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Privacy & Data Protection

Privacy & Data Protection

This Privacy Notice explains how Scottish Future Trust Limited (Company Number SC348382) ("SFT", "we", "our" or "us") with registered address at Thistle House, 4th Floor, 91 Haymarket Terrace, Edinburgh EH12 5HE, stores, manages, and protects your personal data in compliance with UK data protection legislation.

Please read the following notice which explains how we collect, use and handle the personal data that we receive from you when you interact with this website. We act as a controller of your personal data, which means we are responsible for deciding how we process your personal data.

 

THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data 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).

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, title and name of employer.
  • Contact Data includes personal 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.
  • Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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.
  • We do not collect any special categories of personal data nor any information about criminal convictions or offences. Special categories of personal data means personal data about your racial or ethnic origin; religious or philosophical beliefs; health; sex life or sexual orientation; genetic data; or biometric data for the purpose of uniquely identifying you.
  • Our website does not collect or compile personal data for dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

 

COLLECTION OF DATA

Your personal data will generally come from either you or us.

  • We may capture limited personal data automatically via the use of cookies on our website. Please see our Cookies Policy for more information.
  • You may give us your personal data by filling in online forms, or by corresponding with us by post, phone, email or otherwise.
  • We may receive personal data about you from various third parties as set out below:
    • Mailchimp/Intuit (when you subscribe to our newsletter)
    • Google Analytics

HOW WE USE YOUR PERSONAL INFORMATION

This Privacy Notice explains how we collect and use personal information about you. In general terms, we collect and use personal information to:

  • administer, manage and develop our business;
  • provide you with information about us and our work and other information, which may be of interest to you;
  • verify your identity;
  • contact you by post, email or telephone;
  • understand your needs and how they may be met; 
  • maintain our records;
  • to provide you with support services;
  • to notify you about changes to our Privacy Notice;
  • register for participating in programmes and toolkits operated by us;
  • to manage newsletter subscriptions; and
  • aggregate data for website analytics and improvements.

 

LAWFUL BASIS FOR PROCESSING

We rely on the following legal basis in relation to the collection and use of your personal data:

  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
  • Public task: We rely on this lawful basis where the processing of personal data is necessary for the proper performance of our public function.

 

HOW WE SHARE YOUR PERSONAL DATA

Most personal data is kept within SFT. We may also share your personal data with third parties where that is necessary to comply with the law, or to protect our rights and/or operate our public functions:

  • Professional advisors: We may share your personal information with our professional advisors, including our legal and accountancy service providers, auditors and insurance brokers.
  • Restructuring: Your personal data may be disclosed as part of any re-structuring or re-organisation of SFT.
  • Legal process and safety: We may share with legal, or government regulatory authorities as required by applicable law such as industry regulators to fulfil our legal obligations and to assist them in fulfilling their regulatory functions.
  • Other third parties as necessary to comply with the law or with your permission.

 

INTERNATIONAL TRANSFERS

We may transfer, store and process your personal data outside the UK.  An international transfer may happen not only when personal data is sent to a recipient who is outside the UK but also when personal data is accessed or viewed from outside the UK. We do not ordinarily transfer any personal data outside the UK; however, we may be required to do so where certain business functions require us to do so and only where appropriate safeguards have been engaged.

SUBSCRIBING

You can subscribe on the website to receive our regular newsletter. You can unsubscribe at any time by clicking on the 'unsubscribe' tab on the newsletter or contact us at: [email protected]

SECURITY

Our Website is hosted on servers in the European Economic Area. We employ appropriate security measures to help protect your personal information and guard against access by unauthorised persons. Information storage is on secure computers in a locked and certified information centre and the information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure we cannot guarantee the security of your information transmitted to our website.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 other applicable legal and regulatory requirements.

YOUR RIGHTS

You have a number of rights under UK data protection laws in relation to your personal data.

Subject to applicable limitations, you have the right to:

  • Receive certain information about our processing;
  • Request access to the personal data that we hold about you (often known as a data subject access request);
  • Request transfer, correction, deletion, of your personal data;
  • Object to or request restriction of processing;
  • Object to decisions based solely on automated processing, including profiling;
  • Be notified of a personal data breach;
  • Complain to the Information Commissioner’s Office ; or
  • Withdraw your consent to processing (if we process your personal data on the basis of your consent).

 

If you wish to exercise any of the rights set out above, please contact us as set forth in the Contact Information and Further Advice section below.

WHAT WE NEED FROM YOU

If you choose to exercise your rights, 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.

CONTACT INFORMATION AND FURTHER ADVICE

Should you have any questions regarding the use of your data or this policy, please contact us by the following methods:

  • In writing: Data Protection Officer, Scottish Futures Trust Limited, Thistle House, 4th Floor, 91 Haymarket Terrace, Edinburgh, EH12 5HE.
  • By email: [email protected]

 

COMPLAINTS 

We seek to resolve all complaints about how we handle personal information directly. Our complaints procedure can be accessed here. You can also lodge a complaint with the Information Commissioner’s Office, using the contact details provided below:

  • Online: https://ico.org.uk/global/contact-us/contact-us-public/
  • By phone: 0303 123 1113
  • By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF

 

UPDATES TO THIS NOTICE

We may make changes to this Privacy Notice. This Privacy Notice was last updated on 19 July 2024.