This is the privacy policy of Midlands 103 and its legal successors.

This policy explains our approach to digital information collection, storage and use in connection with all our digital content. We are committed to protecting your privacy. Midlands 103 will ensure that it keeps all personal data you provide to us in accordance with our obligations under the Data Protection Acts 1988 to 2018 and General Data Protection Regulation (GDPR) (EU 2016/679).

We may update this policy from time to time, so please review it regularly. If you have any questions about this policy or the information which we hold, please contact us at: compliance@midlands103.com or write to us at Midland 103, Tindle House, Axis Business Park, Tullamore, Co. Offaly.

This policy applies to Midlands 103’s digital services only and not to other websites, APPs, social media sites linked to or from Midlands 103 digital services.

  1. The information we collect

Midlands 103 will never collect any unnecessary personal data from you and will not process your information in any way, other than as specified in this notice.

The personal data that Midlands 103 collects varies depending on the online activity you have consented for,  below lists the information Midlands 103 may collect when you, take a survey, enter a competition or if you make  direct contact with the station:

  • Name
  • Email
  • Contact Phone Number (where required for a competition entry, survey or where you contact the station via SMS or Whatsapp)
  • Home Address (where required for a competition entry, survey or to reply to direct contact)
  • Confirmation that you’re over 18 (where required for a competition entry or survey)
  • IP Address (To allow us geo-fence audio streams, this data is not used beyond this purpose)
  • Information contained in a curriculum vitae or work experience request (where sent directly to the station)

 

Midlands 103 collects your personal data when you;

  • enter a competition
  • participate in an online survey
  • contact the station directly

Lawful Basis for Processing

We process your personal data based on the following lawful basis.

  • Direct Marketing emails are based on either Consent or Legitimate interest. Where we use legitimate interest, we will have completed a legitimate interest assessment where we conduct a balance test between our legitimate interests and your privacy rights.

Automatic Data Collection

Midlands 103 uses cookies and captures IP addresses as part of the essential operation of our sites and media streams. This data is used to geo-fence our content and media streams so we can adhere to our licencing agreement regarding the broadcasting of licenced material.  We also use cookies to maintain preferences you have selected, manage load balancing and DDOS mitigation these cookies are used only for this purpose and do not track you beyond our digital assets.

Marketing/Advertising Cookies

With your consent, we use marketing cookies to better target advertising and make it more relevant to you and your interests. We also use these cookies to frequency cap the number of times you will see an individual ad.  Advertising cookies collect information regarding your use of both our website and other websites you may visit. This information allows advertising networks to target their audience.

Where consent is not provided you will still receive ads but they will not be targeted.

You can find more about Advertising cookies here https://policies.google.com/technologies/partner-sites

You can also have control over what third party cookies are used on your device by using tools like

http://www.youronlinechoices.com/ie/your-ad-choices

Or

http://optout.networkadvertising.org/

Site Analytics

Midlands 103 uses Google Analytics to monitor the usage of its digital assets, which is an essential part of the running of any website.  It provides the information we require to manage our server capacity and the popularity of our content. This information is anonymous. Please see : https://www.google.com/analytics/learn/privacy.html for more details .

Social Media

You should be aware that you may be making available personally identifiable information about yourself when you submit material to our social media pages or to other interactive elements of our digital services.

  1. How we use the personal data we collect:

 

Midlands 103 takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

We do not employ automated decision making methods to any of your personal data under our control.

The purposes and reasons for processing your personal data are detailed below: –

  • We collect your data to administer a service which you have subscribed to and given consent for your personal data to be processed, including inter alia Station Newsletter and/or promotional material.
  • We collect your data as part of a competition entry to allow us contact you regarding the competition. This data is processed based on consent.
  • We collect personal data to administer your personalised preferences such as news content or preferred music and services.
  • We collect data you provide to us when you contact us directly to respond to your specific inquiry or to administer the relevant site activity where we have a legitimate interest.
  • We automatically capture your IP addresses to geo-fence our content.
  • Comply with legal regulatory requirements and legitimate business purposes.

 

  1. Your Rights

You have the right to access any personal information that Midlands 103 processes about you and to request information about: –

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source

 

If you wish to make a Subject Access Request please contact compliance@midlands103.com

You have the right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.

You have the right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.

You have the right to restriction of processing – where certain conditions apply to have a right to restrict the processing.

You have the right of portability – you have the right to have the data we hold about you transferred to another organisation.

You have the right to object – you have the right to object to certain types of processing such as direct marketing. (eg Newsletter Opt-out)

You have the right to object to automated processing, including profiling

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

  1. Information collected for journalistic purposes

Under Article 85 of the GDPR (EU 2016/679), material acquired and used for journalistic purposes is exempt from certain Articles of  GDPR,  including Chapter II (principles) other than Article 5(1)(f), Chapter III (rights of  the data subject) Chapter IV (controller and processor obligations), Chapter V (transfer of data),  Chapter V1, Chapter VII and Chapter IX.

Please note that the requirement to process personal data in a manner that ensures appropriate security remains when processing for journalistic purposes.

 

  1. Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this policy or where there is a legal requirement. Midlands 103 uses third-parties to provide services regarding surveys, competitions and events; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice and are subject to the GDPR (EU 2016/679).

Midlands 103 reserves the right to allow its data processor to perform statistical analyses of user behavior and characteristics, in order to measure interest in and use of the various sections of its sites so as to improve design and navigation and to gather marketing information. Only aggregated data from these analyses, not individual data, will be used for this purpose.

Midlands 103 commits to keeping your personal information confidential save that we:

  • use a range of data sub processing companies to help manage your information. However, we require these companies to comply strictly with our instructions and they are not allowed to use your information for their own business purposes (unless you have explicitly agreed to this). We also require these companies to have appropriate physical and technological security measures to protect your personal information.
  • may share your information with third parties where you have specifically agreed to this. We will not, however, sell your data to any third party.

 

  1. Our commitment to security

Midlands 103 employs appropriate technical and organisational security measures to prevent unauthorised access, alteration, disclosure or destruction of your information.

We use the following industry standard methods to protect your data:

  • SSL (HTTPS) across all websites
  • Encryption
  • Enterprise firewalls

Unfortunately, the sending of information via the internet is not completely secure. Although we will do our utmost to protect your information, we cannot guarantee the security of your data sent to our digital services within Midlands 103; any sending of information is therefore at your own risk.

  1. Transfer Outside the EEA

Midlands 103 utilises services (or parts of them) that may be hosted/stored outside the EEA which means that we may transfer any information which is submitted by you through one of our digital services to outside the European Economic Area (“EEA”) for the below purposes: –

 

  • Newsletter Subscription

Data Processor is MailChimp, more info here https://mailchimp.com/legal/privacy/

MailChimp have a proven track record in providing email marketing services across the globe. They have are Trusted Certified and are Certified with the EU-US Privacy Shield Framework.

Midlands 103 App

To access certain features of the Midlands 103 app, users are required to create an account with personal information to sign in. This information is collected and processed by our app developer Harpoon Connect. Privacy Policy regarding our app can be found here: http://harpoonconnect.com/privacy/

Competition Forms and Surveys

Data Processor is Wordpres.com, more information here https://automattic.com/privacy/

Events Registration Forms

Data Processor is Eventbrite. For more information: https://www.eventbrite.ie/support/articles/en_US/Troubleshooting/eventbrite-privacy-policy?lg=en_IE

Eventbrite are Certified with the EU-US Privacy Shield Framework.

Research

Data Processor is Survey Monkey. For more information:

https://www.surveymonkey.com/mp/legal/privacy-policy/

Streaming Services

Data Processor is Sharpstream Ltd. For more information, http://www.sharp-stream.com/privacy

Therefore, when you sign up to our newsletter or enter a competition or register to attend a station event or participate in a station survey, the personal information you submit may be stored on servers which are hosted outside the EEA. Where this is the case, we will ensure that those providers use an appropriate level of protection for your information and agree to abide by GDPR (EU 201/679) by way of standard contractual clauses.

 

  1. How Long We Keep Your Data

Midlands 103 only ever retains personal information for as long as is necessary to provide a service you have consented to or to adhere to certain warranties or proof of delivery for competition winners.

Where you have subscribed to a Newsletter, we will retain your data until you unsubscribe or the Newsletter is canceled. We include unsubscribe links on all newsletter emails.

Where you have registered for an event, we’ll retain your personal data for 13 months after the event as a record of attendance.

Where you enter a station competition, we’ll retain your data for 12 months after the successful competition of the prize or event in the case of tickets.

We have retention policies in place to meet these obligations.

  1. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Midlands 103, or how your complaint has been handled, you have the right to lodge a complaint directly with the Data Protection Commissioner and Midlands 103.

 

The details for each of these contacts are:

 

Midlands 103

Tindle House

Axis Business Park

Tullamore

Co. Offaly

R35 R588

Phone: +353 57 9351333

Fax: +353 57 9352546

 

Data Protection Commissioner

Canal House

Station Road

Portarlington

R32 AP23

Co. Laois

Phone: 1890 252 231

Fax: +353 57 868 4757

Policy Version Updated 24/05/2018