Educating The People of Scotland

Police Scotland Angels Privacy Policy v.01

1. Introduction

This Privacy Policy (together with our terms and conditions and any other documents referred to in it) describes the type of information that we collect from you (“you/your”) through the use of our services (“Services”), or the use of our website PoliceScotlandAngels.org (“Website”), how that information may be used or disclosed by us and the safeguards we use to protect it.

Our Website and Services may contain links to third party websites that are not covered by this Privacy Policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

We have drafted this Privacy Policy to be as clear and concise as possible. Please read it carefully to understand our policies regarding your information and how we will treat it. By using or accessing our Website or the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

Please check back regularly to keep informed of updates to this Privacy Policy. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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.

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.

The ICO will request that you have contacted us and exhausted the complaints procedure first before investigating any complaint.

If you have any comments on this Privacy Policy, please email them to policeangels@protonmail.com or policescotlandangels@outlook.com 

Who We Are

2.1 Here are our details:

– Our Website address is https://policescotlandangels.org/

– Our organisation name is Police Scotland Angels

– Our organisation name is Police Scotland Angels or PSA

– Our Data Protection Officer is Samantha Kerr for all Data Protection and subject access services and can be contacted at: PoliceScotlandAngels@outlook.com

– Sandra Gallacher is the Data Controller’s for Police Scotland Angels

2.2 We respect your right to privacy and will only process personal information about you or provided by you in accordance with the Data Protection Legislation which for the purposes of this Privacy Policy shall mean: (i) the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR), (ii) the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the UK GDPR or the Data Protection Act 2018 and other applicable privacy laws.

3. What we may collect

3.1 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).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number.
  • Contact Data includes address, email address and telephone numbers..
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.
  • Usage Data includes information about how you use our Website and Services.
  • Interaction Data includes any information that you might provide to any discussion forums on the Website.
  • Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them and what kind.
  • Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We are also working closely with third parties (including, for example, business partners, suppliers, sub-contractors, advertising networks, analytics providers, and search information providers) and may receive information about you from them.
  • Analytics includes third-party analytics services (such as Google Analytics) to evaluate your use of the Website, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to our Website and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. By accessing and using the Website, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

3.4

Where we do collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data and it is necessary to do so as instructed by an individual seeking assistance obtaining data being processed about a individual we will obtain your specific consent, and all other necessary legal agreements will be entered into to secure the integrity of any Special Category data obtained on an individual’s behalf for their personal knowledge and use per say in any live or forthcoming court proceedings.

3.5 Under UK GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies Consent and or Public Task depending on the circumstances of the data and the threshold of wellbeing:

a) You have given consent to the processing of your personal data for one or more specific purposes;

b) processing is necessary to protect the vital interests of you or of another natural person;

c) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

d) processing is necessary for the purposes of the legitimate interests pursued by us or by an individual such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.

3.6 If you provide personal information to us about another data subject, you are responsible for ensuring that you have their consent to provide that data for the uses set out in this Privacy Policy and for bringing this Privacy Policy to their attention.

4. How we may collect and use your data

4.1 We (or Police Scotland Angels) may collect, store and use your personal information by way of different methods to collect data from and about you including through:

Direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

a) present Website content;

b) use any of our Services;

c) create an account on our Website;

d) subscribe to our Services or publications;

e) request marketing to be sent to you;

f) give us some feedback.

4.2 In addition to the above, we may use the information in the following ways:

a) To personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.

b) To administer a contest, promotion, survey or other site feature.

c) Present Website content effectively to you.

d) Provide information, and services that you request, or (with your consent) which we think may interest you.

e) Carry out our contracts with you.

f) Provide the relevant Services to you

4.3 If you are already our subscriber, we will only contact you electronically about things similar to service previously undertaken or enquired about by yourself.

4.4 If you are a new contact, you will only be contacted if you agree to it.

4.5 We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.

4.6 In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 4, you can let us know at any time by contacting us at:

policescotlandangels@protonmail.org  or if DPA and GDPR related PoliceScotlandAngels@outllook.com  and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible advice and services to you.

4.7 In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the advice and services we can provide you if you don’t provide your personal data in these cases.

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

a) Where we need to perform the contract we are about to enter into or have entered into with you.

b) 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.

c) Where we need to comply with a legal or regulatory obligation, for example compliance with health and safety, tax or other statutory obligations.

4.9 Generally we on consent as a legal basis for processing your personal data You have the right to withdraw consent to marketing at any time by contacting us at policescotlandangels@protonmail.org or if DPA and GDPR related PoliceScotlandAngels@outlook.com and we will either destroy your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.

4.10 As already indicated above, with your permission and/or where permitted by law, We agree that we will not do anything that we have not agreed to under this Privacy Policy, and we will not send you any unsolicited marketing or spam. We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended.

5. Cookies

5.1 All Cookies used by and on our website are used in accordance with current UK Cookie Law.

5.2 We use cookies to distinguish users and improve our Website. Please look at our Cookie Policy for more cookie information.

6. Where we store your data and security

6.1 We will never transfer your collected data to storage outside the UK.

6.2 Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our website. In addition, we limit access to your personal data to those founder members only 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.

6.3 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. See ICO.org

6.4 By giving us your personal data, you agree to this arrangement. We will do more than we reasonably can to keep your data secure.

6.5 Any payments made by you, is done via the Police Scotland Angels gofundpage.

6.6 We have implemented security measures such as a firewall to protect any data and maintain a high level of security.

6.7 Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts. Virtual Private Networks and encrypted internet use are used at all times.

6.8 We will keep personal data for as long as is necessary which is usually the life of our relationship. We may however be required to retain personal data for a longer period of time to ensure we comply with our legislative and regulatory requirements. We review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to. This is mainly defendant on any special category sensitive high risk Criminal or Medical Data in line with DPA2018 and GDPR UK per the Information Commissioners Office Guidance* We prefer to adhere to the law rather than merely guidance as we have found the ICO’s guidance not as stringent as we would expect from a regulatory body, who are allowing the unlawful data sharing of criminal and medical personal data without the correct Information sharing agreements.

Data Protection Impact Assessments, Appropriate Policy Documents and Privacy Notices. You will find this privacy notice has been written with precision to ensure there is no ambiguity between the legislation and the ‘guidance’.

Should there be any form of data breach from Police Scotland Angels we will inform the ICO with 72 hours of being notified, as an organisation with integrity and honesty you have our commitment in truth that this will happen.

Police Scotland Angels are not affiliated in any way to any Scottish Government or her sister agencies including non-government departments or any other third sector organisation and receive no grant in aid or any funding for our work.

Therefore, our outcomes are not compromised, we cannot be paid off by the state, they do not own us and we are not bought and paid for.

We are an independent organisation mad up of the people of Scotland for the People of Scotland and rely on donations only.

7. Disclosing your information

We are allowed to disclose your information in the following cases:

7.1 We are allowed to disclose your information in the following cases:

7.1.1 We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.

7.1.3 We can exchange information with others to protect against fraud or any form of criminality. The precepts of no harm loss or injury.

7.2 IF AND A BIG IF WE contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:

[Insert the list of companies that may access the data] We do not contract with third parties at this moment in time we are a one stop shop.

7.3 Where any of your data is required for such a purpose, we will take MORE THAN reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under UK GDPR and the law. Any third party that we share data with will not be permitted to use it for any other purpose than fulfilling their contract with us. Should this happen, we would take more than reasonable steps to ensure your data is handled safely and any breach will be subject to the ICO and a civil court proceeding.

8. Your rights

8.1 When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided above in this Privacy Policy.

8.2 Under the UK GDPR, you have the right to:

  • request access to, deletion of or correction of, your personal data held by us at no cost to you;
  • request that your personal data be transferred to another person (data portability);
  • be informed of what data processing is taking place;
  • restrict processing;
  • to object to processing of your personal data; and
  • complain to a supervisory authority, the ICO to regularly whitewash, Police Scotland, PIRC and Local Authorities, including NHS and PHS and PHE.
  • It is within our remit to hold the ICO to account for failing to ensure that Government agencies and service providers actually adhere to the law and do not act ultra vires, or simply have white paint on their procurement framework.

8.3 You also have rights with respect to automated decision-making and profiling as set out in section 11 below. We do not use your data for marketing purposes but included this caveat to ensure we are working in line with the act.

8.4 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. We do not use your data for marketing purposes but included this caveat to ensure we are working in line with the act.

8.5 To enforce any of the foregoing rights or if you have any other questions about our Website or this Privacy Policy, please contact us at policescotlandangels@protonmail.org for any personally agreed Data Protection Subject Access Requests please contact Samantha at PoliceScotlandAngels@outlook.com

9. Links to other sites

9.1 Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

10. Changes

10.1 If we change our Privacy Policy, we will post the changes on this page so please check this page for our current policy.

11. Automated Decision-Making and Profiling

11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under UK GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us. We do not use your data for the purposes of automated decision-making but included this caveat to ensure we are working in line with the act.

11.2 The right described in section 11.1 does not apply in the following circumstances:

a) the decision is necessary for the entry into, or performance of, a contract between the you and us;

b) the decision is authorised by law; or

c) you have given you explicit consent.

11.3 Where we use your personal data for profiling purposes, we do not use your personal data for profiling purposes for the purposes of automated decision-making, however should this change we would inform you in plain English and the the following shall apply:

a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;

b) Appropriate mathematical or statistical procedures will be used;

c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and

d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

12. Terms and Conditions

12.1 Please also visit our Terms and Conditions section https://policescotlandangels.org/ establishing the use, disclaimers, and limitations of liability governing the use of our Website.

13. Your agreement

13.1 By using our Website and by way of acknowledgment, you agree to our Privacy Policy.

14. Dispute Resolution

14.1 We will use our best efforts to negotiate in good faith and settle any dispute that may arise out of or relate to this Privacy Policy or any breach of it.

14.2 Any dispute shall not affect our ongoing obligations under this Privacy Policy.

14.3 This Privacy Policy and any dispute or claim relating to or connected with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales and the courts of England and Wales are the only place where disputes or claims relating to or connected with this Privacy Policy (including non-contractual disputes or claims) may be decided.

Our website address is: https://policescotlandangels.org

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Visitor comments may be checked through an automated spam detection service.