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Privacy Statement

1. Who are we

21Six Platform Media Ltd t/a Platform Media (“we”, “us”, “our”) launched in May 2023 as the content agency for Platform, a group of media and technology companies that also includes a podcast production company, Folding Pocket, and a technology company that is set for launch later this year. Since 2020, Platform has been creating and distributing digital content for Folding Pocket projects and, separately, an increasing number of brands, organisations, agencies, rights holders, and talent. To service this increased demand, we launched Platform Media to oversee all content campaigns across the group. The company is based in London, where our studio is located, and we are incorporated in England under company number 13157419, our registered office is The Barn, Calcot Mount, Calcot Lane, Curdridge, SO32 2BN.

We are committed to protecting and respecting the personal data that we hold. We collect, store, transfer, and use personal data for various purposes, and our policy is to be transparent about why and how we do this. We process personal data provided to us for the purposes described in this privacy statement and in accordance with relevant data protection laws.

We have implemented appropriate measures and safeguards to ensure that your personal information is kept safe and secure. We will only share personal data with others when we are legally permitted to do so, and we will always seek your explicit consent where necessary. Individuals have certain rights over their personal data, and if you wish to exercise any of these rights, please contact us at privacystatement@platformmedia.uk.

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please contact us at privacystatement@platformmedia.uk, or lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office.

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2. Data Controller and contact information

If you have any questions about this privacy statement or how and why we collect, process, store, and transfer personal data, please contact us at privacystatement@platformmedia.uk

3. What is Personal Data?

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we collect, process, store, and transfer personal data.

We collect, process, store, and transfer personal data for numerous purposes. The means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are outlined in detail in our relevant sections. Personal data may be obtained directly from the individual it relates to, from a third party acting on behalf of that individual, or from publicly available sources such as press articles, social media profiles, or online searches. Where necessary, we always make sure to inform the individual of the necessary information regarding the use of their data, and reference may be made to this privacy statement.

4. Data that we hold:

The data we process will depend on the nature of our interaction with you. We process data for the purposes of running our business including for production, broadcasting, distribution, marketing, and direct inbound inquiries. Where we engage with individuals, we request that individuals only provide the personal data that is necessary for the purposes of our engagement, most of the personal data that we process about you comes from you, which is likely to include your name, age, and email address.

(a) Terminology Explained

“personal data” is information relating to you that identifies you and includes not only facts about you but also intentions and opinions about you.

Personal Data includes information held on, or relating to the use of, a computer, laptop, mobile phone, or similar device. It covers data derived from equipment such as access passes within a building, data on the use of vehicles, and sound and image data such as CCTV. It also covers video, audio, and images captured as part of a production.

“Processing” means doing anything with the data, for example, it includes collecting it, holding it, disclosing it, and deleting it.

“special category data” is Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, health, sexual orientation, sex life, trade union membership, and genetic and biometric data are subject to special protection and considered by EU privacy law to be “special category data”.

If we process special category data about you, we will only carry this out for one of the permitted reasons under Schedule 8 of the Data Protection Act 2018, including where it is necessary at law or where there is a substantial public interest in doing so.

(b) Who sees the data?

Internal use: Your personal data may be disclosed to our employees working on your production.

External use: We will only disclose your personal data outside our company if the disclosure is consistent with a ground for processing on which we rely and doing so is lawful and fair to you. We may disclose your data if it is necessary for our legitimate interests as an organisation or the interests of a third party (but we will not do this if these interests are overridden by your interests and rights in particular to privacy).

Specific circumstances in which your personal data may be disclosed include:

  • Disclosure to external recipients of electronic communications (such as emails) which contain your personal data.
  • Disclosure of aggregated and anonymised diversity data to relevant regulators as part of a formal request.
  • If you have an on-screen role, disclosure of footage, images, or audio recordings of you as part of any of our broadcast, distribution, and marketing productions. Or, whether you have an on-screen or off-screen role, to allow us to credit your role.

(c) Why would we need to process your data?

We may professionally process personal data for various purposes, including:

  • Operating and managing our business efficiently and compliantly;
  • Responding to queries from members of the public in a timely and professional manner;
  • Evaluating the suitability of individuals to take part in our productions and assessing the impact of their contributions to our productions;
  • Producing, exhibiting, exploiting, distributing, publicising, advertising, and promoting our productions by any media (now known or hereafter invented) throughout the world in a professional and lawful manner;
  • Making payments to individuals in a secure and timely manner.

(d) What data is processed by us?

The data we capture and the lawful way in which it is processed is dependent on the way in which we obtained the data and who we received it from:

  • Members of the Public who contact us by phone, e-mail, website, or otherwise in writing:
    • your name, contact details, and handwriting – to correspond with you and for administrative purposes (with such processing being necessary for the purposes of our legitimate interests).
  • Prospective Employees, Freelancers, and any other such contributors:
    • your name, contact details, and handwriting – to correspond with you and for administrative purposes (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it);
  • your image and the other information in your passport, driving license, and other official documents – to verify your identity and to ensure compliance with relevant laws (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it);
  • information about your work history, qualifications, and experiences – to assess your suitability to work with us or take part in our programs and/or to comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests);
  • information about you on social media and the internet including images of you and other information – to verify your identity and to assess your suitability to work with us or take part in our productions (with such processing being necessary for the purposes of our legitimate interests);
  • where relevant, information about your physical and mental health – to assess your suitability to work with us or collaborate on our productions and/or to comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it – and undertaken with your consent);
  • information about any criminal convictions or cautions you have or any criminal activity or proceedings you have been involved in – to assess your suitability to work with us or take part in our productions and/or to comply with contractual and regulatory obligations (with such processing being necessary for the purposes of our legitimate interests and/or for the performance of our contract with you or steps taken prior to entering into it – and undertaken with your consent);
  • your financial details including your bank details – to pay or reimburse pre-approved costs or expenses (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you or steps taken prior to entering into it); and
  • your age, gender, gender identity, ethnicity, disability, and sexual orientation – for diversity analysis monitoring (with such processing being necessary for the purposes of our legitimate interests and undertaken with your explicit consent).

Contributors:

  • Information contained in footage filmed for our productions or provided to us including a very wide range of personal information about you including:
  • your image; your age; date of birth; handwriting; information about your personal; home and family life and your work history; qualifications and experiences (with such processing being necessary for the purposes of our legitimate interests and for the performance of our contract with you);
  • information about your racial and ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, health, sex life, or sexual orientation (so-called ‘special category data’) (with such processing being necessary for the purposes of our legitimate interests and/or the performance of our contract with you and undertaken with your explicit consent and/or in connection with public interest journalism); and
  • information about any criminal convictions or cautions you have or any illegal activity or proceedings you have been involved in (so-called ‘criminal convictions and offenses data’) (with such processing being necessary for the purposes of our legitimate interests and/or the performance of our contract with you and undertaken with your explicit consent and/or in connection with public interest journalism).

Should we ever intend to process your personal information with your consent, we will seek your explicit consent in writing.

(e) Retaining your data.

Although there is no specific period for which we will keep your personal data, we will not keep it for longer than is necessary for the intended purpose for which it was collected.

For individuals who may have been featured in our productions, we will keep your personal data until the show has been produced and for a period afterward. In considering how long to keep it, we will take into account its relevance to our business and your participation either as a record or in the event of a legal claim. Some data, such as production footage itself and credit information, will be kept indefinitely as we have an ongoing legitimate interest in retaining the product.

(f) Access to your personal data and other rights

We try to be as open as we reasonably can about the personal data that we process. If you would like specific information, just ask us.

You also have a legal right to make a “subject access request”. If you exercise this right and we hold personal data about you, we are required to provide you with information on it, including:

  • Giving you a description and copy of the personal data
  • Telling you why we are processing it

If you make a subject access request and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

As well as your subject access right, you may have a legal right to have your personal data rectified or erased, to object to its processing, or to have its processing restricted. If you have provided us with data about yourself, for example, your address, you have the right to be given the data in a machine-readable format for transmitting to another data controller. This only applies if the ground for processing is Consent.

If we have relied on consent as a ground for processing, you may withdraw consent at any time – though if you do so that will not affect the lawfulness of what we have done before you withdraw consent.

We have implemented appropriate measures and safeguards to ensure that your personal information is kept safe and secure. We will only share personal data with others when we are legally permitted to do so, and we will always seek your explicit consent where necessary.

As mentioned Individuals have certain rights over their personal data, and if you wish to exercise any of these rights, please contact us at: privacystatement@platformmedia.uk.

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please contact us at privacystatement@platformmedia.uk, or lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office.

5. Security

We take the security of all the data we hold very seriously. To ensure that your personal information is kept safe and secure, we have implemented a range of measures and safeguards. Our staff has been trained on data protection, confidentiality, and security, and we have a framework of policies and procedures to ensure that our security measures are regularly reviewed and we ensure that all information provided by you is securely stored and protected by relevant data access control measures.

While we do our best to protect your personal data, the transmission of information via the Internet is not 100% secure and any transmission is at your own risk. Once we have received your information, we employ procedures and security measures to try to prevent any unauthorised access.

6. Who do we share personal data with?

As we have previously stipulated we will only share your personal data when we legally need to, and when doing so we will ensure that either contractual arrangements or security mechanisms are in place to ensure we are compliant with our data protection and security standards.

At times your personal data may be processed by our staff and all forms of employees, including third-party external support providers. A list of those included:

  • Insurance Companies
  • Legal representatives
  • Health & Safety advisors
  • IT Services
  • Regulatory authorities
  • Accountancy services who are supporting us with providing their services
  • Production partners; co-producers and production consultants.
  • Commissioning partners such as distribution partners, broadcasters, and sales agents.
  • Others – There may be occasions where we have the need to share your data with additional third parties not listed above. Should this happen we will notify you beforehand.

It is possible that we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights e.g. Ofcom.

7. Does my data go outside of the UK?

We may transfer your personal data outside the UK and EEA where we have a foreign server storage provider or our productions are broadcast outside of the UK. If you are featured in a production of ours the data constituting your performance may be transferred out of the UK and EEA for program broadcast, distribution, and marketing purposes.

8. Changes to our privacy statement

We may update or amend this privacy statement from time to time and any updates to this privacy policy will appear on this website. This privacy statement was last updated on 22nd May 2023 and is currently in review.