Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”)
Who are we?
Scottish Community Alliance (SCA) is the data controller (contact details below). This means it decides how your personal data is processed and for what purposes.
How do we process your personal data?
- SCA complies with its obligations under [the GDPR] by keeping personal data up to date;
- by storing and destroying it securely; by not collecting or retaining excessive amounts of data;
- by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
We use your personal data for the following purposes: –
o To enable us to provide our charitable activities for the benefit of the public as specified in our constitution;
o To fundraise and promote the interests of the charity;
o To maintain our own accounts and records.
o To operate our web site and deliver the services that individuals have requested.
o To inform individuals of news, events, activities or services run by SCA .
What is the legal basis for processing your personal data?
Article 6 processing:
- Consent of the data subject for photographs to be taken for marketing purposes and processing data for event management.
- Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract in relation to reporting to funders on activities which may include case studies and images;
- Processing is necessary for compliance with a legal obligation in relation to the charity and company law requirements;
- Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject. This is in relation to: –
o Fortnightly briefing – Local People Leading
It is necessary for us to process contact details for this purpose, and that the mailing is a proportionate way of approaching individuals to connect and inform about activities and policy developments happening across the community sector. We have taken into account that the nature of the data being processed is names and email addresses only, and that it would be reasonable for these individuals to expect that they may receive these mailings as they have previously subscribed to them. We have determined that the impact is likely to be minimal however as there is a clear opt out procedure if they no longer wish to receive the Briefing
o Shared resource – programmes of practical support to communities
It is necessary for us to process contact details for the purpose of being able to allocate these resources from within these programmes to applicants. We have taken into account that the nature of the data being processed is names, contact and (where necessary) banking details of organisations only, and that it would be reasonable for these individuals to expect that they may have their information used for these purposes. We have determined that the impact is likely to be minimal.
Article 9 Processing:
- Processing is carried out by a not-for-profit body and the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes); and there is no disclosure to a third party without consent.
Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only with:
- Funders, where necessary.
- IT company for maintenance and repair.
We will only share your data with third parties outside of the organisation with your consent.
How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary depending on the specific purpose it is being kept for
- Staff administration – collected when staff are recruited at the point of collection and is updated when changes to staff and/or data and shall be retained for 7 years after the employment ends.
- Company law compliance – collected when directors join the board and point of collection and amended when there are any changes to the board. For company regulation, these details are show on the public record on Companies House. These records shall be retained for 6 years following the end of the directorship.
- Charity law compliance – collected when trustees join the board and at the point of collection and amended when there are changes to the board. These details may be requested by/disclosed to a member of the public as this is a statutory requirement.
- Events – collected when event is marketed at the point of collection and delegate lists are provided on day of event and these are retained indefinitely for historical/statistical purposes.
- Fundraise and raise awareness of charitable work – collected at the point of contact with the data subject and shall be retained indefinitely for reporting/historical/statistical purposes.
- Fortnightly briefing – collected when individuals subscribe at the point of collection and this shall be held until subscriber unsubscribes.
- Surveys for evaluation or research – collected when organisation provides data or database at the point of collection and retained indefinitely for reporting/historical/statistical purposes.
- Images – collected at events, the point of collection and may be used on website or reporting to funders and shall be retained indefinitely for reporting/historical/statistical purposes.
- Reporting for funders – collected during charitable activities and shared indefinitely for reporting/historical/statistical purposes.
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following above purposes and use the following criteria to determine how long to retain your personal data; statutory, reasonable timeframes and on some occasions as a record of our charitable activities.
Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
- The right to request a copy of your personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary for us to retain such data;
- The right to withdraw your consent to the processing at any time;
- The right to request that we provide the you with his/her personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable).
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable);
- The right to lodge a complaint with the Information Commissioners Office
The Information Commissioner’s Office – Scotland
45 Melville Street
Telephone: 0303 123 1115
Transfer of Data Abroad
When we process data it is in electronic format and occasionally transferred to countries or territories outside the EU:
- Staff administration records are held on GDrive. The servers are in the US and a Privacy Shield is in place;
- Membership administration records are held on GDrive. The servers are in the US and Privacy Shield is in place;
- Company law compliance records are held on GDrive. The servers are in the US and Privacy Shield in place;
- Charity law compliance records are held on GDrive. The servers are in the US and a Privacy Shield is in place;
- Events records are held on Eventbrite. The servers are in the US and a Privacy Shield is in place;
- Fundraising and charitable activities data records are held on GDrive. The servers are in the US and a Privacy Shield is in place;
- Images are held on GDrive. The servers are in the US and a Privacy Shield is in place;
- Reporting records are held on GDrive. The servers are in the US and a Privacy Shield is in place;
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
Where and whenever necessary, we will seek your prior consent to the new processing. Contact Details To exercise all relevant rights, queries of complaints please in the first instance, contact us at:
Scottish Community Alliance
21 Walker Street,
0131 260 9501