Privacy noticeUpdated: November 21, 2022
We are committed to protecting and respecting the privacy of individuals who:
- interact with us (by phone, email, in writing, to our website https://ilf.scot, or on social media)
- apply for funding from us
- receive funding from us.
This Privacy Notice explains:
- the types of personal information that we collect and process in relation to our funding activities
- how we get and use your personal information
- the legal basis we use to justify processing your personal information; and when we might share such personal information to other organisations
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.
1. Where we get your information
We collect data directly from you, your representatives or other professionals who are known to you, (for instance teacher, or social workers).
2. What we collect
- Personal information that you provide in relation to any enquiry or feedback that you send to us;
- Personal information that you provide in the application form for any ILF Scotland Fund, including, but not only:
- 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.
- Personal information, like your email address and how you want us to contact you;
- Personal information that you give us when you sign up to use our services and email alerts for updates;
- Personal information that our website gathers when you sign up to use funding services, including the IP address and details of your computer or tablet and which web browser you use; and
- Certain non-personal information about when and how you visit and use our website. You can turn this off by clicking ‘no’ on the top of the screen when you open our website.
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.
3. How we use your information
Your personal information will be used by us to:
- confirm your identity
- confirm your eligibility and
- understand and evaluate your application prior to a funding decision being made, to make sure that we make fair and consistent decisions
- to respond to any queries and/or feedback you send to us, where appropriate
- to update you on changes to your funding application and/or funding award
- to provide you with information about other support and services which may be of use to you, based on information you have provided to us
- to make sure that our online services work on the devices that you use
- to understand and improve our website by checking how it is used
- to help you to get back to previously viewed pages on our website
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 so we can send you important information about our funds, such as the ILF Scotland Newsletter.
4. How we can legally use and share your information
ILF Scotland uses most personal information in the “Performance of a Public Task” 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 “Legitimate Interest”; 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 rely on “Legitimate Interest”, you have agreed to us using your information in this way by signing a form or sending us an email or letter confirming that.
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:
- Counter Fraud Services or the Police ask us to for it – this is called “Legal Claims and Judicial Acts“.
5. Where your information is stored
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 2 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:
- Campaign Monitor – email
- Text Local – mobile communications
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. Giving Your Information to 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:
- The Department for Work and Pensions (DWP)
- Her Majesty’s Revenues and Customs (HMRC)
- The Scottish Social Security Agency (SSSA)
- Your Local Authority Social Work Department
- Your chosen Financial Management Organisation (if you use one).
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 or 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 to “The Privacy and Electronic Communications Regulations”.
Links to other websites
This Privacy Notice is only for ILF Scotland, and the services that we provide, and to 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 return visit to our website will be seen as a new visit with previous visit status and cookie preference choices lost. 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. However, please be aware that your cookie preferences may reduce our ability to send you email alerts but you would still receive emails directly to your personal email address if you have stated this as a preferred method of contact.
- understand your preferences when using our website
- measure how you use our website so it can be updated and improved based on your needs
- remember the notifications you have seen so that we do not show them to you again
- identify unique and returning visitors to our website and
- identify where people are visiting our website from (i.e. directly from their own device or via linked sites)
Cookies on our website are not used to identify you personally.
We store cookies on your device to ensure our web services function correctly for you. This enables you to start the process of completing an application, to save it and return to complete the application at a later time. When you return, the presence of the cookie on your device will allow you to return to the point in your application process where you last left it. However, if you choose not to allow cookies to be placed on your device, you will simply have to navigate 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 the needs of its users and to help us make improvements, for example, improving our website’s search facility. Google Analytics works by placing a number of cookies (as detailed in section 12 below (Google Analytics)) on your computer.
Google Analytics stores information about:
- the pages you visit on our website
- how many times people download forms and information sheets from our website
- how long you spend on each page of our website
- how you got to our website and
- what you click on while you are visiting our website
The Google Analytics software does not collect or store your personal information (for example your name or email address), so the information that is collected using the Google Analytics software cannot be used to identify who you are. It does collect your unique IP Address to count the number of times you visit our web pages and access the documents but there is no corresponding link to your personal identity. 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 third party and only named ILF Scotland staff members have access to the analytics reports for usage and service improvement requirements as described above.
Use of our website without amending your cookie preference to disable the cookies relating to Google Analytics indicates that you accept our use of these cookies in connection with your visit to our website.
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.
Users of ILF Scotland services have the following rights:
- The right to request any information that we hold about you – Subject Access Request
- The right to have us delete all the information that we hold about you – Right to be Forgotten – it is important to note that this is only an option for people who no longer wish to receive any funding from ILF Scotland
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:
- information required to be disclosed by law or in connection with legal proceedings
- legal professional privilege
- crime and taxation: risk assessment or general
- health, social work, education and child abuse
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 firstname.lastname@example.org).
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 Date: 1st August 2019
Review Date: July 2022
Next review: July 2023