Sky Privacy Centre

DATED 2023-06-20 · VERSION 20230701_rev01 · COMPARED WITH 20230301_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20230301_rev01 to 20230701_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 - to tailor our Sky VIP Programme to you and provide the applicable rewards.
 _Where we have a legitimate interest_
 - for market research
 - to build a profile about you and your time as a Sky or Sky Protect customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
+- to understand your financial situation and ability to afford our products and services so we can ensure we provide you with the right type of customer service, appropriate direct marketing (where applicable) and consider any affordability issues you might be experiencing.
 - for the following activities explained further in the section "More information about certain activities" below:
     - AdSmart and PromoSmart
     - Online and digital advertising
     - AdVance
 - to provide tailored and personalised recommendations which would require an additional purchase or transaction by you.
 - to monitor, record, store and use customer service communications we have with you. **1.** (see **Additional info** tab)
 - records of your customer service interactions with us, such as call recordings and records of your conversations and correspondence with us.
 - images recorded by cameras at Sky Retail Stores or fitted to Sky's engineer vans.
 **Customer Service Interaction Data & CCTV Data**
+From you, including when you contact us and your image from CCTV footage recorded when you visit a Sky Retail Store or other Sky locations.
+From you, including when you:
+from you when in the vicinity of one of our Sky vans.
+- contact us and your image from CCTV footage recorded when you visit a Sky Retail Store or other Sky locations.
+- are in the vicinity of one of our Sky vans.
 **Customer Service Interaction Data & CCTV Data**
 _Where we have a legitimate interest_
 - for market research.
 - to monitor, record, store and use customer service communications we have with you. **1.** (see **Additional info** tab)
+- to help prevent and detect crime.
+- to help prevent and detect crime, fraud and protect or enforce our or any third party's rights.
 - to support public and road safety.
 - to protect the safety of Sky employees.
 _Where we have a legal obligation_
 **Special category data**
 This includes:
 - health data or other special category data
+- biometric information (such as facial scans)
+- biometric information (such as facial scans and voice recognition)
 **Special category data**
 From you, when you provide it to us or our business partners.
 **Special category data**
+_Where we have a legitimate interest_:
+- to help prevent and detect crime, fraud and protect or enforce our or any third party's rights.
 _With your explicit consent:_
 - to provide assistance and support on your account.
 - to verify your identity as part of consumer credit agreement authorisations, such as by matching your facial scans to your ID documents.
 ### Information we collect automatically
 **1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems.
 **2.** For example, this may include content available on Sky Store or content you'd need a package upgrade or app subscription to watch.
 **Device Information & Telemetry Data**
+This includes:
+This includes technical information, including diagnostic (such as errors and system statuses), traffic and location data.
+- technical information, including diagnostic (such as errors and system statuses), traffic and location data.
 **Device Information & Telemetry Data**
 From the devices you use to receive Sky content, products and services.
 **Device Information & Telemetry Data**
 _Where we have a legitimate interest_
 - to improve and develop our voice-related services (including our voice algorithms, the recording of the voice searches made and the success of the "Hello Sky" command when you use Sky Glass).
 - to understand how people are using our voice-related services and the common themes and trends based on that usage.
+**Video Data (as well as any corresponding audio data)**
+Video and audio data from your Sky Live device
+**Video Data**
+If you use Sky Live and the Sky based apps on the Sky Live device.
+**Video Data**
+_To provide your service / perform our contract with you_:
+- To allow you to use the relevant Sky Live app you have requested.
+This data will only ever be collected and processed by Sky if you agree to this. If you use third party apps on Sky Live that process video and/or audio data the third party is responsible for this and you should refer to their privacy information for details of what data they are capturing and how they are using it. Please note, more detail on Sky Live can be found under the Sky Live tab in the section **More information about certain activities** below.
 ### Information from third parties
 **Third Party Data**
 Information we obtain from third parties, including:
 - address verification data
 - contact information
 - modelled household
 - profile information (such as affluence and household composition)
 - personal data that is publicly available.
+- personal data relating to your financial circumstances and payment performance (such as county court judgments and payment history against other credit agreements).
 **Third Party Data**
 From other organisations, such as address verification services, data brokers, property and lifestyle agencies, and credit reference agencies.
 These organisations include:
 - Royal Mail
 - Experian
+- Equifax
 - Dunnhumby
 - CACI
 - TwentyCi
 - TransUnion
 - Mastercard
 - Ordnance Survey
+- Emma's Diary (where you have consented to this)
 - Nectar360
 - Frasers Group
 If you want to manage how these organisations use your personal data and share it with companies like Sky, you should get in touch with them directly. In the case of Experian, you can access their Consumer Information Portal [here](https://www.experian.co.uk/privacy/consumer-information-portal/opt-out-options/).
 **Third Party Data**
 - to send you direct marketing where we're not relying on your consent to do so. For example, if you're a prospective customer.
 - to verify the personal data we hold about you is accurate (for example, your address).
 - to build a profile about you and your time as a Sky or Sky Protect customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
+- For the following activities explained further in the section "More information about certain activities" below:
+- to understand your financial situation and ability to afford our products and services so we can ensure we provide you with the right type of customer service, appropriate direct marketing (where applicable) and consider any affordability issues you might be experiencing.
+- For the following activities explained further in the section **More information about certain activities** below:
     - AdSmart
     - PromoSmart
     - Online and Digital advertising
     - AdVance
 **Third Party Data**
 **1.** The automated decision is influenced by your credit history and, depending on the outcome of this automated decision-making process, we may not enter into the loan agreement with you. If you would like us to review decisions taken about you as part of this process, please contact us as set out below.
+## More information about certain activities
+## **More information about certain activities**
+_Turning Sky Live on and off_
+The camera and microphone on Sky Live can be turned off by pressing the button on top of the Sky Live device. If you do this, no video or audio is captured by Sky Live and the camera and microphone are inoperable.
+In addition to this, depending on the service or app you use, you will be able to control the camera and microphone using the controls within the relevant service or app.
+_Status of Sky Live_
+When the Sky Live camera and microphone are active, you can tell when video and audio are being captured because the LED light on the front of the device will be white. This will only be happening when you are interacting with Sky Live (e.g. playing a game or making a video call) and if the LED light is not on, the Sky Live camera and microphone are not capturing any video or audio.
+_Audio and video data leaving Sky Live_
+The video and audio data captured by the Sky Live device will only leave the device in real time to operate the relevant service you are using at the time (e.g. making a video call). That data will only be stored or accessed by us off the device if clearly explained to you at the time and you agree to this.
+An example of when video might be stored off the device is when you choose to share your photo or video using the Video booth app in which case the photo or video will be stored in the cloud for a short period for you to access it via another device.
+_Other data we collect_
+Other than the audio and video data leaving Sky Live and explained above, Telemetry data (as explained above) is collected automatically to enable diagnostics and trouble-shooting.
+Subject to you choosing to opt out (details of which can be found under 'Your choices'), product analytics data (as explained above) is collected automatically to help us improve our content, products, services and customer experiences.
+Sky Live captures additional product analytics data due to the unique capabilities of the camera. This is movement data (in the form of numerical co-ordinates, not actual video) when you move or make gestures or poses in front of the camera. This data is aggregated and anonymised after it is collected and is used to help us improve the performance of the Sky Live camera.
+_Can Sky Live identify me?_
+Sky Live does not identify you or anyone else in front of the camera or via the microphone. If we introduce functionality in the future that enables this we will tell you using an appropriate method.
 AdSmart is Sky's tailored TV advertising solution and is used on Sky's and Virgin's TV platforms. AdSmart allows us to show adverts within your TV services (including on Sky+, Sky Q, Sky Glass, Sky Stream and Sky Go) to the people most likely to be interested in the products and services being promoted.
 With AdSmart, Sky can show different adverts to different households (in groups of 5,000 or more across Sky and Virgin households) watching the same programme or service. To do this we create a profile about a household comprising factors like interests, age and location using the information you have provided to us, information about your use of our products and services, and information we have acquired from other organisations, and which we may combine with information received from brands wishing to target their advertising to a particular audience. We use this profile information to define groups of audiences to whom we send adverts.
 As part of showing these adverts, we also carry out quality and frequency checks, such as whether adverts were displayed correctly and how often particular adverts have been shown.
 Sometimes we share information with suppliers and partners to provide our services and for the other purposes described above. We only share information with these companies where necessary or where we have a legitimate reason to do so and only where we are satisfied that they have appropriate security measures and controls in place to protect your personal data. When these companies act on our behalf, they will only process your personal data in accordance with our instructions and for the reasons set out in this notice.
 Some of our suppliers and partners process personal data outside of the UK or EEA (as applicable). We ensure that these companies have measures in place to comply with their obligations under UK or Irish data protection law, and we will only transfer personal data to these companies where we can rely on an approved data transfer mechanism, such as a [UK Government](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/) or [EU Commission](https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) adequacy decision or by including the appropriate [Standard Contractual Clauses](https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) in our contracts with these companies. Sky typically relies on the Standard Contractual Clauses available here, together with the ICO's [data transfer addendum](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-data-transfer-agreement-and-guidance/) (where appropriate).
 You can see more information below about how we share your information with third parties.
+Credit reference agencies ([Experian](https://www.experian.co.uk/legal/crain/), [Equifax](https://www.equifax.co.uk/crain) and [CRIF](https://www.crif.com/privacy-policy/)) fraud and crime prevention agencies ([CIFAS](https://www.cifas.org.uk/fpn))
+Credit reference agencies ([Experian](https://www.experian.co.uk/legal/crain/), [Equifax](https://www.equifax.co.uk/crain) and [CRIF](https://www.crif.com/privacy-policy/)), fraud and crime prevention agencies ([CIFAS](https://www.cifas.org.uk/fpn)) and other communications providers and banks with whom we have a shared interest in combatting fraud and piracy.
+We share your personal data, such as your contact details, financial data and other information described below, with credit reference and fraud prevention agencies:
+We share your personal data, such as your contact details, financial data and other information described below, with credit reference and fraud prevention agencies and other relevant parties :
 - for use in automated credit decisions;
 - to help assess whether you are likely to be able to afford the products and services you wish to take from us to help protect your interests and ours;
 - for the prevention and detection of crimes such as fraud, piracy and money laundering; and
 - for identity check and data verification purposes.
 _Fraud prevention_
 If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.
 Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place. Where appropriate, we may also share your data with other organisations to assist with the prevention and detection of fraud.
+_Anti-piracy_
 Where we reasonably suspect that you are pirating Sky or third-party content, we may share information with other organisations with a similar legitimate interest in preventing, detecting and prosecuting piracy.
 Data brokers
 Where a brand or advertiser wishes to target a specific advertising campaign to particular Sky households (for example, using AdSmart), we share your contact details with a data broker (such as Experian) The data broker will match that data against data provided by the brand or advertiser to identify Sky households for that campaign without Sky and the brand or advertiser accessing each other's customer data.
 Promotional and reward fulfilment partners
 When you take advantage of promotions, competitions and rewards when you purchase our products and services or within the Sky VIP scheme, we may share your contact details with third parties to fulfil these.
 Third party app and content providers
+We share certain personal data with third-party app and content providers (such as Netflix and Disney+) when you choose to pay and/or access those third-party services via Sky. We do this to enable and/or verify your ability to access the relevant third-party service via Sky and with certain third-party providers this personal data is held on a joint controller basis (meaning we use and share the data for the joint purpose of ensuring your access to the service).
+We share certain personal data with third-party app and content providers (such as Netflix and Disney+) when you choose to pay and/or access those third-party services via Sky (including on Sky Live). We do this to enable and/or verify your ability to access the relevant third-party service via Sky and with certain third-party providers this personal data is held on a joint controller basis (meaning we use and share the data for the joint purpose of ensuring your access to the service).
 Third-party app and content providers may also share personal data with us about your use of their apps and services. This is provided to us so we can provide functionality to you within Sky's services such as resume options for programmes you have started watching elsewhere and personalised recommendations. You should refer to the third-party's own privacy notice for more details about what information they share and how to manage your preferences.
 Other nominated individuals
 When Sky receives a request for the ownership of a vulnerable customer's account to be transferred to a nominated individual, the existing account holder's personal data may be shared with the new account holder. The ownership of the account would only be transferred once Sky has received signed acceptance and authorisation of the transfer from both parties.
+Courts, enforcement agents, government bodies, regulators
+Courts, enforcement agencies, government bodies, regulators
+We share personal data with the courts, enforcement agencies (e.g. the police) and with regulatory authorities (e.g., Ofcom in the UK) where this is required, in order for us to comply with our legal and regulatory obligations.
+We share personal data with the courts, law enforcement agencies (e.g. the police) and with regulatory authorities (e.g., Ofcom in the UK) where this is required, in order for us to comply with our legal and regulatory obligations.
 We may also share your contact details and account information with government departments to determine eligibility for certain products, services & offers (such as the Sky Broadband Social Tariff).
 Business Successors
 In the event the structure of our business changes so that another company in the Sky Group provides our products and services to you, we will pass your personal information to that company. This includes, for example, a merger between us and another company, where another company acquires us or some or all of our assets, where we acquire another company or where our holding company restructures our corporate group.
 If you have any queries or comments about this privacy and cookies notice, please write to Customer Relations, Sky Subscriber Services Ltd, PO Box 43, Livingston, West Lothian, EH54 7DD, UK or to Customer Relations, Sky Subscriber Services Limited, One Burlington Plaza, Burlington Plaza, Dublin 4, ROI or contact Sky's Data Protection Officer via [dp.department@sky.uk.](mailto:dp.department@sky.uk.)
 ## Changes to this notice
 We will occasionally update our privacy and cookies notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. This may include phone, SMS, e-mail, post or interactive social media. We encourage you to periodically review our notice to be informed of how we use your information.
+**This privacy and cookies notice was last updated 01 February 2023.**
+**This privacy and cookies notice was last updated 20 June 2023.**