Updated 25 May 2018
1. About Central Scotland Regional Equality Council Limited
Central Scotland Regional Equality Council Limited hereafter referred to as CSREC is a Scottish Charity registered with The Office of the Scottish Charity Regulator (OSCR) with registration number SC010373. We are also a Company Limited by Guarantee registered with Companies House with registration number SC208570. The following acts apply to us:
- Charities and Trustee Investment (Scotland) Act 2005 (2005 Act)
- Charities (Protection and Social Investment) Act 2016
- Companies Act 2006
The main aims of CSREC are:
• to work towards the elimination of discrimination in all its forms in Central Scotland
• to reduce inequality and promote a culture of human rights
• to promote good relations between persons of protected characteristics without distinction on grounds of age, disability, marital status, pregnancy/maternity status, race, religion/belief, sex, sexual orientation and gender reassignment
• to promote, build and work in partnership to further our aims.
2. About the personal information we use
This information notice tells you what to expect when CSREC collects personal data. It applies to information we collect and use about:
• visitors to our websites
• job applicants and our current and former employees
• members of CSREC
• people who volunteer their time to work with us
• service user data we process as part of our core work programmes
• professional experts and consultants
• surveys we conduct
• complainants and other individuals in relation to an CSREC complaint or complain against another organisation through our support and advice service
• complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry
• people who attend our events or use our services, e,g. those who subscribe to our newsletters or request a publication from us
• people who contact us via social media.
The personal information we use includes information that identifies you such as your name, address, date of birth, national insurance number and postcode.
We also use more sensitive types of personal information, including information on age, disability, marital status, pregnancy/maternity, race, religion/belief, sex, sexual orientation, gender reassignment, philosophical beliefs; trade union membership; health; and socio-economic identity.
The information we use can relate to personal and family details; education, training and employment details; financial details; lifestyle and social circumstances; goods and services; visual images; details held in our casework record; and responses to surveys.
Visitors to our websites
When you visit our websites, your computer will automatically be issued with a number of small text files known as “cookies”.
To opt out of being tracked by Google Analytics across all websites you can install a Google Analytics Opt-Out Browser Add-On.
We will make it clear when we collect personal information and will explain what we intend to do with it. When you provide such personal information, you accept that we may retain your personal information and that it may be held by us or any third party that processes it on our behalf for the purposes of providing the information, goods or services which you have requested.
Online Data Collection
We use independent online providers of event booking, survey or other services. We check that their privacy notices assure personal data is processed in ways meeting data protection legislative requirements. However, you may wish to read the providers’ privacy notices as outlined below:
We use a third party provider, Mailchimp, to deliver our monthly e-newsletters for CSREC and specific projects such as the Support and Advice Service, Forth Valley Communities for Conservation, Dementia and Care in Our Communities, Equality for All, Volunteering for All, MAHRS and Falkirk, Stirling and Clackmannanshire People’s Rights and Equality Groups.
Mailchimp uses click and open rate monitoring which allows us to record how many of the emails we send are opened and how many successfully delivered emails registered at least one click. We record and use this data to inform activities at an aggregated level. Individual subscribers to our newsletters are not monitored. Further information on click and open rates is available on the Mailchimp site.
We routinely use Twitter, Facebook YouTube and Vimeo to provide information and communicate. We occasionally use Hootsuite to schedule tweets or Facebook posts. We do not collect any data via our social media accounts beyond the standard analytics available for each platform. Our policy on how we use social media provides additional information.
The standard privacy policies for the Social Media tools we use can be found below:
We use third party provider Eventbrite to manage our event bookings.
3. Our purposes for using personal information
We process personal information about our services users to enable us to operate and deliver our services, maintain our own accounts and records, promote our services, and to support and manage our employees. We also process personal information about staff, volunteers, members and former employees in relation to requirements to maintain our records.
4. Our legal basis for using personal information
CSREC, as data controller, is required to have a legal basis when using personal information. We consider that performance of our tasks and functions are in the public interest. So when using personal information our legal basis is usually that its use is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us. In some situations we may rely on a different legal basis; for example, compliance with a legal obligation to our funders to which we are subject. For example under the Public Finance and Accountability (Scotland) Act 2000, HMRC, OCSR may be required to provide the Scottish Government, UK Government, Regulators, our funders and others with specific data sets if we are legally obliged to do so under law. We will ensure our best to make sure that data provided for this as anonymised as possible,
When we are using more sensitive types of personal information, including health information, our legal basis is usually that the use is necessary:
• for the provision of our services; or
• for reasons of public interest in the area of public health, public safety; or
• for reasons of substantial public interest for aims that are proportionate and respect people’s rights, for example research.
On occasion we may rely on your consent as our legal basis for using your personal information. When we do this we will explain what it means, and the rights that are available, to you.
5. Who provides the personal information
When you do not provide information directly to us, we receive it from other individuals and organisations involved in the delivery our services. These include public bodies such as Local Authorities, funders and suppliers of goods and services.
6. Sharing your information
The personal information we collect about you will mainly be used by our staff (and volunteers) at CSREC so that they can support you.
We will never sell or share your personal information with organisations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
CSREC may however share your information with our trusted partners and suppliers who work with us on or on our behalf to deliver our services, but processing of this information is always carried out under our instruction. We make sure that they store the data securely, delete it when they no longer need it and never use it for any other purposes. Some examples of where we may share your information are with our fulfilment partners who help to create and send information to you to reduce our costs, with our partners who help us to process donations and claim Gift Aid and our partners who help us to manage our social media accounts.
We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.
7. Legal disclosure
We may disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements.
8. Keeping your information safe
We take looking after your information very seriously. We’ve implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
Unfortunately the transmission of information using the internet is not completely secure. Although we do our best to protect your personal information sent to us this way, we cannot guarantee the security of data transmitted to our site.
Our websites may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or Web sites that have links on our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those websites or advertisers.
9. How long we hold your information for
We only keep it as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, the collection of Gift Aid).
10. Your rights
You have various rights in respect of the personal information we hold about you – these are set out in more detail below. If you wish to exercise any of these rights or make a complaint, you can do so by contacting our Admin team at CSREC, Rooms 1A and 1B, Community Education Centre, Park Street, Falkirk FK1 1RE, by email at firstname.lastname@example.org and by phone 01324 610950. You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, https://ico.org.uk/
• Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge. Please make all requests for access in writing, and provide us with evidence of your identity.
• Right to object: You can object to our processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Please contact us as noted above, providing details of your objection.
• Consent: If you have given us your consent to use personal information (for example, for marketing), you can withdraw your consent at any time.
• Rectification: You can ask us to change or complete any inaccurate or incomplete personal information held about you.
• Erasure: You can ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
• Portability: You can ask us to provide you or a third party with some of the personal information that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
• Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.
• No automated-decision making: Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any automated decision-making.
Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request.