1. Introduction
This privacy policy explains how the High Knightswood and Anniesland Community Council (“HKA CC”), in partnership with DirectoryWest Ltd (“DirectoryWest”), collects, uses, and protects your personal data when you apply for a free grit bin through the DirectoryWest Community Grit Bin Pilot Program. This policy is compliant with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA).
2. Data Controller and Processor
For the purposes of this program, HKA CC is the data controller, and DirectoryWest is the data processor. This means that HKA CC is responsible for determining the purposes and means of processing your personal data, while DirectoryWest processes your data on behalf of HKA CC and under their instruction.
3. Information We Collect
We collect the following categories of personal data when you apply for a grit bin:
- Identity Data: Your full name.
- Contact Data: Your address, contact number, and email address.
- Health Data: Information about your mobility difficulties.
- Socio-economic Data: Information about your ability to afford a grit bin.
- Location Data: The location where you would like the grit bin to be placed.
4. Purpose and Lawful Basis for Processing
We collect and process your personal data for the following purposes:
- To assess your eligibility for the program: We use the information you provide to determine whether you meet the criteria for receiving a free grit bin.
- To communicate with you about your application: We may need to contact you to clarify information or to inform you of the outcome of your application.
- To arrange delivery and installation of the grit bin: If your application is successful, we will use your contact and location information to arrange delivery and installation of the grit bin.
- To follow up and gather feedback: We may contact you after the grit bin has been installed to check that everything is okay and to gather feedback on the program.
- To improve the program: We may use aggregated and anonymized data to analyze the effectiveness of the program and to make improvements for future initiatives.
The lawful basis for processing your personal data is:
- Article 6(1)(e) of the UK GDPR: Processing is necessary for the performance of a task carried out in the public interest (i.e., providing support to vulnerable residents during winter weather).
- Special Category Data (Health Data): Article 9(2)(g) of the UK GDPR: Processing is necessary for reasons of substantial public interest (protecting the vital interests of individuals in need of assistance during winter weather).
5. Data Sharing
Your information will be shared between HKA CC and DirectoryWest for the purposes outlined in this privacy policy. We will not share your information with any other third parties, except where required by law or with your explicit consent.
6. Data Security
We have implemented appropriate technical and organizational security measures to protect your personal data from unauthorized access, use, or disclosure. These measures include:
- Secure storage: We store your information on secure servers with access controls and encryption.
- Access controls: We restrict access to your information to authorized personnel who need it for the purposes outlined in this privacy policy.
- Data breach procedures: We have procedures in place to handle any suspected data breaches, including notifying the Information Commissioner’s Office (ICO) where necessary.
7. Data Retention
We will retain your personal data for no longer than is necessary for the purposes for which it was collected. We will review the retention periods periodically and securely delete or anonymize data that is no longer needed.
8. Your Rights
Under the UK GDPR, you have the following rights in relation to your personal data:
- Right of access: You have the right to request access to your personal data.
- Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data.
- Right to erasure: You have the right to request that we delete your personal data in certain circumstances (e.g., if it is no longer needed for the purposes for which it was collected).
- Right to restriction of processing: You have the right to request that we restrict the processing of your personal data in certain circumstances (e.g., if you contest the accuracy of the data).
- Right to data portability: You have the right to request that we transfer your personal data to another organization in certain circumstances.
- Right to object: You have the right to object to the processing of your personal data in certain circumstances (e.g., if you believe the processing is unlawful).
To exercise any of these rights, please contact HKA CC using the contact details below.
9. Contact Us
If you have any questions about this privacy policy or our data processing practices, please contact HKA CC:
- Email: hello@hka.scot
- Mail: High Knightswood & Anniesland Community Council, c/a Glasgow City Council, John Street, Glasgow
10. Online and Offline Applications
This privacy policy applies to both online applications submitted through the HKA CC website (hka.scot) and offline applications submitted in paper form. We take the same care to protect your personal data regardless of how you submit your application.
11. Updates to this Privacy Policy
We may update this privacy policy from time to time to reflect changes in our data processing practices or legal requirements. Any changes will be posted on the HKA CC website (hka.scot). We encourage you to review this policy periodically.
This revised privacy policy is now aligned with the key principles of the UK GDPR and DPA, ensuring lawful and transparent processing of personal data.