Welcome to the Bank of Scotland Foundation’s Matched Giving privacy notice.
Bank of Scotland Foundation is an independent charity working with charities across Scotland supporting people and their local communities.
The Bank of Scotland Foundation respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you submit an application for Matched Giving and tell you about your privacy rights and how the law protects you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) nor do we collect any information about criminal convictions and offences.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how the Bank of Scotland Foundation collects and processes your personal data when you apply for Matched Giving.
It is important that you read this privacy notice together with any other privacy notice we make available to you so that you are fully aware of how and why we are using your data. This privacy notice supplements other privacy notices and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
DATA CONTROLLER AND CONTACTING US
Bank of Scotland Foundation (a private company limited by guarantee with Company Number SC229825) is the data controller and responsible for your personal data (collectively referred to as “BoS Foundation”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at using the details set out below:
Email address: [email protected]
The Mound, Edinburgh, EH1 1YZ
CHANGES TO THE PRIVACY NOTICE
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
USE OF YOUR DATA
THE DATA WE COLLECT
When you apply for Matched Giving, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity Data includes first name, last name, title and employee ID number.
Contact Data includes your address, email address and telephone numbers.
Profile Data includes your username.
Marketing and Communications Data includes your preferences in receiving information from us about upcoming BoS Foundation events.
We also collect, use and share Aggregated Data such as the number of applicants in a given year or trends amongst applicants. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
HOW WE COLLECT YOUR DATA
We collect data from you from Direct Interactions. You may give us your Identity Data, Contact Data and Marketing and Communications Data by completing a Matched Giving application or by corresponding with us by post, phone, email or otherwise.
We may also collect data relevant to your application regarding volunteering hours and fundraising amounts from the charities named in your application.
PURPOSE OF PROCESSING
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (being the interest of our Foundation in conducting and managing applications for funding and to enable us to give you the best service) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service we provide to you or other transactions. We may still contact you to administer our services or for our other legitimate purposes.
HOW WE USE YOUR DATA
We plan to use your data in the ways set out in the list below. We have tried to identify our legitimate interests where appropriate.
We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the list below.
Identity Data and Contact Data to give you information relating to our Foundation and to process your application and respond to queries.
Identity Data, Contact Data and Profile Data to manage our relationship with you as necessary for our legitimate interests (for running our Foundation, provision of administration services, and developing our services).
Marketing and Communications Data to manage your preferences and run our events.
HOW WE SHARE YOUR DATA
We may share your personal data with the parties set out below:
Relevant Line Managers within Lloyds Bank to confirm the accuracy and legitimacy of the claim. We may also need to share your personal data with other departments within Lloyds Bank to carry out fraud prevention checks.
Charities named in your application if your application is successful and payment has been made.
External Auditors as part of the annual audit of the Bank of Scotland Foundation.
Fraud prevention agencies who carry out fraud prevention checks on our behalf against applicants, office bearers and other relevant persons.
Service providers who provide us with IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers based in consultancy, banking, legal, insurance and accounting services.
Law enforcement agencies, regulators and other authorities and government bodies who require reporting of processing activities in certain circumstances.
We may share your data or Aggregated Data with other entities in the Lloyds Banking Group (LBG) to monitor LBG’s “Helping Britain Prosper” plan. We may also share anonymised data or Aggregated Data with Lloyds Bank Foundation for England & Wales, Halifax Foundation for Northern Ireland, Lloyds Bank Foundation for the Channel Islands to ensure a consistent standard of service across the foundations.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA).
HOW LONG WE KEEP YOUR DATA
We will retain your personal data and for a period of 10 years. This period is in line with Lloyds Banking Group’s retention policy. Lloyds Banking Group is the sole donor of Bank of Scotland Foundation.
After a period of 10 years, your personal data will be removed from the grant management system. Details of the grant will be maintained, to highlight the grant relationship with your charity.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
In some circumstances, you can ask us to delete your data. See Request Erasure below for further information.
CHANGE OF PURPOSE
We will only use your personal data 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
EXERCISING YOUR LEGAL RIGHTS
If you wish to exercise any of the rights set out above, please Contact us.
You will not have to pay a fee to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.