Privacy Notice Training and Events

23 May 2018

This privacy notice tells you about the information we collect from you as a training customer or event delegate.

What is the purpose of this document?

Volunteer Scotland is committed to protecting the privacy and security of your personal information.
This privacy notice describes how we collect and use personal information about you as a customer of Volunteer Scotland's training services, in accordance with the General Data Protection Regulation (GDPR).

Volunteer Scotland is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to all training customers and event delegates. This notice does not form part of any contract to provide services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

 

Data protection principles 

We will comply with data protection law. This says 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

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). 

There are “special categories” of more sensitive personal data which require a higher level of protection.

We may collect, store, and use the following categories of personal information about you:

  • Personal contact details such as name, title, job title, addresses, telephone numbers, and personal email addresses.
  • Details regarding the organisation you are associated. 
  • Social media account usernames 
  • Photographs. 

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

  • Information about your health: when we ask if you have any special requirements, you may provide us with information that relates to your health in terms of disability or special dietary requirements you have.
  • Information about your race or ethnicity, religious beliefs, disability information and sexual orientation for equal opportunities monitoring purposes.

 

How is your personal information collected?

We typically collect personal information about training course attendees and event delegates through the application to attend one of our courses/events; this may be in the form of an electronic document, online form, or using an online event management system such as Eventbrite. We may sometimes collect additional information from your host organisation directly.

 

How will we use the information about you?

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  1. In some circumstances, with your consent 
  2. Where we need to perform the contract we have entered into with you.
  3. Where we need to comply with a legal obligation.
  4. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests).
  2. Where it is needed in the public interest [or for official purposes].


Situations in which we will use your personal information

We need all the categories of information in the list above (see The kind of information we hold about you) primarily to allow us to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. Less commonly, we will obtain your consent. The situations in which we will process your personal information are listed below.

  • To allow us to effectively administer your attendance on a training course, workshop, conference or other Volunteer Scotland hosted event
  • Equal opportunities monitoring
  • To store your details on our customer database (CRM) or event management system (Eventbrite) in order to manage the transactional relationship with you in relation to training or events
  • To approach you with a request to opt in to marketing information (please see separate Volunteer Scotland privacy notice in relation to marketing)
  • To follow up with you after the training courses to measure the impact for reporting purposes
  • To take photographs at events and to use the photographs for a specific purpose; if so, we will explain the purpose to you and obtain your consent first. 
  • Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. 


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 or we may be prevented from complying with our legal obligations (such as Health and Safety compliance).


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.

 

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:

  1. With your explicit written consent. 
  2. Where we need to carry out our legal obligations and in line with our Health and Safety Policy. 
  3. Where it is needed in the public interest, such as for equal opportunities monitoring in line with our Equality and Diversity policy. 

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.

Our obligations

We will use your particularly sensitive personal information in the following ways:

  • We will use information you provide about dietary conditions to ensure that any catering we provide is in accordance with the condition you have, ensuring we are meeting our obligations under health and safety legislation. 
  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in Jubilee House (or other external training or event venue) is maintained and provide any appropriate adjustments.
  • We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, disability or lack of, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need consent? 

We will ask for your consent to obtain the special category data listed above and in other limited circumstances (see Situations in which we will use your personal information). 

 

Information about criminal convictions

We do not envisage that we will require to obtain or hold information about criminal convictions for the purpose of training or events.


Automated decision-making

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.


Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the EU.

If we do, you can expect a similar degree of protection in respect of your personal information.


Why might you share my personal information with third parties?

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

Which third-party service providers process my personal information?

”Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes: ILM Scotland (for the purpose of providing you with ILM accreditation for your course); catering providers (to enable you to be provided with a meal that matches your dietary requirements); Eventbrite (to facilitate attendance at a Volunteer Scotland event); Saleforce CRM – cloud based customer database.

How secure is my information with third-party service providers and other entities in our group?

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.

What about other third parties?

We may need to share your personal information with a regulator or to otherwise comply with the law.


Transferring information outside the EU

We may transfer the personal information we collect about you to the following country outside the EU  in order to perform our contract with you: United States (Eventbrite). There is an adequacy decision by the European Commission in respect of that country. This means that the country to which we transfer your data are deemed to provide an adequate level of protection for your personal information.


Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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.

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.

 

Data retention

How long will you use my information for?

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 available separately. 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. Otherwise, we will retain and securely destroy your personal information in accordance with the data retention schedule set out and available separately.

 

Rights of access, correction, erasure and restriction 

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, by law you have the right to:

  • 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 processingof 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 Business Development Co-ordinator in writing.


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 clearly 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 the limited 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 hello@volunteerscotland.org.uk  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.


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.

If you have any questions about this privacy notice, please contact hello@volunteerscotland.org.uk