhere that relates to our brands (i.e. simply to show your love for our brands). When you do this, we may contact you (via the relevant platform) to ask if we can publish or use your content on our services or other platforms.
Interacting with us via social media and other platforms:
Information collected automatically during your use of our services:
When you use or receive services from us over the internet, we automatically record information about your use of those services, your interaction with our adverts and our emails as well as information about the device you are using and your internet connection. We do this in two ways:
Log data: When you use our services, certain information gets recorded in our log files such as your device's Internet Protocol (IP) Address, its unique ID, its operating system and location, and your browser type, the pages you viewed, cookie information and referral links (the link that sent you to a particular page).
Web technologies: In conjunction with our log data we may use specialist web technologies such as pixels or tags embedded in our web pages and emails and small data files which we store on your device (known as "cookies"). These technologies enable us to recognise your device and to track your interaction with our services, emails and adverts. We do not use these technologies to personally identify you, although we may add some data collected via these technologies to marketing records we hold about you. In the UK and the European Economic Area (EEA), we will obtain your consent prior to storing or accessing data on your device (for e.g. a Cookie ID), in-line with our legal obligations. For all users, we will provide you with tools and/or clear instruction on how to opt-out from these technologies.
See the Cookies Notice for the site you are using to find out more about the technologies deployed through the particular service you are using. You can find the link in the footer.
Information collected via specialist companies:
We sometimes use specialist companies to provide us with information they hold in relation to you or to collect information on our behalf. For example, we use market research agencies to provide us with consumer insights to help shape BBC Studios programmes, products and services. Generally speaking, this will be anonymous or aggregated data that means we are unable to identify you specifically. If personal information is shared with us then we will always ensure this is done lawfully and, where appropriate, with your consent.
We might also use the services of social media platforms and advertising agencies or platforms to enable us to reach certain audiences and to better target our marketing messages or the advertising shown on some of our services. For example, we might use anonymous information about your browsing on our services or elsewhere to infer your interests and to put you into appropriate "market segments". This information is not used to identify you as a person and we do not attempt to combine it with personal information that we may hold. See the specific cookies notice for the service you are using for more information.
3. HOW WE USE YOUR INFORMATION and Legal Basis For Processing
Purposes for which we will use your information
Depending on which of our services you are using (or how you are otherwise interacting with us), we may use your data for the purposes described below, and in ways which are consistent with our relationship with you (i.e. as a consumer or in a business context). We have set out a description of all the ways we might use your personal data and the types of data this could include. Under UK or European data protection law we are required to tell you our lawful basis or processing your personal data and we have included this in the table below.
CATEGORIES OF PERSONAL DATA (EXAMPLES)
To provide our products and services to you. Including, as applicable, (i) the administration of your account, (ii) processing and delivering your order, providing a service you have requested or administering our events (including travel and accommodation support for industry events).
(i) Our legitimate interests to keep our records updated and to manage our services effectively.
(ii) Performance of a contract with you
Our legitimate interests to ensure you have a good experience in using our services or in your business dealings with us, to keep our records updated and to respond to requests and feedback.
To manage and secure our services. Including troubleshooting, testing, system maintenance, reporting, and data hosting, preventing fraud or other potentially illegal activities (including copyright infringement), blocking disruptive users, protecting the safety of users and enforcing our terms of service.
Our legitimate interests for running our business, provision of administration and IT services, network security, and to prevent fraud
To measure and improve our products and services, the effectiveness of our marketing and emails, and our customer relationships and experiences. We may use specialist research or IT service providers to help us to do this.
Our legitimate interests to study how customers use our products and services, to keep our services updated and relevant, to develop our business and to inform our marketing strategy
Consent (if you are located in the UK/EEA), in relation to non-essential cookies and related technologies used to support this purpose.
Consent where your personal information is shared/disclosed directly in response to a research questionnaire/survey.
To send you emails with news, offers and promotions relating to our content, brands and services and special promotions from our brand partners in accordance with your contact preferences. These communications may be personalised to you based on what we think may interest you.
We may also send notifications via your device or web browser, where you have specifically given permission when requested by your browser or device.
If you unsubscribe or opt-out from email marketing, we may add your email address to a suppression list to ensure we respect your preference.
Consent, as applicable, or our legitimate interests to promote our content, brands and services, and those of our partners and to manage your preferences.
To personalise your experience and our marketing communications to make it more relevant to you and to tell you about goods or services that we think might interest you.
We sometimes promote our products and services to you through advertising on other websites and services. This advertising may be personalised to you based on your browsing or purchase history with us.
Consent (in relation to cookies and related technologies in the UK/EEA), or
Our legitimate interests to promote our services and engage our consumers and audiences
To market our products and services to you via social media. When we post marketing messages on social media platforms, we sometimes use the audience segmentation tools of the platform to show these to particular types of people – for example, based on your age, interests or (broad) location. When we do this, we only receive aggregated anonymous reports on the performance of these posts, no personal data is shared with us.
Custom Audiences: We may use your contact details and browsing/transactions data we hold about you in order to show you relevant marketing and promotional posts on social media. When we do this, an encryption technique is applied to the data so the social media platform can only read the data that it already holds in order to create a match so it can show you the relevant advertising post.
For general social media marketing we do not use personal data we hold about you.
Where we use Custom Audiences, we may use the following data
Our legitimate interests to promote our services and engage our consumers and audiences
Measuring and analysing the effectiveness of our marketing messages shown to you on our websites, in our emails and elsewhere online (e.g. where we purchase media space on other websites).
Our legitimate interests to analyse how customers use our products and services, to develop our products and services, to grow our business and to inform our marketing strategy
To analyse and report on brand sentiment and feedback on social media. When you post about us, our brands or programmes on social media, we may collate and report on this using a specialist platform so that we can better understand public perception. To do this we use a service called Synthesio.
Our legitimate interest to better understand how our brands are perceived and to engage with our customers/audiences.
To conduct market research into our brands and services. We use specialist market research agencies to conduct research on our behalf. When we do this, the agencies will not usually share any information to enable us to identify respondents. If they were to do this, it would be explained to you at the time you take part in the research.
However, we may carry out research relating to actors and public figures and when we do this, we will receive information about public opinion of such people.
For respondents: no personal data only anonymous demographical data and opinions.
For ‘talent’ and other public figures: name and public opinions/perceptions about them.
Our legitimate interest to better understand how our brands or talent are perceived and to engage with our customers/audiences.
To personalise adverts shown to you by our partners and advertisers on our services (that include advertising). This may include advertising personalised to you based on your browsing of our websites and other websites, and inferred interests or demographics for the service you are using.
Our partners and advertisers may also measure and analyse the effectiveness of the adverts shown to you.
To find out more about advertising and to opt out of your data being used to personalise it, see the Cookies Notice for the service you are using.
Consent (in relation to cookies and related technologies in the UK/EEA), or
Our legitimate interests to promote our brand partners and to generate revenue to help fund services.
Where we propose using your personal information for any other uses or for any other lawful basis, we will ensure that we notify you first and get your consent as appropriate.
4. SHARING & DISCLOSING YOUR INFORMATION
Information shared within the BBC group
To improve your experience of our services and brands, information about your use of our services may be shared between companies in the BBC Studios Group for the purposes of research, analysis, marketing and ad-serving. In addition, another company in the BBC group may provide data processing services on behalf of a BBC Studios company. For example, most of our newsletter subscription services are managed by a team in the BBC Studios Distribution UK headquarters.
Information shared with our suppliers
We use third parties to perform business functions on our behalf, such as sending our newsletters, hosting our online services, providing our customer services and fulfilling product orders and processing payments. We only disclose the information necessary to enable these third parties to perform their services. Our suppliers are contracted to comply with our instructions and we require that they do not use your personal information for their own business purposes. In all cases, we require our suppliers to keep your personal information secure and confidential, and where necessary, we would undertake a separate review of the supplier’s IT systems and processes for this purpose.
Information shared via third party sharing buttons, widgets and other embedded content
Information shared through pixels and cookies
Information shared with other parties
Generally, we will only disclose your data to other parties with your consent, for example if you choose to share content via social media functionality. Where required or allowed by law, we may disclose your personal information to law enforcement agencies, government/regulatory bodies, internet service providers and content protection organisations without your consent. For example, if you post inappropriate or objectionable content on our services or where we reasonably believe you may be in breach of the law or there is a safety concern, we may report your content and behaviour to relevant parties.
Sale or transfer of all or part of our business or assets
We reserve the right to transfer your personal information in the event we sell or transfer all or a part of our business or assets so that the buyer can continue to offer you the services. We will make reasonable efforts to provide you with advance notification of the transfer of your information in such circumstances.
5. WHERE WE STORE AND USE YOUR INFORMATION
As described in the previous section, we may share your information with other companies in the BBC Group or with contracted third party service providers. These companies may be located in, or use IT equipment located in, countries different to that in which your information is collected. Where this is the case, we will take steps to ensure that your information receives an appropriate level of protection.
If you are in the UK, or EEA:
Processing your data in countries such as the USA involves transferring your data outside the European Economic Area (EEA). Many of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
We require our recipients to provide a similar level of protection when transferring personal data out of the EEA.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. HOW LONG WE KEEP YOUR INFORMATION
We will hold your personal information on our systems for as long as is necessary for the relevant service or as long as is set out in any relevant contract you hold with us, in accordance with our retention policy. Where you contribute to one of our online services, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. After this time, your personal information will either be securely deleted or anonymised so that it can be used for analytical purposes.
7. CHILDREN USING OUR SERVICES
Except where otherwise indicated, we do not knowingly collect or store any personal information from children under the age of 16. In some cases, we may restrict our services, such as competitions, to those aged 18 or over. If appropriate, we will take steps to determine the age of persons submitting their information to us and may seek to obtain the consent of your parent or guardian.
If you are under 16, we request that you do not provide us with information relating to you or to others. Please seek the guidance of your parent or guardian before using our services.
If you are the parent or guardian of a child who is under 16 and you become aware that your child has provided us with information without your consent, please contact us at email@example.com. We will delete such information from our records within a reasonable time.
8. PROTECTING YOUR INFORMATION
We protect your information in many different ways. These include staff training, investing in technology and following strict handling and storing procedures. We maintain appropriate organisational and technological safeguards to help protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the information we hold about you. We also seek to ensure our service providers do the same. Unfortunately, no system can be guaranteed as completely secure and there is an inherent risk in transmitting information over the internet. It may be possible for an unrelated party to intercept or access such transmissions unlawfully.
If you believe that your personal information under our control has been compromised, including access to any accounts you hold with our services, please contact us immediately using the details under ‘Contact Us’ below.
9. YOUR RIGHTS & CHOICES
You have a number of rights and choices available to you in relation to personal information we hold about you. If you would like to exercise any of these, please follow the instructions provided or submit a request to us in writing using the contact details provided below.
Communication Preferences: If you wish to stop receiving marketing communications from us, please click on the "unsubscribe" link at the bottom of the relevant email. This will not necessarily unsubscribe you from all communications, only the brand/service in question. If you wish to opt-out completely then please contact us using the details provided below. Please note that you cannot unsubscribe from some service-related messages (which are not used to send marketing materials).
In accordance with industry standards, we reserve the right to retain a minimal amount of data necessary to ensure we do not contact you in the future – for example by adding your email address to a ‘suppression list’.
Opt-out from personalised advertising cookies and other tracking: If you wish to opt-out of personalised advertising or other forms of "tracking" please refer to the cookies notice for the service you are using (you can find the link in the website footer). Be aware that opting out of personalised advertising will not prevent adverts from being displayed to you but they will no longer be tailored to your interests or browsing behaviour.
Access information we hold about you: You can find out what information we hold about you and can receive a copy of it. When submitting a request, please provide us with enough information to enable us to locate your record(s), including the email address we may hold for you and the details of the service you use.
We will require you to prove your identity before granting access to your personal information. You will not have to pay a fee to access your personal data (or to exercise any of the other rights detailed below). However, we may be entitled to 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.
We will process your request within applicable legal timeframes. For the UK and the EEA, this is one calendar month, but we can extend this time if your request is particularly complicated or large.
Correct your information: You can have any incomplete or inaccurate personal information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Delete your information: In some circumstances you can ask us to delete information we hold about you. For example, when we no longer need it because you initially gave us consent and you wish to withdraw it. Sometimes we may not be able to delete your information because (i) we are legally required to keep it; or (ii) we need it for our own legitimate business purposes, for example if you were to unsubscribe from an email list, we would need your email address to add to a suppression list to ensure you were not contacted. We will only refuse to delete information where permitted by law. Where applicable, we will explain the reasons for refusing your request.
IF USING UK OR EEA SERVICES, YOU HAVE THE FOLLOWING ADDITIONAL LEGAL RIGHTS:
Stop us from using your personal information: You can ask us to stop using your information for direct marketing purposes (see communication preferences). You can also ‘object’ to us processing your information where we are relying on a legitimate interest. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restrict the processing of your personal information: You can ask us to suspend the processing of your personal information if you are concerned about its accuracy or how it is being used. You can also ask us not to delete your information (for example because you need it to establish, exercise or defend legal claims).
Transfer your personal information in a machine-readable format (to you or a third party): This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
CALIFORNIA RESIDENTS HAVE THE FOLLOWING SPECIFIC LEGAL RIGHTS:
Under the Californian law, including the California Consumer Privacy Act (Cal. Civ. Code 1798.100), if you are a resident in California you may contact us in relation to the following rights regarding your personal data:
Right to access: You have the right, twice a year, to request access to the personal information that we have collected about you and/or shared outside the BBC Studios group in the past 12 months.
You also have the right to access a list of companies with whom we have shared your personal data for direct marketing purposes. However, BBC Studios group companies do not share personal information with unrelated companies without providing you with a choice in such disclosures.
Right to deletion: You have the right to request that we delete your personal information. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.
Right to opt in/opt out of sale of personal data: For individuals aged 16 years or older, you have the right to opt-out of sale of personal data we may hold on you to third parties. For individuals between 13 to 16 years old, you have the right to opt-in to the sale of personal data we may hold on you.
BBC Studios group companies do not “sell” customers’ personal data other than in the limited ways described in our cookies notice. The cookies notice provides instructions on how you can opt out from the sharing of your personal information.
Exercising your rights: If you wish to exercise any of your privacy rights or have any queries about how we use your personal data, please contact our Privacy Team at: firstname.lastname@example.org or write to us at the appropriate address below.
If you are a BBC Shop customer who resides in California, you can also call our toll-free number (provided below) to exercise your rights of access to your personal information.
11. CONTACT US
Alternatively, you can write to us by post:
Data Protection Officer
1 Television Centre
101 Wood Lane
For questions or requests relating to BBC Shop, please email email@example.com or write to:
BBC Studios Americas Inc
1120 Avenue of the Americas
BBC Shop Customer Services (toll-free)
12. RIGHT TO COMPLAIN
If you have a concern about how we have processed your personal data, you should contact us in the first instance via the contact details above.
For UK and/or EEA services:
If you feel we have not resolved your concern you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
If you live in a country or territory located in the European Union (EU) or European Economic Area (EEA), and you think that some, or all, of the issues you are concerned about have taken place in your country of residence, you can complain to your national data protection regulator. For contact details of national data protection regulators in the EU and EEA, please refer to the European Data Protection Board website.