1. What is the purpose of this document?
West Hull Community Radio Ltd (‘WHCR’) is committed to protecting the privacy and security of your personal information.
This privacy policy (‘Privacy Policy‘) describes how we collect and use personal information about you during and after your volunteering relationship with us in accordance with laws that regulate processing of your personal information (together, ‘Data Protection Laws‘). This Privacy Policy applies to all prospective, current, and former volunteers.
For the purposes of Data Protection Laws such as the GDPR, WHCR acts as a “data controller” and means that we are responsible for deciding how we use personal information about you.
2. Data protection principles
We comply with Data Protection Law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected for specified, explicit and legitimate purposes and not processed in a manner that is incompatible with those purposes.
- Adequate, relevant, and limited to the purposes we have told you about.
- Accurate and kept up-to-date.
- Kept only for as long as necessary for the purposes we have told you about.
- Processed in a manner that ensures appropriate security of the personal information.
3. The type of information we hold about you
Personal information (which may also be called personal data), means any information about you from which you can be identified, whether directly or indirectly. We may collect, store, and use some or all of the following categories of personal information about you:
| Category | Data collected | What we use it for |
| All volunteers | Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses | To contact you about your volunteering and involvement with WHCR. |
| All volunteers | Date of birth | To ask for consent if the volunteer is under 18 (in circumstances where we are able to accept applications from under 18s). |
| All volunteers | Emergency contact information. | To contact someone in case of emergency. |
| Website users | IP addresses, cookies, and other online identifiers. | For targeted online advertising and visitor measurement. |
4. How is your personal information collected?
We collect personal information about you directly through the application and recruitment process. We may sometimes collect information from third parties, including former employers for certain roles.
We may collect additional personal information throughout the period of you volunteering for the WHCR. For example, you may be captured on our CCTV systems, and volunteers may consent to have their photo taken and used in a marketing campaign.
Please ensure that any personal information you supply to us which relates to third party individuals must be provided to us with their knowledge you are giving it to us and of our proposed use of their personal information.
5. The lawful grounds on which we use information about you
We may also use and share your personal information in the following situations, which are likely to be rare:
- Contract – Where we need to perform any contract with you, or in order to take any pre-contract steps made at your request;
- By Law – Where it is necessary for us to comply with a legal obligation;
- Consent – Where you have freely provided consent for particular purposes;
- Legitimate Interest – Where it is necessary for our legitimate interests (or those of a third party). In broad terms our legitimate interest is fulfilling the purpose of WHCR, which may involve taking steps to ensure and monitor compliance with our legal obligations and internal standards and procedures, assessing suitability of volunteers for potential roles and keeping records of volunteer activities and performance.
We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests), such as in a medical emergency.
- Where it is needed in the public interest.
6. How we use particularly sensitive personal information
We may process ‘special category’ or ‘sensitive’ personal information, such as information regarding your racial or ethnic origin, political, philosophical and religious beliefs, trade union membership, mental or physical health, sex life/gender orientation or your genetic/biometric data. We will only do this with your explicit consent; in compliance with a legal obligation or, to protect your vital interests (or someone else’s interests) when you are not capable of giving your consent; or, where you have already publicised such information; or, where we need to use such sensitive data in connection with a legal claim that we have or may be subject to.
In particular, with your consent, where it is needed to assess your volunteering capacity on health grounds, subject to appropriate confidentiality safeguards, we will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments.
7. If you fail to provide personal information
If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our customers, workers, and volunteers) and we may not be able to process your application to volunteer with us, offer you certain volunteering opportunities or retain you as a volunteer.
8. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is related to the original purpose.
9. Data sharing
We may disclose your information in the following circumstances:
- To other WHCR group entities, suppliers, or service providers where it’s necessary to do so to facilitate your volunteering. By way of example, we may disclose your email address, online ID, or phone number to an online social platform such as Facebook Messenger or WhatsApp used for the purposes of communication regarding WHCR activities.
- Where we are legally obliged we will share the information of volunteers.
- For the purpose of providing a reference.
If we share your data, we require third parties to respect the security of your data, use it only for lawful purposes and handle it in accordance with Data Protection Laws.
We do not sell or rent your information to third parties for marketing purposes.
10. Data security
We have put in place appropriate technical and organisational measures to protect the security of your information.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those volunteers, employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Further detail as to how we deal with data breaches can be found in our Data Protection Policy.
11. Transferring information outside the EU
We may decide to use the data hosting or data processing services of a supplier or service provider who is based outside the UK and European Economic Area (EEA), which means that your personal information may be transferred to countries that are not considered to have the same standards for legal protection of personal information as the UK. We will always take steps to choose entities who respect data security and have, or will put, in place suitable legal safeguards to protect your personal information.
12. Data retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Personal information that we no longer need will be securely destroyed.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
13. Your rights
Under the GDPR, you have the following legal rights in relation to our collection and processing of your personal information:
- Right to be informed – you have the right to be told how your personal information will be used. This Policy and other policies and statements used on the WHCR website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
- Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information (and other related information). Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exceptions that apply. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded, unreasonable or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
- Right of erasure – at your request we will delete your personal information from our records as far as we don’t have a valid reason for holding on to it (e.g. to comply with a legal obligation).
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Please keep us informed if your personal information changes during your volunteering relationship with us.
- Right to restrict processing – you have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or whether our use is legitimate or not.
- Right to object – you have the right to object to processing where we are: (i) processing your personal information on the basis of the legitimate interests ground and we have no compelling reason we can demonstrate to continue with that processing; (ii) using your personal information for direct marketing, or; (iii) using your personal information for statistical purposes/
If you wish to exercise any of these rights, please contact dataprotection@westhullfm.org.uk For more information about your rights or if you are not happy with our response to a request, you can contact the Information Commissioner’s Office (ICO) – for more details, see www.ico.co.uk
14. Data protection officer
We have appointed a Data Protection Officer (DPO) to oversee data protection standards at WHCR. If you have any questions about this privacy notice or how we handle your personal information, please contact our DPO at dataprotection@westhullfm.org.uk
15. Changes to this privacy policy
We reserve the right to update this privacy policy at any time, and we will provide you with access to a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions about this privacy policy, please contact dataprotection@westhullfm.org.uk
Last updated 02 03 2023