User Privacy Notice
Purpose of this Privacy Notice
If you are to receive a device and/or support under the Connecting Scotland programme this Privacy Notice will tell you how we use your personal data, and about the rights you have over your personal data.
We may update this Privacy Notice from time to time to reflect changes in our practices or in the law but if we do so, we will provide you with access to an updated copy of the Privacy Notice as soon as reasonably practical. This Privacy Notice was last updated on 20/11/2020.
Who we are
The Connecting Scotland programme is funded and operated by the Scottish Government. The programme is managed by the Scottish Council for Voluntary Organisations (SCVO) on behalf of the Scottish Government – SCVO is a charity registered in Scotland with charity number SC003558 and having its registered office is Mansfield Traquair Centre, 15 Mansfield Place, Edinburgh, EH3 6BB. Connecting Scotland is also supported by your local Council and the third sector or public sector organisation who provides you with the device and support under the programme.
For the purpose of the Connecting Scotland programme, you will provide some personal data. The Scottish Government is usually the data controller of the personal data that you provide for the programme, and SCVO is the Scottish Government’s data processor – this is because SCVO stores and manages the data on behalf of the Scottish Government. Within this Privacy Notice, references to “we”, “us”, “our” mean the Scottish Government.
The organisation who will provide you with the device is also a processor of Scottish Government as they collect the personal data from you (and provide this to SCVO).
How to contact us
If you have any questions regarding this Privacy Notice or how we use your personal data for the purposes of the Connecting Scotland programme, you can contact us at the following details:
You can contact us by email or phone at:
0800 0 590 690
What information do we collect?
The information that is collected on you may include:
- Date of birth
- Contact phone number
- Email address
- Local Authority
- Number of Adults in Household
- Number of Children in Household
- Ages of Adults in Household
- Ages of Children in Household
- What criteria you meet for inclusion in the programme – specifically on whether you have children living with you, are a care leaver or have another vulnerability which makes you more likely to be isolated during the coronavirus pandemic
- Whether you have a disability
- Level of digital need within the household
- Level of digital skills and confidence within the household
- Device SIM Mobile Number
We may also record notes of the interactions that we or our partners have with you for the purpose of the programme – for example if you email or call for support. These details will be recorded and stored.
We may also ask you for feedback on the programme and we will collect information from you for this purpose.
We may also have access to details of your data usage if you receive internet connectivity from us (but cannot see what you use the internet for and/or which websites you visit).
How do we collect your personal information?
You may give us your personal data directly by filling in our forms or by corresponding with us. We will also receive personal data indirectly from (a) SCVO and the organisation who will provide the device and support to you, and (b) from your use mobile data usage if we provide you with internet connectivity.
How will we use the information?
We will use this data to:
- Provide you with support to use your device and internet connection
- Contact you with important information regarding the project, your device or your internet connection
- Share information on public services which can provide you with support
- Contact you to evaluate the success of the programme
- Manage the mobile connectivity contracts
- Produce anonymous statistical reports on the number of people who have received support
- Provide auditors with evidence on how public funds have been spent
The Scottish Government relies on the following lawful basis for processing your personal data for the above purposes: 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 (Article 6(1)(e) of the GDPR).
The Scottish Government relies on the following additional category for processing special category (health) data for the above purposes: processing relates to personal data which are manifestly made public by the data subject (Article 9(2)(e) of the GDPR).
Do we share your data?
We share your personal data with others in certain circumstances:
- SCVO has access to your personal data as the party who manages the programme and data on our behalf. SCVO may also, through the programme, provide you with direct support to use your device and internet connection.
- The organisation who collected your personal data and who will provide you with the device and support has access to your personal data. This is so that they can provide you with the necessary support.
- We contract with third party service providers and suppliers to deliver certain services (for example to manage our CRM system and to provide hosting services). Our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies.
- Your local Council will not usually have access to the personal information which you supply for the programme unless such sharing is helpful to provide you with access to other services and/or support. If this sharing takes place then your local Council would provide you with a separate privacy notice explaining how they will use the personal data received from us.
- We will also provide your personal data to third parties where there is a legal obligation to do so.
- We will provide information about you to any other person who is authorised by you
The personal data that we collect from you will usually be stored inside the UK or the European Economic Area (EEA). We may transfer data outside the UK or the EEA where our service providers host, process, or store data outside the UK or the EEA. Where we do this, we will ensure that the transfer is to a country covered by an adequacy decision or is otherwise made in circumstances where we have put appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws (e.g. standard contractual clauses).
How long do we hold your data?
Generally, we will not hold your personal data for any longer than is necessary for the uses outlined in this Privacy Notice, unless we are required to keep your personal data longer to comply with the law and any regulatory requirements.
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 we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.
We will delete your personal data three years after we have stopped providing you with a service.
Keeping your details up to date
Please contact us at the contact details above as soon as possible after there is any change to your personal details, including your contact details.
Your rights over your information
You have the following rights under the data protection laws:
- Access: Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Rectification: Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Erasure: Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- Object: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Restriction: Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Portability: Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw Consent at any time where we are relying on consent to process your personal data.
You can exercise you rights by contacting us at the contact details noted above.
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 fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
Further details about your rights can be found on the ICO’s website at https://ico.org.uk
Your right to complain
If you have a complaint about our use of your personal data, you can contact the Information Commissioner’s Office online at https://ico.org.uk/concerns or by phone on 0303 123 1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.