Privacy Notice
At Personal Assistant Network Scotland (“PANS”), we are committed to protecting and respecting your privacy.
This policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others and how we will keep it secure. Our policy applies to all service users and website browsers.
By giving the PANS your information or by using our website you are confirming that you are agreeing to be bound by this policy.
Who are we?
PANS is a project dedicated to bringing high-quality, professional information and support to the heart of personal assistant community in Scotland. We are a part of the Workers Education Association who are registered under company number 02806910 at the registered office at 4 Luke Street, London, EC2A 4XW.
The WEA is registered with the Information Commissioners Office (ICO) as a Data Controller under reference Z4686639. We have appointed a Data Protection Officer (DPO) to oversee our processing or personal information.
Why do we collect, process and store personal information?
We collect, process and store personal information about you to fulfil our obligations as a community provider and to deliver efficient and effective services.
PANS will process your data to:
- Communicate information that may be of interest to you.
- Respond to your enquiries and register you for any events hosted by PANS.
- Personalise our support to meet your individual needs.
- Fulfil statutory reporting and statistical research purposes.
- Follow up post support and membership for feedback and destination tracking.
- Issue you with a PANS badge.
How do we collect information about you?
The methods by which we collect information are:
- Website
- Call Centre (Support Centre)
- Email (when you email us)
How do we manage your personal information?
Processing of your personal information will be undertaken in accordance with the principles of the Data Protection Act 2018 and UK General Data Protection Regulation.
Access to information is restricted to authorised individuals on a strictly need to know basis. We will treat your personal information fairly and lawfully. We will ensure that information is:
- Processed for a specific purpose.
- Kept up to date, relevant and not excessive.
- Not kept any longer than necessary.
- Kept secure.
What information do we hold about you?
The information we hold on our records concerns our relationship with you. For example:
- Identifiers – including name, gender, ID number and your photograph.
- Contact details – including address and e-mail address.
- Employer details
- Learning support requirements.
- Records of your correspondence with PANS
- Records of your attendance at any event hosted by PANS.
This list is not exhaustive, as we hold records of most contacts we have with you, or about you, and we process this information so we can deliver services to you.
We will only ask for personal information that is appropriate to enable us to deliver our services. In some cases, you can refuse to provide your details if you deem the request to be inappropriate. However, you should note that this may impact on our ability to provide some services too you if you refuse to provide information that stops us from doing so.
The types of information collected from you can be categorised as:
– Personal Information
This information can be used to identify you as an individual.
- Name (Including previous names)
- Gender
- Employment status details
- Employer Name
- Employer contact email
- Scottish PVG Scheme registration
- Photograph
– Personal Contact Information
This is the personal information you have given us in order that we are able to contact you, this includes:
- Email address
- Postal address
– Customer Feedback
This is the information you voluntarily share with us about your experiences of PANS and includes unsolicited comments, suggestions and feedback which is typically collected in surveys or contact forms.
What are the lawful bases for processing information?
- Contract
When you become a member we enter into a contractual agreement (Membership). If you choose to use services such as learning support this is also covered under your contractual agreement. - Legal Obligation
PANS is governed by certain legislation, regulations and standards that may require us to retain your data as well as share it with a range of different organisations and public sector agencies or government bodies. - Public Task
PANS is project involvement in performing a public task, we are required to use your personal data for statistical analysis and research purposes as well as sharing aggregated reports with a range of different organisations and public sector agencies or government bodies. Some processing will involve sharing your contact details with organisations who will ask you to complete surveys. - Vital Interests
In an emergency we may be required to share your personal details with the Emergency Services. - Legitimate interest
We may process your personal data if it is necessary for our legitimate interests, and you would reasonably expect us to hold and process this data. - Consent
You have given clear consent for us to process your personal data for a specific purpose, like sending us a query or subscribing to receive marketing information.
Under what circumstances will personal data be shared?
Normally, only our employees and volunteers will be able to see and process your personal information. However, there may be times when we will share relevant information with third parties. When sharing personal information, this will be done on a strictly need to know basis and we will comply with all aspects of the Data Protection Act and UK General Data Protection.
When necessary or required we may share aggregated personal information as follows:
- With local authorities and government departments in Scotland as necessary for administering justice, or exercising statutory, governmental, or other public duties.
- With other statutory organisations, for example social services and health authorities as necessary for exercising statutory duties.
This is not an exhaustive list as there are other circumstances where we may also be required to share personal information, for example:
- To meet our legal obligations
- In connection with legal proceedings (or where we are instructed to do so by Court Order)
- To protect the vital interests of an individual (in life-or-death circumstances)
How will personal data be protected?
We are committed to ensuring your information is secure. WEA are Cyber Essentials + accredited and take technical measures to protect the confidentiality and integrity of personal information irrespective of the method of collection.
What rights do I have about my personal data and how it is used?
You have rights under Data Protection legislation regarding the information WEA process about you:
- The right to be informed – to be informed why, where, and how we use your information.
- The right of access – to access personal information we hold about you.
- The right to rectification – to ask for your information to corrected if inaccurate or incomplete.
- The right to erasure – to ask for your information to be deleted or removed if there is no need for us to continue processing it.
- The right to restrict processing – to ask us to restrict the use of your personal information.
- The right to portability – to ask us to copy information from one system to another.
- The right to object – to object to how your information is used.
- Rights in relation to automated decision making – to challenge any decisions made without human intervention.
- The right to lodge complaint to the Information Commissioners Office, contact details are below.
- If our processing based upon your consent – to withdraw your consent.
How long is personal data kept?
We will only hold your data for as long as reasonably necessary and in line with our Data Retention Schedule. This does mean that your data may be retained for a period after you have stopped using PANS services.
Further information
If you would like to exercise any of your rights above, have any questions that you feel have not been covered by this privacy notice, or if you have concerns or a complaint in relation to PANS processing your personal data, please don’t hesitate to contact us on:
Tel: 0300 303 3464
Email: dataprotection@wea.ac.uk
Address: 4 Luke Street, London, EC2A 4XW
You have the right to complain to the Information Commissioners Office if you are unhappy with the way we process your data. Details can be found on the ICO Website, or you may write to the ICO at the following address:
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
Email: casework@ico.org.uk
Address: Information Commissioners Officer, Wycliffe House, Water Lane, Cheshire, SK9 5AF