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Revolution Radio Privacy Notice/Data Protection Policy

As a business/employer Revolution Radio Limited (Revolution Radio) must meet its contractual, statutory and administrative obligations. We are committed to ensuring that the personal data of our employees is handled in accordance with the principles set out in the Commissioner’s Guide to Data Protection.

This privacy notice tells you what to expect when Revolution Radio collects personal information about you. It applies to all volunteers, employees, ex- employees, agency staff, contractors, secondees and non-executive directors. However the information we will process about you will vary depending on your specific role and personal circumstances.

Revolution Radio is the controller for this information unless this notice specifically states otherwise. Details of our Data Protection Officer can be found here.

This notice should be read in conjunction with any other of our corporate policies and procedures. When appropriate we will provide a ‘just in time’ notice to cover any additional processing activities not mentioned in this document.

In this notice

  • How do we get your information
  • What personal data we process and why
  • Lawful basis for processing your personal data
  • How long we keep your personal data
  • Data sharing
  • Do we use any data processors
  • Your rights in relation to this processing
  • Transfers of personal data
  • Further information
    • Whistleblowers
    • Equal opportunity monitoring
    • Monitoring of staff
    • Security passes/fobs/keys/access to systems
    • CCTV

 

How do we get your information

We get information about you from the following sources:

  • Directly from you.
  • From your employer if you are a secondee.
  • From referees, either external or internal.
  • From Occupational Health and other health providers.
  • From Pension administrators and other government departments, for example tax details from HMRC.
  • CCTV images taken using our own CCTV systems.

 

What personal data we process and why

We process the following categories of personal data:

Information related to your employment (FTE/Contractor/Volunteer/Non-Executive Director)

We use the following information to carry out the contract we have with you, provide you access to business services required for your role and manage our human resources processes. We will also use it for our regulatory purposes in our role as a supervisory authority.

  • Personal contact details such as your name, address, contact telephone numbers (landline and mobile) and personal email addresses.
  • Your date of birth, gender and NI number.
  • A copy of your passport or similar photographic identification and /or proof of address documents.
  • Marital status.
  • Next of kin, emergency contacts and their contact information.
  • Employment and education history including your qualifications, job application, employment references, right to work information and details of any criminal convictions that you declare.
  • Location of employment (eg Wilmslow or regional offices).
  • Details of any secondary employment, political declarations, conflict of interest declarations or gift declarations.
  • Security clearance details including basic checks and higher security clearance details according to your job.
  • Any criminal convictions that you declare to us.
  • Your responses to staff surveys if this data is not anonymised.
  • Your political declaration form in line with our policy and procedure regarding party political activities.
  • Information related to your salary, pension and loans

 

We process this information for the payment of your salary, pension and other employment related benefits. We also process it for the administration of statutory and contractual leave entitlements such as holiday or maternity leave.

  • Information about your job role and your employment contract including; your start and leave dates, salary (including grade and salary band), any changes to your employment contract, working pattern (including any requests for flexible working).
  • Details of your time spent working and any overtime, expenses or other payments claimed, including details of any loans.
  • Details of any leave including sick leave, holidays, special leave etc.
  • Pension details
  • Your bank account details, payroll records and tax status information.
  • Details relating to Maternity, Paternity, Shared Parental and Adoption leave. Information relating to your performance and training

We use this information to assess your performance, to conduct pay and grading reviews and to deal with any business / employer / employee related disputes. We also use it to meet the training and development needs required for your role.

  • Information relating to your performance at work eg probation reviews, PIPs, promotions.
  • Grievance and dignity at work matters and investigations to which you may be a party or witness.
  • Disciplinary records and documentation related to any investigations, hearings and warnings/ penalties issued.
  • Whistleblowing concerns raised by you, or to which you may be a party or witness.
  • Information related to your training history and development needs. Information relating to monitoring

We use this information to assess your compliance with corporate policies and procedures and to ensure the security of our premises, IT systems and employees.

  • Information derived from monitoring IT acceptable use standards.
  • Photos and CCTV images.
  • Information relating to your health and wellbeing and other special category data

 

We use the following information to comply with our legal obligations and for equal opportunities monitoring. We also use it to ensure the health, safety and wellbeing of our employees.

  • Health and wellbeing information either declared by you or obtained from health checks, eye examinations, occupational health referrals and reports, sick leave forms, health management questionnaires or fit notes i.e. Statement of Fitness for Work from your GP or hospital.
  • Accident records if you have an accident at work.
  • Details of any desk audits, access needs or reasonable adjustments.

Information you have provided regarding Protected Characteristics as defined by the Equality Act and s.75 of the Northern Ireland Act for the purpose of equal opportunities monitoring. This includes racial or ethnic origin, religious beliefs, disability status, and gender identification and may be extended to include other protected characteristics.

 

Lawful basis for processing your personal data

Depending on the processing activity, we rely on the following lawful basis for processing your personal data under the GDPR:

  • Article 6(1)(b) which relates to processing necessary for the performance of a contract.
  • Article 6(1)(c) so we can comply with our legal obligations as your employer.
  • Article 6(1)(d) in order to protect your vital interests or those of another person.
  • Article 6(1)(e) for the performance of our public task.
  • Article 6(1)(f) for the purposes of our legitimate interest. Special category data

Where the information we process is special category data, for example your health data, the additional bases for processing that we rely on are:

  • Article 9(2)(b) which relates to carrying out our obligations and exercising our rights in employment and the safeguarding of your fundamental rights.
  • Article 9(2)(c) to protect your vital interests or those of another person where you are incapable of giving your consent.
  • Article 9(2)(h) for the purposes of preventative or occupational medicine and assessing your working capacity as an employee.
  • Article 9(2)(f) for the establishment, exercise or defense of legal claims.
  • Article 9(2)(j) for archiving purposes in the public interest.

In addition we rely on processing conditions at Schedule 1 part 1 paragraph 1 and Schedule 1 part 1 paragraph 2(2)(a) and (b) of the DPA 2018. These relate to the processing of special category data for employment purposes, preventative or occupational medicine and the assessment of your working capacity as an employee. Our Safeguards Policy provides further information about this processing.

Criminal convictions and offences

We process information about staff criminal convictions and offences. The lawful basis we rely to process this data are:

  • Article 6(1)(e) for the performance of our public task. In addition we rely on the processing condition at Schedule 1 part 2 paragraph 6(2)(a).
  • Article 6(1)(b) for the performance of a contract. In addition we rely on the processing condition at Schedule 1 part 1 paragraph 1.

Our Safeguards Policy provides further information about this processing.

 

How long we keep your personal data

Revolution Radio will retain your personal data for up to 6 months from the time you leave the business, should you request this I can be removed prior to the 6 months, This request must be given formally via letter or email.

 

Data Sharing

In some circumstances, such as under a court order, we are legally obliged to share information. We may also share information about you with third parties including government agencies and external auditors. For example, we may share information about you with HMRC for the purpose of collecting tax and national insurance contributions.

 

Do we use any data processors?

No - all processing is done within Revolution Radio and will only be processed by the management team.

 

Your rights in relation to this processing

As an individual you have certain rights regarding our processing of your personal data, including a right to lodge a complaint with the Information Commissioner as the relevant supervisory authority. For further information please see ico.org.uk

 

Transfers of personal data

We do not transfer staff personal data overseas.

 

Further information Personnel files

Physical and electronic records are held for each member of staff. Data is held securely on Revolution Radio systems and at our premises.

You can request your personnel file by emailing Chris or Nick or by submitting an access request to data@revolutionradio.com. You can also make a verbal request for your information.

You will not be able to take away your physical file. Your request will be handled outside the case management area with restricted access. We will consult internally with members of staff who might hold personal data about you.

 

Whistleblowers

Revolution Radio has a policy and procedure in place to enable its current staff and ex-employees to have an avenue for raising concerns about malpractice. If you wish to raise a concern please refer to our ‘Whistleblowing process’- Revolution Radio's whistleblowing policy and procedure can be found on our website; https://www.revolutionradio.com/about-us/whistleblowing-process/. Although every effort will be taken to restrict the processing of your personal data and maintain confidentiality whether this is possible will be dependent on the nature of the concern and any resulting investigation.

 

Equal opportunities monitoring

Equal opportunities information provided by job applicants is attached to the relevant application on our Employee Information System. This information is not made available to any staff outside our recruitment team (including managers) in a way which can identify you. This information is anonymised after six months and retained for reporting purposes only.

 

Monitoring of staff

All of our IT systems, On-Air systems and the alarm/access system for the entry and exit of our premises are auditable and can be monitored, though we don’t do so routinely.

We are committed to respecting individual users’ reasonable expectations of privacy concerning the use of our ICT systems and equipment. However, we reserve the right to log and monitor such use in line with our Acceptable Use Standard.

Any targeted monitoring of staff will take place within the context of our disciplinary procedures.

 

Security passes/Fobs/Keys/Access to Systems

All staff are all issued with some form of security entry that holds personal information.

Staff IDs (names and ID) are held on a standalone machine controlled by Management and can only be accessed by a restricted number of people. Should you lose your key or fob you will need to complete a lost security pass form and return it to Chris or Nick. When you leave Revolution Radio your details are deleted as soon as possible from this system.

 

CCTV

We operate CCTV inside our Northampton premises to monitor access to certain areas of the office and studios.

Please see the Revolution Radio CCTV Policy for further information.