Privacy Notice
OA Scotland’s Privacy Notice
It is important that you read this notice, together with any other privacy notice that is provided on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
Who We Are
Scotland’s Officers’ Association gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.
Officers’ Association Scotland’s registered office is New Haig House, Logie Green Road, Edinburgh, EH7 4HR. We are a ‘Registered Charity’ Scotland (SC039262). We are a company Limited by Guarantee registered in Scotland under company number (SC 173449). We are registered on the Information Commissioner’s Office Register and act as the data controller and data processor when processing your data.
Data Protection Principles
We will comply with the data protection principles under the data protection legislation. This says that the personal information we hold about you must be:
Information That We Collect
Officers’ Association Scotland processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from is:
We collect information in the below ways:
Equality, Diversity and Inclusion QuestionnaireOfficers’ Association Scotland wants to meet the aims set out in our Equality, Diversity and Inclusion commitment. This includes not discriminating under the Equality Act 2010. OA Scotland have introduced an equality and diversity questionnaire that is intended to help us maintain best practice and identify barriers to workforce equality and diversity.
The information on the questionnaire will be used for evaluation purposes only to ensure we are meeting our Equality & Diversity Policy and will play no part in the registration or service delivery.
This information will include Special Category Data and is optional. The information we will collect will be:
The intention of analysis is to establish if there are different success rates between genders, people of different sexual orientation, ages, different ethnic backgrounds or faiths, and people with disabilities. If there are differences in these areas, it will enable action to be taken to ensure that no group is treated unfairly.
All questions are optional. You are not obliged to answer any of these questions but the more information you supply, the more effective our evaluation will be. All information supplied will be treated in the strictest confidence.
With the help of feedback from our community groups, beneficiaries and staff, we will continue to develop arrangements to review and evaluate the effectiveness of our employment and service delivery policies. If our evaluation reveals any gaps in our policies, we will take the necessary action.
How We Use Your Personal Data (Our Legal Basis For Processing)
OA Scotland takes your privacy very seriously and will never disclose or share your data outside our Partners listed in this notice without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:
Your Rights
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now by requesting you read the information provided at www.knowyourprivacyrights.org.
You have the right to access any personal information that OA Scotland processes about you and to request information about:
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use (currently OA Scotland does not use any automated decision-making processes).
If we receive a request from you to exercise any of the above rights, we will ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. We only share your data with recognised partners that are appropriate to your specific support programme. Our partners may include those listed below, but there is a wider support network that we may work with to support individual cases. We will keep you informed of partners linked within your specific programme:
Partners
Employers and Training Provided
Safeguarding Measures
OA Scotland takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
How We Store Personal Data
Your personal data will be stored in a secure Information Technology system. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
Consequences Of Not Providing Your Data
You are not obligated to provide your personal information to RFEA The Forces Employment Charity, however, as this information is required for us to provide you with our services and legitimate interests, we will not be able to offer some/all our services without it.
Legitimate Interests
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
OA Scotland only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years plus current year.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Change Of Purpose
We will only use your personal information 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 we need to use your personal information for an unrelated or new purpose, we will notify you and we will explain the legal basis which allows us to do so.
Special Categories Data
Owing to the provision requirements of some of our more specialised services, OA Scotland sometimes needs to process sensitive personal information (known as special category data) about you; for example, information about your health. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Do We Need Your Consent?
We do not need your consent if we use special categories of your personal information in accordance with our reasons outlined above:
In limited circumstances, if the need arises, we will approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information About Criminal Convictions
We will only use information relating to criminal convictions or alleged criminal behaviour where the law requires us to do so. This can arise when it is necessary for us to comply with the law or for another reason where there is a substantial public interest in us doing so.
Less commonly, we will, if necessary, use information relating to criminal convictions or alleged criminal behaviour where it is necessary in relation to legal claims, where it is necessary to protect your interests or someone else’s interests and you are not capable of giving your consent, or where you have already made the information public.
We will only collect information about criminal convictions or allegations of criminal behaviour where it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions/allegations as part of the specific programme or if we are notified of such information directly by you while you are on one of our programmes.
Recruitment
We will collect your personal details, including but not limited to your name and contact details (together with your e-mail address) and other relevant information from your Curriculum Vitae (“CV”). On occasion, this will also include sensitive personal information such as details of criminal convictions and ethnic origin. When we receive your details and CV electronically, this may be through a direct application on our website or an application that you have made through a third-party job board.
We will likely obtain further personal information about you during our relationship with you. This information will have obtained from you directly.
Our standard terms of business state that we retain applicant data such as CVs, interview notes and special category data (information on criminal convictions, biometric data etc) for the purposes of the specific role you apply for and that, as controllers of your data, you will be informed if we plan to retain your CV on file to notify you about potential future roles.
The length of time we will hold or store your personal information is for 6 months once the position has been successfully filled.
Duty To Inform
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time with us.
Lodging A Complaint
OA Scotland only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Officers’ Association Scotland
CEO
New Haig House
Logie Green Road
Edinburgh, EH7 4HR
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (National Rate)
Fax: 01625 524 510
It is important that you read this notice, together with any other privacy notice that is provided on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
Who We Are
Scotland’s Officers’ Association gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.
Officers’ Association Scotland’s registered office is New Haig House, Logie Green Road, Edinburgh, EH7 4HR. We are a ‘Registered Charity’ Scotland (SC039262). We are a company Limited by Guarantee registered in Scotland under company number (SC 173449). We are registered on the Information Commissioner’s Office Register and act as the data controller and data processor when processing your data.
Data Protection Principles
We will comply with the data protection principles under the data protection legislation. This says that the personal information we hold about you must be:
- used lawfully, fairly and in a transparent way
- collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
- relevant to the purposes we have told you about and limited only to those purposes
- accurate and kept up to date
- kept only as long as necessary for the purposes we have told you about
- kept securely
Information That We Collect
Officers’ Association Scotland processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect from is:
- Full Name
- Title and Rank
- Service
- Date of Birth
- Service Number
- Enlistment Date
- Discharge Date
- Campaigns Served
- Employment History
- Home Address
- Personal Email
- Business Email
- Financial Problems
- Evidence of your right to work in the UK/immigration status
- Family, lifestyle and social circumstances
- Copies of driving licence, passport, birth and marriage certificates, decree absolute
- Home Telephone Number
- Mobile Telephone Number
- Special Category Data – i.e. health/medical information, information about criminal convictions/allegations and offences (not in all cases; only where applicable to the service programme offered).
We collect information in the below ways:
- Paper and Website Registrations
- Telephone Disclosures
- Employment CVs
- Employee Data
- Review meetings
- Group Events
- Webchat and Webinars
Equality, Diversity and Inclusion QuestionnaireOfficers’ Association Scotland wants to meet the aims set out in our Equality, Diversity and Inclusion commitment. This includes not discriminating under the Equality Act 2010. OA Scotland have introduced an equality and diversity questionnaire that is intended to help us maintain best practice and identify barriers to workforce equality and diversity.
The information on the questionnaire will be used for evaluation purposes only to ensure we are meeting our Equality & Diversity Policy and will play no part in the registration or service delivery.
This information will include Special Category Data and is optional. The information we will collect will be:
- Gender
- Age
- Ethnicity
- Sexual Orientation
- Disability
The intention of analysis is to establish if there are different success rates between genders, people of different sexual orientation, ages, different ethnic backgrounds or faiths, and people with disabilities. If there are differences in these areas, it will enable action to be taken to ensure that no group is treated unfairly.
All questions are optional. You are not obliged to answer any of these questions but the more information you supply, the more effective our evaluation will be. All information supplied will be treated in the strictest confidence.
With the help of feedback from our community groups, beneficiaries and staff, we will continue to develop arrangements to review and evaluate the effectiveness of our employment and service delivery policies. If our evaluation reveals any gaps in our policies, we will take the necessary action.
How We Use Your Personal Data (Our Legal Basis For Processing)
OA Scotland takes your privacy very seriously and will never disclose or share your data outside our Partners listed in this notice without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purposes specified in this notice. Where you have consented to us providing you with marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:
- We collect your personal data in the performance of a contract or to provide an employment service to you as a client/beneficiary.
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes.
- We will occasionally send you marketing information where we have assessed that it is beneficial to you as a client/beneficiary and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests.
Your Rights
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now by requesting you read the information provided at www.knowyourprivacyrights.org.
You have the right to access any personal information that OA Scotland processes about you and to request information about:
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source/provider
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use (currently OA Scotland does not use any automated decision-making processes).
If we receive a request from you to exercise any of the above rights, we will ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure. We only share your data with recognised partners that are appropriate to your specific support programme. Our partners may include those listed below, but there is a wider support network that we may work with to support individual cases. We will keep you informed of partners linked within your specific programme:
Partners
- The MOD. As a sub-contractor, delivering the Career Transition Partnership to the MOD, we process data for all Armed Forces Service Leavers.
- Right Management as part of our contract in delivering the Career Transition Partnership service for the Ministry of Defence (MoD). We jointly process personal information on Service Leaver clients two years prior to leaving the service and two years post-discharge; this data is used specifically in the service of employment support and job finding. Details are at https://www.right.com
- Right Management as part of our Ex-Forces Programme, hosts the database system which we use to process data. This allows clients the opportunity to access Rightjob and other benefits as a Veteran.
Employers and Training Provided
- An employer registered on our Executive Jobs Board– To support your job searching activities, we will only share information you have consented to share and with vetted employers
- Training providers – To support your job searching activities, we will only share information you have consented to share
Safeguarding Measures
OA Scotland takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including:
- Restricted Access
- IT Authentication
- Data Encryption
- Virtual Private Networks (VPN)
- Firewalls
- Controlled Anti-virus/malware
- Pseudonymisaton
- Security Cleared Employees
How We Store Personal Data
Your personal data will be stored in a secure Information Technology system. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
- In addition, we limit access to your personal information to only OA Scotland personnel, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions. Details of these measures are available upon request from our Data Protection Controller.
- Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure, in a contractual arrangement.
- We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office (ICO) of a suspected breach where we are legally required to do so.
Consequences Of Not Providing Your Data
You are not obligated to provide your personal information to RFEA The Forces Employment Charity, however, as this information is required for us to provide you with our services and legitimate interests, we will not be able to offer some/all our services without it.
Legitimate Interests
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
How Long We Keep Your Data
OA Scotland only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years plus current year.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Change Of Purpose
We will only use your personal information 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 we need to use your personal information for an unrelated or new purpose, we will notify you and we will explain the legal basis which allows us to do so.
Special Categories Data
Owing to the provision requirements of some of our more specialised services, OA Scotland sometimes needs to process sensitive personal information (known as special category data) about you; for example, information about your health. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Do We Need Your Consent?
We do not need your consent if we use special categories of your personal information in accordance with our reasons outlined above:
In limited circumstances, if the need arises, we will approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
Information About Criminal Convictions
We will only use information relating to criminal convictions or alleged criminal behaviour where the law requires us to do so. This can arise when it is necessary for us to comply with the law or for another reason where there is a substantial public interest in us doing so.
Less commonly, we will, if necessary, use information relating to criminal convictions or alleged criminal behaviour where it is necessary in relation to legal claims, where it is necessary to protect your interests or someone else’s interests and you are not capable of giving your consent, or where you have already made the information public.
We will only collect information about criminal convictions or allegations of criminal behaviour where it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions/allegations as part of the specific programme or if we are notified of such information directly by you while you are on one of our programmes.
Recruitment
We will collect your personal details, including but not limited to your name and contact details (together with your e-mail address) and other relevant information from your Curriculum Vitae (“CV”). On occasion, this will also include sensitive personal information such as details of criminal convictions and ethnic origin. When we receive your details and CV electronically, this may be through a direct application on our website or an application that you have made through a third-party job board.
We will likely obtain further personal information about you during our relationship with you. This information will have obtained from you directly.
Our standard terms of business state that we retain applicant data such as CVs, interview notes and special category data (information on criminal convictions, biometric data etc) for the purposes of the specific role you apply for and that, as controllers of your data, you will be informed if we plan to retain your CV on file to notify you about potential future roles.
The length of time we will hold or store your personal information is for 6 months once the position has been successfully filled.
Duty To Inform
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time with us.
Lodging A Complaint
OA Scotland only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority.
Officers’ Association Scotland
CEO
New Haig House
Logie Green Road
Edinburgh, EH7 4HR
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (National Rate)
Fax: 01625 524 510
