Your privacy is important to us. This privacy statement explains what personal data Sleep Scotland and Teens+ collects from you, through our interactions with you and how we use that data.
Who we are
Sleep Scotland and its subsidiaries, TEENS+ and the Befriending service (“we”, “our”, “us”) is the data controller when you provide information to/for any of our services.
Legal basis for using your information
All organisations need a legal reason to use your personal information; if they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. It’s quite complicated, but below are the most relevant grounds you should be aware of.
With your consent (C)
There are some activities where we process personal information with your consent, which you are able to withdraw at any time, although if you do, we may not be able to provide the product or service you have requested. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. We will indicate in the Policy where we rely on consent.
To fulfil a contract (A)
We also process your personal information in order to fulfil a contract we have with you. For example, when you book a course with us, we will process your information to administer that course.
For a legitimate interest (LI)
Sometimes we may use your information to help achieve our business objectives but only where that activity doesn’t negatively affect your rights. For example, we might use your information to analyse the training courses.
To comply with legal obligations (LO)
There may be situations where we need to use your information to comply with legal obligations. For example, we are required by law to keep records with various organisations such as Disclosure Scotland, the Care Inspectorate and the Scottish Social Services Council.
What information to we collect?
When you interact with our services we collect information about you and that particular interaction. Generally this may include
- your personal details;
- contact information, and preferences;
- more sensitive information, for example when you tell us about dietary requirements, disabilities, and religious beliefs;
- information about your use of our services;
- images of you at Ravenscroft which is covered by CCTV;
- conversations you have when you call our teams;
- information about anyone you’re travelling with or meeting to attend our services, if that information is provided to us; and
- information about the devices you use to interact with us.
Where you provide information to us about other people, you need to make sure you have their permission to do so.
When and how we collect your information
We collect information you provide to us directly and indirectly when interacting with our products and services, including when you stay with us. This may include when you
- book a place on a course or interact with staff online, over email or on the phone;
- visit our website;
- fill out our online forms; and
- interact with us, by email, text, or on social media.
There may be situations where we use data processors – companies who act on our behalf – to collect your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
We collect information about you when it is provided to us by third parties. This might include online airlines, hotels or conference centres etc. This could be when you make bookings, or where you interact with anyone who supports our organisation. You should always read the privacy policies of third parties you use, as they will use your information in accordance with their own privacy policies.
When you, or someone on your behalf to make enquiries about our services, they may pass us information about your booking, including information about anyone else on that booking. Where you interact with third parties who promote our services for us, these third parties may pass us your information.
When you post comments, reviews, or engage in discussions about our services, we may receive this information from the platform you interacted with or from our partners who support us.
We may also obtain information about you from our partners and other companies that have your permission to share your information both online and offline.
Sometimes we may want to improve our services by getting a better understanding about our customers and their preferences. Where we do receive information about you from other sources, we may combine it with information we already hold about you and use it in accordance with this Policy. We may receive updated information about you from organisations that provide services to you. For example, we might be updated if you move home so that we can keep our records up to date or receive updated bank details to ensure that you can continue to use our services.
How we use your personal information
The reason we use your information will often be obvious from the way you interact with us. For example, if you book a place on one of our courses, we would use that information to administer your place on the course. However, our uses of your information may not always be so obvious. You can find out more below. When you provide your information to us, we may use it in the following ways.
|Use of personal information||Legal basis for processing
(where there is more than one, the exact grounds will depend on the activity; see above for an explanation of each)
|To provide you with services you have requested, including administering your booking, responding to any enquiries, complaints or requests you may have||C, LI, A|
|To manage our relationship with you||C, LI, A|
|To make decisions about what direct marketing to show you based on how you have interacted with us||LI|
|To improve our services online and offline, including our website||LI|
|To allow you to interact with us online and offline, on social media and elsewhere||LI, C, A|
|To monitor the use of our services and content||LI, LO|
|To verify your identity||LI, A|
|To conduct analysis, system testing and statistical research||LI, LO|
|To comply with legal obligations on us||LO, LI|
|To send you service related communications||LO, LI, C, A|
|To send you direct marketing, where you have consented||C, LI|
|To allow social sharing functionality||C, LI, A|
|To ensure the acceptable use of our services||LI, LO|
|To facilitate payments and credit checks||LO, A, C, LI|
|Facilitate the restructuring or sale of all or part of our business||LO, LI, C, A|
|To investigate and respond to disputes||LI, LO, C|
|To provide you with help and support where it may be required||LI, A|
Further information on how we use your information
We sometimes use your information for reasons that we think you might want a bit more detail on, so to help we have added more information to these below.
In addition to sending you information about the services you use with us, where we have your permission we may send you direct marketing communications about our services and events.
Direct marketing communications may be sent by post, email, telephone, SMS and MMS messages, and via other electronic means such as when you visit our website. We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our services.
You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
Analysis and service development
We may use your information to improve the services we offer. For example, we may look at the preferences indicated by our customers to change the way or place of running courses.
Linked services, third-party sites and content
Our website may, from time to time, contain links to other websites which are outside of our control and are not covered by this Policy. We do not accept any responsibility or liability for other websites’ privacy policies. If you access other websites using the links provided, please check their policies before submitting any personal information.
If we provide a service that is dependent on age or residency we have an obligation to verify relevant information. Where relevant we may pass your information to a third party for this purpose.
Payments and credit checks
Your information may be used to take payment for products and services and may be used to verify credit details related to payments.
Disclosures required by law
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
If you post or send offensive or inappropriate content anywhere on or to any of our websites, or otherwise engage in disruptive behaviour on any of our websites, we may use the information that is available to us about you to stop such behaviour. This may involve responding to or informing relevant third parties and law enforcement agencies about the content and your behaviour.
We do not send data to any country outside of the United Kingdom or European Union.
Training and quality
If you contact us by phone or on live chat, the conversation may be recorded and listened to for training and quality purposes.
How we share your personal information
Where you provide your information to us we may share it within our organisation and sharing with our suppliers. What sharing takes place will depend on the activity that your information is being used for. Your information will only be shared and used in accordance with this Policy and where an agreement is in place to ensure that your information is protected. We do not sell your information.
Sharing with our processors
There may be situations where we use data processors — companies who act on our behalf — to process your information for us. These processors can only use your information in accordance with our instructions and for the purposes in this Policy.
Sharing with commercial partners
We may share your information with third parties for their own purposes, including direct marketing, where we have told you about this and you have given permission.
Sale of our business
If we restructure or sell all or part of our organisational operations, we may transfer your information as part of that activity. Where this is the case your information will be used in accordance with this Policy unless you are notified otherwise.
Access and control
Updating your information
Please ensure you keep your information up to date by contacting us at Sleep Scotland.
Controlling direct marketing
You can change your mind about receiving direct marketing from us. Opt-out from any marketing or product communication you have received from us by emailing using the contact details below.
Requesting copies of your information
You may request a copy of your personal information which we may hold about you. You may also ask us to correct any inaccuracies in your personal information. This right may be restricted by law where disclosing information may result in the personal information of other individuals being disclosed and it would be unreasonable to do so.
Where we may rely on consent to use your information, you have the right to withdraw that consent for that processing activity at any time. However, we may have the right to rely on an alternative legal basis for the processing activity and will inform you of that.
If you do withdraw consent we may not be able to provide you with the product or service you have requested.
You may have the right to object, erase, or restrict our processing of your information – for example, where we process your personal information because this is in our legitimate interests, you may object to this. We will carefully consider your request as there may be circumstances which require us to, or allow us to, continue processing your data.
Complaining to the regulator
If you have any comments, concerns or complaints about our uses of your information we would ask that you contact us first, so that we can try and resolve any matter. However, where we are unable to help, you are able to complain to the Information Commissioner’s Office in the United Kingdom or the data protection regulator in your country of residence, who will be able to liaise with the UK Information Commissioner in the UK.
Retention of your information
We will retain your information for as long as necessary for the uses set out in this Policy or while there is a legitimate business reason for doing so. If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. For example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Cookies and similar technologies
Changes to our privacy and cookie policies
From time to time we may make changes to this Policy. This might be in relation to changes in the law, best practice, changes to the services we provide or collection and use of your personal information. We will always display clearly when the Policy was last updated and where appropriate, notify you of any relevant changes.
If you would like to get in touch, please contact us:
18G Liberton Brae