This document was last updated 14 July 2022.
This notice is set out to help you understand the types of data that we collect from you, and/or your business, and how that data is used and managed.
This notice applies to all websites & applications developed and delivered by The Bailies of Bennachie. The Bailies of Bennachie is a registered charity incorporated in Scotland under charity number SC047231 and has a registered office at PO BOX 11535, Huntly, Aberdeenshire, AB54 9AD. All significant decisions about data processing and policy implementation will be made using UK GDPR (General Data Protection Regulation).
The Bailies of Bennachie are committed to protecting the privacy and security of your personal data. We continually monitor compliance through implementing policies & procedures to safeguard data and by setting regular reviews to manage these policies and procedures.
In accordance with ICO (Information Commissioners Office) requirements of Data Controllers (the main decision maker when it comes to how people’s personal information is managed), The Bailies of Bennachie is registered with the Information Commissioners Office (ZB342548). When you are using The Bailies of Bennachie website, The Bailies of Bennachie is the Data Controller.
We care about Bennachie, its natural environment, history, and culture - protecting its unique landscape for future generations. The Bailies work with landowners and stakeholders around Bennachie. This includes Forest Enterprise Scotland (from April 2019 - Forest and Land Scotland), Pittodrie Estate and others including Monymusk Estate, Forbes Estate, Aberdeenshire Council, and the Bennachie Centre Trust. The joint aim of all parties being to look after and maintain Bennachie for the enjoyment of future generations on the hill.
There are many events and activities for volunteers & members to engage in. Levels of engagement will vary for each member. Types of engagement includes volunteer work parties on Bennachie to support maintenance of pathways, Bennachie Landscapes Projects including excavations and other historical projects, wildlife groups to learn about and monitor Bennachie’s animal, bird & plant wildlife activity, fundraising events & donations. The Bailies of Bennachie also create publications and distribute these through local outlets in Aberdeenshire and through its online shop. A library archive has also been created to include the history of The Bailies of Bennachie and its Charity Trustees, volunteers, and members contributions & achievements over the years. There is a fun and learning website for younger people to learn more about Bennachie, including its wildlife to help them understand more about Bennachie and nature.
Who do we collect information about?
We regularly collect personal information directly from Charity Trustees, Volunteers, Members, Suppliers, Contractors & Customers.
We occasionally collect limited indirect personal information about emergency contacts, family members and children
Type of Information we collect
Personal data is information about you and from which you can be identified. We will collect and process personal data about you depending on our relationship with you. Most of the personal information we process is provided to us directly by you. Data collection can be through a variety of channels, including by telephone, email, via our website or on site and via third parties.
We will collect some or all the categories listed
- Personal Information: such as name, address, date of birth, age, gender, email, phone number, photo ID, car registration, emergency contacts
- Sensitive information: such as health, medication & medical history, if you have an accident whilst on a working party or walk that you inform us of, we may record details of that accident and any injury you suffer in an accident log
- Social information, Interests, attendance, skills, and capabilities
- Volunteer and member group information - including media images around the activities and achievements of members and volunteers
- Transaction Data - Details about payments to and from stakeholders and other details of products and services provided to us or purchased from us
- Profile - Purchases made by you, your interests, preferences, registration form details, information provided by you in connection with your visit, feedback, competition, and survey responses
- Usage - Information on how you use our website, products and services including details of the bookings or purchases you make
- Marketing - Your preferences in receiving marketing communications from us
The Bailies of Bennachie can be found on social media platforms such as Facebook, Twitter, and Instagram. Social Media is an important part of our awareness effort. These platforms are run by commercial companies and The Bailies of Bennachie is not the Data Controller or Data Processor of your social media profile. You should contact these social media platforms directly if you have concerns over how your personal data is being used and stored by them.
How we use your information
Your information is used in the following ways:
- Administer purchases, confirm your purchases, and otherwise communicate with you about your purchase.
- Provide you with other products and volunteering support such as parking permits.
- Administer, manage & support volunteers and members
- Help us to provide, review, develop and improve our support, services & activities; this may include contacting you (including by email) for research purposes
- Use photographs, videos, member & volunteer feedback, and testimonials for promotional purposes
- Provide you with information that you have requested from us
- Send you notifications of volunteering party events to encourage members and volunteers to attend
- Contact, publish photographs & names of winners in relation to prize draws, competitions, and other promotional activities
- Send you notifications of AGM’s, EGM’s, issue annual reports and any other news updates or letters
- Customise our website according to your interests and ensure that content is presented in the most effective manner for your computer, tablet, or mobile device
- Allow you to participate in interactive features of our service where you have chosen to do so
- Use data analytics to improve our website, products/services, marketing, customer, member & volunteer relationships, and experiences.
- Address any claims made against us; for example, we may share details of our accident logs with our insurers in connection with any claim made or likely to be made against us in connection with legal proceedings (i.e., the establishment, exercise, or defence of legal claims)
- Comply with any legal or regulatory obligation (including in connection with a court order)
- Delivery of services & contractual agreements we have with or otherwise concerning you
- To protect our rights, & safety of our volunteers, members, contractors and other third parties
The Bailies of Bennachie will only process personal data where we have a lawful basis for doing so. The legal grounds for processing data will depend on the purpose of the data collected and its processing requirements. Under UK GDPR, the lawful bases we rely on for processing your data are Consent (which you can withdraw at any time), Contractual, Legal Obligation, Legitimate Interest and Vital Interest. We will only process data which is relevant, and limited to what is necessary for processing.
When you become a Bailies member, you become a member for life. This means we will continue to process and hold your data until you tell us otherwise. Please inform us if your details should change at any time.
The Bailies of Bennachie use third parties who provide elements of our services for us. We have contracts in place with these 3rd parties who are data processors (the people who process personal information on our behalf). This means they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct them to.
The Bailies of Bennachie will not share your information with any third parties for the purposes of direct marketing
The Bailies of Bennachie will not transfer any personal data out with the UK/European Economic Area or to any third party without your knowledge. We may be required to transfer your information as part of a division/merger of some or all of our charity assets as part of any restructuring or reorganisation of this Charity. If we need to do this, we will let you know prior to transfer.
We do not currently offer children memberships or volunteering opportunities; however, children do accompany their parents, guardians or responsible adult who volunteer or are members. We also operate a Fun and Learning website that provides educational information in a child friendly way. We occasionally attend school events to educate groups of children around relevant aspects of Bennachie. We occasionally run competitions during which we make provisions to verify age and gain parental or guardian consent where required.
In line with the Children’s code, we make the following considerations:
- Ensure the best interests of the child is the primary consideration
- We undertake impact assessments to mitigate risks to the rights and freedoms of children
- Take a risk-based approach to ensure the educational content suits all age groups
- Information we process is detailed in this privacy notice
- We will not profile or use personal information in ways that could be shown to be detrimental to their wellbeing
- We will not use geolocation on our websites or applications or make this visible to others
- We do not use nudge techniques or lead children to provide personal information or turn off privacy protections
- We do not communicate through toys
Protecting your personal information
The Bailies of Bennachie will continue to look for new ways to protect data. However, in the event of a data breach we will notify the ICO (Information Commissioners Office) within 72 hours of becoming aware of the breach. Where we do not yet have all the relevant details we will notify when we expect to have the results of the investigation. We use the ICO guidance framework on managing a security breach to guide us.
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at email@example.com if you wish to make a request.
Bailies of Bennachie, PO Box 11535, Huntly, Aberdeenshire, AB5 9AD, www.bailiesofbennachie.co.uk
Further information around your rights can be found at https://ico.org.uk/your-data-matters
The ICO’s address:
Information Commissioner’s Office