Reform Radio Privacy Notice 

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Policy Governance

The following table identifies who within Reform Radio is Accountable, Responsible, Informed or Consulted with regards to this policy. The following definitions apply:

• Responsible – the person(s) responsible for developing and implementing the policy.
• Accountable – the person who has ultimate accountability and authority for the policy.
• Consulted – the person(s) or groups to be consulted prior to final policy implementation or amendment.
• Informed – the person(s) or groups to be informed after policy implementation or amendment.

Review and Revision

This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months.

Policy review will be undertaken by the Operations Manager.

Privacy Notice

At Reform Radio we are committed to protecting the personal details that we process when you engage with us. This Privacy Notice explains why we may ask for your personal information and tells you what we will do with it.

We collect and use personal data to manage our relationships with our young people and partners, and to better understand how we can meet and exceed their expectations. This allows us to operate more efficiently and effectively to ultimately help us reach our goal that every young person should have the best opportunities to engage with.

Please read this Privacy Notice carefully, and any other documents referred to, to understand how we collect, use, and store your personal information.

The Privacy Notice tells you:

1. Who we are
2. Where we collect information from
3. Information we collect
4. What we do with your information
5. Legal Basis for processing your information
6. How we update your information
7. Who we share information with
8. How to access, correct or delete your information
9. How we keep your data safe
10. How long we store your data for
11. Changes to the Privacy Notice
12. Contact us
13. Further information

By providing us with personal information, you consent to its collection and use as set out in this Privacy Notice. We aim to be clear, transparent and to use your information in a way that you would reasonably expect us to. We may update this Privacy Notice from time-to-time so please check it regularly.

If you have any questions about this Privacy Notice or our Website Cookies please contact our Data Protection Officer by email.

1. Who we are

Reform Radio broadcasts the best in music, arts and culture from Bonded Warehouse, Manchester to the world. Reform Radio is more than just an online station. We’re a revolutionary not-for-profit that uses the engagement of radio to work with and develop new skills in young people struggling to find employment. Our radio community supports the wider community; and so it goes around.

We’re a registered community interest company, meaning our focus is primarily to benefit our local community, rather than to make a profit for shareholders.

2. Where do we collect information from?

We collect information in the following ways:

Information you give us

• Reform Radio may obtain personal information from you when, for example, you complete our online Consent Form to participate on a programme, register with us for a mailing list, apply to become a volunteer or DJ, take part in an event or make a donation.

Information from Third Parties

• We may also receive information about you from independent third parties, such as ticketing sites like Eventbrite. We will only receive information from third parties in this way if you have given your consent for your information to be passed on to us. You should check their Privacy Notice when you provide your information to understand how they will process your information. Once we have obtained this information from the third party it will be covered by our Privacy Notice as well as by the originating third party.

Information we get from your use of our website and services

• We collect information about the services you use and how you use them, like when you watch a video on our YouTube channel, visit our websites or view and interact with our adverts and content.

Information in the public domain

• We may obtain some information from publicly available sources such as Companies House, newspaper articles or open postings on social media such as Facebook and LinkedIn. 

3. What information do we collect?

The types of personal information that Reform Radio collects may include:

• Your title, name, gender and date of birth;
• Your contact details (address, email, phone number and social media contact details);
• Emergency contact details;
• Your General Practitioner’s contact details;
• Your professional activities and employment details;
• Your interest in future activities at Reform Radio;
• Any other information provided by yourself at the request of Reform Radio.

In some limited circumstances, the personal information that Reform Radio collects may include information that is considered ‘Special Category’. This may include personal information regarding racial or ethnic origins, political opinions, religious beliefs, health and also information concerning criminal offences. Where this information is collected we will tell you so you know why it is needed.

If you are under 13 you should ask permission of a parent or guardian before sending personal or sensitive information to anyone online.

4. What might we do with your information?

If you have applied for one of Reform Radio projects, Reform Radio will use your information to run, fund, develop and evaluate Reform Radio’s projects. 

We will also use your information to:

• Provide you with the services, products or information that you asked for;
• Provide you information about other services, products or information we think might interest you where you have consented to being contacted;
• Invite you to events;
• Ensure that safeguards are in place for your safety and health where necessary, in line with our Children & Vulnerable Adults Safeguarding Policy;
• Keep a record of your relationship with us and record the contact we have with you; and
• Ensure we know how you prefer to be contacted.

5. Legal Basis for processing your information

Personal Data

Under the UK GDPR and the DPA 2018, we must have a legal reason to collect, keep and use your data. We rely on the following legal basis for processing your personal data:

1. Consent
2. Legitimate Interests
3. Legal Obligation
4. Contract

We process your personal data to allow us to run Reform Radio effectively as a non profit social outreach organisation and in pursuit of our objectives.  

When we process your personal information, we make sure to consider and balance any potential impact on you and your rights under data protection laws. We will always ensure that your personal data will not be used where our interests are overridden by the impact on you.

Where possible we ask for your informed consent, making sure that the consent you are giving is clear and specific. 

We also process data for our legitimate interests as an organisation. These cover matters that you’d expect us to be working on for both Reform Radio’s and our community’s benefit.

The following are some examples of instances where we process your data for our legitimate interest:

• Direct marketing: We use digital marketing to connect you to other projects or opportunities which we believe you will be interested in, which further the aims and objectives of Reform Radio and don’t unduly impact the rights of the individual.
• Data analysis: We carry out limited analysis to help us understand the needs of our community, including gathering information from publicly available resources. This is used in a variety of ways, including guiding strategic goals, for funding bids and in quality management.

We also process data to ensure we are meeting legal obligations for our staff, community and learners. These obligations include safeguarding, equality & diversity and employment.

You can opt out of your data being used for data analysis, direct marketing or other reasons by contacting the Data Protection Officer. You will then not receive any further contact in these areas from Reform Radio except to comply with your request.

For our staff, we process data needed through the Contract and Legal Obligation categories. We process the data needed to ensure that we’re upholding our employee’s contracts and statutory requirements around employment, discrimination and health & safety.

Special Category Data

We also collect some Special Category Data for safeguarding, research and reporting purposes. This is collected under the basis of Consent & Legitimate Interest of article 6 of UK-GDPR and is processed under the “Not-for-profit bodies”,“Safeguarding of children and individuals at risk” and “Safeguarding of economic well-being of certain individuals” conditions of the UK-GDPR and DPA 2018.

6. Direct Marketing

At Reform Radio,  we believe that no one should receive unsolicited marketing or communications. To this end we only send direct marketing to those who have given us informed consent through our Consent Form. Those who we directly market to are able to easily hit the unsubscribe button at the bottom of any of our communications, and they’ll be unsubscribed from our mailing lists. Individuals can also unsubscribe by contacting any member of staff, who will be responsible for informing their line manager or the DPO, whichever is appropriate. If you’d like to no longer receive any communications or marketing from us, contact ourplease contact our Data Protection Officer on DPO@reformradio.co.uk or 0161 806 0879.

7. How we update your information

We review records of our Young People, DJs and others who engage with Reform Radio to ensure your data is as accurate as possible and always appreciate it if you let us know if your contact details change. It is important that we keep your personal data as up to date as possible so that we can continue providing you with the best opportunities and support. 

8. Who we share your information with

We are committed to protecting your data and therefore it will never be sold to external organisations and will only be disclosed to those acting as agents and data processors carrying out work on our behalf. Where we enter into a relationship with an external party, any such arrangements will be subject to a formal agreement between Reform Radio and that organisation to protect the security of your data. These Parties may include:

• Our delivery partners within the UK us to deliver our projects effectively.
• Public service entities for the purposes of ensuring safeguarding of those that we work with.
• We will use data storage and workspace services to store and access your data. These data processor’s services allow us to effectively manage your data and utilise it in the best way to support our community.

9. How to access, correct or delete your information

Under the General Data Protection Regulation 2016/679 you have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email the Data Protection Officer or write to us at Data Protection Officer, Reform Radio, Bonded Warehouse, 18 Lower Byrom Street, M3 4AP. To help us locate any personal information about you (or in case we need to get in touch with you to obtain further information to help us locate your records) please include your full name, address and telephone number with your request.

If you do not want to receive any further information about Reform Radio and would like us to remove your name from our mailing list, use the unsubscribe link in the email you have received.  You can also contact us using the details above.

10. How we keep your data safe

We aim to ensure that there are appropriate, physical, technical and managerial controls in place to protect any personal information you may provide to us, for example our online forms are always encrypted and our network is protected and monitored. Within our offices all our staff receive training on handling data securely.

Where we use external companies to collect or process data on our behalf, we carry out comprehensive checks on them before we work with them and ensure that contracts are in place that set out our expectations and requirements. We may need to transfer your personal data outside of the European Economic Area (EEA) to allow them to perform services on our behalf (for example invitation or participation in an event outside of the EEA). In doing so your data may be stored or processed outside of the EEA. Where this happens, we will endeavour to ensure that your data is being processed in accordance with the appropriate security requirements in line with our legal responsibilities, and by submitting your details in such circumstances you agree to this transfer.

Despite all of our precautions no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we will always strive to protect your personal information, we cannot guarantee the security of any information which you disclose to us and so wish to draw your attention that you do so at your own risk.

11. How long we store your data for

We will hold your personal information on our systems for as long as is necessary for the relevant activity. If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us, we won’t keep any information that we don’t need.

12. Changes to this Notice

Any changes to this Notice will be notified by displaying the word ‘NEW’ next to the ‘Privacy Notice’ link on our Site at least 30 days before putting such changes into effect. This Privacy Notice was last updated in May 2021.

13. Contact us

If you have any queries about this Notice or any complaints with regard to the administration of the Privacy Notice please contact our Data Protection Officer on DPO@reformradio.co.uk or 0161 806 0879.

14. Further information

The laws governing how your personal data can be used are:

• General Data Protection Regulation 2016/679
• The Privacy and Electronic Communications Regulations 2003
• Data Protection Act 2018

You can also contact the Information Commissioner’s Office (ICO) at www.ico.org.uk to find out more or report a concern. The ICO is the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. We work with them to make sure that we collect, store, and use your information appropriately and not do anything you would not reasonably expect us to do with your data.