POLICY FOR THE PROTECTION OF VULNERABLE GROUPS

(Hereinafter – ‘Policy’)

1. General Purposes and Objectives

1.1. Our goal is to reflect the world as it is and make our content accessible and inclusive to the greatest extent possible.

1.2. This Policy defines our approach to these members of the vulnerable group(s), specified in Section 2, in order to ensure that we fulfill all necessary legal obligations, as well as expand representation and ensure accessibility for such vulnerable group(s).
1.3. We will use reasonable security measures to protect rights and legitimate interests of vulnerable groups.

2. Definition of Vulnerable Groups

2.1 The vulnerable groups, covered by this Policy, are as follows:

1. Prisoners;
2. Refugees;
3. Migrants;
4. Minorities;
5. People with mental illness;
6. Employees;
7. Physically and/or intellectually disabled people;
8. Children;
9. LGBTQ+;
10. Sex workers;
11. Victims of crimes;
12. Other categories that may be reasonably considered as a member of vulnerable groups.

    2.2. Vulnerable groups include persons who may face discrimination due to such factors as age, disability, ethnicity, gender, sexual orientation, socio-economic status or other characteristics.

3. Our principles

3.1 We prohibit any form of discrimination based on characteristics associated with a vulnerable group(s), including age, disability, race, gender, sexual orientation, socio-economic status or other characteristics.
3.2 We encourage non-discrimination and equal opportunities for vulnerable groups throughout the TV industry, as well as promote the representation of vulnerable groups in our TV programs.
3.3 We strive to be fair to everyone, and our content is based on respect and openness. For this reason, we are straightforward and fair in our dealings with sources, audiences and vulnerable groups.
3.4 We will seek the informed consent of vulnerable groups. The members of vulnerable groups will be duly informed about the nature and context of their participation in accordance with the GDPR and other applicable data protection laws.
3.5 We take proper care of vulnerable groups, who may be caused harm as a result of their participation.

4. Data protection and processing

4.1 We process personal data of vulnerable groups in accordance with the law only if at least one of the conditions given in Article 6(1) of GDPR is met, in particular:

1. the data subject has given consent to the processing of his or her personal data;
2. processing is necessary for the performance of a contract;
3. processing is necessary for compliance with a legal obligation to which the controller is subject;
4. processing is necessary in order to protect the vital interests of the data subject or of another natural person;
5. processing is necessary for the purposes arising out of legitimate interests of the controller or third party;

4.2. In order to ensure data security, we use technical and organisational measures that protect data against accidental or unlawful destruction, loss, modification, unlawful disclosure or unlawful access to personal data.

5. Our strategy for protection of vulnerable group(s)

5.1. We pay special attention to appropriate and respectful language usage and avoidance of harmful stereotypes.
5.2. We also promote accurate and culturally acceptable representation of vulnerable persons.
5.3. In order to ensure the protection of vulnerable groups, we also establish mechanisms for regular feedback, commentaries, consultation and cooperation with the vulnerable group(s) and their representatives.
5.4. In order to determine the appropriate level of care, we identify the potential risks associated with our content, and if potential risks exist, we also assess the level of risk in each case.
5.5. If risks have been identified for the vulnerable person in connection with his/her contribution to our content, he/she should be provided with relevant information about these risks and any steps that will be taken to mitigate or eliminate them.
5.6. We also take appropriate measures to reduce the risk to be offended, as well as other risks, that can cause harm to rights and legitimate interests of vulnerable groups.
5.7. The safety and well-being of vulnerable groups will be properly taken into account.

6. Informed Consent

6.1. Vulnerable groups will give their informed consent for participation in the TV program, unless there are legal grounds to act without such consent.
6.2. We find out whether a vulnerable person is able to give informed consent. Vulnerability may mean that they are unable to make judgments due to injury, serious illness or lack of understanding.
6.3. We will protect interests, privacy and dignity of vulnerable groups before putting any sensitive facts or experience into the public domain.

7. Protection of Interests

7.1. Even if a vulnerable person gives informed consent for his/her participation in the TV program, we will consider, whether participation is in the best interests of that person and/or other persons, such as, for example, his/her close relatives.
7.2. The safety and security of the vulnerable person, as well as potential benefits of his/her participation will also be considered.
7.3. The assessment of vulnerable participants should be carried out by appropriately registered and qualified professionals, such as, for example, psychologists or psychiatrists, who also understand how media works, as well as have experience of working with certain vulnerable groups.
7.4. If risks have been identified for a vulnerable participant, he/she will be provided with relevant information about these risks and any steps that will be taken to manage or mitigate such risks.
7.5. The information should be given clearly at the earliest stage of the participation in a way that is understandable to the vulnerable person.
7.6. When communicating with vulnerable person with specific needs, it is important to use the methods that are the most suitable for communication with such a person. These may include, for example, using oral recorded consent methods or other methods suitable for such vulnerable person.

8. Assessment of the Impact of Participation on Vulnerable Groups

8.1. A vulnerable person may have special individual needs depending on his/her disability or conditions.
8.2. Where necessary, professional advice should be taken and any potentially negative impacts on the vulnerable person will be thoroughly discussed.
8.3. A final judgement on whether to include materials into TV program will depend on an assessment of:

1. How the vulnerable person may be affected;
2. How well known these facts are in their community;
3. What support they have in place; and
4. What support is available going forward.

8.4. Due care should be taken to ensure that vulnerable participants receive sufficient support during their participation in the TV program.
8.5. We also need to be clear about the limits of any support we can offer and the time frame within which we can offer it.
8.6. In some circumstances, such as victims of gender-based violence, it may be less stressful for a vulnerable person to have a team consisting of members of the same sex.

9. Regular Trainings

9.1 We also conduct regular trainings for our employees.
9.2. Regular trainings will help foster understanding, empathy and cultural competence of our professionals to approach sensitive topics with due care and accuracy.
9.3. Regular trainings will cover topics such as unconscious bias, stereotyping and respectful reporting practices.

10. Privacy and Security

10.1. We should pay attention to the expectations of privacy and security of vulnerable persons.
10.2. It may be appropriate to have measures in place to protect information concerning vulnerable persons, their careers, friends or relations which could reveal the vulnerable person’s identity or location.
10.3. The (alleged) victims of some offences, including rape and most offences with a sexual element, have a lifelong right not to be identified as victims of those offences. This right exists whether or not the alleged crime has been reported to police.
10.4. The (alleged) victims of female genital mutilation, forced marriage and/or human trafficking are also afforded automatic anonymity by law in relation to those alleged offences.
10.5. Individuals can waive their anonymity, but they must do this in writing.
10.6. There is also a lifelong right to anonymity for teachers where they are accused of a criminal offence against a registered pupil at their school.
10.7. The anonymity in relation to such an allegation will end or can be lifted in a number of circumstances, including if the teacher is charged with the criminal offence. The teacher may also waive their anonymity in writing.
10.8. The collection of personal information must be handled in accordance with data protection legislation and GDPR.

11. Regular Assessment and Control

11.1. We will regularly assess the effectiveness of this Policy practices, guidelines, practices and measures applicable to the vulnerable groups.
11.2. Regular assessment may involve, for example, conducting internal controls, seeking external feedback and other similar actions.
11.3. We will continuously improve our measures and identify areas that require further attention in accordance with applicable laws.