1.0 OUR CORE BELIEFS REGARDING USER PRIVACY AND DATA PROTECTION
- User privacy and data protection are human rights
- We have a duty of care to the people within our data
- Data is a liability, it should only be collected and processed when absolutely necessary
- We will never sell, rent or otherwise distribute or make public your personal information
2.0 RELEVANT LEGISLATION
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
- Australian Privacy Act 1988 (APA)
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.
If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 10.0) for clarification.
3.0 PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA). This useful plugin helps us to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 7.0 below).
3.2 Contact forms and email links
Should you choose to contact us using the contact form on our Members page or an email link like this one, none of the data that you supply will be stored by this website or passed to / be processed by any of the third party data processors defined in section 7.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.
4.0 PAYMENTS MADE ON THIS WEBSITE
On our Donate page and Members page payment is processed via PayPal, we do not have access to, or hold any records pertaining to your debit or credit card information. Inform Scotland only collects the necessary information such as name, email address, and transaction ID.
This information needs be retained within our financial systems for a period of 7 years in accordance with HMRC guidelines for retaining financial information.
5.0 HOW WE STORE YOUR PERSONAL INFORMATION
Data is stored within this website’s database in the content management system that this website is built on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
6.0 ABOUT THIS WEBSITE’S SERVER
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
An SSL security certificate is installed on this website which protects against the interception of data between your computer/ devices and this website, in other words whenever you fill in a contact form on the Members page.
7.0 OUR THIRD PARTY DATA PROCESSORS
Third parties that process personal data on our behalf are listed below. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. These third parties are based in the USA and are EU-U.S Privacy Shield compliant.
8.0 DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
9.0 DATA CONTROLLER
The data controller of this website is Inform Scotland whose registered office is:
Suite 1/1, 34 St Enoch Square,
10.0 DATA PROTECTION OFFICER