Section 7: Privacy
People trust the BBC and we must be transparent with them. We should make it clear to people how we intend to use their personal information even if it is simply an IP address, email address or a phone number. Personal information is collected, for example, when people visit our websites, enter competitions, register with an interactive community or become part of a database of contributors. We must handle personal data in accordance with the guidelines issued by Information Policy and Compliance.
Production departments often gather personal information about contributors and potential contributors via their websites before storing it in databases. This information should not normally be accessible to other departments outside the production area which has collected it. Any proposal to make an exception should be referred to Information Policy and Compliance (IPC).
Contributors' personal details, comments or other personal information should not normally be given to third parties without the consent of the contributor. If consent cannot be obtained, this should be referred to a senior editorial figure, or for independents to the commissioning editor, who may wish to consult Information Policy and Compliance. If we have consent, a contract should require the third party to use the information only for the use agreed between the contributor and the BBC.
Any proposal to collect personal information on a BBC publicly funded website which might be disclosed to third parties, including BBC Worldwide, must be referred to a senior editorial figure, or for independents to the commissioning editor, who may wish to consult Information Policy and Compliance and BBC Fair Trading.
Any request for a contributor's personal information from the police must be referred to Editorial Policy and Programme Legal Advice before responding.
Cookies record information about a user's preferences on their computers or other devices. When we place cookies on users' devices, we must be transparent with them about their options to accept or reject them. Further advice can be obtained from Information Policy and Compliance.
Where third parties supply programming code which contains cookies to the BBC, advice must be sought from IPC before the code may be used.
Sending Emails and Viral Marketing
We should not send emails to people unless they have agreed to receive them (i.e. we should not send 'spam').
If personal information is going to be used for promotion, marketing, research or any other secondary purpose, our users must "opt in". For example, we should not send promotional emails about our output when people have originally given us their email address in order to enter a competition.
However, in some instances, we may wish to offer audiences the opportunity to email BBC online content to a friend.
When sending emails to a list of subscribers, we should take care to ensure that the email addresses of the subscribers are not visible to others on the list.
Viral marketing can be an effective way of promoting BBC content online, especially where this is by personal recommendation. But, particularly when running a marketing campaign, we should take care that:
- users have given their explicit consent to be sent marketing messages from the BBC or their agents
- marketeers working, or distributing BBC content, on interactive spaces (such as social networking sites, blogs or message boards) are not pretending to be ordinary members of the public. This should not prevent 'mystery content' from being distributed, provided there is a 'reveal' when its origins are made clear to those who have received it
- the content should be suitable for viral treatment, bearing in mind that we are very unlikely to be able to control who receives it once it has been released.
The BBC may sometimes help to trace missing people by broadcasting details provided by relatives and friends. However, we should take editorial responsibility for the content of the message and be aware that not every missing person wishes to be found. It may be appropriate to hold back information the missing person might regard as private, embarrassing or distressing.
(See Guidance: Missing People)