Contributor Privacy Policy

PRIVACY POLICY FOR CONTRIBUTORS

Introduction

This privacy policy explains what data Five Mile Films Limited (“Five Mile” or “we”) collect about you and why, how we use it and who we share it with, as well as your rights as a data subject. Your information is very important to us and we will look after it in accordance with laws and regulations relating to the protection of personal data applicable in the UK.

This privacy policy applies to the personal data of participants or contributors whose contribution we are considering, or have decided, to include in a programme which we have produced, are producing or intend to produce. It is important that you read this privacy policy together with any agreement or notice provided to you, so that you are fully aware of how and why we are collecting and using your data. This privacy policy supplements any other notices (if provided) and is not intended to override them.

Some of our productions involve child contributors, including young children. Where a child is under 13 and a parent or guardian applies on their behalf, this privacy policy is provided to the parent/guardian to read on the child’s behalf, because the child may not be able to understand it. In those cases, references in this policy to “you” and “your” personal data include the child’s personal data as well as the parent/guardian’s data (where relevant). We expect parents/guardians to discuss participation in the relevant production and this privacy policy with the child in an age-appropriate way. We apply additional care and safeguards when processing children’s personal data, and parents/guardians may exercise the child’s data protection rights on the child’s behalf by contacting us as described in “How to contact us” below.

We may update this privacy policy from time to time and will post any changes on our website.

This privacy policy was last updated on 2^nd February 2026.

Who are we?

Any reference to “we“, “us” and “our” is to Five Mile Films Limited and its subsidiary companies. We are the “data controller” of your personal data and you can contact us by email at privacy@fivemilefilms.co.uk or write to us at Privacy Manager, Five Mile Films, 34 Whiteladies Road, Bristol, BS8 2LG for more information about how we process your data.

What personal data do we process about you?

We process your personal data when you your apply to take part in, provide a contribution to, or otherwise participate in, one of our productions This could include for example, your identity information (such as your name, gender, date of birth, age, image, voice, video and/or photos of yourself), contact information (such as your address, email address, telephone number, social media handles), identification documents (such as your passport details or other national identifier, driving licence, your national insurance or social security number) information about your personal life (such as your hobbies and interests, details about your family, relationships and dependants, views of your property), employment information (such as your income, current employment status, employer, role, details about your previous roles) and any other personal data contained in your application, your contribution or otherwise disclosed to us during the production process..

You also provide personal data in your agreement with us and any other communication with us concerning your contribution (or potential contribution). If you are reimbursed for your contribution, you may provide us with your banking details.

In some instances, we may also collect “Special Category Data” (for example, information about your ethnicity, sexual orientation, or your health information) and “Criminal Offence Data” (for example, information about criminal convictions, procedings or investigations, court orders, or court proceedings) as part of the production process, to assess your suitability to contribute to productions, to obtain and administer insurance, to arrange and administer any medical treatment you may need, and to enable the creation, sale and distribution of our productions.

We may collect information about you from a number of sources (such as LinkedIn or other online sources or referees), including from you directly.

Why do we use your personal data and what is our lawful basis?

We process your personal data for the purposes of our business, including for the creation, sale, and distribution of our productions.

As a controller, we are required to have a lawful basis for processing your personal data. We will use the personal data we collect about you for:

The performance of the contract and relationship between us.

This includes processing of personal data concerning your application to take part in, contribution to, or participation in one of our productions and our assessment of it, the duration of your contract, your remuneration, your bank details, your references, checks we may make to verify personal data provided or background checks. Such processing shall include, where necessary, sharing your contact information and bank details with third parties for the purposes of facilitating payment of any residuals or other fees (to the extent that these are payable to you in accordance with the terms of our contract). If relevant, we may also process personal data concerning your health, any disability and any adjustments to filming arrangements.

Lawful basis: To perform our contract with you and to comply with our legal obligations.

Where we process your Special Category Data and/or Criminal Offence Data for this purpose, one of the following grounds will also apply: (1) To fulfil our legal or regulatory obligations and exercise our rights including those as an employer (where applicable) – e.g. for the health and safety of our crew, programme contributors, and others, (2) For reasons of substantial public interest based on the law (e.g. where necessary for our health and safety obligations or for insurance purposes), (3) You have manifestly made the information public (including where you do so when participating in our productions), (4) Where necessary for you to receive treatment from a medical professional, or (5) Your explicit consent. Please also see the note on the special purposes exemption below.

In limited circumstances, where we are processing your data with a view to publication and the special purposes exemption applies, some data protection obligations and rights may be limited to the extent permitted by law (see “The Special Purposes” below)

Contacting you (or others on your behalf, such as your agent for example) in connection with your application to take part in, contribution to, or participation in our productions.

This includes processing contact information you have provided to us, including your address, phone number, or the personal data of an emergency contact or next of kin.

Lawful basis: Necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms.

The creation, sale, and distribution/broadcast of a production you are taking part in.

This includes processing of personal data connected with your application to take part, contribution to, or participation in, one of our productions, such as the processing of images, video, audio, background information, or other pertinent information relating to you. Such processing may include conducting background checks and, where necessary, sharing your personal data with third parties for the purposes of the assessment and exploitation of your contribution, including the commissioning party, broadcaster, rights management platforms, and/or distribution agents.

Lawful basis: Necessary for our legitimate interests or those of a third party to publish your contribution as journalistic, artistic, or literary material which we believe is in the public interest and to manage and administer our respective businesses effectively and properly, where we consider that our, or a third party’s, legitimate interests do not override your own interests, rights and freedoms.

Where we process your Special Category Data and/or Criminal Offence Data for this purpose, one of the following grounds will also apply: (1) You have manifestly made the information public (including where you do so when participating in our productions), or (2) Your explicit consent. Please also see the note on the special purposes exemption below.

To assess your suitability to provide a contribution to one of our productions.

This includes processing of your personal data, Special Category Data (such as your health information) and/or Criminal Offence Data to assess your suitability to provide a contribution to our production in order to safeguard your health, safety and welfare and the health, safety and welfare of our employees, contributors, crew and the general public.

Lawful basis: Necessary for our legitimate interests or those of a third party to assess your suitability to provide a contribution to a production.

Where we process your Special Category Data and/or Criminal Offence Data for this purpose, one of the following grounds will also apply: (1) To fulfil our legal or regulatory obligations and exercise our rights including those as an employer (where applicable) – e.g. for the health and safety of our crew, programme contributors, and others, (2) For reasons of substantial public interest based on the law (e.g. where necessary for our health and safety obligations or for insurance purposes), (3) You have manifestly made the information public (including where you do so when participating in our productions), or (4) Your explicit consent. Please also see the note on the special purposes exemption below.

Contacting you in relation to opportunities to contribute on further productions we may be working on.

This includes processing of your contact information.

Lawful basis: Consent, where we have asked for your consent to contact you for such purposes. Where we do not have your consent, we consider it is necessary for our legitimate interests to manage and administer our business effectively, including for marketing purposes, where our legitimate interests do not override your own interests, rights and freedoms.

Monitoring of diversity and equal opportunities.

This may include personal data on your nationality, racial and ethnic origin, gender, sexual orientation, religion, disability, or age as part of diversity monitoring initiatives. We may also share aggregated and anonymised diversity statistics with regulators if formally required/requested.

Where we process your Special Category Data for this purpose, one of the following grounds will also apply: (1) To fulfil our legal or regulatory obligations and exercise our rights including those as an employer (where applicable), (2) For reasons of substantial public interest based on the law (e.g. identifying or keeping under review the existence or absence of equality of opportunity or treatment), or (3) Your explicit consent.

Please note: Five Mile Films contributes to an industry-wide diversity monitoring initiative called Diamond. The Diamond project uses personal data 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 will share this with Creative Diversity Network Limited (CDN), Soundmouse and Silvermouse 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, CDN and Sky. If you provide Diamond with your diversity data, they will issue you with a separate privacy notice.

Financial planning and budgeting

This includes processing of personal data connected with any remuneration paid in respect of your contribution.

Physical and system security

This includes CCTV footage and records of use of swipe cards or similar entry cards.

Maintaining appropriate business records during and after your participation in a programme.

This includes personal data relating to your contribution in one of our productions.

Day to day business operations including marketing and travel on our behalf (where relevant).

This includes personal data relating to your contribution in a production and may include a photograph or profile of you as well as details of travel arrangements and location.

To fulfil our legal and regulatory obligations.

This includes processing your personal data where required to do so by law. For example, to comply with accounting, tax reporting, health and safety, or audit requirements.

Lawful basis: To comply with our legal obligations. Where we process your Special Category Data for this purpose, we do so to fulfil our legal or regulatory obligations and exercise our rights including those as an employer (where applicable) – e.g. for the health and safety of our crew, programme contributors, and others).

Disputes and legal proceedings.

This includes any personal data relevant, or potentially relevant, to a dispute or legal proceeding affecting us.

Lawful basis: To comply with our legal obligations and where necessary for our legitimate interests to manage and administer our business effectively, where we consider that our legitimate interests do not override your own interests, rights and freedoms. Where we process your Special Category Data or Criminal Offence Data for this purpose, we consider the processing is necessary for the establishment, exercise or defence of legal claims.

Who else do we share your data with?

Your information will be used by the relevant production team for the purposes of making the programme. It may also be shared internally or with our legal advisers to prepare contractual documentation or provide legal advice, and with any other in-house teams involved in commercial exploitation such as the finance teams where a payment is required, the distribution team, and our medical advisers, health and safety and insurance providers if their advice is required, and with the commissioning party / broadcaster for the purposes of the production and exploitation of the programme.

We may pass your information to our third-party service providers such as agents, editors, SaaS providers, ticket providers and other associated organisations for the purposes of casting, filming, editing, selling and distributing our productions, facilitating your application, entry or enquiry or nomination for the 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 and we will ensure that there is a data processing agreement in place between us and such third parties which ensures that processing is compliant with UK data protection law.

Please be assured that we will not otherwise share your information further, unless:

we are required to do so by law, for example by a court order or for the purposes of prevention of fraud or other crime
we are asked to by competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or

Sending your personal data internationally

We may transfer your personal data to other members of our group, and to third party service providers outside of the UK, to countries which do not have similarly strict data protection and privacy laws.

Where we transfer personal data to other members of our group, or our service providers, we will ensure a similar degree of protection is afford to it by ensuring appropriate safeguards are implemented in accordance with UK data protection laws.

How long do you keep my information?

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

In general, where you have been involved with the production of one of our programmes, we will keep your personal data for as long as the programme is being broadcast, distributed or otherwise exploited. Where you have been involved in the casting of a programme, unless you agree that we can keep your information for longer (e.g. where you may be interested in appearing in other programmes) we will keep your personal data until such time as production is complete.

In considering how long to keep your personal data, we will take into account its relevance to our business and your contribution either as a record or in the event of a legal claim.

Some information, such as production footage of your contribution will be held indefinitely as we have an ongoing legitimate interest in retaining this.

Do you need my consent to include me in a programme?

There are circumstances in which we can make programmes about an individual without their consent provided we comply with the relevant laws and regulatory codes, such as the Ofcom Broadcasting Code.

We do not generally rely on obtaining your consent to process your personal data to make a programme in which you appear. This is something which we do as part of our legitimate business interests, as explained above. We may occasionally rely on your explicit consent to process your Special Category Data and/or Criminal Offence Data. You can withdraw your consent at any time (see ‘The right to withdraw consent’ below). In limited circumstances, where we are processing with a view to publication and the special purposes exemption applies, some data protection obligations and rights may be limited to the extent permitted by law (see “The Special Purposes” below).

Where you have entered into a contract with us to participate in our programmes, we may be entitled to show the programme whether or not you later change your mind about participation.

What are my data subject rights and how can I use them?

In law you are the data subject and you have several rights that you can exercise over your data. These rights include:

The right to be informed in a clear and concise manner about what we do with your personal data;
The right of access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
The right to rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
The right to erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
The right to restrict processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
The right to data portability. You have the right, in certain circumstances, to obtain personal data you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice;
The right to object. You can ask us to stop processing your personal data, and we will do so if we are:
- relying on our own (or someone else’s) legitimate interests to process your personal data, save where we can demonstrate our compelling legal grounds for the processing; or
- processing your personal data for direct marketing;
The right to withdraw consent. If we rely on your consent (or explicit consent) as our lawful basis for processing your personal data, you have the right to withdraw that consent at any time. Once we have received notification that you have withdrawn your consent, we will stop any processing that relies on consent where we can do so. In limited circumstances, where we are processing your data with a view to publication and the special purposes exemption applies, some data protection obligations and rights may be limited to the extent permitted by law (see “The Special Purposes” below).

If you want to exercise any of these rights, please contact us (our contact details can be found in the Contact Us section below). Please note that these rights are not always applicable and there may be some situations in which you cannot exercise them or they are not relevant. You should also note that as explained below, these rights may not apply to the extent that they are incompatible with the Special Purposes as set out below. If we cannot comply with your request to exercise your rights we will usually tell you why.

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

The Special Purposes

The UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (the Act) require us to use your data within the legal framework explained above. However Schedule 2 Part 5 of the Act contains a “special purposes” exemption for processing for the purposes of journalism, academic, artistic or literary purposes. This exemption can apply to our processing of personal data where it is processed with a view to publication of journalistic or artistic material, and we reasonably believe that publication of that material is in the public interest. In assessing whether publication is in the public interest we must have regard to relevant editorial codes (including the Ofcom Broadcasting Code and, where relevant, the BBC Editorial Guidelines).

Where the special purposes exemption applies, certain provisions of UK data protection law (including some transparency obligations and data subject rights) may be disapplied to the extent that we reasonably believe applying them would be incompatible with the special purposes (in our case the publication of journalistic or artistic material). We do not apply this exemption on a blanket basis and consider issues on a case-by-case basis, documenting our reasoning as we do so.

What this means in practice:

If, for example, you withdraw your consent (including explicit consent for special category data), we will stop any processing that continues to rely on consent where we can do so. However, if we have already recorded your contribution and are in the process of editing, delivering, distributing or broadcasting the production, it may not be possible to remove or stop using that material without compromising the programme’s journalistic or artistic purpose. In such circumstances, we may continue processing and using your information for publication and distribution of the production where the special purposes exemption applies. This may also mean that some rights (for example, access, erasure, restriction or objection – see above) may be limited to the extent permitted by law where compliance would be incompatible with the special purposes.

In some productions (for example, investigative documentaries), we may obtain personal data from third parties (such as whistleblowers, confidential sources, or publicly available materials), or we may record programme material using covert methods. In those circumstances, it may not be possible, or it may be inappropriate, to inform the individuals concerned at the time we obtain their personal data or to seek their consent, because doing so could prejudice the investigation or otherwise be incompatible with the journalistic purpose and the public interest in publication. Where the legal tests are met, we may rely on the special purposes exemption to limit certain transparency obligations and/or certain rights, to the extent permitted by law.

Where relevant, the broadcaster and/or the commissioning party (as an independent controller) may also rely on the special purposes exemption for its own processing, applying the same legal tests.

How to contact us

If you have any questions about our privacy policy or the information that we hold about you please contact privacy@fivemilefilms.co.uk.

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.