What this privacy policy covers

This policy explains how The BIG Project uses, stores and protects any personal data it manages through the provision of its programmes and membership services.

The BIG Project takes its obligations to any personal data held very seriously and has updated this policy to accommodate new General Data Protection Regulation (GDPR) that come into effect on 25 May 2018.

We may update this policy from time to time to provide additional information or clarity. This page will be the master copy of our policy, and we encourage users to check for any updates regularly.

We intend to try and use plain English and youth work terminology as far as possible under our requirements for this policy. Any use of ‘us’, ‘we’ or ‘our’ etc. refers to The BIG Project. Any use of ‘you’, ‘your’ or ‘you’re’ etc. refers to the user of our services. There are some legal terms used out of necessity but please get in contact if you require clarification on any of this policy.

To contact us regarding this policy, please email: info@thebigproject.org.uk or write to The Big Project, Broomhouse Primary School, 33-39 Saughton Road, Edinburgh, EH11 3RQ.

General Data Protection Regulation (GDPR)

The General Data Protection Regulation (GDPR) takes effect from 25 May 2018. GDPR is an evolution of the existing Data Protection Act (DPA) and Data Protection Directive. It is intended to give all of us greater visibility and control of our personal information (referred to as personal data).

Personal data is defined as, “… ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.”

What this means is any information an organisation holds that could be used to identify a person, counts as personal data.

You can find out more about GDPR and how the Information Commissioner’s Office (ICO) applies it to UK organisations on their website www.ico.org.uk

Child Protection and privacy

The BIG Project, like its members and many of its partners, operates in the youth sector, interacting with young people aged 5 years+. Where relevant, and if there exists a conflict, Child Protection legislation and policy supercedes GDPR.

Types of information

Information, or data, that we hold is done so on a consent or legitimate interests basis, meaning that we hold and use information based on your permission (consent) to do so, such as providing your email address and name when you sign up to our email newsletter, or on the requirement for that information to provide our services (legitimate interests).

There are three main types of information The BIG Project holds to provide services to you:

The information you give us

You provide us with information when you use our services. This may be an application to join The BIG Project or registering for a training session we provide. In all cases, you choose to provide the information requested so that we may provide the service.

Information will typically be provided to us via a form. This form may be accessed online, such as a membership application on our website, or via a physical form, at/or during a The BIG Project event, such as a registration form.

Information that technology gives us

Information is sometimes automatically passed between your chosen technology and The BIG Project’s technology by accessing our digital services. The most common usage is website analytics and browser cookies.

Your web browser automatically passes information about itself and your device (computer/mobile etc.) to any internet location you visit. Your browser has specific settings you can adjust to limit or increase these options.

This information is often referred to as metadata and is information including log data, information passed by your web browsers like IP address or other web browser information; device information, like what type of computer or mobile device accessed our website; location information, such as an approximate location while accessing our website.

Electronic communications

We maintain an active email newsletter and bulletin service to opted-in users and we usually receive information, such as a confirmation when you open an email, when the email is opened, and any links clicked—but only if your technology and services permit it.

This service operates an independent op-out, meaning you may unsubscribe without having to contact us.

The controller of Personal Data

Any personal information provided to or gathered by The BIG Project is controlled by The BIG Project, Scottish Charity No: SC035600. Registered in Scotland. The Big Project, Broomhouse Primary School, 33-39 Saughton Road, Edinburgh, EH11 3RQ.

To communicate with our Data Protection Officer, please email info@thebigproject.org.uk or write to the above address.

How information is used

We use any information you provide to us to fulfil the service or services related to your data. For example, to apply for membership, we will ask for the information about you that we require to grant membership, according to our membership criteria. Likewise, we will ask for names, contact details, dates and times when you book an event so that we know who will attend and when.

In essence, the information is directly related to being able to fulfil the service we set out to provide to you or that required by law.

The core uses of personal data held by The BIG Project are:

  • To provide, update, maintain and improve our services
  • As required by law, legal process or regulation
  • To communicate and respond to requests, comments and questions
  • To send service emails and other communications essential to providing membership and services
  • For billing, account management and other administrative matters
  • To maintain security and standards

In addition to the core purpose we use data for, we may also use the information to analyse or profile our users to fulfil legal obligations, reporting obligations and to maintain and improve our services.

This may include:

  • We may use data to analyse our services, e.g. satisfaction surveys and programme evaluation surveys to see how we are doing and take on board feedback
  • We may profile data on a geographic basis, e.g. we may look at whether a service will qualify for funding or programme access due to relevant geographic criteria
  • We may profile data on age, gender or ethnicity, e.g. we occasionally seek to understand our membership demographics to improve our offering and complete our annual reporting
  • We may profile data for aggregated statistics to complete reports, e.g. we are often required to complete annual reports for programmes we run as a contractual obligation.

Sharing information

Some of The BIG Project programmes, events or activities are supported or funded by other organisations. These programmes and events can require that reporting, financial and evaluation data be shared with the supporting funder or partner as a condition of the contract. We will always make you aware of where this applies.

The current obligations on The BIG Project are as follows:

The BIG Project Membership

Membership data for The BIG Project primarily contains data about relevant member groups, but applications and member information records include personal data relating to member contacts.

Personal data from direct memberships and applications come directly to The BIG Project only and is not shared.

PVG Scheme

All staff who apply for PVG scheme membership/updates provide sensitive personal data required to process the PVG Checks. These details are submitted by The BIG Project directly to Volunteer Scotland Disclosure Services. Disclosure Scotland produces PVG certificates and shares these with applicants and with The BIG Project.

Events

The BIG Project uses the Eventbrite platform to manage our bookings for training and events. Eventbrite is a third-party, cloud-based system and data is not held locally. Eventbrite store data globally in compliance with GDPR and the EU-US Privacy Shield Framework.

The BIG Project never sells data to third parties.

Individual rights

GDPR provides certain rights for individuals. These are how they apply to The BIG Project:

The right to be informed – the core purpose of this policy; we aim to tell you about the collection of personal data.

The right of access – you have access to your personal information (often called a “data subject access request”). This enables you to ask for a copy of the personal information we hold about you. This is normally free but please note that, as per ICO guidelines, an administration fee may apply, “when a request is manifestly unfounded or excessive, particularly if it is repetitive.”

The right to rectification – this is the right to have corrections made. This a shared obligation between us to keep personal data as up to date as is practical.

The right to erasure – this enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).

The right to restrict processing – This enables you, where appropriate, to ask us to suspend the processing of personal information about you. For example, if you are checking the accuracy of information we hold.

The right to data portability – in clearer words, the ability for you to take personal data from us to an alternative supplier. Less relevant to our operations but the right remains.

The right to object – where we are using a legitimate interest basis, and there is something which makes you want to object to processing on these grounds. This may mean we are unable to provide some services to you.

Rights about automated decision making and profiling – automated decision-making takes place when an electronic system uses personal information to decide without human intervention. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Security and where information is stored

The BIG Project takes every reasonable precaution to ensure any data we hold is secure and stored according to GDPR.

The following details explain the groupings for data storage; the technology involved and location.

In addition to the secure storage outlined below, access to any The BIG Project system is always protected by the requirement for secure login to our systems. Any physically held data is protected locally by secure entry system, alarm and CCTV.  Filing cabinets where used are locked.

Membership

Our membership data is stored locally, accessed and updated in a Microsoft Access Database 2013 system.

Website

The BIG Project website is hosted on 1&1 cloud hosting. No data is held locally. 1&1 data centres are among the most secure in the world and are held in European GDPR-compliant data centres.

Events

The BIG Project uses the Eventbrite platform to manage our bookings for training and events. Eventbrite is a third-party, cloud-based system and data is not held locally. Eventbrite store data globally in compliance with GDPR and the EU-US Privacy Shield Framework.

Data retention

The BIG Project will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

To achieve this, we have grouped personal data and set the following general limitations:

Membership data

Data is considered active and current during a membership period of 12 months. The BIG Project will hold data for up to 24 months after non-renewal before being archived. Only the base data required to identify a returning member will be archived.

Event registration data

The BIG Project uses personal data to allow participants to register for training and other event opportunities. This is typically through the Eventbrite booking platform but occasionally through direct communication with The BIG Project (forms and emails etc.)

The BIG Project will hold data for up to 36 months from the event completion date.

Financial data

Like other organisations, The BIG Project is required to hold organisational financial records for accounting, auditing and taxation purposes.

The BIG Project will hold data for up to 84 months from the end of financial year.

Employee & Committee member data

The BIG Project holds various personal data on current and former employees and trustees.

Data is considered active and current during the period an employee is actively employed by the organisation or for the tenure of a trustee. The BIG Project will hold data for up to 12 months for employees and committee member and 48 months from the last contract for freelancers and contractors.

Cookies

Like the majority of websites, The BIG Project website uses modern technology and data provided by you and your browser to try and provide the best service and experience we can.

Cookies may be used on our website. A cookie is a very small text file that is placed on your computer’s hard drive when accessing a website and it collects standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

You can set your browser to refuse cookies, and you can find out more information on how to refuse and delete cookies at http://www.aboutcookies.org. However, please note that some of this website may not function as a result.

Terms of use

If you access The BIG Project website you agree to be bound by the conditions in this legal message and further agree that the Courts of Scotland shall have exclusive jurisdiction in respect of any dispute arising from this legal message.

If you do not agree with the conditions in this message, do not use this website. Continued use of the website, regardless of acceptance or not of cookie policy etc., constitutes implicit acceptance.

The copyright in the material contained in The BIG Project website belongs to The BIG Project. All rights are reserved. Except solely for your own personal and non-commercial use no part of this website may be copied, performed in public, broadcast or adapted without the prior written permission of The BIG Project.

v.2.2 May 2018. Edited & customised by The BIG Project.