Introduction
This is the Privacy Policy of Tipp F.M. Limited trading as Tipp FM, which operates as a local service independent broadcaster based in Clonmel, Co. Tipperary. The purpose of this Privacy Policy is to outline Tipp FM’s policy concerning the collection, use, retention, disclosure and transfer of Personal Data which is gathered and processed by Tipp FM. This Privacy Policy also sets out Tipp FM information management practices.
Tipp FM respects the privacy of all those individuals whose Personal Data it encounters, which includes the following:
A. all users of the Tipp FM website (i.e. the Tipp FM desktop and mobile sites), Tipp FM social media pages and apps and other Tipp FM services (whether on-air or online);
B. Tipp FM employees and contractors (including applicants for employment with Tipp FM);
C. all members (including former employees) of Tipp FM sponsored pension schemes;
D. Tipp FM business contacts and suppliers; and
E. Individuals whose Personal Data is provided to Tipp FM in the form of content for editorial, content creation, journalistic purposes (including those who contribute content for live discussion or other purposes including audience participation).
For each of these categories of individuals, this Privacy Policy will explain why Tipp FM collects and how Tipp FM uses the Personal Data it collects. Tipp FM will ensure that it keeps all Personal Data provided to it in accordance with Tipp FM’s obligations under applicable data protection laws. Tipp FM will update this Privacy Policy from time to time to reflect any material changes in technology, legislation or Tipp FM’s data use practices which may materially affect the way in which Tipp FM processes Personal Data.
This is not an exhaustive statement of all Tipp FM’s data protection practices and Tipp FM may apply specific policies within certain environments. Tipp FM might include a separate privacy notice at the point of capturing data on a new service and any specific consents obtained or information provided in this way will apply specifically to that service and will supplement this Policy. Tipp FM may also introduce additional user choices on our digital platforms which will be clearly explained to users as required by data protection law.
What is Personal Data?
Personal Data is any information relating to a living individual that allows for the identification of that individual. Personal Data can include a name, address, contact details, an identification number, IP address, CCTV footage, accesses cards/co-tags, audio-visual or audio recordings of a person, details about an individual’s location or any other detail(s) specific to that individual.
In circumstances where Tipp FM controls Personal Data by deciding why and how that Personal Data is processed, Tipp FM will be a “Data Controller”. Any entity that processes Personal Data controlled by Tipp FM and does so on behalf of Tipp FM, is a “Data Processor”. Data Processors may include third party service providers engaged by Tipp FM (for example communications providers, payroll and marketing or recruitment agencies). As required by applicable data protection law, when Tipp FM appoints a Data Processor, we will ensure that appropriate contractual protections are in place.
In circumstances where content is produced independently of Tipp FM, the third-party producer shall usually be the Data Controller, and as such, it is the privacy policy of such third-party producers that will govern the collection and processing of Personal Data. Where content is co-produced, Tipp FM and the third-party producer may be Joint Data Controllers. In such situations, it may be necessary for Tipp FM to share Personal Data with the third-party producer and vice versa.
Tipp FM Website, Social Media and Apps
This section of the Privacy Policy sets out the type of Personal Data collected by Tipp FM, the purposes for which such Personal Data is collected and processed and the lawful justifications for such processing in the context of the Tipp FM website (https://www.tippfm.com) & App (Tipp FM App).
Tipp FM is not responsible for the privacy practices of any external websites, device manufacturers or platforms which may be accessed or used in connection with a person’s use of the Tipp FM website, Tipp FM social media pages or App. They are subject to their own privacy statements which may materially differ from those of Tipp FM so users should review them for further information.
What Personal Data does Tipp FM collect and use online?
Tipp FM collects various types of Personal Data when a person uses the Tipp FM website, Tipp FM social media and/or app. The following are examples of Personal Data collected by Tipp FM:
(i) Competitions: When a person enters a competition, Tipp FM may collect and use the entrant’s name and contact details (including postal address, email address, telephone number) in connection with the competition (including mobile competitions). Where Tipp FM operates competitions in conjunction with a third-party commercial partner, subject to the competition rules and notices, that partner may collect and use the data.
(ii) Programme Participation, Audience Participation and Ticketing: When a person engages with Tipp FM to participate in a Tipp FM programme/event (as an audience member or as a contributor) or to obtain tickets for a Tipp FM programme or event, Tipp FM may use the individual’s name, contact details (including postal address, email address, telephone number) and such personal data (which may include special category data) disclosed by the individual in order to process applications for tickets or applications to participate in such programmes.
(iii) Social Media Pages: Content such as messages and photographs, that is posted on social media pages on which Tipp FM has a presence may be made publicly available and may be used in connection with the operation and promotion of Tipp FM social media pages, apps and services, the Tipp FM website and radio programmes. If content is posted that is deemed to be in breach of this Privacy Policy or the policies operated by such websites, social media platforms or apps, such content may be removed by or at the request of Tipp FM or the operators of those social media websites. If such inappropriate content is posted to a social media page that Tipp FM controls you can report it
at the following address [email protected] and Tipp FM will endeavour to ensure that appropriate action is taken in accordance with the Tipp FM policies and the policies of the relevant social media platforms.
(iv) Tipp FM may record which users opened and clicked any embedded links in communications sent by Tipp FM in order to measure a campaign’s effectiveness. The Tipp FM Site uses cookies, web beacons, device identifiers, social plugins, tracking pixels, etc. “Cookies” are small pieces of information stored by your internet browser that collect data such as your browser type, your operating system, web pages visited, time of visits, content viewed, advertisements viewed and other click stream data. Tipp FM use cookies to help us tailor our websites to your needs, to deliver a better, more personalised service and to remember certain choices you’ve made so you don’t have to reenter them. Cookies also enable us to identify traffic to our website including pages visited, visitor numbers and traffic paths taken.
Tipp FM may use advertising networks to help present advertisements or other content on our website and other websites that display Tipp FM advertisements. Advertising networks use cookies, web beacons, or similar technologies on your computer or mobile or other device to serve you advertisements or content tailored to interests you have shown by building a profile of your internet browsing on this website and other websites you have visited.
Interest-Based Online Advertising and Google Analytics & Cookies
This section of our Privacy Notice provides details about interest-based online advertising (also called “targeted advertising”, “remarketing”, or “behavioural advertising”), Google Analytics, and your choices with respect to this type of advertising.
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” as outlined above. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this
website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en.
Other third-party cookies such as those from YouTube, Google and double click.com are also in use to enhance your experience on the site and to help us tailor content to our user’s needs.
We further use Google Analytics’ 3rd-party audience data such as age, gender and interests to better understanding the behaviour of our customers and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this website or other websites because we contract with Google, Independent Radio Sales Ireland Limited (IRS) and other similar companies to target our ads based on information we or they have collected, including information that was collected through automated means (such as cookies and web beacons). These companies also use automated technologies to
collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.
You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioural Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’
preferences at http://www.google.com/ads/preferences/, Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because that page is not operated by the Tipp FM, we are unable to perform the opt-outs on your behalf.
(v) Tipp FM Apps: By signing in to the Tipp FM app this sign-in will also be used by Tipp FM to collect and use details regarding the app usage of users of Tipp FM app. Such details may include the time and date that the app is opened and closed, what content was viewed and the duration of the app session. Using this information enables us to generate statistical reports, such as to measure the popularity of content or to look at ways to improve our service. When users choose to receive in-app push notifications, we may also use this information to send such users customised in-app messages regarding our services, including newsletters, messages about new app features and Tipp FM content,
special offers, promotional announcements, surveys and other information; all of which will be customised for your particular preferences. Tipp FM may also verify the location of a user’s device while using the app or country of the relevant Appstore registered credit or debit card. Tipp FM may block usage of the app in some cases based upon this information. This is because there may be territorial restrictions on the use of certain content. All of this information is linked through the relevant user accounts (such as Apple App Store or Google Play Store). Users may be able to use their device settings to prevent Tipp FM from verifying their device’s location. However, in that case, use of that specific app may be impaired or discontinued.
The purposes and lawful justifications for Tipp FM’s data processing
Tipp FM collects and processes the Personal Data described above for a variety of purposes. As required by data protection laws, below is a summary of these purposes and the lawful justifications that support them:
Purpose: Service delivery, management and improvement e.g. to identify content which is most popular among users of Tipp FM services, to promote such content to Tipp FM users in a customised manner and to restrict the use of Tipp FM services in territories where restrictions apply to its use.
Lawful Justification: Such processing is necessary for Tipp FM to meet its statutory obligations and to provide the relevant services.
Purpose: To evaluate users’ interests and to deliver tailored advertising based on user preferences and interests.
Lawful Justification: Such Processing is necessary for Tipp FM commercial interests in attracting commercial sponsors.
Purpose: Using content provided by individuals on Tipp FM social media pages.
Lawful Justification: We rely on individuals’ consent for these uses. If a user wishes to withdraw consent to the processing of any content posted by them on Tipp FM social media pages, they can contact Tipp FM’s Data Protection Representative.
Purpose: Competitions or draws.
Lawful Justification: It is necessary to process data to operate the relevant competitions or draws. Additional uses of the data may arise where consent has been provided under the relevant competition rules.
Purpose: Communicating with and maintaining contact details of business contacts and suppliers
Lawful Justification: As necessary for the performance of the relevant contract with such business contacts and/or suppliers and otherwise in order to enable Tipp FM to perform its local broadcasting objectives, which necessarily requires that Tipp FM engage external service providers.
Purpose: General correspondence with members of public (by post or email address) for example where an individual sends correspondence to Tipp FM to comment on content of broadcast or for other miscellaneous reasons.
Lawful Justification: For the particular purpose for which the correspondence is sent to Tipp FM. Depending on the particular context of such correspondence the relevant lawful basis will likely be either the individual’s consent or performance of Tipp FM’s public interest objectives.
Purpose: For audience ticketing and audience participation purposes, which may from time to time include sensitive categories of personal data including but not limited to data revealing individual’s religious or philosophical beliefs, health data, trade union membership or data revealing sexual orientation or details of sex life.
Lawful Justification: Such data will be processed for the purpose of meeting Tipp FM’s public interest & Local broadcasting objectives
Advertising and Marketing
This section of the Tipp FM’s Privacy Policy sets out how Tipp FM may use Personal Data for marketing and online advertising purposes.
Marketing communications
If a person provides consent for marketing communications Tipp FM may use their name, address, email address, postal address and/or telephone number for marketing communications. Users who have chosen to receive in-app push notifications will also receive marketing communications in that way. Tipp FM will not contact users by email, phone or SMS for direct marketing purposes unless the users have consented to be contacted for such purposes as required by data protection laws. Users can opt-out of receiving direct marketing communications from Tipp FM by following the unsubscribe link in the relevant marketing message.
If users sign up to receive marketing communications from Tipp FM’s partners and provide their contact details to Tipp FM for such purposes, we may provide their name and contact details (e.g. email or mobile number) to Tipp FM’s commercial partners (such as organisations that are partnering with Tipp FM in relation to the provision or sponsorship of programmes) so that they can send you marketing communications. Tipp FM will not provide such information to third parties for direct marketing purposes unless the users have consented to Tipp FM giving their Personal Data to third parties for that purpose. If a user opts-out from receiving communications from our partners, Tipp FM will no longer share that user’s contact details with our partners. However, users will still need to directly opt-out from communications from the partners to whom we have already given their information.
Tipp FM uses third party service providers to help deliver its marketing communications. Those third party data processors are subject to contractual and legal restrictions in relation to any unauthorised use of your information.
Online Advertising
By using Tipp FM online services and app we may use information gathered from you, and information gathered from third parties, to provide our users with certain tailored advertising offerings through our website and other services. Tipp FM gathers web viewing Personal Data from users across its various services, which may then be used by Tipp FM and its service providers to deliver advertising to particular groups of users based on the preferences or interests inferred from the data collected and processed by Tipp FM (or a third-party service provider’s) technology. For example, Tipp FM uses cookies, web beacons, social plugins, tracking pixels and similar technologies to collect information from a mobile or other device.
Tipp FM Staff Data
As an employer, Tipp FM collects and processes Personal Data in relation to its staff, applicants for employment with Tipp FM, pension scheme membership, as well as independent contractors engaged by Tipp FM. Such Personal Data includes:
(a) Personal Details: name, date of birth, PPS number, bank account details, next of kin, details of social media accounts;
(b) Contact details: address and phone numbers(s);
(c) Employment History/application details: educational history, employment history;
(d) Editorial of journalistic content: links to work e.g. links to show-reels or audio files;
(e) Medical information: medical certificates, sick notes, health and safety data;
(f) Family details: names and dates of birth of children (if a person is applying for parental leave);
(g) Details required for pension purposes, passport details, birth certificates, marriage certificates
and details of prior pension scheme membership;
(h) Car registration and vehicle insurance details for the purpose of expense claims;
(i) Details regarding trade union membership (for the purposes of payment of trade union
membership fees only); and
(j) Performance – related data: performance management ratings for managers and annual incremental salary reviews of employees.
Tipp FM also engage a number of third parties for the collection and processing of Personal Data of its staff and contractors to assist in the normal course of personnel and benefits administration.
The purposes and lawful justifications for Tipp FM’s data processing
Tipp FM collects and processes the employment-related Personal Data described above for the purposes and with the lawful justifications described below:
Purpose: Payroll, including payment of salaries and expenses of staff and independent contractors, making income tax returns, processing of voluntary payroll deductions and for the purposes of internal budgeting and projection of payroll costs.
Lawful Justification: Such processing is necessary for the performance of the employment contract and contracts for services between Tipp FM and each employee or contractor.
Purpose: For maintaining human resources records.
Lawful Justification: For the performance of the employment contract between Tipp FM and each employee and to meet legal obligations in relation to employment records.
Purpose: For recruitment purposes.
Lawful Justification: Such processing is based on the consent of the individual applicant.
Purpose: Performance appraisal including for conducting salary reviews.
Lawful Justification: Necessary for the performance of the employment/services contract.
Purpose: IT security and maintenance e.g. IT helpdesk, device encryption, the provision of secure remote access to Tipp FM networks and systems.
Lawful Justification: This is necessary for compliance with our legal obligations in relation to data security and to protect Tipp FM’s legal obligations for ensuring that workplace policies are adhered to.
Purpose: Provide information in the context of disputes or legal claims
Lawful Justification: Necessary for the purpose of establishing, exercising or defending a legal claim (Article 9(2)(f) in respect of Special Categories of Personal Data).
Purpose: Freedom of Information or regulatory requests.
Lawful Justification: To comply with statutory obligations.
Purpose: To assess the working capacity of employees and for related reasons (such as insurance), in limited circumstances Tipp FM may process employee’s health data and disclose it to third party service providers for these specific purposes.
Lawful Justification: For purposes connected with Tipp FM obligations under employment law with regard to the health and safety and working capacity of its employees. Where such data is processed it shall be subject to suitable and specific measures.
Personal Data obtained by Tipp FM for programming purposes
Journalistic and editorial purposes
In performing its role as a media organisation, and in the course of researching and preparing content for potential broadcast or publication by Tipp FM for journalistic or programme content and programme-making purposes, Tipp FM, gathers and records in a variety of forms news, information, data, opinions, on and off-record quotes or views from people and sources. These activities will frequently involve the collection and processing of Personal Data. Data protection law permits Tipp FM to process such Personal Data in pursuit of the rights of freedom of expression and information, including processing for journalistic purposes and the purposes of academic, artistic or literary expression and provides for exemptions from certain data protection obligations where such obligations would be incompatible with Tipp FM’s exercise of the rights of freedom of expression. In exercising such rights, Tipp FM will not unreasonably encroach on the privacy of an individual. This Policy is not intended to limit or restrict Tipp FM’s ability to rely on such interests in the course of its journalistic activity, which under law is to be interpreted broadly.
Programme content purposes
For editorial purposes Tipp FM must retain and process certain Personal Data (including sensitive categories of data such as political opinions) to ensure that editorial decision-making practices are appropriate so as to ensure that certain content is presented in an objective and impartial manner. This helps to ensure political balance in the context of political reporting, particularly in election cycles, and also in preventing and defending defamation claims made against Tipp FM.
Processing for Security Purposes
CCTV
Tipp FM has closed circuit television cameras (“CCTV”) located throughout its premises covering buildings, internal spaces, car parks, roads, pathways and grounds. Tipp FM’s CCTV system is
implemented in a proportionate manner as necessary to protect Tipp FM property against theft or pilferage and for the security of employees and visitors to the Tipp FM premises (to protect their vital interests). Whilst CCTV footage is monitored by Tipp FM security staff, access to recorded footage is strictly limited to authorised personnel. Footage is retained for 30 days, except where incidents or accidents have been identified in which case such footage is retained specifically in the context of an investigation of that issue. CCTV footage may be used in the context of disciplinary proceedings involving Tipp FM employees and to detect, establish and/or defend legal proceedings (to protect the vital interests of Tipp FM, staff and affected individuals). CCTV footage is not disclosed to third parties except where disclosure is required by law (such as for the purpose of preventing, detecting or investigating alleged offences) and in such instances disclosure is based on a valid request. Signage indicating that CCTV is in use displayed throughout the Tipp FM premises. To request a copy of CCTV footage, contact [email protected]. Your request will be considered in light of data protection law.
Disclosures/Recipients
Tipp FM discloses Personal Data to third parties in certain instances. For example, Tipp FM uses third party service providers for the processing of Personal Data for a number of purposes, including, to gauge programme audience numbers, to perform data analytics, to manage its email marketing communications, for the administration of competitions. These service providers are subject to a contractual obligation to only process Personal Data obtained from Tipp FM for purposes for which it was obtained and in accordance with Tipp FM’s instructions. Tipp FM will not provide your Personal Data to third parties who may contact you for direct marketing or promotional purposes unless you have consented to Tipp FM disclosing your Personal Data to such
third parties for that purpose. In certain circumstances Tipp FM will disclose personal data to other external third parties such as its professional advisors as necessary in the context of the performance of their services. Such recipients may include external legal advisors, auditors, actuaries, pension and tax advisors, pension administrators and other professional advisors. Disclosure of such data will take place for a variety of reasons including in order to ensure that Tipp FM meets its tax and other (including tax) obligations and in order performing its statutory objectives in the public interest. Tipp FM may also disclose personal data to its insurance providers in connection with legal claims and prospective legal claims or proceedings.
Data Retention
Tipp FM endeavours to ensure that Personal Data is retained for an appropriate period and no longer than necessary. Retentions of data is detailed in our Data Retention Policy.
Data Transfers outside the EEA
Tipp FM does not generally transfer any Personal Data outside the European Economic Area (“EEA”). However, in some cases Tipp FM may use carefully selected service providers, including certain cloud storage service providers, to perform certain functions which involves data transfers outside the EEA. Certain of Tipp FM’s service providers may also store Personal Data in data centres located outside the EEA. These service providers are subject to a contractual obligation to comply with applicable data protection law and to ensure that appropriate measures are put in place to ensure the protection of any personal data that is transferred outside the EEA.
Your Data Protection Rights
In certain circumstances, you have the following rights under data protection law in relation to your
personal data:
A right to access Personal Data held by Tipp FM
(a) Any individual has a right to make an access request, in writing, under data protection law for a copy of their Personal Data held by Tipp FM. Tipp FM may ask for further identification details to confirm your identity before the relevant information is.
(b) It should be noted that there are specific exemptions relating to accessing Personal Data held for journalistic, artistic and literary purposes, which may be relevant to Tipp FM.
Other data protection rights
(a) Rectification of inaccurate personal data;
(b) Erasure of personal data (also known as the “right to be forgotten”);
(c) Restriction of processing of persona data;
(d) Right to data portability;
(e) Right to object to processing of personal data.
However, under data protection law, these rights are available only in certain circumstances. If you
wish to exercise any of your data protection rights, please contact [email protected]. Please provide as
much detail as possible to enable us to respond to your request and to locate relevant personal data
about you
Information Security
In accordance with applicable laws, Tipp FM ensures that all Personal Data controlled by Tipp FM is
held securely using appropriate security measures including the following:
• Physical measures such as locked filing cabinets and offices containing Personal Data;
• IT security systems;
• Restricted access to Personal Data subject to approvals;
• Time limits on retention of personal data;
• Provision of targeted data protection training to employees, contractors and other staff who have access to and process Personal Data;
• Password restrictions on access to Personal Data; and
• Technical measures including:
• Encryption on Tipp FM laptops; and other portable Devices
• Logging mechanisms to record certain access to Personal Data and alteration and other processing of Personal Data
In the event of a personal data breach, Tipp FM will comply with applicable reporting and notification
obligations under data protection law.
Contact Us/Complaints
If you wish to make a complaint about Tipp FM’s data protection practices, please contact the Designated Privacy Person at [email protected]. You may also lodge a complaint to the Data Protection Commission at the following;
Data Protection Commission
Canal House, Station Road
Portarlington
Co. Laois, R32 AP23
Telephone +353 761 104800 or email: [email protected] (https://www.dataprotection.ie/docs/Raise-a-Concern/1716.htm).
