Our Privacy Notice - Radio Cayman One

1. Scope

The Cayman Islands Government department Radio Cayman respects your privacy and takes care in protecting your personal data. As a data controller, we comply with the Cayman Islands Data Protection Act (2021 Revision) (the “DPA”). This privacy notice (“Privacy Notice”) demonstrates our commitment to ensuring your personal data are handled responsibly. It applies to Radio Cayman, the Community's Station that has been operating since 1976.

Radio Cayman is part of the Cabinet Office portfolio. This Privacy Notice does not apply to processing of personal data for human resources and finance functions, where the Cabinet Office as a Civil Service Entity is the data controller. Read more about the Cabinet Office, including privacy information, at gov.ky/cabinetoffice.

2. What Personal Data We Collect

Radio Cayman collects personal data directly from you and indirectly from third party sources. Personal data collected by Radio Cayman is limited to what is necessary for our processing activities.

In this Privacy Notice, personal data includes any data relating to an identified or identifiable living individual and includes your name, contact details, and photographs and videos where you are identified or identifiable.

Radio Cayman collects your personal data in various ways, including:

a. Personal data you provide through our website radiocayman.gov.ky, such as your Internet Protocol (“IP”) address, details of which device or version of web browser you used to access our website content, and other information about how you used our website (please see Section 9 in this Privacy Notice for more information about our use of Cookies and how you can control what personal data you provide);
b. Information you choose to provide when interacting with Radio Cayman through our social media channels, i.e. on Facebook @RadioCayman Choice, Instagram @RadioCayman, X @RadioCayman, and YouTube @RadioCaymanChoice (this includes personal data that you include in comments and direct messages as well as personal data that is accessible as a result of your engagement with the channel);
c. Personal data you or a third party provide when you or that third party visit the Radio Cayman premises at Broadcasting House, 111 Elgin Avenue, Grand Cayman and other locations; contact us by email, by telephone or through our social media channels; call into one of our talk shows; or otherwise access our various programmes and services, including our advertising, promotional and talk show services;
d. Personal data collected through CCTV or other monitoring and security mechanisms at Broadcasting House and other locations where we operate, if these data were collected directly by Radio Cayman or by any other data controller who may then lawfully disclose the data to Radio Cayman for a legitimate purpose (e.g. to investigate a breach of the law or a security incident); and
e. Any other personal data where the collection is necessary to achieve our lawful purpose(s).

3. How We Use Your Personal Data

Radio Cayman provides the Cayman Islands with a 24-hour broadcast service daily, including music, programming, talk shows, and the most extensive and credible local, regional and international newscasts. We broadcast live on:

a. Radio Cayman (89.9FM in Grand Cayman and 93.9FM in the Sister Islands), the premier station for news, information and music 24 hours per day;
b. Breeze FM (105.3FM in Grand Cayman and 91.9FM on Cayman Brac), the all music station broadcasting a magical mix of Pop, Soca, Latin, Reggae, Religious and Country music all day long; and
c. Our various social media channels described in section 2 above.

In delivering on our mission, Radio Cayman may use your personal data for the following purposes:

a. Implementing policies, providing services and programmes, and managing your relationship with us;
b. Selling, arranging, organising, producing, delivering and broadcasting advertising content, programming, news, community announcements and public service announcements on our various channels;
c. Researching, investigating, publishing and broadcasting journalistic materials;
d. Responding to your enquiries;
e. Verifying your identity;
f. Measuring how users interact with Radio Cayman’s website and social media channels and continually improving our broadcasting and communications channels;
g. Sending you marketing communications;
h. Communications and public relations activities;
i. Media relations activities;
j. Statistical and other reporting, both internally and externally;
k. Seeking legal advice, and exercising or defending legal rights; and
l. Complying with our legal obligations, including all legislation that applies across the public sector, e.g. legislation that provides for records and information management.

4. How We Share Your Personal Data

Radio Cayman may share your personal data as required, including under applicable legislation, with recipients that include our data processors, and third parties. We will only share your personal data as permitted by the DPA.

Your personal data may be shared with the following recipients that support our public functions and operations:

a. With other public authorities: Personal data may be shared with other public authorities – here, “public authorities” means Ministries, Portfolios, Offices, Departments, Statutory Authorities, Statutory Bodies and Government Companies – for the purposes set out in this Privacy Notice.
b. With data processors external to the CIG: Personal data may be shared with persons providing services to Radio Cayman as a data processor in compliance with the DPA. When they are acting as data processors, these service providers are only able to use personal data under our instructions. We engage data processors for a variety of processing activities, which may include:
1. i. Webhosting;
2. ii. Information Technology;
3. iii. Records and Information Management, including storage facilities;
  iv. Communications;
4. v. Marketing and campaigns;
5. vi. Events management; and
6. vii. Security operations and fraud prevention.
c. With legal advisors and other persons if required by law or in relation to legal proceedings or rights: Personal data may be disclosed as legally required, for the purpose of or in connection with proceedings under the law, if necessary to obtain legal advice, or if the disclosure is otherwise necessary to establish, exercise or defend legal rights. This may include disclosing your personal data for the following purposes:
1. i. Seeking legal advice;
2. ii. Exercising or defending legal rights;
3. iii. Complying with internal and external audits or investigations by competent authorities; and
4. iv. Complying with information security policies or requirements.
d. With other third parties: Personal data may be disclosed to other third-party recipients for the purposes set out in this Privacy Notice and in accordance with the DPA.

5. Our Legal Bases for Processing Your Personal Data

Depending on applicable laws and other circumstances, Radio Cayman will rely on specific legal bases, or “conditions of processing”, under the DPA to process your personal data. These may include:

a. A legal obligation to which Radio Cayman is subject;
b. To exercise public functions;
c. To perform or enter into a contract with you, e.g. for advertising services;
d. To protect your vital interests;
e. Consent; and
f. For the purposes of legitimate interests pursued by Radio Cayman or by a third party or parties to whom the personal data may be disclosed, e.g. when broadcasting or publishing news and other programming that includes photographs, videos and/or audio recordings that include personal data.

Where we process your sensitive personal data, we will also meet a second legal basis. These may include:

a. To exercise our public functions;
b. In relation to legal proceedings, including obtaining legal advice and otherwise establishing, exercising or defending legal rights;
c. To protect your vital interests; and
d. If you have taken steps to make the personal data public.

6. Security and International Transfers

Radio Cayman has put in place appropriate technical, physical and organisational measures in order to keep your personal data secure. These safeguards to maintain the confidentiality, integrity and availability of your personal data may include:

a. Developing and maintaining written plans to identify, prevent, detect, respond to, and recover from security threats, events and incidents;
b. Developing robust authentication procedures for accessing all systems that store personal data;
c. Administrative and technical controls to restrict access to personal data on a “need to know” basis;
d. Maintaining systems, software and applications, anti-virus software, firewalls, and other computer security safeguards, and appointing appropriate personnel to be responsible for keeping such safeguards up to date, including through actions such as patching, license renewals/expiry monitoring, system health checks and account/user access management;
e. Contractually requiring that our Data Processors maintain appropriate security measures;
f. Maintaining appropriate records of access to and processing of personal data;
g. Ensuring employees are trained on security policies and measures that have been implemented;
h. Using appropriate measures, such as encryption, pseudonymisation and chain of custody records, to protect personal data, including when stored on laptops, tablets and other storage devices;
i. Utilising appropriate and secure methods to destroy personal data as legally required; and
j. Taking other reasonable measures as required at any time by legislation, rules and policies.

Radio Cayman will only transfer your personal data to a country or territory that ensures an adequate level of protection for your rights and freedoms in relation to the processing of your personal data, unless there is a relevant exemption or exception under the DPA. Exceptions may include your consent or appropriate safeguards.

7. How Long We Keep Your Personal Data

Radio Cayman may store your personal data for as long as we need it in order to fulfil the purpose(s) for which we collected your personal data, and in line with any applicable laws. This includes the National Archive and Public Records Act (2015 Revision), which governs the creation, maintenance and disposal of all public records. Sometimes, we may anonymise your personal data so that it is no longer associated with you.

8. Your Rights

Radio Cayman will respect and honour your rights in relation to your personal data and implement measures that allow you to exercise your rights under the DPA and other applicable legislation.

In accordance with the DPA, your rights in relation to your own personal data include:

a. The right to be informed and the right of access: The right to request access to all personal data Radio Cayman maintains about you as well as supplementary information about why and how we are processing your personal data. This is commonly known as a Data Subject Access Request and certain supplementary information about our processing is contained within this Privacy Notice.
b. Rights in relation to inaccurate data: The right to request the rectification, blocking, erasure or destruction of any inaccurate personal data Radio Cayman maintains on you. We will ensure, through all reasonable measures, that your personal data is accurate, complete and, where necessary, up‑to‑date, especially if it is to be used in a decision-making process.
c. The right to stop or restrict processing: The right to restrict or stop how Radio Cayman uses your personal data in certain circumstances.
d. The right to stop direct marketing: The right to cease the use of your personal data by Radio Cayman for direct marketing purposes.
e. Rights in relation to automated decision making: The right to obtain information about and object to the use of automated decision making by Radio Cayman using your personal data. Radio Cayman does not currently use automated means to make decisions about you. However, we will update this Privacy Notice and we will also notify you in writing as required if this position changes.
f. The right to complain: The right to complain to the Ombudsman about any perceived violation of the DPA by Radio Cayman.
g. The right to seek compensation: The right to seek compensation in the Court if you suffer damage due to a contravention of the DPA by Radio Cayman.

You may contact Radio Cayman, using the contact details listed below, to access and review your personal data or to exercise any other rights provided to you under the DPA. Radio Cayman will take into consideration circumstances where, under the DPA or other applicable legislation, your rights may be limited or subject to conditions, exemptions or exceptions. In particular, Radio Cayman may be exempt from complying with certain notices or Data Protection Principles where your personal data are being processed for journalistic purposes.

Upon contacting Radio Cayman, we may need to verify your identity prior to fulfilling a request and may request additional information as required. In accordance with the DPA, we may also charge a reasonable fee in relation to your request if it is unfounded or excessive in nature, or reserve the right not to comply with the request at all.

To learn more about your rights, visit ombudsman.ky.

9. Cookies

Cookies, in combination with pixels, local storage objects, and similar devices (collectively, "Cookies" unless otherwise noted), are used to distinguish between visitors to a website.

When you visit our website (radiocayman.gov.ky), small files known as Cookies may be stored on your computer, phone, tablet or any other device through your web browser. Information is stored in these text files.

Enabling Cookies may allow for a more tailored browsing experience and is required for certain website functionality. In the majority of cases, a Cookie does not provide us with any of your personal data.

You can block Cookies by activating the setting on your internet browser that allows you to refuse the setting of all or some Cookies for all websites or specific websites. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. However, if you use your browser settings to block all Cookies (including strictly necessary Cookies), you may not be able to access all or parts of our website.

10. Data Protection Principles

When processing your personal data, Radio Cayman will comply with the eight Data Protection Principles defined within the DPA:

a. Fair and lawful processing: Personal data shall be processed fairly. In addition, personal data may be processed only if certain conditions are met, for example the data controller is subject to a legal obligation that requires the processing or the processing is necessary for exercise of public functions.
b. Purpose limitation: Personal data shall be obtained only for one or more specified, explicit and legitimate purposes, and not processed further in any manner incompatible with that purpose or those purposes.
c. Data minimisation: Personal data shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they are collected or processed.
d. Data accuracy: Personal data shall be accurate and, where necessary, kept up-to-date.
e. Storage limitation: Personal data processed for any purpose shall not be kept for longer than is necessary for that purpose.
f. Respect for the individual’s rights: Personal data shall be processed in accordance with the rights of data subjects under the DPA, including subject access.
g. Security – confidentiality, integrity and availability: Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
h. International transfers: Personal data shall not be transferred to a country or territory unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.

11. How to Contact Us

Radio Cayman has appointed a Data Protection Leader. If you have any questions about this Privacy Notice or how your personal data is handled, or if you wish to make a complaint, please contact:

Name: Martha Watler
Telephone number: +1 345 949 7799
Email Address: foi.rcy@gov.ky
Address: PO Box 1110, Grand Cayman KY1-1102

Radio Cayman aims to resolve inquiries and complaints in a respectful and timely manner.

12. Changes to this Privacy Notice

Radio Cayman reserves the right to update this Privacy Notice at any time and will publish a new Privacy Notice when we make any substantial updates. From time to time, Radio Cayman may also notify you about the processing of your personal data in other ways, including by email or through our publications.

This Privacy Notice was last updated on 12 December 2024.