Radio Verulam GDPR Legitimate Interest Assessment

This assessment determines whether a Legitimate Interest exists for the storage and processing of data for:

  1. Current or past advertising or sponsorship clients
  2. Prospective advertising or sponsorship clients in the St Albans area
  3. Guests and contacts who supply or may supply personal data to us
  4. Scheduled programme, podcast and Listen again audiences
  5. Media contacts

Privacy Notice

We have updated our privacy notices on our website.

Existing Supporting Clients

  • A Legitimate Interest exists because there is a direct appropriate relationship between Radio Verulam and an active/current advertising or sponsorship Client.
  • There is a reasonable expectation that their data will be processed in order to communicate with them and to keep records of that business.

We have a need to contact our clients about:

  1. Ongoing contracts and agreements
  2. News about the station and its volunteers
  3. new features and optional modules which may enhance their business, based on our ongoing commercial interests
  4. our presence at trade shows and events
  5. feedback on our systems and future requirements

We choose to primarily use email because:

  1. It’s very cost-effective
  2. It’s the most effective way to contact the number of business in the area.
  3. Clients can choose whether to open it or not, so it’s not intrusive
  4. It’s fast, especially where timing is an opportunity
  5. We can send or link to required files or documents

In what other ways can we achieve mass communication?

  1. Telephone : This is a secondary way of contacting clients.
  2. Post : Will be used for transactional contact (e.g. invoices)
  3. SMS – we may contact clients by text where this is agreed by the client.
  4. Personal visit : This may be required to discuss ongoing contracts, issues or renewals.

Can they opt-out?

Yes from any communication channel or contacting us directly. Such an opt-out would be stored in the CRM in use.

Balancing Test:

  1. We do not believe that such processing & communication has a negative impact on the rights or safety of the individual.
  2. Access to the data is strictly controlled and protected.
  3. Communications will never disclose other individual’s details to a recipient.
  4. Details will never be sold to a third party
  5. All communications via email will include Unsubscribe options.

Final checklist – existing customers

  • We have checked that legitimate interests is the most appropriate basis.
  • We understand our responsibility to protect the individual’s interests.
  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
  • We have identified the relevant legitimate interests.
  • We have checked that the processing is necessary and there is no less intrusive way to achieve the same result.
  • We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests. . We do not believe it would result in discrimination, financial loss, reputational damage, loss of confidentiality or professional secrecy. Or any other economic or social disadvantage.
  • We only use individuals’ data in ways they would reasonably expect, unless we have a very good reason.
  • We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason.
  • We have considered safeguards to reduce the impact where possible.
  • We have considered whether we can offer an opt-out and can do so.
  • We keep our LIA under review, and repeat it if circumstances change.
  • We include information about our legitimate interests in our privacy notice.

Customer lifecycle (what period)

Date will be held while the contact is an active customer or if the contact unsubscribes. Proof of unsubscription from processing will be retained and may be deleted at the request of the client.

Prospects and Past Customers

  • A Legitimate Interest exists because we have a need to promote our services to business in the St Albans district.
  • There is a reasonable expectation that they will be contacted by companies offering them similar services in order to promote their goods or services.
  • We believe that radio has some unique advantages that prospects may not be aware of.
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We have a need to contact our prospects about:

  1. Promotional opportunities that the radio station can offer
  2. The benefits and advantages of supporting the station
  3. To improve our products, programmes and services.

We choose to primarily use email because:

  1. It’s very cost-effective
  2. Prospects can choose whether to open it or not, so it’s not wholly intrusive
  3. It’s fast
  4. We can send or link to required files or documents

In what other ways can we achieve mass communication?

  1. Telephone : This would take far too long and cost too much to call some 400+ prospects directly, even allowing for a first-time response for each prospect, especially in the case of an urgent announcement.
  2. Post : this can be an occasional complementary service, which may reach some who either don’t receive emails or have no email address on our system. However it is costly and time-consuming.
  3. Magazine advertising: Inappropriate for potential advertisers.
  4. SMS – where we may have mobile numbers for our prospects, we do not have permission to text. We believe this could be deemed intrusive unless consent is given, as people will usually look at a text message when it arrives.
  5. Personal visit : It would not be practical or cost-effective at all to use this method, except where a prospect has shown interest.

Can they opt-out?

Yes from any communication channel such as marketing or events, by calling, emailing or writing to us. This can be done through the Privacy Policy on the website.

Balancing Test:

  1. We do not believe that such processing & communication has a negative impact on the rights or safety of the individual.
  2. Access to the data is strictly controlled and protected.
  3. Communications will never disclose other individual’s details to a recipient.
  4. Communications will be occasional rather than often, for example once every three months.
  5. All communications via email include both Unsubscribe and Profile Update options.
  6. Details will never be sold to a third party

Final checklist – prospects

  • We have checked that legitimate interests is the most appropriate basis, and have sent several emails asking for consent as well.
  • Any who unsubscribe will be marked as such and not mailed. Base will be updated at the same time.
  • We understand our responsibility to protect the individual’s interests.
  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
  • We have identified the relevant legitimate interests.
  • We have checked that the processing is necessary and there is no economic less intrusive way to achieve the same result.
  • We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests. We do not believe it would result in discrimination, financial loss, reputational damage, loss of confidentiality or professional secrecy. Or any other economic or social disadvantage.
  • We only use individuals’ data in ways they would reasonably expect, unless we have a very good reason.
  • We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason.
  • We have considered safeguards to reduce the impact where possible.
  • We have considered whether we can offer an opt-out and can do so.
  • We keep our LIA under review, and repeat it if circumstances change.
  • We include information about our legitimate interests in our privacy notice.

Customer lifecycle (what period)

Data will be held while the contact is an active prospect or if the contact unsubscribes. 

Guests and interviewees

A Legitimate Interest exists because we have a requirement to keep records of guests for both Health & Safety and in case or a complaint or other issue.

There is a reasonable expectation that they will want to do this to promote their cause or organisation.

We have a need to contact guests about:

  1. Timing for studio on-air appearances or telephone interviews
  2. Offering follow-up information for enquiries from the public

We do not use mass communications for guests at this time.

Can they opt-out?

Yes from any communication channel such as marketing or events, or by telephone or in writing.

Balancing Test:

  1. We do not believe that such processing & communication has a negative impact on the rights or safety of the individual.
  2. Access to the data is strictly controlled and protected.
  3. Communications will never disclose other individual’s details to a recipient without the explicit consent of the primary contact.
  4. All communications via email will usually be of a one-to-one and personally sent email.

Final checklist – prospects

  • We have checked that legitimate interests is the most appropriate basis, and have sent several emails asking for consent as well.
  • Any who unsubscribe will be marked as such and not mailed. The CRM will be updated at the same time.
  • We understand our responsibility to protect the individual’s interests.
  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision.
  • We have identified the relevant legitimate interests.
  • We have checked that the processing is necessary and there is no economic less intrusive way to achieve the same result.
  • We have done a balancing test, and are confident that the individual’s interests do not override those legitimate interests.
  • We only use individuals’ data in ways they would reasonably expect, unless we have a very good reason.
  • We are not using people’s data in ways they would find intrusive or which could cause them harm, unless we have a very good reason.
  • We have considered safeguards to reduce the impact where possible.
  • We have considered whether we can offer an opt-out and can do so.
  • We keep our LIA under review, and repeat it if circumstances change.
  • We include information about our legitimate interests in our privacy notice.

Customer lifecycle (what period)

Data will be held while the contact is an active prospect or if the contact unsubscribes. 

Media Contacts

A Legitimate Interest exists because the media requires both a news feed and advertising revenue to sustain its own business.

We have a need to contact the media about:

  1. News about the station, its volunteers and its activities
  2. Advertising in their media

We choose to primarily use email because:

  1. It’s very cost-effective
  2. It is always done on a 1-to-1 basis, no mass communications are employed
  3. We also use telephone as appropriate
  4. We can send or link to required files or release information documents

In what other ways can we achieve mass communication?

  1. As we don’t use mass communication for the media, this is not applicable.

Can they opt-out?

Yes from any communication channel.

If a contact leaves their media position:

Their details will be removed from the list. Old emails will not be deleted without a request for historical business reasons.​