Privacy Statement
Welcome to The Spartans Community Foundation (The Foundation) privacy notice for our website. The Foundation respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you. This privacy notice gives you information on how The Foundation collects and processes personal data. It is important that you read this privacy notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you. This is so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.
Controller
The Foundation is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our”).
Contact details
If you have any questions, or would like to exercise your legal rights, please contact our data protection officer:
Debbi McCulloch: info@spartansfc.com
Postal address: Spartans Community Foundation, Ainslie Park, 94 Pilton Drive, Edinburgh, EH5 2HF
Call: 0131 5527854
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy notices and policies under regular review. This notice was last updated on 01/3/2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Third party links may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
The data we collect 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).
We may collect, use, store and transfer different kinds of personal data about you depending upon the nature of our interaction with you. For details as to the types of personal data we collect and use, please see paragraph 4 (how we use your personal data) below.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you at the time if that is the case.
How is your personal data collected?
We use different methods to collect data from and about you including through:
· Direct interactions: you may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you register for a programme, express interest in an event or fundraising.
· Automated technologies or interactions: as you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
· Third parties or publicly available sources: we will receive personal data about you from various third parties and public sources, for example, your school, your previous employer(s), the police etc.
How we use your personal data
We will only use your personal data when the law allows us to. The purposes for which we may use your personal data are set out here along with the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds we are relying on to process your personal data.
Third Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Withdrawing consent You can ask us to stop sending you marketing messages at any time by emailing: info@spartanscf.com
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. You can find out more about cookies at: http://www.allaboutcookies.org
Change of purpose
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
CCTV
In the interest of public safety and maintaining workplace security we have internal and external CCTV in operation. If you would like to request any footage of yourself, please contact the Data Protection Officer with the following information:
1. a specific date and time
2. proof of your identify
3. a description of yourself
We will keep all CCTV Footage for 31 days and all requests for information will be responded to within 30 days
If you have any queries, please contact the Data Protection Officer by emailing info@spartanscf.com
People who contact us via social media
If you send us a private or direct message via social media the message will be stored by that social media platform under its terms and conditions. Please see your social media platform’s privacy/terms and conditions for further information. We will not share messages with any other organisations.
People who email us
We will monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.
Whom might we share your data with
We may share your personal data with the parties for the purposes set out in the table at paragraph 4 (how we use your personal data) above. We may also share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring we have the correct safeguards in place.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
Your legal rights
Any person wishing to exercise their right to request their data, see what data we hold and request deletion of their data should make their request in writing where possible. We recommend using The Foundation's Subject Access Request form to ensure we have all the information we need to comply with your request. This is available on request from the Data Protection Officer. You should then return it when completed to the Data Protection Officer. Please contact info@spartanscf.com to request a subject access request form.
The Foundation aims to comply with requests for access to personal information as quickly as possible. The Foundation must comply with a subject access request within forty days of receipt of the request, or within forty days of the receipt of any additional information required to comply with the request and the relevant fee. Occasionally it could take us longer if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
The Foundation may not comply with a request where it has received an identical or similar request from the same individual unless a reasonable interval has elapsed between compliance with the original request and the current request.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.