Privacy
Introduction
Alcohol Focus Scotland is committed to data security and the fair and transparent processing of personal data. This privacy policy sets out how we will treat the personal data which you provide to us in compliance with applicable data protection law, in particular the General Data Protection Regulation (EU) 2016/679 (GDPR).
This policy sets out who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, and how to contact us and supervisory authorities if you would like to report a concern about the way in which we process your data.
Who are we?
Alcohol Focus Scotland (AFS) is a Registered Scottish Charity (SC009538) and a Company Limited by Guarantee (Scottish Company No. SC094096). Our registered address is
Alcohol Focus Scotland
166 Buchanan Street
Glasgow
G1 2LW
For the purposes of the GDPR, AFS is the ‘controller’ of the personal data you provide to us.
AFS owns and operates the following websites:
www.alcohol-focus-scotland.org.uk (main website)
This Policy, together with our Cookies Statement, Training Terms and Conditions and any other documents referred to in them, sets out the basis on which AFS processes personal data.
What personal data do we collect?
We may collect and process the following personal data:
Information you provide to us
We may collect your name, e-mail address, postal address, telephone number and job role, if you:
- complete a form on our Website;
- correspond with us by phone, e-mail, or in writing;
- report a problem;
- sign up to receive our communications;
- enter into a contract with us to receive products and/or services.
Information we collect about you
If you visit our websites, we may automatically collect information about your activity via cookies. We only use this information for statistical analysis purposes and then the data is removed from the system.
For more information please see our Cookies Statement.
Information we receive from other sources
We may also receive information about you if you use any of the other websites we operate or the other services we provide.
If you are a learner, we may also receive information about you from your centre or employer when they register to receive products and/or services from us.
Information about other people
If you provide information to us about any person other than yourself, such as your relatives, next of kin, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
Sensitive personal data
In certain limited cases, we may request your explicit consent to collect certain sensitive personal data from you. The definition of ‘sensitive personal data’ includes: information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, physical or mental health, sexual life, or details of criminal offences, or genetic or biometric data; however, it is very unlikely that we would need to collect these types of data.
How do we use your personal data?
When we ask you to supply us with personal data we will make it clear whether the personal data we are asking for must be supplied so that we can provide the products and services to you, and whether the supply of any personal data we ask for is optional.
Performance of a Contract:
We may use your personal data to fulfil a contract, or take steps linked to a contract:
- to provide the products and/or services to you;
- to communicate with you in relation to the provision of the contracted products and services;
- to provide you with administrative support such as account creation, security, and responding to issues;
- and provide you with information about our training, events and other activities related to the products and/or services AFS provides to you.
Legitimate interests:
We may use your personal data where this is necessary for purposes which are in our legitimate interests.
These interests are:
- communicating with you about activities carried out by AFS which may be of interest to you;
- communicating with you in relation to any issues, complaints, or disputes;
- improving the quality of experience when you interact with our products and/or services, including testing the performance and customer experience of our Website;
- performing analytics on marketing data, determining the effectiveness of promotional campaigns.
You have the right to object to the processing of your personal data on the basis of legitimate interests as set out below, under the heading Your Rights.
Consent:
Where you have given your express consent to receive marketing communications, we may use your personal data to:
- send you newsletters, and information about our training, events and other activities, products and services offered by AFS which may be of interest to you;
- develop, improve and deliver marketing for products and services offered by AFS.
Where required by law:
We may also process your personal data if required by law, including responding to requests by government or law enforcement authorities, or for the prevention of crime or fraud.
Who do we share your personal data with?
We may share your personal data with trusted third parties including:
- legal and other professional advisers, consultants, and professional experts;
- service providers contracted to us in connection with provision of the products and services such as providers of IT services and customer relationship management services, e.g. marketing services; analytics and search engine providers that assist us in the improvement and optimisation of our websites.
We will ensure there is a contract in place between us and the third parties listed above, which will include obligations in relation to the confidentiality, security, and lawful processing of any personal data shared with them.
Where a third party recipient is located outside the European Economic Area, we will ensure that the transfer of personal data will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission where the data protection authority does not believe that the third country has adequate data protection laws.
We will share personal data with law enforcement or other authorities if required by applicable law.
If you are a learner taking a City & Guilds training course with AFS, we will share your personal data with City & Guilds so that they can award your qualification. We may share learners’ personal data with the regulator, the Scottish Qualifications Authority, on request.
AFS will not sell your personal data.
How long will AFS keep your personal data?
Where there is a contract between us, we will retain your personal data for the duration of the contract, and for a period of six years following its termination or expiry, to ensure we are able to comply with any contractual, legal, audit and other regulatory requirements, or any orders from competent courts or authorities.
Where you have consented to marketing communications, you may change your preferences or unsubscribe from marketing communications at any time by clicking the unsubscribe link in an email from us or by contacting AFS directly at the email or postal address given below.
Where do we store your personal data and how is it protected?
We take all reasonable steps to ensure that our staff protect your personal data and are aware of their information security obligations. We limit access to your personal data to those who have a genuine business need to know it.
We take reasonable steps to protect your personal data from loss or destruction. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Where you have a username or password (or other identification information) which enables you to access certain services or parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Your Rights
Under the GDPR, you have various rights with respect to our use of your personal data:
Right to Access
You have the right to request a copy of the personal data that we hold about you by contacting us at the email or postal address given below. Please include with your request information that will enable us to verify your identity. We will respond with 30 days of request.
Please note that there are exceptions to this right. We may be unable to make all information available to you if, for example, making the information available to you would reveal personal data about another person, if we are legally prevented from disclosing such information, or if your request is manifestly unfounded or excessive. We may make an administrative charge for this service in certain circumstances, which will not be larger than the cost to AFS to provide the requested information.
Right to Rectification
We aim to keep your personal data accurate and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal data is not accurate or if it changes, so that we can keep your personal data up-to-date. We will respond to any such requests within one month.
Right to Erasure
You have the right to request the deletion of your personal data where, for example, the personal data are no longer necessary for the purposes for which they were collected, where you withdraw your consent to processing, where there is no overriding legitimate interest for us to continue to process your personal data, or if your personal data has been unlawfully processed. If you would like to request that your personal data is erased, please contact us using the contact details provided below. We will respond to any such requests within one month.
Right to Object
In certain circumstances, you have the right to object to the processing of your personal data where, for example, your personal data is being processed on the basis of legitimate interests and there is no overriding legitimate interest for us to continue to process your personal data, or if your data is being processed for direct marketing purposes. If you would like to object to the processing of your personal data, please contact us using the contact details provided below.
Right to Restrict Processing
In certain circumstances, you have the right to request that we restrict the further processing of your personal data. This right arises where, for example, you have contested the accuracy of the personal data we hold about you and we are verifying the information, you have objected to processing based on legitimate interests and we are considering whether there are any overriding legitimate interests, or the processing is unlawful and you elect that processing is restricted rather than deleted. Please contact us using the contact details provided below.
Right to Data Portability
In certain circumstances, you have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format. This right arises where you have provided your personal data to us, the processing is based on consent or the performance of a contract, and processing is carried out by automated means. If you would like to request that your personal data is ported to you, please contact us using the contact details provided below.
Please note that the GDPR sets out exceptions to these rights. If we are unable to comply with your request due to an exception we will explain this to you in our response.
Contact
If you have any queries about this Policy, the way in which AFS processes personal data, or about exercising any of your rights, please send an email to enquiries@alcohol-focus-scotland.org.uk or write to:
Business Support Manager
Alcohol Focus Scotland
166 Buchanan Street
Glasgow
G1 2LW
Complaints
If you believe that your data protection rights may have been breached, and we have been unable to resolve your concern, you may lodge a complaint with the Information Commissioner’s Office (ICO) www.ico.org.uk
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Changes to our Privacy Policy
Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
Version 2
Date: 18 September 2018