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Dublin Public Radio Association CLG Website Privacy Policy

Introduction

Dublin City FM is committed to protecting and respecting your privacy. We adhere to the Privacy Policy (the “Policy”) together with any disclaimers, sets out the basis on which any personal data we collect from you, or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Policy relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity.

1. Information we may collect from you

We collect personal data from you which you volunteer when you provide such personal data to us, or via our services with which you interact. We may also be given other personal data relating to you by other persons, or we may obtain such other personal data about you as may be provided to us in the course of our legitimate business activities.

We may collect and process Data. Including the following in the course of providing services to you, which could contain your personal data:

your full name; your address; your various email addresses; your various phone numbers including mobile phone numbers; your nationality; financial information about you, including your bank account details, credit card details, or other payment details; details of contracts you have entered with third parties for us to provide services to you; details of your relationship to other parties; details of your membership of professional or other organisations; your date of birth; details of your children and other relations; medical details, including details of allergies; details of your car registration number; details of your driving licence; details of your passport and all other Data which you ask us to process on your behalf, or which is necessary for us to process in order for us to fulfil our role as providing community and special interest radio broadcasting.

2. Security and where we store your personal data

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available. The transmission of information via the internet is not completely secure and may involve the transfer of data to countries outside of the European Economic Area (EEA). This occurs typically through use of cloud solutions for web hosting, email hosting or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your personal data for their own purposes. Non-EEA countries may not provide an adequate level of protection in relation to processing your personal data. By submitting your data, you agree to this transfer, storing and processing.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us. Any transmission of data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek and to prevent unauthorised access.

3. Uses made of your personal data

  • In our legitimate interest of advertising our services. Provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes (our list of services below),
  • in our legitimate interest of advertising our services, provide details of any loyalty scheme or promotion
  • Carry out our obligations arising from any contracts entered into between you and us
  • Comply with legislation and/ or
  • Notify you about changes to our services

4. List of services

We may use your data to send you information relating to our services, events, competition and products which may be of interest to you. If you do not want us to use your data in this way please notify us to that effect.

We keep your Data for varying periods according to our Retention Schedule.

5. Disclosure of your information

We may disclose your Data to third parties in order to comply with any legal obligation, or to protect our rights, property, or safety of staff or customers.

6. Links to other sites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit data to those websites.

7. Your rights

As an individual, under EU law you have certain rights to apply to us to provide information or make amendments to how we process data relating to you. These rights apply in certain circumstances and are set out below: –

  • The right to access data relating to you (access right).
  • The right to rectify/correct data relating to you (right to rectification)
  • The right to restrict the processing of data relating to you (right of restriction)
  • The right to erase/delete data relating to you (right of erasure)
  • The right to ‘port’ certain data relating to you from one organisation to another (right to data portability)

8. Changes to this policy

We reserve the right to change this Policy from time to time at our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this Policy as modified.

8. Contact us

Questions, comments, requests and complaints regarding this Policy and the information we hold are welcome and should be addressed to us at admin@dublincityfm.ie . All requests will be dealt with promptly and efficiently.

Dublin City FM is committed to protecting and respecting your privacy. We adhere to the Privacy Policy (the “Policy”) together with any disclaimers, sets out the basis on which any personal data we collect from you, or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Policy relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity.

9. Security and where we store your personal data

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available. The transmission of information via the internet is not completely secure and may involve the transfer of data to countries outside of the European Economic Area (EEA). This occurs typically through use of cloud solutions for web hosting, email hosting or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your personal data for their own purposes. Non EEA countries may not provide an adequate level of protection in relation to processing your personal data. By submitting your data, you agree to this transfer, storing and processing.

Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us. Any transmission of data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek and to prevent unauthorised access.

10. Uses made of your personal data

·        

In our legitimate interest of advertising our services. Provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes (our list of services below),

  • in our legitimate interest of advertising our services, provide details of any loyalty scheme or promotion
  • Carry out our obligations arising from any contracts entered into between you and us

 

  • Comply with legislation and/ or
  • Notify you about changes to our services
 
 

Introduction

The purpose of this document is to provide a concise policy statement regarding the Data Protection obligations of Dublin Public Radio Association CLG, trading as Dublin City FM. This includes obligations in dealing with personal data, in order to ensure that the organisation complies with the requirements of the relevant Irish legislation, namely the Regulation (EU) 2016/679, the European Union’s new General Data Protection Regulation (‘GDPR’), Irish Data Protection Act (1988), and the Irish Data Protection (Amendment) Act (2003).

Rationale

Dublin Public Radio Association CLG must comply with the Data Protection principles set out in the relevant legislation. This Policy applies to all Personal Data collected, processed and stored by Dublin Public Radio Association CLG in relation to its members, staff, service providers and clients in the course of its activities. Dublin Public Radio Association CLG makes no distinction between the rights of Data Subjects who are employees and those who are not. All are treated equally under this Policy.

Scope

The policy covers both personal and sensitive personal data held in relation to data subjects by Dublin Public Radio Association CLG. The policy applies equally to personal data held in manual and automated form.

All Personal and Sensitive Personal Data will be treated with equal care by Dublin Public Radio Association CLG. Both categories will be equally referred-to as Personal Data in this policy, unless specifically stated otherwise.

This policy should be read in conjunction with the associated Subject Access Request procedure, the Data Retention and Destruction Policy, the Data Retention Periods List and the Data Loss Notification procedure.

Dublin Public Radio Association CLG as a Data Controller

In the course of its daily organisational activities, Dublin Public Radio Association CLG acquires, processes and stores personal data in relation to:

•     Employees of Dublin Public Radio Association CLG

•     Members of Dublin Public Radio Association CLG

•     Customers of Dublin Public Radio Association CLG

•     Third party service providers engaged by Dublin Public Radio Association CLG

In accordance with the Irish Data Protection legislation, this data must be acquired and managed fairly. Not all staff members will be expected to be experts in Data Protection legislation. However, Dublin Public Radio Association CLG is committed to ensuring that its staff have sufficient awareness of the legislation in order to be able to anticipate and identify a Data Protection issue, should one arise. In such circumstances, staff must ensure that the Chief Executive Officer is informed, and in order that appropriate corrective action is taken.

Due to the nature of the services provided by Dublin Public Radio Association CLG, there is regular and active exchange of personal data between Dublin Public Radio Association CLG and its Data Subjects. In addition, Dublin Public Radio Association CLG exchanges personal data with Data Processors on the Data Subjects’ behalf.

This is consistent with Dublin Public Radio Association CLG’s obligations under the terms of its contract with its Data Processors.

This policy provides the guidelines for this exchange of information, as well as the procedure to follow in the event that a Dublin Public Radio Association CLG staff member is unsure whether such data can be disclosed.

In general terms, the staff member should consult with the Chief Executive Officer to seek clarification.

 

Subject Access Requests

Any formal, written request by a Data Subject for a copy of their personal data (a Subject Access Request) will be referred, as soon as possible, to the Chief Executive Officer, and will be processed as soon as possible.

It is intended that by complying with these guidelines, Dublin Public Radio Association CLG will adhere to best practice regarding the applicable Data Protection legislation.

Third-Party processors

In the course of its role as Data Controller, Dublin Public Radio Association CLG engages a number of Data Processors to process Personal Data on its behalf. In each case, a formal, written contract is in place with the Processor, outlining their obligations in relation to the Personal Data, the specific purpose or purposes for which they are engaged, and the understanding that they will process the data in compliance with the Irish Data Protection legislation.

 

These Data Processors include:

        

Web-based Mailing-List Clients

        

Accounting Software Providers

        

CCTV Service Providers

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Data Protection Principles

The following key principles are enshrined in the Irish legislation and are fundamental to the Dublin Public Radio Association CLG’s Data Protection policy.

In its capacity as Data Controller, Dublin Public Radio Association CLG ensures that all data shall:

1.      

... be obtained and processed fairly and lawfully.

For data to be obtained fairly, the data subject will, at the time the data are being collected, be made aware of:

·        

The identity of the Data Controller (Dublin Public Radio Association CLG)

·        

The purpose(s) for which the data is being collected

·        

The person(s) to whom the data may be disclosed by the Data Controller

·        

Any other information that is necessary so that the processing may be fair.

Dublin Public Radio Association CLG will meet this obligation in the following way.

·        

Where possible, the informed consent of the Data Subject will be sought before their data is processed;

·        

Where it is not possible to seek consent, Dublin Public Radio Association CLG will ensure that collection of the data is justified under one of the other lawful processing conditions – legal obligation, contractual necessity, etc.;

·        

Where Dublin Public Radio Association CLG intends to record activity on CCTV or video, a Fair Processing Notice will be posted in full view;

·        

Processing of the personal data will be carried out only as part of Dublin Public Radio Association CLG’s lawful activities, and Dublin Public Radio Association CLG will safeguard the rights and freedoms of the Data Subject;

·        

The Data Subject’s data will not be disclosed to a third party other than to a party contracted to Dublin Public Radio Association CLG and operating on its behalf.

2.      

.... be obtained only for one or more specified, legitimate purposes.

Dublin Public Radio Association CLG will obtain data for purposes which are specific, lawful and clearly stated. A Data Subject will have the right to question the purpose(s) for which Dublin Public Radio Association CLG holds their data, and Dublin Public Radio Association CLG will be able to clearly state that purpose or purposes.

3.      

..... not be further processed in a manner incompatible with the specified purpose(s).

Any use of the data by Dublin Public Radio Association CLG will be compatible with the purposes for which the data was acquired.

4.      

.... be kept safe and secure.

Dublin Public Radio Association CLG will employ high standards of security in order to protect the personal data under its care. Appropriate security measures will be taken to protect against unauthorised access to, or alteration, destruction or disclosure of any personal data held by Dublin Public Radio Association CLG in its capacity as Data Controller.

Access to and management of staff and customer records is limited to those staff members who have appropriate authorisation and password access.

5.      

... be kept accurate, complete and up-to-date where necessary.

Dublin Public Radio Association CLG will:

·        

ensure that administrative and IT validation processes are in place to conduct regular assessments of data accuracy;

·        

conduct periodic reviews and audits to ensure that relevant data is kept accurate and up-to-date. Dublin Public Radio Association CLG conducts a review of sample data every six months to ensure accuracy; Staff contact details and details on next-of-kin are reviewed and updated every two years.

·        

conduct regular assessments in order to establish the need to keep certain Personal Data.

 

6.      

... be adequate, relevant and not excessive in relation to the purpose(s) for which the data were collected and processed.

Dublin Public Radio Association CLG will ensure that the data it processes in relation to Data Subjects are relevant to the purposes for which those data are collected. Data which are not relevant to such processing will not be acquired or maintained.

7.      

... not be kept for longer than is necessary to satisfy the specified purpose(s).

Dublin Public Radio Association CLG has identified an extensive matrix of data categories, with reference to the appropriate data retention period for each category. The matrix applies to data in both a manual and automated format.

Once the respective retention period has elapsed, Dublin Public Radio Association CLG undertakes to destroy, erase or otherwise put this data beyond use.

 

Retention & Destruction Schedule

Document Description

Retention Period

Destruction Method

Contract of Employment

7 years

Shredding

Summary of Performance

5 years

Shredding

Annual Leave Records

2 years

Shredding

Job Applications

1 year

Deletion

CV’s

1 year

Deletion

Bank details

6 years after employment ended

Deletion

 

8.      

... be managed and stored in such a manner that, in the event a Data Subject submits a valid Subject Access Request seeking a copy of their Personal Data, this data can be readily retrieved and provided to them.

Dublin Public Radio Association CLG has implemented a Subject Access Request procedure by which to manage such requests in an efficient and timely manner, within the timelines stipulated in the legislation.

As part of the day-to-day operation of the organisation, Dublin Public Radio Association CLG’s staff engage in active and regular exchanges of information with Data Subjects. Where a formal request is submitted by a Data Subject in relation to the data held by Dublin Public Radio Association CLG, such a request gives rise to access rights in favour of the Data Subject.

There are specific time-lines within which Dublin Public Radio Association CLG must respond to the Data Subject, depending on the nature and extent of the request. These are outlined in the attached Subject Access Request process document.

Dublin Public Radio Association CLG’s staff will ensure that, where necessary, such requests are forwarded to the Chief Executive Officer in a timely manner, and they are processed as quickly and efficiently as possible, but within not more than 40 days from receipt of the request.

Implementation

As a Data Controller, Dublin Public Radio Association CLG ensures that any entity which processes Personal Data on its behalf (a Data Processor) does so in a manner compliant with the Data Protection legislation.

Failure of a Data Processor to manage Dublin Public Radio Association CLG’s data in a compliant manner will be viewed as a breach of contract and will be pursued through the courts.

Failure of Dublin Public Radio Association CLG’s staff to process Personal Data in compliance with this policy may result in disciplinary proceedings.



Definitions

 

For the avoidance of doubt, and for consistency in terminology, the following definitions will apply within this Policy.

Data

This includes both automated and manual data.

Automated data means data held on computer or stored with the intention that it is processed on computer.

Manual data means data that is processed as part of a relevant filing system, or which is stored with the intention that it forms part of a relevant filing system.

Personal Data

Information which relates to a living individual, who can be identified either directly from that data, or indirectly in conjunction with other data which is likely to come into the legitimate possession of the Data Controller. (If in doubt, Dublin Public Radio Association CLG refers to the definition issued by the Article 29 Working Party and updated from time to time.)

Sensitive Personal Data

A particular category of Personal data, relating to: Racial or Ethnic Origin, Political Opinions, Religious, Ideological or Philosophical beliefs, Trade Union membership, Information relating to mental or physical health, information in relation to one’s Sexual Orientation, information in relation to commission of a crime and information relating to conviction for a criminal offence.

Data Controller

A person or entity who, either alone or with others, controls the content and use of Personal Data by determining the purposes and means by which that Personal Data is processed.

Data Subject

A living individual who is the subject of the Personal Data, i.e. to whom the data relates either directly or indirectly.

Data Processor

A person or entity who processes Personal Data on behalf of a Data Controller on the basis of a formal, written contract, but who is not an employee of the Data Controller, processing such Data in the course of his/her employment.

Chief Executive Officer

A person appointed by Dublin Public Radio Association CLG to monitor compliance with the appropriate Data Protection legislation, to deal with Subject Access Requests, and to respond to Data Protection queries from staff members and service recipients

Relevant Filing System

Any set of information in relation to living individuals which is not processed by means of equipment operating automatically (computers), and that is structured, either by reference to individuals, or by reference to criteria relating to individuals, in such a manner that specific information relating to an individual is readily retrievable.