GENERAL DATA PRIVACY REGULATIONS - MAY 2018
DATA PRIVACY NOTICE
Cairngorms Business Partnership Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, employees, members and partners and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Cairngorms Business Partnership Ltd (CBP)
Limited Company registered in Scotland under company number SC390658
Registered address: Inverdruie House, Aviemore, PH22 1QH
Main Trading address: Inverdruie House, Aviemore, PH22 1QH
VAT number: 109174718
Email address: firstname.lastname@example.org
Telephone number: 01479 810200
Postal Address: Inverdruie House, Aviemore, PH22 1QH
We are a member of Scottish Chamber of Commerce
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
- The right to access the personal data we hold about you. Part 10 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way
- For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
- Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
- If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us)
- Date of birth
- Email address
- Telephone number
- Business name
- Job title
- Payment information
- Information about your preferences and interests
Your personal data is obtained from the following;
- Completing an application to become a member of the CBP
- By you agreeing to be held on our database
- Signing up for email updates
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
- Providing and managing your account.
- Supplying products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by clicking the unsubscribe button at the bottom of mailings or by contacting email@example.com.
With your permission and where permitted by law, we may also use your personal data for marketing purposes and to keep you informed about the Cairngorms National Park, which may include contacting you by email, telephone, text message or post with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
For businesses in the Cairngorms National Park who are not members of the Cairngorms Business Partnership we will use your data to update you on events and opportunities you may be interested in as well as giving you the opportunity to complete periodic business surveys.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Your data will be held so long as you wish to receive information about the Cairngorms National Park. If you inform us you no longer want to receive this information and we have no other basis for holding your data.
- Your data will be held whilst you are a member of the Cairngorms Business Partnership and, if you cease to be a member of the Cairngorms Business Partnership for a period of 5 years unless you give us consent to continue to hold your data.
- For businesses who are not members of the Cairngorms Business Partnership we will hold basic data on your business until such time as you withdraw your permission for us to hold such data.
8. How and Where Do You Store or Transfer My Personal Data?
- We will only store your personal data within the European Economic Area (the ‘EAA’). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
9. Do You Share My Personal Data?
We may sometimes contract with the following third parties to supply services to you on our behalf. Those third parties may require access to some or all of your personal data that we hold
- STR Global, 26 Alva Street, Edinburgh EH2 4PY
Purpose: to undertake quarterly business survey
- Openbrolly, Northport Studio, 9a Lossie Wynd, Elgin IV30 1PU
Purpose: hold data in relation to hosting and maintaining visitcairngorms.com
- Mailchimp, The Rocket Science Group LLC, 975 Ponce de Leon, Ave NE, Suite 5000, Atlanta, GA 30308 (MailChimp participates in and has certified its compliance with the EU-US Privacy Shield Framework)
Purpose: to provide services such as email bulletins and updates
- Intuit Quickbooks, 1 Cathedral Piazza, Victoria, London, SW1E 5BP
Purpose: All accounts processes
- Eventbrite, 10-11 Charterhouse Square, EC1M 6EE
Purpose: booking site for events
- Creative Core, 5 Rubislaw Place, Aberdeen, AB10 1XN
Purpose: development of Snow Roads app and website
- Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Purpose: hosting CBP emails and vault storage. The data stored within Google Analytics is not personally identifiable, so storing this information without an expiry does not go against GDPR.
- Peter Munro & Company, 15-17 High Street, Kingussie, PH21 1HS
Purpose: completion of annual accounts
- FaceBook, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Purpose: relationship marketing
- Easypromos, C/Guell, 58, 17001 Girona, Spain
Purpose: running competitions
If any of your personal data is required by a third party, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
Email address: firstname.lastname@example.org
Telephone number: 01479 810200
Postal Address: Cairngorms Business Partnership Ltd, Inverdruie House, Aviemore,
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Our privacy notice is available at https://visitcairngorms.com