PRIVACY POLICY

TELL ME SCOTLAND – OPERATED BY THE IMPROVEMENT SERVICE

PLEASE READ THIS POLICY CAREFULLY

Improvement Service, a company limited by guarantee and registered in Scotland (Company No. SC287978) and operating from iHub, Quarrywood Court, Livingston, EH54 6AX and the operator of TellMeScotland (we) are committed to protecting and respecting your privacy.

This policy (together with our Terms and Conditions of Service and any additional terms of use incorporated by reference into these documents, together our Terms of Use) applies to your use of TellMeScotland.

TellMeScotland is a website that displays local authority and other organisational notices that can be viewed with or without a free-of-charge user account that allows customised notifications. This policy sets out the basis on which any personal data we collect about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We process your personal data for certain legitimate purposes outlined in this privacy policy. If we are unable to process your personal data as outlined in this policy, you may not be able to register for a TellMeScotland user account which provides access to customised notifications and alerts, typically by SMS (short method service) and by email.

You may withdraw from this service in full or in part at any time by:

  • unsubscribing from SMS/email alerts; or
  • cancelling your account on the user/edit sub-page when logged in; or
  • contacting the site administrator at tellme@improvementservice.org.uk.

However if you do withdraw from this service, this means you will no longer be able to use TellMeScotland’s customised notifications service, although other access to the site will not be affected. Please note that if you withdraw from this service, this does not affect the legality of any processing carried out before that time.

WE ARE YOUR DATA CONTROLLER

For the purpose of Data Protection Law, we are the data controller in relation to the processing of your personal data arising from your use of TellMeScotland.

We may share some of your personal data with the third parties identified below, for the purposes of allowing the provision of a customised notification and alerts service. In such circumstances, the Service Provider and Improvement Service will be data controllers in common only in so far as facilitating a customised notifications service by way of login, logout, provision of data relating to the chosen notification and alerts methods, and notification criteria selection. The Improvement Service is not responsible for the handling of your personal data by the Service Provider in respect of delivery of the relevant services. Each Service Provider will have its own privacy policy and you should read the relevant Service Provider’s privacy policy carefully should you enrol for a service.

Any reference to the Data Protection Law includes the Data Protection Act 1998 and all applicable laws and regulations relating to the processing of personal data and privacy from time to time, including where applicable the guidance and codes of practice issued by the Information Commissioner or any other applicable supervisory authority, and the equivalent of any of the foregoing in any relevant jurisdiction. For the avoidance of doubt this also includes, from implementation, the General Data Protection Regulation (“Data Protection Law”), which is due to become effective in the UK on 25th May 2018.

INFORMATION WE COLLECT FROM YOU

We will collect and process the following personal data about you:

  • Personal data you give us when you register for an account (submitted information): This is personal data you give us when you register for a TellMeScotland user account or correspond with us e.g. report a problem. The personal data you give us when you register may include your name, surname, postcode, email address and mobile telephone number, as well as a password to facilitate login.
  • Personal data we collect about you when you use the service. When you use TellMeScotland we collect data that helps us understand how you are using the service so that we can improve it over time. The information we collect includes the type of device you are using, the unique device identifier that the manufacturer embeds into the device (eg the IMEI number of a mobile phone), your operating system and browser versions and the IP address from which you are accessing the service. Every device that connects to the internet has an IP address and we use it to identify the geographic locations from which people access the TellMeScotland service. We store this information securely in logfiles on our servers. We may also pass this information to Service Providers, so that they in turn may understand how people are using their services.

COOKIES

The TellMeScotland service uses cookies (small text files that we place on your device) to help provide our services to you and keep your account safe. For more information, please read our Cookie Policy. [https://www.tellmescotland.gov.uk/cookie-policy]

USES MADE OF THE PERSONAL DATA

We use personal data held about you in the following ways:

  • To allow the creation of a user account for login;
  • To allow the use a postcode, or multiple postcodes, for provision of notifications and alerts on a geographic basis;
  • To allow the provision of notifications and alerts using means that include the use of SMS alerts (requiring a mobile telephone number) and email alerts (requiring the use of an email address).
  • To help you with any queries you may have in relation to the service, for example if you raise an issue with our help desk; and
  • To develop and improve the services that we offer and to help the organisations with whom you may enrol do the same;

DISCLOSURE OF YOUR PERSONAL DATA

We will disclose the personal data we process about you to the following third parties:

  • Website technical services provider, contracted to manage and develop the TellMeScotland website, where an account is registered;
  • Data and infrastructure services provider, contracted to provide infrastructure for hosting data and associated services, where an account is registered; and
  • Messaging and alerts service provider, contracted to facilitate the provision of SMS and email alerts, and by other means that may be developed, where an account is registered and these methods of alerts and notifications are selected.

These may change over time subject to contractual arrangements.

In addition, we may disclose your personal data to third parties:

  • If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.

WHERE WE STORE YOUR PERSONAL DATA

All personal data you provide to us is stored on secure servers in the UK. Your personal data will not be passed outwith the EEA. Where we have given you (or where you have chosen) a password that enables you to access TellMeScotland services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Please note that we cannot be held responsible for the location of any personal data held by a third party or Service Provider for the purposes set out in this policy e.g. to enrol with a service. Such third parties shall have their own privacy policies and you should read these carefully.

How Long We Will Keep Your Data For

We shall keep your data for as long as your TellMeScotland is active. Your TellMeScotland shall automatically be disabled after eighteen months of non-use, at which point your personal data shall be securely removed.

Information Security

We work hard to protect your information and keep it safe from unauthorised disclosure, alteration or destruction. Some of the measures we use include:

  • using a reputable hosting provider for your data;
  • making sure our staff and the staff of any contractors we use are security cleared and vetted;
  • encrypting our services and data;
  • reviewing our processes and activities regularly to make sure they are fit for purpose;
  • restricting access only to those employees who need to know the information in order to deliver the service;
  • having our service checked regularly by an independent security company; and
  • applying formal risk management to all of our activities.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to TellMeScotland; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features as outlined above to try to prevent unauthorised access to your personal data. As above, we cannot be held responsible for the security of your personal data held by a third party or Service Provider for the purposes set out in this policy. Such third parties shall have their own privacy policies and you should read these carefully.

YOUR RIGHTS

You have the following rights:

  • You can withdraw from this service, seek to restrict our processing of your personal data or object to us processing your personal data for use with TellMeScotland at any time by contacting us at tellme@improvementservice.org.uk or by cancelling your account when logged in to the website. Please note that if you do this you may no longer be able to use the full TellMeScotland service.
  • You can withdraw from sharing your data with a Service Provider by logging in to TellMeScotland and making any changes necessary. Please note that if you do this you may not be able to access that Service Provider’s service or the service itself may be limited. We will also stop telling any Service Providers that you may have enrolled with about any changes that you make to your personal details such as a change of address or telephone number.
  • You have the right to lodge a complaint with the Information Commissioners Office (ICO) if you think that we have infringed your rights. You can find more information about reporting a matter to the ICO at the following link: https://ico.org.uk/
  • You have the right to access personal data held by us about you. You can access your personal data and correct, update or delete it at any time by logging in to TellMeScotland and making any amendments as necessary. Otherwise you can contact tellme@improvementservice.org.uk

In certain circumstances you have the right to ask us to provide you with your personal data in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party. You can see what information we hold about you by logging in to TellMeScotland and viewing your user account details page. You can also view the information we hold about you by logging in to TellMeScotland and selecting the appropriate menu option. More information can be found at https://ico.org.uk

THIRD PARTY LINKS

TellMeScotland may, from time to time, contain links to and from the websites of third parties such as Local Authorities or Health Boards. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

CHANGES TO PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on the TellMeScotland website and, where appropriate, notified to you when you next start the service. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the service.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to: tellme@improvementservice.org.uk