1. YOUR DATA AND HOW WE USE IT

1.1 Summary

We collect and process personal data to fulfil our charitable purposes and to deliver programmes to participants. When we collect your personal data, we aim to be clear about our reasons for doing so, and we will only use it in ways that you would reasonably expect.

In general, we collect data when you:

• visit our website;
• communicate with us;
• apply for a job/apply to be a trustee;
• take part in a programme or event with us;
• donate to us.

At some point, we will need to collect and use some of your personal data. We will do our best to keep your information up to date. Please let us know if your details change.

We want to be open, honest and fair in the way that we use your data. Section 4 of this Privacy Statement gives you details of your legal rights over your personal data.

If you aren’t yet a donor or customer, we might use some publicly available data to help us to get to know you. This is in our legitimate interests as a charity dependant on fundraising for income. You have the right to opt out of marketing and fundraising messages at any time.

We might also sometimes combine information that you’ve already given us with data from publicly available sources, such as information about the area where you live. This is so we can better understand you as a programme participant, candidate, partner or donor. This then helps us to work and communicate more effectively. Again, this is in our legitimate interest as a charity.

We keep your data secure and strive to continually improve our data systems and processes.

We use carefully chosen suppliers to help us with specific tasks. This sometimes means we need to share some of your personal data with them. For example, this could be to send you an email newsletter that you’ve opted in to (Mail Chimp), or to process a payment. We share only the information needed to carry out the particular task. Our contracts with our suppliers require them to only act on our instructions, to keep your data secure and to comply with data protection laws. We always keep control of your data.

Like any other organisation in the UK, if asked by the police, or other regulatory or government authority, we may be required by law to pass on your personal data to them, and we might not be allowed to tell you if this happens.

The rest of section 1 goes into more detail about what we do with your personal data depending on your relationship with us.

1.2 When you visit our Website

When you use our website, we collect and process certain types of personal data and place some cookies on your device. For details, please see the cookies policy at https://venturescotland.org.uk/cookie-policy/

1.3 If you are a Programme Participant or Applicant

If you are completing a referral form for someone else (e.g. if you are a parent, carer or referrer), you should tell the participant (or applicant) that we will have their data and that they have certain rights relating to it. Show them this section of the Privacy Statement and help them to understand it.

If you are a programme participant (or applicant), we may use your personal data for the purposes of:

• Processing your journey onto, through and exiting our programmes
• Managing your health, safety and wellbeing and that of people around you
• Statistical analysis to aid evaluation, improvement and reporting

Referral Form

We may be given some of your personal data by you or your referrer. This information helps us to plan and prepare your programme, and usually includes your:

• full name plus preferred name
• date of birth
• pronouns
• contact details (email, phone number, post code)
• Not in employment, education or training (NEET) info
• reasons for wanting to participate in our programmes
• and other contextual information about you.

Intro/Handover Form

This form is filled out in the handover meeting when you have decided to start our programme  and includes details about your:

• email address
• Lived experiences and current circumstances
• Information of other agencies you received help and support from (name of organisation and address, your support worker’s name, your support worker’s contact information, what they provide support with.
• Scottish Candidate Number

ACEs and Diversity Monitoring Info

This form is optional and is filled out in the Journey meeting and includes the following details about you:

• email address
• gender and if you consider yourself to be transgender
• sexual orientation
• ethnic origin
• religion
• disabilities
• any Adverse Childhood Experiences

Medical Form

Before you can take part in a Venture Scotland programme, we require you to complete a medical form. On this form we ask for some sensitive personal information, including:

• full legal name
• date of birth
• mobile number
• detailed medical information, including medical conditions, allergies and regular or recently medication taken
• information on your dietary needs
• your doctor’s contact info
• emergency name, relationship to you and contact details
• any other information you may decide to tell us that helps us look after you.

This sensitive data is strictly confidential, and we take extra care with it. We mainly use it to manage the health, safety and wellbeing of you and those around you, including to provide appropriate support and medical care if required.

After your time with us, we need to keep this data along with other records about your time with us. This helps us to meet our legal responsibilities. We won’t get rid of this information for at least three years after your programme ends if you are over 18. If you are under 18, we need to keep it until you are at least 21 years old.

The lawful condition for processing the sensitive data for health, safety and wellbeing purposes is substantial public interest – safeguarding of children and individuals at risk.

We also ask for some sensitive data about your background and characteristics. This is used for statistical analysis. Usually this is information you’ve chosen to tell us in the referral and medical forms. For certain funded courses we might also ask you for extra information. We anonymise and aggregate sensitive data as soon as possible in the analysis process. This anonymised data is then used to help us understand and improve how we include as many people as possible, and to help us report to donors and to partner organisations (see 1.4 and 1.6 below).

The statistical analysis of sensitive data is carried out in accordance with UK GDPR Article 89 and is done in our legitimate interest, using the information to manage the health, safety and wellbeing of you and those around you, including to provide appropriate support and medical care if required.

During or after your course we may also collect:

• your responses to any evaluation questions

This information is used to evaluate and report on the impact of our work and to help us improve our programmes. It is anonymised whenever possible. We will never identify you in a report or case study without your express permission in advance.

• any feedback you give us

We use this information to keep improving our centres and courses. Feedback and evaluation information is used in line with our legitimate interests.

• photos or film of your group participating in the programme

Photos or films of your group participating in the programme are used to evaluate and report on the impact of our work. This information is anonymised whenever possible. We will never identify you in a report or case study without your express permission in advance.

We also collect:

• your contact details

We may need to send you important information about the programme. You can’t opt out of receiving this type of message.

You are in control of whether to receive marketing messages from us. Our marketing is done in line with the legitimate interests of the charity.

We may also hold records of any written communication with us.

Also, if you want to achieve an SQA qualification as part of the programme, we will tell them your name, SQA number and the award level you’ve achieved so that they have a record of your award.

Records of SQA candidate assessment will show:

• a list of candidates registered with SQA for each qualification offered in the centre
• details of candidate assessment, including the name of the assessor, location, date and outcome
• internal verification activity
• assessment results
• certificates claimed

From time to time, we might offer third-party awards as part of our programme. We will let you know the arrangements for these if you decide to be presented for the award.

Other courses are funded in whole or part by donor organisations or individuals. Our agreements with these partners sometimes require us to share anonymised demographic data with them, or to report on the results of our statistical analyses of participant data

1.4 If you are a Partner or an Organisation receiving our services

We deliver some projects that involve working with partner organisations and in order to keep you safe we ask you to complete a medical form. On this form, we ask for some sensitive personal information, including:

• full legal name
• date of birth
• mobile number
• detailed medical information, including medical conditions, allergies and regular or recently medication taken
• information on your dietary needs
• your doctor’s contact info
• emergency name, relationship to you and contact details
• any other information you may decide to tell us that helps us look after you.

1.5 If you came on a Venture Scotland course in the past

We keep a historical archive of participants for three years. If you came on a programme with us in the past, we may have records of:

• your name, age and other basic information about you at the time
• photographs or film of you during your course
• your Journey Programme notes and other evaluation paperwork from the course.

1.6 If you are a Donor, or a Prospective Donor

If you have donated to us, or if we consider you to be a prospective donor, the personal data we hold on you may include:

• your name and contact details
• your preferences on how to contact you
• your history of donations to us
• your job title and other information about the company you work for
• general information about your interests and business activities
• records of events you have attended with us
• your history of support for us
• records of your written communications with us.

We usually gather or generate this information in the course of setting up or fulfilling your donation agreement with us. If you are not yet one of our donors, we might have obtained some information from publicly available sources through our prospect research. This information is used in line with our legitimate interest as a charity reliant on fundraising. You always have the option to opt out of any messages we send you, and you can request at any time that we stop processing your data or delete it. See Section 4 of this Privacy Statement to find out how to do that.

We are registered with the Scottish Fundraising Adjudication Panel and comply with the Fundraising Code of Practice.

1.7 If you are a Staff Member

If you are a Venture Scotland staff member, we will usually hold the following information about you in order to manage your relationship with us:

• your name and contact details
• your CV and cover letter on application
• details of your qualifications, specific to your role
• medical health information
• emergency contact information
• financial payment information
• your preferences on how to contact you.

In order to keep you safe we ask you to complete a medical form. On this form, we ask for some sensitive personal information, including:

• full legal name
• date of birth
• mobile number
• detailed medical information, including medical conditions, allergies and regular or recently medication taken
• information on your dietary needs
• your doctor’s contact info
• emergency name, relationship to you and contact details
• any other information you may decide to tell us that helps us look after you.

1.8 If you are an Ambassador, Volunteer or Trustee

If you are a Venture Scotland ambassador, volunteer or trustee, we will usually hold the following information about you in order to manage your relationship with us:

• your name and contact details
• your job title and other information about your place of work
• your preferences on how to contact you
• medical health information
• emergency contact information
• financial payment information

In order to keep you safe we ask you to complete a medical form. On this form, we ask for some sensitive personal information, including:

• full legal name
• date of birth
• mobile number
• detailed medical information, including medical conditions, allergies and regular or recently medication taken
• information on your dietary needs
• your doctor’s contact info
• emergency name, relationship to you and contact details
• any other information you may decide to tell us that helps us look after you.

1.9 If you are a Job Applicant or Applying to be a Board Member

If you have applied for a job at Venture Scotland, we will usually hold the following information about you in order to fulfil the recruitment process and manage your relationship with us:

• your name and contact details
• your CV and cover letter
• your preferences on how to contact you
• if successful in gaining employment, the contact information of your references.

1.10 Marketing and Fundraising Communications

If you have opted in, or if you have previously participated in our programme, donated to us, or attended an event with us, then from time to time, we may tell you about news, events, activities or offers which we think may be of interest to you. You can opt out of receiving these messages whenever you like.

We limit the number of marketing and fundraising messages that we send, and we use profiling and segmentation to make sure that you only get messages that we think are likely to be relevant to you.

If you do not wish to receive marketing or fundraising messages by post, phone, text or email, you can notify us to change any of your preferences at any time using the contact details in section 5 of this policy. Emails of this type that we send have unsubscribe links at the bottom to make it easy for you to opt out of receiving them.