Summary Privacy Notice

Glasgow Centre for Inclusive Living (GCIL) is committed to protecting the privacy of the people whose personal information we process and to meeting our obligations under Data Protection legislation.

GCIL uses personal information for a range of purposes and our privacy notices provide information about why we obtain and collect your personal information, how we process it and your data protection rights.

This privacy notice provides a summary of that information. We are developing more detailed privacy notices for each of the main groups of individuals (data subjects) whose personal information we process. These will be published on the Privacy section of our websites with links provided in this summary notice and when we first ask you to provide personal information for a specific purpose. In the meantime, if you require more detailed information about how and why we process your information, please contact our Data Protection Compliance Officer using the contact details provided below.

Who we are

We are Glasgow Centre for Inclusive Living (GCIL), a Disabled People's Organisation (DPO) committed to promoting inclusive living by assisting disabled people to challenge barriers and make informed choices. GCIL is registered with the Information Commissioner's Office under number Z9141658, is a registered Scottish charity under number SCO24299, and registered company limited by guarantee number 161693 (Scotland).

How to contact us

If you have any questions or suggestions regarding this privacy notice or our approach to data protection generally, please contact our Data Protection Compliance Officer by email at gcil@gcil.org.uk or by writing to:

The Data Protection Compliance Officer

Glasgow Centre for Inclusive Living

117-127 Brook Street

Glasgow

G40 3AP

You can change how we contact you at any time, simply by contacting us by email at gcil@gcil.org.uk or calling us on 0141 550 4455.  We also welcome calls using Text Relay (via NGT).

Whose personal data do we hold?

GCIL collects and processes the personal data of

• people who use our services
• our members
• people who sign up for our Newsletters
• people who attend our events
• GCIL led participants in focus groups/research/campaigns
• other contacts required for business purposes e.g. freelance journalists
• our volunteers
• our Board of Directors
• our suppliers and their employees
• our partners
• GCIL employees, former employees, job applicants

Why do we process information about you?

GCIL processes personal data for a wide range of purposes:

• to manage and administer our services to you
• to report to our funders
• to monitor whether we are reflecting the diversity of the community
• to administer membership records and meet our responsibilities as a charity and company limited by guarantee
• to support our events
• to keep you informed about the work of GCIL and issues relating to the independent living agenda including events and training courses
• to give you the opportunity to be involved in policy work, campaigns, events consultations, research, personal stories/case studies and blogs etc.
• to send you information about third parties which we think you may find helpful
• to improve the services we provide to you
• to influence and shape policy
• to publicise the work of GCIL
• to manage our employees and volunteers
• to recruit
• to administer and maintain our accounts
• to maintain our records

We only collect, use and otherwise handle your personal data for these purposes where we have a legal basis to do so under Data Protection legislation.

These include:

• to fulfil a contract with you as an employee, a contractor or a user of our contract-based services
• where you have consented to this for specified, explicit and legitimate purposes
• to meet specific legal and statutory obligations such compliance with employment and health and safety legislation
• where it is necessary for our legitimate interests relating to running our daily operations, as long as, in each case, these interests are in line with applicable law and your legal rights and freedoms.
• for research, historic and statistical purposes

What information do we collect about you?

The type and quantity of data we collect and use depends on why you have provided it.

Personal information collected may include your name, address, telephone number and e-mail address.

If you are involved in focus groups, consultations, blogs, campaigns, awareness raising, personal stories/case studies, events etc, your opinion, feedback, comments, personal circumstances and photographs may be collected by GCIL.  We may also capture your views on video or audio, depending on the activity.  If we are filming or photographing an event, this will be made clear to all attendees in advance and you will have the option of not being photographed.  We will only use your information and/or images if agreed by you.

If you become a volunteer we will keep records of skills, attendance and training.

If you are employed by us we will keep records of bank account details, contractual information, attendance and absence, training and performance.

We sometimes need information relating to any accessibility or dietary requirements you have and information regarding your health, gender, sexual orientation, race/ethnicity, criminal proceedings, outcomes and sentences, offences and alleged offences, religious and philosophical beliefs.  Where we process this more sensitive personal information, we will handle it in compliance with the more robust rules around special category data under Data Protection law.

Sharing your data

Your personal data will be only be shared internally with those GCIL staff and volunteers who have a legitimate reason to access it.

We regularly need to share personal information with other organisations to carry out our work, for example housing associations or care agencies. Where this is necessary, we are required to comply with data protection legislation. We will only disclose or share personal information with your consent or where there is a legitimate and lawful purpose to do so such as fulfilling a contract with you or because we have a statutory requirement do so such as complying with employment or health and safety legislation.

We have joint procedures and data sharing agreements with partner agencies with whom we regularly share personal information to ensure that this information is properly protected and appropriately, fairly and lawfully handled and disposed of.

Some of our suppliers provide us with services that requires them to collect or process personal data on our behalf (data processors), such as IT service providers. Where this is the case, we carry out comprehensive checks on these companies, and put in place contracts to control how they manage the data they collect or have access to. This means that they cannot do anything with your personal information unless we have instructed them to do so. They will hold it securely and retain it for the period we instruct.

GCIL will never sell or inappropriately disclose your personal data to any other external organisation or individual.

Transfer of data overseas

It may sometimes be necessary to transfer your personal information overseas, out with the European Economic Area (EEA). Any transfers made will be in full compliance with all aspects of Data Protection legislation. Mailchimp, for example, are a US-based third-party provider that we use to deliver our newsletter: Mailchimp are signed up to the EU-US Privacy Shield.

How long we retain your personal data?

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. At the end of this period the information will be destroyed or deleted in line with our confidential destruction procedures.  We retain anonymised statistical information to help inform our work, but you cannot be identified from that data.

Security of your Information

We are committed to ensuring that your right to privacy is respected and that your personal information is secure and only available to those who have a right to see it.

We have monitoring and incident management procedures in place to detect, resolve and report any personal data breaches as quickly as possible and to improve our controls by addressing the underlying causes of such breaches.

Cookies

When users enter GCIL websites, their computers will automatically be issued with 'cookies'.  Cookies are text files which identify users' computers to website server.  If accepted, the website then creates "session" cookies to store some of the preferences of users moving around the website, e.g. retaining a text-only preference.  Cookies do not in themselves identify individual users but identify only the computer used: they are deleted on departure from the website.

When using GCIL websites, users will be invited to accept cookies to measure use of the website including number of visitors, how frequently pages are viewed, and the city and country of origin of users.  Information on how people use the site, through cookies and page tagging, helps us improve our website and our services. For this purpose, GCIL uses Google Analytics to measure and analyse usage of the website.  The information collected by GCIL will include IP address, pages visited, browser type and operating system.

Users can set their web browsers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time.  The last of these means that certain personalised services cannot then be provided to that user.

More information about how we use Cookies can be found on our Cookies policy - Hyperlink.

Links to other websites

This privacy notice applies solely to information collected by us.  GCIL websites and social media channels may contain links to other websites. We are not responsible for the privacy practices of those sites.  We encourage you to be aware when you leave any of our sites and to read the privacy notices of any site you subsequently visit.

Your Rights

Under the GDPR, you have a number of rights in relation to your personal information. You have the right to:

i. know what data we hold relating to you and why, and to receive a copy of it,

ii. request rectification of your personal information which means you are able to have inaccurate personal information corrected without undue delay;

ii. request erasure of your personal information when certain conditions apply;

iii. restrict processing under certain circumstances;

iv. object to processing;

v. data portability in some circumstances.

There are also specific legal rights relating to automated decision making but GCIL does not use any such processes.

Requests that relate to rectification, erasure or restricting data processing will be passed to any recipients of your personal information.

There may be occasions when GCIL is unable to comply with requests to exercise the rights detailed above. Should this apply to a request you make, it will be explained to you why GCIL is unable to comply with the request and any options available.

Where your personal information is being processed using consent, one further right is the right to withdraw your consent at any time. You should be aware that, while GCIL will stop using your information for that purpose with immediate effect, it may not always be possible to remove information from the public domain, for example where it has been used in hard copy publications. You should also be aware that the ability to withdraw consent only applies to information considered to be personal. It does not usually apply to information about groups or organisations.

You are not required to pay any charge for exercising your rights. If you make a request, we will respond without undue delay and at least within one month.

For more information on your data protection rights see https://ico.org.uk/forthepublic .

To exercise any of these rights or for more information, please contact our Data Protection Compliance Officer, using the contact information provided in this notice.

Complaints

If you are dissatisfied with our response to a complaint you send us, or have any concerns about our handling of your personal data, you can complain to the Information Commissioner's Office by using the details below:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone:      0303 123 1113

Online:            https://ico.org.uk/concerns/handling/

Changes to our Privacy Notices

We will keep our privacy notices under regular review to make sure they are up to date and accurate. This notice was last updated on 15th May 2019. The latest full versions are always available from our website at .