Privacy Policy

This website is operated by Highland Community Care Forum. We take your privacy seriously and we ask that you read this policy carefully, as it contains important information on:

• the personal information we collect about you when you access our website;
• what we do with that personal information; and
• who that personal information might be shared with.

We are the controller of the personal information that we collect from you on our website, which means that we are legally responsible for how we collect, hold and use your personal information. It also means that we are required to comply with data protection laws when collecting, holding and using your personal information.

We have appointed a Data Protection Officer (DPO), Daradjeet Jagpal, who ensures that we comply with data protection laws. If you have any questions about this policy or how we hold or use your personal information, please contact the DPO by: email at daradjeet@infolawsolutions.co.uk; telephone on 07852 905 779; or writing to: The Data Protection Officer, Highland Community Care Forum, 5 Tulloch Street, Dingwall, IV15 9JY.

You can also contact us by: email at carers@connectingcarers.org.uk; telephone on 01463 723 575; or writing to us at the above address.

Your attention is particularly drawn to section 2 of this policy, which confirms that you consent to your personal information and special category personal information being held and used by us as described in section 1 of this policy.

1. What personal information do we collect about you and why?

Our website is a place for you to find out more about us, our work and the services that we provide.

When you visit our website, we collect personal information about you when you:

• complete and submit a “contact us” form;
• contact us by telephone, email or letter;
• subscribe to receive communications from us;
• report a problem with our website;
• notify us of any changes to personal information that you have previously provided to us, including your contact details; and
• log in to your Member Account page on our website.

We use such personal information to:

• provide you with the information and services that you have requested from us;
• communicate with you, including in response to any of your enquiries, requests, comments, complaints and suggestions;
• improve our services and respond to changing needs; and
• keep the personal information that we hold accurate and up to date.

We may not be able to provide the above services to you if you do not provide us with sufficient personal information to allow us to do so.

We may also collect personal information about you through the use of cookies on our website.  For further information on cookies, please see our Cookie Policy [INSERT LINK]

2. What is our legal basis for holding and using your personal information?

Data protection laws require us to have a legal reason for collecting, holding and using your personal information.

Our legal reasons for holding and using your personal information are:

• performance and management of any arrangements between us;
• legal and regulatory obligations which apply to us as a charity registered in Scotland;
• protection of your vital interests; and
• our legitimate interests – while you have a legitimate interest in the protection of your personal information, we may also have an overriding legitimate interest in handling and using your personal information.

In some circumstances, we may rely on your consent as the legal reason. By providing us with your personal information and special category personal information (relating to your health, racial or ethnic origin, religious or other beliefs, sexual orientation or gender) and the personal information and special category personal information of other individuals via our website, you:

• consent to it being used by us as described in section 1 of this policy; and
• confirm that you have informed the other individuals if they are 12 years old and above of the content of this policy and they have provided their consent to their personal information and special category personal information being used by us as described in section 1 of this policy.

You and the other individuals have the right to withdraw your consent to us holding and using your and their personal information and special category personal information by contacting us.  Once you / they have withdrawn your / their consent, we will no longer use your / their personal information and special category personal information for the purpose(s) set out in section 1 of this policy, which you originally agreed to, unless we have another legal reason for doing so.

3. Who do we share your personal information with?

We may share your personal information with the following organisations for the purposes described in section 1 of this policy:

• our IT service providers, including the providers of our document management systems on which your personal information is stored and accessed by us, and our website hosts, who maintain our website;
• local and other public authorities for performance of the arrangements that we have entered into with them as part of the services that we provide to you;
• third parties who deliver services to you; and
• our professional advisers and consultants.

4. How long do we keep your personal information?

We will only keep your personal information for as long as we need to for the purposes described in section 1 of this policy, including to meet any legal or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we handle and use your personal information and whether we can achieve those purposes through other means, and the applicable legal or other requirements.

5. How do we keep your personal information secure?

The security of your personal information is important to us and we use technical and organisational measures to safeguard your personal information.

However, while we will use reasonable efforts to safeguard your personal information, the use of the Internet is not entirely secure and, for this reason, we cannot guarantee the security of any personal information that is transferred by or to you via the Internet.  If you have any concerns about the security of your personal information, please contact our DPO for more information.

6. What if you provide us with personal information about somebody else?

We understand that there may be situations where you provide us with personal information about somebody else via our website. In those situations, you confirm that:​

• the other individual has consented to you acting for them and to your use of their personal information;

• you have informed the other individual of our identity and the contents of this policy, including the purposes for which we will use that individual’s personal information described in section 1 of this policy; and

• the other individual has explicitly consented to our use of that individual’s personal information for the purposes described in section 1 of this policy.

This policy will apply to our collection, handling and use of the other individual’s personal information in the same way that it applies to your personal information.

7. Where is your personal information stored?

Our servers are located in the United Kingdom and the information that we collect directly from you will be stored in these servers.

Some of the organisations we share your personal information with (listed in section 3 of this policy) may be based or may make use of data storage facilities that are located outside the United Kingdom. Their handling and use of your personal information will involve us and/or them transferring it outside the United Kingdom. When we and/or they do this, we will ensure similar protection is afforded to it by:

• only transferring it or permitting its transfer to countries that have been deemed to provide an adequate level of protection for personal information under data protection laws; or
• using specific contracts with such organisations, which are approved for use in the United Kingdom, and which give your personal information the same protection it has in the United Kingdom after it is transferred.

Please contact us for further information on the specific mechanism used when we transfer your personal information outside the United Kingdom.

8. What about third-party links?

Our 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 personal information about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy policy of every website you visit to understand how they collect, hold and use your personal information.

9. What rights do you have in relation to your personal information that we collect, hold and use?

It is important that the personal information that we collect, hold and use about you is accurate and current. Please keep us informed of any changes by contacting our DPO.  Under certain circumstances, the law gives you the right to request:

• A copy of your personal information and to check that we are holding and using it in accordance with legal requirements.
• Correction of any incomplete or inaccurate personal information that we hold and use about you.
• Deletion of your personal information where there is no reason for us continuing to hold and use it. You also have the right to ask us to do this where you object to us holding and using your personal information (details below).
• Temporarily suspend the use of your personal information, for example, if you want us to check that it is correct or the reason for processing it.
• The transfer of your personal information to another organisation.

You can also object to us holding and using your personal information where our legal basis is a legitimate interest (either our legitimate interests or those of a third party).

Please contact our DPO if you wish to make any of the above requests. When you make a request, we may ask you for specific information to help us confirm your identity for security reasons. You will not need to pay a fee when you make any of the above requests, but we may charge a reasonable fee or refuse to comply if your request for access is clearly unfounded or excessive.

10. Feedback and complaints

We welcome your feedback on how we hold and use your personal information, and this can be sent to our DPO.

You have the right to make a complaint to the Information Commissioner, the UK regulator for data protection, about how we hold and use your personal information.  The Information Commissioner’s website is https://ico.org.uk/ and complaints can be made here.

If you would like to receive this policy in an alternative format, for example, audio, large print or braille, please contact our DPO.

11. Updates to this policy

We may update this policy at any time, and you should check our website occasionally to ensure you are aware of the most recent version that will apply each time you access our website.

Last updated: 21 February 2022