Privacy Policy

Wey Valley Radio (Alton) Ltd · Company no. 09822128 · ICO registration ZC132136 · Version 1.2 · Approved by the board · Last updated 10 November 2026

Who we are

Wey Valley Radio (Alton) Ltd (known as Wey Valley Radio) is a not for profit company limited by guarantee, operated by volunteers and established for the benefit of the local area around Alton in Hampshire.

Our registered company number is 09822128 and our registered office is at 3 Amery Street, Alton, England GU34 1HN. We are registered with the Information Commissioner’s Office (ICO) under registration reference ZC132136.

This privacy policy explains how we collect and use information about you when you interact with our project and its services. If you have any questions about this privacy policy or how we process your information, please email [email protected]

This privacy policy has been prepared in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, which together form the primary framework for data protection law in the United Kingdom. Our processing of your personal information is governed by these laws, and we are committed to handling your data in a way that is lawful, fair and transparent.

Information we collect

The information we collect depends on how you interact with Wey Valley Radio. We have set out below what we collect from each group of people we deal with, why we collect it, and the lawful basis on which we process it.

Visitors to our website

When you visit https://weyvalleyradio.uk/, we may collect:

• Technical information such as your IP address, browser type, and device type, gathered automatically through standard web analytics
• Information about pages you visit and how long you spend on them
• Any information you choose to provide if you contact us through the site or sign up to a mailing list

Lawful basis: Legitimate interests (to understand how our website is used and improve it) and, where applicable, consent (for non-essential cookies and mailing list sign-ups).

Listeners who contact the station

When you phone, email, message us on social media, or write to us, we may collect:

• Your name and contact details
• The content of your message and any related correspondence

Lawful basis: Legitimate interests (to respond to your communication and keep a record of station correspondence).

If you phone the studio, your call is recorded. See “Calls to and from the studio” below.

People who send us news stories

When you use the “Send us a story” form on our website, we collect:

• Your name, email address and, if you give it, your phone number
• Whether you are willing to be named as the source of the story
• The story itself: the headline, your description, when and where it happened, any link, and any files you attach
• A check that the form was submitted by a person rather than an automated program, provided by Cloudflare Turnstile (see “Cookies” below)

We use this to assess the story, to contact you to check details or ask for more, and to keep a record of where a story came from. We may broadcast or publish the information you send us. We will not name you on air or online unless you have told us we may, and if you asked us to check first, we will. If you ask to stay anonymous, we still hold your details so that we can contact you and stand behind what we broadcast, but we will not pass them to anyone outside the news team, including anyone the story is about.

Stories and attachments often contain information about other people. We handle that information under the journalism provisions of the Data Protection Act 2018, which allow us to receive, assess and, where it is in the public interest, broadcast it. Please do not send us details of anyone’s health, beliefs or other private matters unless they are essential to the story.

Lawful basis: Legitimate interests (gathering and verifying news as a licensed broadcaster, and keeping a record of our sources). The choice you make on the form about being named is how we record your permission to identify you.

Competition and prize draw entrants

When you enter a competition or prize draw that we run, we may collect:

• Your name or social media username
• The content of your entry, which may include the name of your business
• Your contact details, if you win, so that we can award the prize
• A record of the entry list and of how the winner was selected

Lawful basis: Consent, which you give by entering after being told how your information will be used, for administering the promotion and awarding the prize. Legitimate interests, for retaining a record of the draw so that we can show it was run fairly if we are asked. Where a prize is provided by a third party, we share only the information needed for that party to issue the prize, and the terms of the individual promotion will say so.

Programme contributors, guests and interviewees

When you appear on or contribute to a Wey Valley Radio programme, we may collect:

• Your name and contact details
• A recording of your contribution
• Background information you provide for the programme

Lawful basis: Consent (for the recording and broadcast of your contribution) and legitimate interests (for keeping a record of contributors).

News contacts

Our news team keeps a contacts list of people we speak to for local news stories: for example council officers, emergency services, schools, businesses, charities and the organisers of community groups and events. When you are on this list we hold:

• Your name, organisation and role
• The email address and phone number you have given us
• The subjects you can speak about and brief professional notes, such as the best time to call
• A record of when we last contacted you and about which story

Lawful basis: Legitimate interests (keeping a working list of sources so that we can produce accurate local news). Where you act for a community group or are a private individual rather than speaking in a professional or public role, we ask you first and record your agreement.

Only the news team can see this list, which is held on the station’s own secure system. We do not use it for marketing or share it with anyone else. We remove anyone we have not contacted for two years, and you can ask to be removed at any time by emailing [email protected] or telling any of our reporters.

Donors and supporters

When you make a donation or financially support the station, we may collect:

• Your name and contact details
• The amount and date of your donation
• A record of how the donation was made

Donations are processed by PayPal. When you donate, your payment details are handled directly by PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A.) under their own privacy terms (https://www.paypal.com/uk/legalhub/privacy-full). We do not receive or store your full card details.

Lawful basis: Legitimate interests (for thanking supporters and maintaining donor records) and, where you tell us how you wish to be contacted in future, consent.

Advertisers and commercial partners

When you advertise with us or work with us commercially, we may collect:

• Business contact details
• Records of the commercial relationship and payments

Lawful basis: Contract (to deliver the agreed services) and legal obligation (for financial and tax records).

Volunteers

When you register as a volunteer with Wey Valley Radio, we collect more detailed information because of our regulatory duties as a licensed broadcaster and our duty of care to volunteers, listeners, and the wider community. We collect:

Basic contact and identification information:

• Full name
• Home postcode
• Email address
• Mobile telephone number
• If you work alone at our studio, the name and phone number of an emergency contact, which we use only if we cannot reach you

Volunteering information:

• Preferred volunteer role(s)
• Skills, experience and previous broadcasting or related work
• Availability and time commitments

Special category data (collected with explicit consent):

• Health conditions and disabilities relevant to your safety and our ability to make reasonable adjustments
• Personal circumstances we should be aware of

Criminal offence data (collected where lawfully required):

• Information about unspent criminal convictions
• Consent to undertake a DBS check where required for your role

Compliance and consent records:

• Signed declarations confirming you have read our broadcast regulations and station policies, including the studio access declaration, and a record of the studio briefing you have had
• Specific consents for data processing
• Date of joining and date of any subsequent annual renewals

Programme monitoring records:

• Reports on shows reviewed after broadcast, recording the show, the date, the presenter, what the reviewer heard and checked, and any advice or follow-up
• Where a report is referred to the board, the board’s decision and any action taken
• The weekly Character of Service log, which records which volunteers carried out that week’s monitoring and their assessment of the station’s output

Monitoring reports describe what was broadcast. They occasionally record something a presenter or guest said on air, for example an opinion expressed during a show.

We review shows after broadcast to meet our obligations under our Ofcom licences and the Ofcom Broadcasting Code, including our commitment to monitor our character of service every week, and to support presenters. Talk-based shows are reviewed every time, soon after broadcast; a new presenter’s shows are reviewed during their first four weeks on air; other presenter-led shows are chosen at random; continuous music and automated programming is not reviewed. Presenters are not told when a particular show is being reviewed, because that would defeat random selection.

Monitoring reports are seen by the volunteer reviewer who wrote them, the board and our compliance officer. They are not shared with other volunteers, and reviewers cannot see any other volunteer records. If a report leads to any action, the presenter concerned is told what was found and can respond. Reviewers are asked to record only what is needed to assess compliance, and to write knowing that the presenter may ask to read the report.

Each year we publish a summary of our Character of Service monitoring on our website, as our Ofcom licence requires. The summary describes how the station’s output met our commitments. It does not name presenters or include individual monitoring reports.

Social gain log:

When you take part in a community activity on behalf of the station – a training session, an event, a workshop, a visit – we record your name against that activity in our social gain log, including whether you led it. We do this so the board can see how volunteers are contributing and support them fairly, and so we can plan and recognise volunteer effort. Our lawful basis is our legitimate interest in managing the station and its volunteers. These names are seen only by the board and the compliance officer. They are never published and are not part of the figures we report to Ofcom, which are totals only. The record is kept for as long as the social gain log is kept, which is for the life of our broadcasting licences plus one year, as evidence for Ofcom. You can ask to see what is recorded about you, or to have your name removed from an activity, by contacting the Data Protection Lead.

Lawful bases for volunteer data:

• Legitimate interests – for managing the volunteer relationship and meeting our duties as a broadcaster
• Legitimate interests – for programme monitoring, as part of operating as a responsible licensed broadcaster
• Legitimate interests – for recording your part in community activities in our social gain log
• Article 9(2)(e) UK GDPR – where a monitoring report records an opinion someone expressed on air that is special category data (for example a political opinion), because the person made it public themselves by broadcasting it
• Legal obligation – where we are required to retain certain records to comply with our Ofcom licence
• Explicit consent (Article 9 UK GDPR) – for health and disability information. You may withdraw this consent at any time by contacting our Data Protection Lead, though doing so may affect our ability to ensure your safety in volunteer activities
• Schedule 1, Part 2, paragraph 18 of the Data Protection Act 2018 (Article 10 UK GDPR) – for criminal conviction and DBS information, which we process for safeguarding purposes to protect children and individuals at risk who interact with the station

Anyone in our studio – CCTV

Our studio at the Alton Assembly Rooms is covered by CCTV. Two cameras record images and sound. Recording is triggered by movement, so it runs whenever someone is in the room. Signs are displayed at the entrance and inside the studio.

This applies to everyone who comes into the studio – volunteers, directors, guests, contributors and contractors.

We use it for four purposes and no others: the security of the premises and our equipment; the safety of volunteers working alone, since the studio is used from early morning until late at night and often by one person in a building where nobody else is present; helping a presenter who has asked for technical support, where seeing the desk and talking to them is quicker than working out a fault over the phone; and to provide context if a compliance matter is being investigated by us or by Ofcom.

We do not monitor how volunteers do their jobs, we do not use recordings as a record of attendance, and nothing recorded is broadcast. Recordings are looked at only where there is a specific reason – a security or safety incident, or an identified compliance matter – and only with the authorisation of our Data Protection Lead, who keeps a log of every occasion a recording is viewed.

If you are a volunteer working alone and we cannot reach you when you are due to have left, the person acting as your Nominated Contact may look into the studio through the camera and speak to you, to check that you are safe. This happens only in that situation, and it is logged like any other access.

If you ask for help with the desk or the playout system, someone may look at the studio through the camera and talk you through it. This happens only when you have asked for help, you can hear and answer whoever is helping, and nothing is viewed afterwards.

Because sound is recorded, conversation in the studio is captured, including conversation unrelated to what is being broadcast. If you are a volunteer, you should also know that a recording may be used in an investigation concerning your own conduct. We would rather say so plainly here than have you discover it later.

Recordings are held on the cameras themselves. We are moving them to a server we own and control in the United Kingdom. We do not use any cloud service to store footage.

When someone views the cameras live – for a welfare check or to help with a technical problem – the live picture and sound currently pass through the camera manufacturer’s servers, which may be outside the United Kingdom. Nothing is stored there. We are changing this so that live viewing also stays on our own systems.

Lawful basis: Legitimate interests (the security of our premises, the safety of people working alone, helping volunteers with technical problems they have asked for help with, and our ability to meet our obligations as an Ofcom licensee). You have the right to object to processing carried out on this basis – see “Your data protection rights” below. We have carried out a data protection impact assessment for this system, which is available on request.

Anyone visiting our studio – sign-in records

Everyone entering our studio signs a sheet recording the date, their name, whether they are a volunteer or a guest, the reason for the visit, and the times in and out. When the Assembly Rooms is open we also slide a marker on the in/out board by the entrance, so that building staff and the fire service know we are in the building. The board records only that Wey Valley Radio is present, not who.

We keep these records so that we know who is in the building in an emergency, so that the fire service can be told, and so that we can raise the alarm if a volunteer working alone does not leave when expected.

Where a visit is booked in advance through our studio booking form, the booking records the same details and whether anyone attending is under 18, so that our Safeguarding Lead can make the arrangements our Safeguarding Policy requires.

Lawful basis: Legitimate interests (health and safety, security and emergency response).

Volunteers holding keys

Where a volunteer is issued a physical key to our studio, we record their name, their role, what they hold and the dates it was issued and returned. Key safe codes are given to every active volunteer, so our volunteer register is the record of who holds them and we keep no separate list. We never record the codes themselves, and when a code is changed we record only the date of the change.

Lawful basis: Legitimate interests (security of the premises and our equipment).

Calls to and from the studio

Our studio phone number is 01420 260001. All calls into and out of the studio are recorded, including the part of the conversation that is not broadcast. We tell every caller this at the start of the call, and before anyone goes on air we explain our rules for callers.

What we collect

• A recording of the whole call.
• The phone number of anyone who calls the studio, and any number we call from the studio.
• The date, time and length of each call.
• Anything you tell us during the call, such as your first name or where you’re calling from.

Why we collect it

We record calls so that we have an accurate record of what was said. That record helps us to:

• deal with complaints, including any complaint made to Ofcom;
• meet our obligations under the Ofcom Broadcasting Code;
• protect our callers, presenters and volunteers, including for safeguarding purposes;
• deal with abusive or nuisance calls.

Our lawful basis

Our lawful basis for recording calls and logging numbers is legitimate interests (UK GDPR Article 6(1)(f)). We have a legitimate interest in running a well-managed, accountable radio station and in keeping a record we can rely on if a complaint or concern is raised.

Anything broadcast on air also becomes part of our output. We keep recordings of our output to meet our obligations under our Ofcom licence (legal obligation, Article 6(1)(c)).

What we don’t do

• We don’t use your phone number for marketing.
• We don’t add your number to any mailing list.
• We don’t pass your details to anyone else for their own use.
• We will only call you back about your call.

Sensitive information

Please don’t share personal details about your health, beliefs or other sensitive matters on a call unless you are happy for them to be recorded. If you do share them, we will only use them for the purposes above.

Callers under 18

Our presenters are asked not to take personal details from callers who sound under 18. Any safeguarding concern is passed to our Safeguarding Lead.

Who can access recordings and call logs

Recordings and the call log are sent automatically to a mailbox managed for the station by the volunteer who administers our phone service, and are seen only by a small number of authorised volunteers. We may share a recording with Ofcom, or with the police, where the law requires us to or where it’s needed to deal with a complaint or protect someone from harm.

Our phone service is provided by a specialist internet telephony company, which processes call data on our behalf.

How long we keep it

• Call recordings and call logs: kept for 42 days, then deleted.
• Recordings needed for a complaint: kept until the complaint, any appeal and any Ofcom process are finished, and then for 12 months, as set out in our Complaints Procedure. Recordings needed for a safeguarding matter: kept until that matter is closed, then deleted.

Your rights

You can ask for a copy of a recording of your call, or ask us to delete it. You can also object to us holding it. We may not be able to delete a recording while it is needed for a complaint, a safeguarding matter or a legal obligation. To make a request, contact our Data Protection Lead at [email protected].

What do we use your information for?

We use your personal information to:

• communicate with you about project activities if you have signed-up as a volunteer or supporter
• update you about our project and its work in the community if you have contacted us as a listener
• inform you about events, services and promotions if you have given your express consent
• enable you to log in to your account if you have one
• use third party communication tools
• enable you to enter competitions should we run any
• assess, verify and follow up news stories sent to us

We may also process your personal information if we have a legitimate interest to:

• analyse, measure and improve the services we offer
• help prevent fraud and loss
• train our volunteers subject to appropriate confidentiality obligations being observed
• comply with relevant regulatory obligations
• keep a record of how a competition or prize draw was run, so that we can show it was administered fairly
• record calls to and from the studio, so that we have an accurate record if a complaint or concern is raised

Third-party communication tools

To help us coordinate our volunteer activities and deliver our services, we use a number of third-party communication and collaboration platforms. These platforms may process your personal information on our behalf or under their own terms, as set out below.

Facebook and Instagram – we run a Wey Valley Radio page on Facebook and an account on Instagram. If you comment on our posts, send us a message, or enter a competition we run on those platforms, your information is processed by Meta Platforms Ireland Ltd under Meta’s own Privacy Policy (available at https://www.facebook.com/privacy/policy). We have no control over how Meta processes information you share with them directly. Any competition we run on Facebook or Instagram is not sponsored, endorsed, administered by, or associated with Meta.

WhatsApp – some of our teams use WhatsApp groups for day-to-day communication. If you are added to one of these groups, your name and phone number will be visible to other group members, and your messages will be processed by Meta Platforms Inc. under WhatsApp’s Privacy Policy (available at https://www.whatsapp.com/legal/privacy-policy). We will always ask for your agreement before adding you to a WhatsApp group.

Google Workspace – we may use Google tools such as Gmail, Google Drive or Google Meet to communicate with volunteers and store documents. These services are provided by Google LLC and your information may be processed under Google’s Privacy Policy (available at https://policies.google.com/privacy).

Zoom – we may use Zoom to host volunteer meetings, training sessions or other online events. If you participate in a Zoom call, your name, email address and any information you share during the session will be processed by Zoom Video Communications Inc. under Zoom’s Privacy Policy (available at https://zoom.us/privacy). We will let you know in advance if a session is being recorded, and will ask for your agreement before doing so.

Dropbox – we may use Dropbox to store and share documents and other files relevant to our activities. If you are given access to our Dropbox, your name and email address will be processed by Dropbox Inc. under Dropbox’s Privacy Policy (available at https://www.dropbox.com/privacy). Access is granted only to volunteers who need it for their role and is removed when you leave.

Slack – if you volunteer with us, we may invite you to join a Slack workspace to communicate with other volunteers and coordinate activities. By accepting that invitation, your name and email address will be processed by Slack Technologies LLC under the terms of Slack’s own Privacy Policy (available at https://slack.com/intl/en-gb/privacy-policy). Participation in our Slack workspace is voluntary but may be necessary to fulfil certain volunteer roles effectively.

Studio phone service – calls to and from the studio are carried by a specialist internet telephony company, which processes call data on our behalf. See “Calls to and from the studio” above.

We take reasonable steps to ensure that any third-party platform we use provides an adequate level of protection for your personal information. However, once your information is processed by these platforms, it is also subject to their own privacy policies and terms of service, which we encourage you to read.

What is our lawful basis for processing your information?

Under UK data protection law, we are required to have a lawful basis for processing your personal information. We rely on the following bases:

Consent – where you have freely given us your permission to do so. We rely on consent when we:

• send you updates about our project and community work (if you have contacted us as a listener)
• inform you about events, services and promotions
• enable you to enter competitions
• share your information with competition sponsors

You may withdraw your consent at any time by contacting us at [email protected]. Withdrawing consent will not affect the lawfulness of any processing we carried out before you withdrew it.

Legitimate interests – where we have a genuine and proportionate business or organisational reason to process your information, and that reason is not overridden by your rights and interests. We rely on legitimate interests when we:

• analyse, measure and improve the services we offer
• help prevent fraud and loss
• train our volunteers, subject to appropriate confidentiality obligations
• gather, verify and follow up news stories sent to us through our website
• keep a list of news contacts so that our news team can reach the right people when a local story breaks
• keep a record of how a competition or prize draw was run and who won it, so that we can respond to a query from a regulator such as the Advertising Standards Authority. We may need to keep this record even if you later withdraw your consent, because without it we could not show the promotion was run fairly
• record calls to and from the studio and keep a log of call numbers, dates and times
• review shows after broadcast, to meet our obligations under our Ofcom licences and the Broadcasting Code and to support our presenters
• record which volunteers took part in community activities on behalf of the station, so that the board can support volunteers fairly and recognise their effort

We have assessed that our legitimate interests are not overridden by your rights and freedoms, taking into account the nature of the information processed and the reasonable expectations of the individuals concerned. Where we rely on legitimate interests, you have the right to object to that processing. Please contact us at [email protected] if you wish to do so.

Legal obligation – where we are required to process your information to comply with the law. We rely on this basis when we share your information with law enforcement agencies, regulators or other governmental bodies where we are legally required to do so, and when we keep recordings of our broadcast output as required by our Ofcom licence.

For some processing we rely on additional bases. Where we collect health or disability information (special category data under Article 9 UK GDPR), we rely on explicit consent. Where we collect criminal record or DBS information (criminal offence data under Article 10 UK GDPR), we rely on the safeguarding condition in Schedule 1, Part 2, paragraph 18 of the Data Protection Act 2018. Where a programme monitoring report records an opinion that is special category data, expressed by a presenter or guest on air, we rely on Article 9(2)(e) UK GDPR, because the person has made it public themselves. The “Information we collect” section above sets out which basis applies to which group.

Cookies

Our website generates cookies. A cookie is a small text file that we place on your device when you visit us. Cookies allow us to measure activity on the website and to make it work better for you. We do not use information transferred through cookies for marketing purposes, nor is that information shared with any other organisation.

We use Cloudflare Web Analytics to understand how our website is used. This is a privacy-focused analytics service that does not use cookies, does not track you across websites, and does

Forms on our website use Cloudflare Turnstile to check that submissions come from a person rather than an automated program. Turnstile processes technical information about your browser and connection for that purpose only, under Cloudflare’s privacy policy (available at https://www.cloudflare.com/privacypolicy/).

not collect any personal data that could identify you. No analytics information is shared with any advertising network.

You can set your browser to refuse cookies but parts of the site will not function properly if you do.

Children

We do not knowingly collect data from children under 13 for general use. This threshold reflects the minimum age at which individuals can generally consent to their data being processed online. For volunteer roles, a higher threshold applies – anyone under 18 requires parental or guardian consent before taking part, in line with our safeguarding responsibilities.

Competitions and prize draws we run may carry their own minimum age, which will be set out in the terms of the individual promotion.

Our “Send us a story” form is intended for adults. If it is clear a story has come from someone under 18, we will not name them, we will contact a parent or guardian before using it, and any safeguarding concern is passed to our Safeguarding Lead.

Children who visit our studio as guests are recorded by our studio CCTV, including sound, like everyone else. We tell the accompanying parent or carer before the visit, and we require their written consent to it.

We will hold this information together with the information relating to the child under the terms of this policy.

With whom do we share your information?

We may share your information in the following circumstances:

• to enable us to comply with the law if requested or obliged to do so by law enforcement agencies, regulatory or other governmental bodies
• with our legal advisors to enable us to fulfil our legal obligations and protect or defend our legal rights
• if we need to share information with providers who perform services on our behalf subject to a satisfactory sub-processing agreement being signed in advance
• to connect you with project volunteers to help us make our programmes or organise events
• if you enter a competition we may provide your information to competition sponsors if you have given your prior consent. If you win a prize we may share the relevant information with sponsors to enable the prize to be awarded
• in the event that we transfer all or a portion of company assets we reserve the right to transfer the information we have about you

For how long do we keep your information?

We will only keep your information for as long as it is necessary for the purpose for which it was collected. Different groups have different retention periods, set out below.

Website analytics

Aggregate website analytics are retained in line with our analytics provider’s standard retention period and contain no information that identifies you.

Correspondence from listeners

Routine correspondence is retained for up to 2 years. Correspondence about a complaint is kept with the complaint record (see below).

Complaints

The complaints log and the file for each complaint (correspondence, written accounts, notes and the decision) are kept for 6 years from the date the complaint is closed, or for 12 months after any Ofcom investigation ends, whichever is later. After that the log entry is anonymised: the name and contact details are removed and only the outcome is kept, so that we can report on trends. A recording of the programme complained about is kept until the complaint, any appeal and any Ofcom process are finished, and then for 12 months. Full details are in our Complaints Procedure.

News stories sent to us

A story we use is kept as part of our programme records, in the same way as other contributor records. Your contact details are removed from it 12 months after the story was last broadcast, unless you have agreed to be kept as a news contact. A story we do not use is deleted, with any attachments, 6 months after we decide not to use it. The copy of your submission held on our website is deleted automatically once our newsroom system has received it, and in any case within 30 days.

Studio call recordings and call logs

Call recordings and call logs are kept for 42 days, then deleted. A recording needed for a complaint is kept until the complaint, any appeal and any Ofcom process are finished, and then for 12 months. A recording needed for a safeguarding matter is kept until that matter is closed, then deleted.

Competition and prize draw entries

Entry records, including the list of entrants and the record of how the winner was selected, are retained for 12 months after the closing date. This allows us to administer the promotion, award the prize, and respond to any query from the Advertising Standards Authority or another regulator. The winner’s details are retained for the same period. After 12 months, entry records are deleted.

Programme contributor recordings and records

Recordings and contributor records are retained for the lifetime of the programme archive, or as long as we hold a broadcast licence, whichever is shorter.

Separately, our logger keeps a recording of everything we broadcast for 42 days, as our Ofcom licence requires, and it is then overwritten. Where a programme is the subject of a complaint, its recording is kept as set out under “Complaints” above.

News contacts

News contact records are reviewed annually. We delete a contact when we have not been in touch with them for two years, when their role ends and we no longer need the details, or when they ask us to. Where a contact is linked to a story we have broadcast, the broadcast record keeps the name as it aired but the contact details are deleted.

Donor records

Donor records are retained for 6 years in line with the statutory limitation period for financial matters and our own accounting needs. After this period, only anonymised donation totals are retained for reporting purposes.

Advertiser and commercial partner records

Commercial records are retained for 7 years to meet financial and tax reporting obligations. After this period, only anonymised summaries are retained for our own records.

Volunteer records

We apply tiered retention to volunteer data, based on the sensitivity of the information and the purpose for which it was collected.

A volunteer is considered to have left when one of the following occurs:

• They submit our Volunteer Leaver’s Form confirming their departure
• They confirm departure by email or in person to a member of management
• They remain Lapsed (failure to renew annual compliance agreement) for six months without re-engagement

From the date of leaving:

Special category and criminal offence data (deleted within 14 days):

• Health and disability information
• Personal circumstances information
• Criminal record and DBS information
• Special category data consents

Standard personal data (deleted within 12 months):

• Contact details (name, postcode, email, mobile)
• Volunteer role, skills, experience, availability records
• Signed compliance declarations

Indefinitely retained (audit trail only):

• The fact that a volunteer was registered with us, and the dates of their compliance renewals
• A record that data has been deleted, with the date of deletion

Exceptions:

• Where a safeguarding concern exists, we retain the relevant records for the period set out in our Safeguarding Policy
• Where we are legally required to retain information for longer (for example for the defence of legal claims), we retain only the specific data needed for that purpose

Programme monitoring records (whether or not you are still volunteering):

• Monitoring reports where no action was needed, or that led only to informal advice: 2 years from the broadcast
• Monitoring reports that led to a warning or other action decided by the board: 6 years from the decision, or 12 months after any Ofcom investigation ends, whichever is later – the same as a complaint file
• Where a monitoring report becomes part of a complaint, it is kept with the complaint file for as long as that file is kept
• The weekly Character of Service log: for the life of our broadcasting licences plus one year, as evidence for Ofcom. Entries name the volunteers who did the monitoring
• Assignments telling a reviewer which show to listen to: 90 days

Social gain log (whether or not you are still volunteering):

• Your name against a community activity you took part in or led: for as long as the social gain log is kept, which is the life of our broadcasting licences plus one year, as evidence for Ofcom

Studio CCTV

Our intended retention period is 42 days. This matches the period for which we are required to keep recordings of our output under our Ofcom licence, so that a recording still exists for as long as a complaint about the same broadcast could reach us. Until recording moves to our own server, recordings are overwritten automatically as the cameras’ storage fills, and the period actually achieved may be shorter than 42 days; we are measuring it and will update this policy with the figure. Where a recording is kept longer because it is needed for an identified incident, investigation or claim, that is recorded and the material is deleted once it is no longer needed.

Studio sign-in records

Completed sign-in sheets are retained for 12 months and then destroyed.

Key records

Records of who held a physical key are retained for 12 months after the key is returned. There is no separate record of who holds the key safe code; that falls under volunteer records above.

Where do we hold your information?

We process your information on systems which may store data outside the UK and the EU, such as cloud-based file management or commercial email platforms. We protect data held on all cloud-based systems through multi-factor login and encrypted data transfer.

Our newsroom system, our programme monitoring records and our email are run on servers we control in the United Kingdom.

Studio CCTV recordings are held on the cameras themselves, and we are moving them to a server we control in the United Kingdom. See “Anyone in our studio – CCTV” above for how live viewing is currently routed.

Where your information is transferred outside the UK, we take steps to ensure that appropriate safeguards are in place to protect it, in accordance with our obligations under UK GDPR Article 46. These safeguards may include standard contractual clauses approved by the UK Information Commissioner, or transfers to countries that benefit from an adequacy regulation made by the UK Secretary of State. If you would like more information about the safeguards we rely on, please contact us at [email protected].

External links

Our website contains links to other organisations, such as local councils, the police, the NHS and community event listings. We are not responsible for the content or privacy practices of these external websites.

Your data protection rights

Wey Valley Radio (Alton) Ltd. is a Data Controller under UK data protection legislation, registered with the Information Commissioner’s Office under registration number ZC132136. Our Data Protection Lead is Julie Cottrell, who is a Director of the station.

If you have any questions about how we use your personal information, or wish to exercise any of the rights listed below, you can contact us by:

• Email: [email protected]
• Post: 3 Amery Street, Alton, Hampshire, GU34 1HN

We do not make decisions about you based solely on automated processing. This means that no decision which significantly affects you will ever be made by an automated system without human involvement.

Under these laws you have the right to:

• request access to the information we hold about you. If you wish to submit a request, please contact [email protected]
• request the restriction of use of your information in certain circumstances
• have your information corrected, erased or moved (if the processing is based on consent)
• object to processing of your information
• request a copy of your information in a structured, machine-readable format (right to portability), where applicable
• withdraw your express consent to processing at any time where such consent is the basis of processing
• make a complaint to the Information Commissioner at ico.org.uk/make-a-complaint if you have concerns about how we use or process your information.

If you have been recorded by our studio CCTV, you may ask for a copy of that footage. Where other people appear or can be heard, we may need to obscure them or withhold part of the recording to protect their privacy. Because we keep recordings for only 42 days, a request made after that period may find that the footage no longer exists; we will tell you promptly if that is the case.

Full details of how to raise a data protection complaint with us, and what happens next, are set out in our Data Protection Complaints Procedure.

We hope that you would contact us first so we can deal with any concerns at [email protected]

Updates

We will update this policy from time to time. It was last updated on 10 November 2026.