At Circle we fully respect your right to privacy and we are committed to protecting personal data that we collect about you and we will handle it in accordance with Data Protection law. The principles of the General Data Protection Regulation (GDPR) require us to make sure your data is accurate, kept up-to-date and that we keep it for no longer than is necessary.
This Privacy Notice explains what data we collect, how we use that data, where we store the information, how long we store the data for and how we store it.
We may update or change this Notice from time to time. The most up-to-date version will always be available on our website www.circle.scot.
What kind of data do we collect and why?
Personal data is any data that identifies you as an individual. This could include your name, address, email address, or even information about your needs or circumstances.
If you are a client, we may collect and process relevant personal data which you consent to provide to us when you are referred to one of our services. We will use this information to provide you with an appropriate level of support. We also use it to improve our services and help provide the best service possible.
We may also disclose the information to a third party where we have a legal obligation to do so.
If you are a supporter, we may collect and process relevant personal data in order that we can:
- Keep a record of our relationship
- Ensure we are contacting you in line with your preferences
- Inform you of our work and the different ways in which you can help
- Ask you to support specific Circle activities
- Inform you about Circle’s events or send you an invitation
- Telephone you to ask for your support
If you are a job applicant, we may collect and process personal details you provide to help us to help you secure a position with Circle.
If you are a supplier, we may collect and process relevant personal data in order that we are able to receive your services and process and pay your invoices.
If you access our website, we will capture data about how you use it, using cookies and similar technology. Cookies are tracking technology which collect information such as details about your computer system and details of your visits to our website. This tells us about how you use our services and your preferences etc.
We also collect personal data that you voluntarily provide when you contact us with queries or complaints.
Sharing your personal data
We will never share or sell your personal data with any third parties, apart from those authorised and contracted to act on our behalf. Whenever we authorise a third party to act on our behalf, that activity is bound by a contract which ensures your data is kept safe. We may however collect data from other parties who have obtained your permission to share your personal data with us.
Circle may need to transfer information/data to other organisations in providing effective services to children, young people and their families. Where the need to transfer information is known in advance we will notify individuals during data collection. We will only pass information on without direct permission where there is a clear legal requirement to do so, or where we believe that not doing so may endanger the child or individual concerned.
Retention of your personal data
We will keep your personal data for as long as we provide you with our services or for the purposes set out in this Privacy Notice. We keep personal information in accordance with our internal retention procedures which are determined in accordance with our statutory obligations and good practice. We will only hold onto your personal data for as long as it is needed, after which time Circle will securely erase or delete the data.
In order to effectively deliver our services, Circle will store data on a secure database and/or on our secure server. All staff are bound by a Confidentiality Agreement within their Employment Contracts and Circle’s Code of Practice. Hard copy files will be handled in a secure manner by all staff and in line with our Data Protection Policy.
How you can update and access your data
We try our best to make sure that the data we are holding is accurate at all times. If you should change address or any other contact details, please do let us know so we can update our records accordingly.
You can change your communication preferences at any time or choose to stop hearing from us altogether. You are also entitled to access a copy of the information we hold on you, free of charge. Please note, you will be required to send proof of identification before we can release this to you.
You can contact us by calling 0131 552 0305, emailing email@example.com or by writing to us at the address below:
18 West Pilton Park
Edinburgh EH4 4EJ
As well as being able to update and request access to your data, as outlined above, under GDPR, you have a number of other rights as follows:
- The right to be informed
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
Information relating to these rights can be found on the Information Commissioner’s Office website: ico.org.uk/your-data-matters/
All requests will be considered without undue delay and within one month of receipt as far as possible.
Our email policy
- All messages sent from Circle email accounts are private and confidential. If you receive a message in error, please notify us and remove it from your system. Any views or opinions expressed via email are solely those of the author and do not necessarily represent those of Circle.
- Although we have taken steps to ensure emails and attachments are virus-free, we do not accept any responsibility for viruses, or for inaccurate or incomplete information or failure to deliver information. It is the recipient’s responsibility to scan emails and attachments to ensure they are virus-free.
- Circle may track and monitor the content of emails sent or received by its employees
- The option for you to unsubscribe is made clear on all marketing emails
At Circle, we are relying on Legitimate Interest as the lawful basis on which we carry out marketing activity.
How to make a complaint
You have the right to make a complaint about anything regarding the processing, storage and retention of your personal data. We would hope to resolve any complaint internally. If you would like to lodge a complaint with us, in the first instance, please contact firstname.lastname@example.org, or write to us at:
18 West Pilton Park
Edinburgh EH4 4EJ
You also have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO). Further information can be found on their website www.ico.org.uk.