Privacy Policy

 

Who we are

Our website address is: www.weescottishlassie.scot

What is the purpose of this document?

Wee Scottish Lassie is committed to protecting the privacy and security of your personal information.

We are a data controller.  This means we are responsible for deciding how we hold and use personal information about you.  This notice explains to you what decisions we have taken in relation to that information.

Our contact details are as follows:

Head Office:  Plymouth, England

Registered office:  Helensburgh, Scotland

 

Telephone: 07722274332

E-mail: nicky@weescottishlassie.scot

This privacy notice describes how we collect and use personal information about you, in accordance with the General Data Protection Regulation (GDPR).  We encourage you to read this notice carefully, so that you are aware of how and why we are using such information.

About Us

Wee Scottish Lassie is a Community Interest Company.   

For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’.  We do not have an appointed Data Protection Officer and any queries in relation to how we hold and use your personal information should be directed to Nicky Watt. If you have any questions about this privacy notice or how we handle your personal information, please contact nicky@weescottishlassie.scot

Data protection principles

In collecting and processing your personal information, we will comply with the data protection law in force at this time.  This requires that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way.
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  3. Relevant to the purposes we have told you about and limited only to those purposes.
  4. Accurate and kept up to date.
  5. Kept only as long as necessary for the purposes we have told you about.
  6. Kept securely.

The kind of information we hold about you

We may collect, store, and use a variety of categories of personal information about you. 

*  Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses

*  Date of birth

*  Marital status and dependants

*  Next of kin and emergency contact information

*  National Insurance number

*  Bank account details, payroll records and tax information

*  Salary, annual leave, pension and benefits information

*  Start date

*  Location of employment or workplace

*  Details of contact we have had with you in relation to the provision, or the proposed provision, of our services

*  Details of any services you have received from us;

*  Our correspondence and communications with you;

*  Information about any complaints and enquiries you make to us;

*  Information from research, surveys, and marketing activities;

*  Information we receive from other sources, such as publicly available information, and information provided by our clients.

*  Copy of driving licence

*  Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application form and process)

*  Employment records (including job titles, work history, working hours, training records and professional memberships)

*  Compensation history

*   Performance information

*  Disciplinary and grievance information

*  Information about your use of our information and communications systems

*  Photographs

We may also collect, store and use the following “special categories” of more sensitive personal information:

*  Information about your health, including any medical condition, health and sickness records.

*  Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about our employees, members or clients through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider.  We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background credit agencies (For example: the Disclosure and Barring Service).

We obtain personal information about you, for example when:

*  You request a proposal from us in respect of the services we provide;

*  Our clients engage us to provide our services and also during the provision of those services;

*  You contact us by email, telephone, post or social media (for example when you have a query about our services);

*  From third parties and/or publicly available resources (for example, from your employer or from Companies House);

*  Through the application and recruitment process;

*  Through our membership process;

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

We may process your personal data for purposes necessary for the performance of our contract with our clients and to comply with our legal obligations.

We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.

We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.

We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.

Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Situations in which we will use your personal information

There are a variety of situations in which we will use the information we collect about you and these are detailed below.

*  Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services);

*  Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;

*  Provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;

*  Seek your thoughts and opinions on the services we provide; and

*  Notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

Where we use your personal information to pursue the legitimate interests of the business, we will only do so provided your interests and fundamental rights do not override those interests.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Do we need your consent to use particularly sensitive information?

We do not need your consent if we use your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law.  In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data.

If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent.

*  Where we need to carry out our legal obligations and in line with our policy.

*  Where it is needed in the public interest, in relation to our occupational pension scheme, and in line with our GDPR.

*  Where it is needed to assess your working capacity on health grounds, subject to appropriate confidentiality safeguards.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

 Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our policy.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

Automated decision-making

We do not use any automated decision-making system to make a decision without human intervention.  However we will notify you in writing if this position changes.

Why might you share my personal information with third parties?

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. 

We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

All our third-party service providers [and other entities in the group] are required to take appropriate security measures to protect your personal information in line with our policies.  We do not allow our third-party service providers to use your personal data for their own purposes.  We only permit them to process your personal data for specified purposes and in accordance with our instructions.

Any third parties with whom we might share your personal information and the basis on which we do so are detailed in the Schedule to this notice.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Transferring information outside the EEA

We do not transfer any personal information we collect about you outside of the EEA

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.  Details of these measures may be obtained from HR.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

GDPR & Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  Details of retention periods for different aspects of your personal information are set out in our GDPR Retention Policy.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our GDPR & Retention policy or applicable laws and regulations.

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

Under certain circumstances, the law grants you specific rights.  These are summarised below.  Please note that your rights may be limited and subject to restrictions in certain situations:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to 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.
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the HR Department.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request for access is unfounded or excessive.  Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).  This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In any circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  To withdraw your consent, please contact the HR Department.  Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Complaints to the ICO

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.  This policy was updated January 2019.

If you have any questions about this privacy notice, please contact the Nicky Watt, Wee Scottish Lassie Head Office, 1 Bluebell Street, Plymouth, PL6 8DY.