Privacy notice

Cumbernauld Living Landscape is a partnership that is improving the town’s greenspaces for both people and wildlife, while helping everyone in the community connect with the nature on their doorstep.

The initiative is a partnership between the Scottish Wildlife Trust, North Lanarkshire Council, Sanctuary Scotland, the James Hutton Institute and TCV.

As lead partner and lead volunteer manager respectively, the Scottish Wildlife Trust and TCV are responsible for the management of data relating to the Cumbernauld Living Landscape partnership. The partnership’s volunteer database is managed by TCV while all other personal data (for example newsletter mailing lists and event attendee lists) are managed by the Scottish Wildlife Trust. Cumbernauld Living Landscape staff employed by both organisations will have access to the data.

We are committed to the safekeeping of personal details of our volunteers, supporters and anyone else whose information we hold. This notice explains how and why we use your personal data, to ensure that you remain informed and in control of your information.

Any references to the Scottish Wildlife Trust, or the Trust, refer to The Scottish Wildlife Trust – a Scottish registered charity (charity number SC005792) and a company limited by guarantee and registered in Scotland (registered number SC040247).

Any references to TCV refer to TCV – The Conservation Volunteers, a Scottish registered charity (charity number SCO39302).

Any references to ‘we’ or ‘us’ refers to both the Scottish Wildlife Trust and TCV.

We use three key definitions to describe people mentioned in this notice. These are definitions used by the Information Commissioner’s Office (ICO), the UK’s independent body set up to uphold information rights (www.ico.org.uk):

‘Data subject’: this is you. As the data subject, we respect your right to control your data.

‘Data controller’: this is us, the Scottish Wildlife Trust and TCV. We determine why and how your personal data is used (as outlined in this notice).

‘Data processor’: this is a person, or organisation, who processes your data on our behalf.

We will never sell your personal data.

We collect your personal data in order to manage our volunteering activities, to keep in touch with you, or for some other legitimate purpose.

We will only ever collect, store and use your personal data when we have an identified purpose and reason to do so. The ICO refers to this as a ‘lawful basis’. Further information about why we collect your personal data is outlined below.

a) To send you information about our work

We collect your personal data so that we can send you information about our work that we feel will be of interest to you. This may include general project updates, fundraising appeals, campaigning opportunities, services, products, newsletters, upgrade and reactivation campaigns, invitations to events, and competitions.

This information is defined as ‘direct marketing’ by the ICO.

We use a number of different lawful bases as defined by the ICO for processing your data for ‘direct marketing’ purposes:

i) Legitimate interest

This is where we have identified a genuine and legitimate reason for contacting you, which crucially does not override your rights or interests.

We use legitimate interest to send you the information listed above by post or telephone (if you are not registered with the Telephone Preference Service, and you have given us your telephone number).

ii) Opt-in consent

This is where you have given us express permission to contact you by particular communication channels.

We use opt-in consent to send you the information listed above by post, email, text message (SMS) or telephone (if you are registered with the Telephone Preference Service).

iii) Contractual

This is where we have agreed to send you information in relation to contractual agreements such as when assisting with grant applications.

We respect your right to update the way we get in touch with you about our work at any time.

b) To get to know you better

Your personal data also helps us get to know you better and to develop a ‘profile’ of you on our secure supporter database. This ‘profile’ enables us to send you the information listed above in a timely and relevant way, to suit you. For example, providing information on activities in which you have registered an interest.

We use the ICO’s definition of ‘legitimate interest’ for the lawful basis for processing your data for these purposes.

c) To enable you to volunteer with us

If you are a Cumbernauld Living Landscape volunteer, we collect your personal data so that we can keep in touch with you about, for example:

• changes to planned volunteer work programmes that you may be taking part in
• the positive impact you have on our work, by sending you a newsletter
• volunteer workshop events

We will also collect personal data to facilitate your volunteering, for example:

• application, reference, skills and disclosure details
• role capacity
• declaration of interests
• attendance, training and performance management
• vehicle checks
• accident and near miss reports

Where you support our activities in other ways, we might collect, for example photographs.

As defined by the ICO, the lawful basis for processing your data for these purposes is ‘contractual’ (where administering your volunteer record) and ‘legitimate interest’ (as defined in section 3c).

We may also hold sensitive information about you (e.g. about any health issues that may impact your volunteering work).

a) Basic information

We will usually collect basic information about you, including your name, postal address, telephone number, email address.

Most of the time, we collect this data from you directly. Sometimes this is in person; other times, it is over the telephone, in writing or through an email. Occasionally we obtain information, such as your telephone number or other contact details, from external sources (only where we have been assured that you have given permission for such information to be shared).

b) Getting to know you better

We also collect information about you that helps us to get to know you better. This may include:

• information about your volunteering interests
• your preferences of how you would like us to contact you
• ways you’ve helped us through volunteering your time
• records of events you’ve attended, or campaigns or activities that you’ve been involved in

Sometimes we will collect other information about you such as your date of birth and gender. When we do so, we will be very clear as to why we are collecting such information, and we will only do so with your specific consent and permission.

Once again, most of the time we collect this data from you directly. Occasionally the information we hold for you may be checked against data from external sources. For example, the Royal Mail’s National Change of Address database may be checked to ensure that the address we have listed for you is up to date. We know moving to a new house can be a busy time and appreciate that you don’t always have the chance to send us your new address. By undertaking this exercise, we can find out your new address if we consider it is in your interest to be given the opportunity to continue to be involved. It is also in our interest to do this as it saves money and resources.

Other ways in which we collect personal data to get to know you better include:

i) Our website

Our website uses ‘cookies’ to help provide you with the best experience possible. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

• Make our website work as you’d expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you
• Track traffic levels on the website and on particular pages

ii) Third parties

From time to time we may obtain contact details from a third party for people who might be interested in hearing from us in the future. Before we process such contact information, we will always check that there is a lawful basis for us to do so – e.g. that each person has given sufficient permission for their data to be shared with us, or that the third party is acting in good faith and the Trust / TCV has a legitimate interest in processing the information.

If you have provided permission for third party organisations to share your data, you should check their Privacy Policies carefully to understand fully how they will process your data.

c) Sensitive personal data

We do not normally collect or store sensitive personal data (such as information relating to health, beliefs or political affiliation) about supporters and volunteers. However, there are some situations where this will occur.

When we do so, we will be very clear as to why we are collecting such information (e.g. dietary requirements for an event you are attending), and we will only do so with your specific consent and permission. In these situations, we will normally collect the data from you (or your parent/guardian) directly.

If you are a volunteer then we may collect extra information about you, for example:

• references
• criminal records checks
• details of emergency contacts
• medical conditions

We may also collect sensitive personal data if you have an accident whilst on Cumbernauld Living Landscape premises. This information will be retained for legal reasons, for safeguarding purposes and to protect us (including in the event of an insurance or legal claim). If this does occur, we’ll take extra care to ensure your privacy rights are protected.

d) Children and young people

In line with data protection law, we will not collect, store or process your personal details if you are under 13 years of age; unless we have the express permission from your parent or guardian to do so.

For further information, please see the Scottish Wildlife Trust’s Safeguarding Policy.

We work with a number of trusted third-party service providers who we may need to share your data with (for example MailChimp). We require them to have appropriate controls in place and to agree to act only in accordance with our written instructions to ensure your data is secure and appropriate controls are in place. All third parties that we work with in this way are subject to pre-contract scrutiny and we will always have a written contract in place with clear data protection clauses before we share any data with them.

The third parties we work with at no point ‘own’ your data, so you will never hear from them independently and they will always delete your data from their systems when they have completed the task in hand. We always send your data to partner organisations securely, to minimise the risk of it being intercepted by unknown individuals and/or organisations.

We only share your information with third parties in the following circumstances:

i) with your consent;

ii) to agencies engaged to administer fundraising and marketing activities on our behalf;

iii) we may provide our advertisers or marketing consultants with aggregate information about our users. We may make use of the personal information we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience. We may also provide aggregated and statistical information to third parties involved in maintaining or developing our website. However, aggregated information is always anonymous;

iv) to any successor organisation carrying on our charitable activities following a reorganisation or merger; or

v) if we require to do so in order to comply with a legal or regulatory obligation; to enforce the legal terms applying to the use of this site, or to protect the rights of the Scottish Wildlife Trust and TCV or users of the site. This includes exchanging information with other organisations to help prevent the risk of fraud or credit risk.

a) Security

All the personal data we process is processed by our staff in Scotland. However, for the purposes of IT hosting and maintenance, your information may be situated outside of the European Economic Area (EEA). This will be done in accordance with guidance issued by the Information Commissioner’s Office.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures which personnel are required to follow when handling personal data.

b) Data retention policy

We will only use and store information for as long as it is required for the purposes it was collected for. We continually review what information we hold and delete what is no longer required.

For further information, please see the Scottish Wildlife Trust’s Data Retention Policy.

We respect your right to control your data. Your rights include:

i) The right to be informed

This privacy notice outlines how we capture, store and use your data. If you have any questions about any elements of this notice, please contact us.

ii) The right of access

If you wish to obtain a record of the personal data we hold about you, through a Subject Access Request, we will respond within one month.

iii) The right to rectification

If we have captured information about you that is inaccurate or incomplete, we will update it.

iv) The right to erase

You can ask us to remove your personal details from our records.

v) The right to restrict processing

You can ask us to stop using your personal data.

vi) The right to data portability

You can ask to obtain your personal data from us for your own purposes.

vii) The right to object

You can ask to be excluded from marketing activity.

viii) Rights in relation to automated decision making and profiling

We respect your right not to be subject to a decision that is based on automated processing.

For more information on your individual rights, please see the Information Commissioner’s Office.

If you would like to exercise any of these rights, please contact:

Data Protection Officer

Scottish Wildlife Trust, Harbourside House, 110 Commercial Street, Edinburgh EH6 6NF

Cumbernauld Living Landscape want to exceed your expectation in everything we do. However, we know that there may be times when we do not meet our own high standards. When this happens, we want to hear about it, in order to deal with the situation as quickly as possible and put measures in place to stop it happening again.

We take complaints very seriously and we treat them as an opportunity to develop our approach. This is why we are always very grateful to hear from people who are willing to take the time to help us improve.

Our policy is:

To provide a fair complaints procedure that is clear and easy to use for anyone wishing to make a complaint.

• To publicise the existence of our complaints procedure so that people know how to contact us to make a complaint.
• To make sure everyone in our organisation knows what to do if a complaint is received.
• To make sure all complaints are investigated fairly and in a timely way.
• To make sure that complaints are, wherever possible, resolved and that relationships are repaired.
• To learn from complaints and feedback to help us to improve what we do.

Confidentiality

All complaint information will be handled sensitively, in line with relevant data protection requirements.

Responsibility

Overall responsibility for this policy and its implementation lies with the Scottish Wildlife Trust Chief Executive.

Information Commissioner’s Office

For further assistance with complaints regarding your data, please contact the Information Commissioner’s Office, whose remit covers the UK.

Wycliffe House, Water Lane, Wilmslow SK9 5AF

Telephone: 0303 123 1113

Email: casework@ico.org.uk

We are not responsible for the privacy practices or the content of any other websites linked to our website. If you have followed a link from this website to another website you may be supplying information to a third party.