This is privacy notice of Capital City Partnership/ESESCommunities.org
ESESCommunities.org (our website) is provided by The Capital City Partnership Limited (we, our or us). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purpose it is used.
Our contact details are Great Michael House, 14 Links Place, Edinburgh EH6 7EZ, firstname.lastname@example.org. For all data matters contact our Data Protection Officer on email@example.com.
We take your privacy very seriously. We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We will also tell you about your privacy rights and how the data protection law protects you.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
1. WHO WE ARE AND IMPORTANT INFORMATION
This privacy notice aims to give you information on how we collect, store, share and process your personal data through your use of this website, including any data you may provide through this website when you sign up to our mailing list. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
This website is not intended for children and we do not knowingly collect data relating to children. Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Third-party links outside of our control
This website 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. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
The personal data we collect about you depends on the particular activities carried out through our website. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name/last name/username.
• Community Benefits Data includes details of personal circumstances, information relating to existing and new community benefit requirements or offerings.
• Contact Data includes postal address/email address/telephone numbers.
• Cookies which record certain information on how you use of our website.
• Feedback Data about your experience using our services and website.
Once the data is collected it is stored on a MIS called HELIX. This is delivered by a company called Hanlon Software Solutions https://hanlons.co.uk and they are ISO9001 and ISO27001 certified, IIP and C2E accredited as well as being an approved Crown Commercial Service supplier and GDPR compliant.
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 notice.
If you fail to provide personal data where we ask for it, we may not be able to provide the support to you that you have requested. We only collect personal data that is essential to provide the support you request.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
• Directly. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• This includes personal data you provide when you:
o Register for our services
o Create an account on our websites such as www.ESESCommunities.org and Helix ;
o Subscribe to a newsletter service or publications;
o Request marketing to be sent to you;
• Indirectly: where you are a benefit provider, we may collect data you make publicly available such as on your website, social media or third party directories.
4. HOW WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason, eg:
• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract either with us or another organisation we introduce you to, or
• for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us.
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:
• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data,
Registering an individual as a representative of an organisation wishing to submit community benefit requests
Registering an individual as a representative of an organisation seeking to deliver community benefits
Registering an individual as a representative of an organisation wishing to receive updates by email, phone and/or post of opportunities and news relating to receiving or delivering community benefits.
In such cases information will be anonymised where possible and only shared where necessary, and with consent
Putting requestors and providers of benefits in direct contact with each other
Where you are a benefit provider, contacting you to request you to provide benefits via our service
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures
Collecting feedback and using it to improve our service, including feedback on benefits previously offered or received
Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices
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 on firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table above.
We may use your personal data to send you updates (by email, text message, telephone or post) about products/services, including exclusive offers, promotions or new products/services. You can opt out of this at any time or change your preferences so you will no longer receive these.
We have a legitimate interest in using your personal data for marketing purposes. This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the CAPITAL CITY PARTNERSHIP group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing Info@esescommunities.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product or service experience or other transactions.
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 email email@example.com.
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.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
• External Third Parties
o Providers acting as processors based in the EEA who provide IT, marketing and system administration services including our website developers and administrators.
o Our external advisers such as legal and financial advisers
o Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets with. During this process we may share your data on the condition it is kept safe and used for no other purpose. 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 notice
• 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.
• Community Benefit requests
o Where you are requesting a community benefit, we will share your contact information with the most appropriate benefit provider when we introduce you;
o Where you are offering a community benefit, we will introduce you to those requesting a community benefit and where necessary, publish your contact information for this purpose.
6. INTERNATIONAL TRANSFERS
Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards:
• A legally binding agreement between public authorities or bodies;
• Certification under an approved certification mechanism as provided for in the UK GDPR;
• Standard Contractual Clauses agreed authorised by the competent supervisory authority; or
• Provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority.
Please contact us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In most circumstances, we will retain records of information relating to the services on our website for no longer than 7 years.
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 requirements.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data (which you can exercise free of charge):
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data (known as the right to be forgotten);
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
• The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website.
For more information on each of those rights, including circumstances in which they do and do not apply, please contact us (see 11. Queries, requests or concerns section below). If you wish to exercise any of the rights set out above, please contact email@example.com in the first instance. Where you do this, please:
• provide enough information to identify yourself (eg your full name, address and/or matter reference number) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates.
No fee required – with some exceptions
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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Changes to this notice and your duty to inform us of changes
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. Queries, requests or concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our Data Protection Officer on firstname.lastname@example.org. We hope we will be able to resolve any issues you may have.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
12. UK GDPR
The ESESCommunities.org service is managed by Capital City Partnership (CCP), an ALEO (Arms-Length External Organisation) of the City of Edinburgh Council, which respects the security of your personal information and undertakes to comply with the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and the UK GDPR (the “data protection laws”). All information you provide will be held and processed in accordance with the data protection laws. CCP is the registered data controller for the data system within ESESCommunities.org.
You should contact CCP with any queries regarding the processing of your personal data.
The ESESCommunities.org service is managed by Capital City Partnership.
If at any point you wish to have your data removed from the system, please contact us via e-mail: email@example.com