ILF Scotland Privacy Notice
We are committed to protecting and respecting the privacy of individuals who:
This Privacy Notice explains:
More detailed information about how your information is used during the process of applying to ILF Scotland funds can be found by reading the data protection policies of that fund. These are on our website at www.ILF.scot. Search for policies.
We collect data directly from you, your representatives or other professionals who are known to you, (for instance teacher, or social workers).
We collect:
Your National Insurance number
Details relating to your receipt of Personal Independence Payments or Disability Living Allowance (if applicable)
Details relating to your disability or impairment and
Bank account details so that we can pay the money to you
If we need to collect any other personal information via our website or a funding application form, we will tell you beforehand. We will make it clear what we need to collect, when we will collect it and what we intend to do with it.
Your personal information will be used by us to:
We will not share your information with anyone else for them to sell you things. We do share the minimum amount of data, e.g. your name, email address or home address with the companies who create and send out our newsletter; as well as the company who send out equipment that you order as part of the technology grant. We have an agreement in place with both companies called a “Data Sharing Agreement” which includes things like: they must tell you if your data is breached and they must only keep your data for an agreed amount of time.
We may scramble and anonymise personal data for the purposes of staff training and/or the testing of new technologies and services. A Data Protection Impact Assessment will be carried out in all such instances and all measures will be taken to ensure that data processed in this way cannot be traced back to any given individual.
ILF Scotland uses most personal information in the “Performance of a Public Task” because we are asked to by Scottish Ministers. For information which is used in the management of an ILF Scotland award, our legal basis is: “The Performance of a Contract” from the agreements you have made with ILF Scotland.
Occasionally we rely on the legal basis of “Consent;” for example, if you have gone to an ILF Scotland event and have told us that you want to hear about future events. Where we have relied on “consent” you will have agreed to us using your information in this way by signing a form or sending us an email or letter confirming that. Where we rely on “Legitimate Interest,” you will have contacted ILF Scotland about our services, for instance, made a complaint and in order to deal with your complaint, we must use your personal information to reply to you.
When we are using more sensitive types of personal information, including proof of address and information relating to health and disability, we need an additional legal basis under Article 9 of the Data Protection Act 2018 for “special category data”. This is outlined below:
We keep your personal information safe on secure servers in the Scottish Government network. These are located in the United Kingdom. Where we receive paper based information, this is scanned via secure printers linked directly to our systems. The original paper version is kept in secure filing cabinets in a secure government building until it has been scanned. It is then destroyed immediately by shredding in the same building.
Calls to ILF Scotland office telephone numbers go directly to our Specialist Casework Team. The Casework Team can see these on their laptops but the information is not recorded or captured as text.
As you read in section 3 above, we do transfer your information to a mailing company so that they can send out our newsletter and other mailings for us. We have an Agreement in place with that company and they are not able to share that information with anyone else. They also cannot keep it or use it to contact you about their own organisation.
We use a system for sending emails to lots of people together this protects your information when we send out a lot of emails or texts at once. The systems that we use for this are:
Social Media
We need to process certain information about you so that you are able to communicate with us through your chosen social media platform. You can contact us directly using these platforms. The information provided by you will be used only for the purpose of responding to your message.
We use some information from our social media pages, such as ‘likes,’ page views, ‘retweets’ and other information about your like: your age, education etc. This helps us to plan what we write on social media to know how well our posts are working for you. No personal information is kept on our systems for this and we never use this information to make decisions about awards.
As long as you join in on our social media, we will have a record of you on our social media sites. You can find out more about how those sites use your information by visiting their privacy notices.
We may share comments made publicly by you via your social media accounts if these posts are relevant to the work of ILF Scotland.
6. Keeping your information secure
Sending information over the internet is not completely secure, and we cannot guarantee the security of your data. As a result, any data that you send to us over the internet is sent at your own risk.
Sending information using the postal system is also not secure, and again, we cannot guarantee the security of your data. As a result, any data that you send to us by post is sent at your own risk.
We have procedures and security in place to keep your data secure once we receive it. As you read in section 4 above (Where your information is kept) we keep your electronic data (including data sent to us in the post, because we scan it on to our systems) on secure servers in the Scottish Government network.
7. Sharing Your Information with Other Organisations
Sometimes, people who receive ILF Scotland funding also receive support from health and social services, schools and education providers and their local authorities. We will only contact these other organisations if we need to get more information about you so that we can process your award, or to confirm what benefits and support packages (with the local authority) you have.
We have agreements in place with all organisations that we share your information with. These are:
In addition, and as you read in section 3 above, sometimes we share your personal information if we have a legal obligation to, or to enforce the terms and conditions and other agreements. This includes exchanging information with other government departments for legal reasons.
We share the minimum amount of your information with companies who are asked by the Scottish Government to make extra payments for specific and unusual reasons. To do this we use a system called ‘Huddle.’ When we use Huddle your information cannot be seen by anyone except the person that we invite to look at it. You can look at the security arrangements of the Huddle system by visiting their website: www.huddle.com/product/security.
We share the minimum amount of your information with companies who send out our mailings. We have looked at the risks of these companies doing this and we have formal agreements in place with them.
When we send electronic communication like email, or make phone calls or fax marketing messages, we comply with, “The Privacy and Electronic Communications Regulations”
8. Links to other websites
Our website has links to other websites. We have no control over the contents of other websites. We are not responsible for what is written on other websites, or whether those websites keep your information safe. The companies that own those sites may collect information from you. They will have their own data protection or privacy policy. You should read it.
This Privacy Notice is only for ILF Scotland, and the services that we provide, and our website.
ILF Scotland Cookies Policy
9. How cookies are used on our website
Our website puts small files (known as ‘cookies’) onto your computer to collect information about how you browse and use our website. Most internet browsers allow users to change their settings and turn off certain cookies. However, please be aware that turning cookies off may reduce some of the tracking services and functionality which our website can provide. Please also note that each time you visit to our website you will need be asked to accept or decline the cookies. Your cookie preferences are a matter for you to decide and your decision will not impact or influence how ILF Scotland processes your information or application.
We use cookies to:
Cookies on our website are not used to identify you personally.
We store cookies on your device to ensure our web site works correctly for you. This means that if you start an application for funding, you will be able to save it and complete it at a later time. \The ‘cookie’ on your device will let you start from the point in your application process where you stopped. However, if you decline cookies, you will have to go through all the previously saved pages to get to the one you left.
Measuring website usage (Google Analytics)
We use Google Analytics to help make sure our website is meeting your needs and to help us make improvements.
Google Analytics works by placing cookies (as detailed in section 12 below (Google Analytics)) on to your computer.
Google Analytics stores information about:
This helps us to know what you find most interesting or useful about our site.
Google Analytics does not collect or store your personal information (for example your name or email address), so the information that is collected using Google Analytics cannot be used to identify who you are. It does collect your IP Address (a unique address for your computer) to count the number of times you visit our website and what you look at on our website. but it does not tell us who you are. It lets us know how the website is being used, not who is using it.
We do not allow Google to use or share our analytics data with any other companies and only a few ILF Scotland staff have can see the reports from Google Analytics.
If you choose not to accept or decline the cookies, the website will assume that you are happy to accept our use of cookies.
Google Analytics
If you allow them, Google Analytics places the following cookies on your computer:
_ga: which helps us count how many people visit ilf.scot by tracking is you’ve visited before. This expires after 2 years.
_gid: which helps us count how many people visit ilf.scot by tracking if you’ve visited before. This expires after 1 day.
_gat: which is used to manage the rate at which page view requests are made. This expires in 10 minutes.
_utma: Like _ga, this lets us know if you’ve visited before, so we can count how many of our visitors are new to ilf.scot or to a certain page. This expires after 2 years.
_utmb: This works with _utmc to calculate the average length of time you spend on ilf.scot. This expires after 30 minutes.
_utmc: This works with _utmb to calculate when you close your browser. This expires when you close your browser.
_utmz: This tells us how you reached ilf.scot (for example from another website or a search engine). This expires after 6 months.
Your rights
Users of ILF Scotland services have the following rights:
Depending on the nature of your request we may not always be able to comply but we will always let you know why we are unable to comply. For example, if you have received an award or funding grant from us, we need to retain this information for 7 years for our financial records and tax purposes and will not be able to remove it during this period of time.
On occasion ILF Scotland may apply an exemption to a Subject Access request. These will be considered on a case by case basis. It is likely that it would only be for one of the following reasons:
ILF Scotland will inform you of any changes to your rights and how we use and protect your information. If you want to exercise your rights as highlighted, please contact us via email on DPO@ilf.scot or call our offices on 0300 200 2022.
Your right to complain
If you are unhappy with how we are using personal information about you please contact Data Protection Officer at Independent Living Fund Scotland, Ground Floor, Denholm House, Almondvale Business Park, Almondvale Way, Livingston, EH54 6GA (telephone 0300 200 2022 or email dpo@ilf.scot).
If after a reasonable period, you are not satisfied with our response to your complaint, you then have the right to complain about how we use personal information to the Information Commissioner’s Office (ICO). Details about this are on their website at www.ico.org.uk.
Document Information
Document Date: 1st August 2019
Review Date: 27th November 2024
Next review: July 2025
