Privacy Policy

Looking after your data securely is important to us

Aberlour looks after thousands of people’s information: children and families, donors and supporters, foster carers, employees and volunteers.

Aberlour takes its information management responsibilities very seriously and we safely and securely store all information. We will be open and transparent about the way we hold and use your information. All the data that we gather is managed in strict accordance with the General Data Protection Regulation (GDPR), The Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).

Sections in this policy

• Aberlour Child Care Trust
• Children and Families Information
• Donors and supporters information
• Foster carers information
• Employees’ and Job Applicants’ information
• Volunteers’ and Volunteer Applicants’ infomation

Aberlour Child Care Trust

This Website is owned and operated by Aberlour Child Care Trust.

Aberlour Child Care Trust are a registered Charity, (Scottish Charity no: SC007991), a company limited by guarantee (Guarantee Company no: SC312912) and you can contact us at;

Aberlour Child Care Trust,
Kintail House,
Forthside,
Stirling,
FK8 1QZ

Tel: 0800 085 6150

Aberlour’s Data Protection Officer is Claire Johnson, and she can be contacted if there are any questions about this policy or any specific questions about any individual’s information. If you wish to make a complaint please contact Quality and Safeguarding Manager, Helen Jones.  Please phone 0800 0856150 or email quality@aberlour.org.uk in either case and use the subject line to identify the nature of your message.

If you feel that your data has not been handled correctly, or you are unhappy with our response to your requests regarding the use of your personal data, you have the right to lodge a complaint with us in the first instance and we will review our response. The next stage is to contact the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113 or online.

Aberlour intends to collect the minimum amount of information we need to interact with you or to provide you with support.

Aberlour does not make any decisions based on automated decision making. This means that no decisions will be taken regarding people’s information without people being involved. We do not make decisions electronically.

We explain our privacy approach managing people’s personal information in the following sections.

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Children and Families Information

Aberlour provides a range of support to children and families through our services. All individuals who are receiving support through a service from Aberlour will have a Privacy Notice explained to them at the time they start to receive a service. This will cover the following information;

The information we hold about you

Aberlour holds basic personal information about you such as your name, address, date of birth, gender, ethnicity, sexual identity, whether you have a disability and the names and contact details of close relatives, so that we can make sure our support meets your needs. We may also hold plans and other information about your health, education, home situation and the support you need, including reports, plans and reviews, e-mails and information that other organisations may tell us about your situation that help us to understand your needs.

Your record may also contain photos and copies of work that you have done.

Why we keep and use information about you

We need to know about you to provide you with the support that can really help you. This is why we will collect and hold your information. Sometimes the law says we must keep records, for example if you are placed in residential care or are being looked after by a foster parent. We want our work to really help you.  Records help us make sure that our support for you gives you what you need. We will only use your information in a way the way that we have discussed with you.

Sharing Information

We usually need to share your information with other people to plan your care and support. This might include your doctor, teachers and social services. We will only share the information that is needed to provide you with support.

Storing your information safely and securely

Your information is private. We have a duty to keep it safe. We store your information on a secure computer system. We may also hold some information about you on paper. If you are “looked after” the law says we must keep your records for your lifetime or for up to 100 years. This means that you can ask to see them in the future. We keep most other records for 7 years. Your worker will be able to explain how long we keep your records for.

What the law says

The law says that we must

• Collect and use your personal information fairly and lawfully
• Keep your information secure
• Respect the rights given to you through information laws which include rights that allow you to question, complain, correct, remove and restrict the information held about you (please discuss with your worker if you have any questions about your rights)
• Make sure the information that we hold is adequate, relevant, accurate and up to date
• The data protection laws say we must have a valid lawful basis in order to process your personal information; Aberlour will process your information on the lawful base of legitimate interest. The legitimate interest is the support that we offer you and we would not be able to do this without processing your personal information. We plan to use your information only in ways that you would expect us to do this and we expect that our use of your information will have minimum impact on your privacy.

You can see your information if you want to

You have the right to see any information that we hold about you except;

• Information that could harm you or someone else
• Information about some legal matters such as if a serious crime has been committed
• Information that is private to someone else

If you want to see your records, you can speak to a member of staff you know, and they will help you to put your request in writing if needed.

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Donors and Supporters Information

The Information we hold about you

We collect personal information from you when you fill out an online form on the website. You may fill out a form for all sorts of reasons, including when you donate, sign up to an event or register to become a volunteer.

When you fill out an online form, we will store the details you share with us, such as your contact details, contact preferences and credit card or bank details. These are all held securely.

Why we keep and use information about you

We may use the personal information to:

• Keep a record of our relationship
• Ensure we are contacting you in line with your preferences
• Inform you of our work and the different ways in which you can help
• Ask you to support our work
• Inform you about Aberlour’s events or send you an invitation
• Telephone you to ask for your support (unless you have opted out of telephone contact)

Sharing Information

We will never share or sell your personal data with any third parties, apart from those authorised and contracted to act on our behalf – such as the company which processes direct debits donations. Whenever we authorise a third party to act on our behalf, that activity is bound by a contract which ensures your data is kept safe.

Cookies

Our website also uses ‘cookies’ to track visits on our site. These are small files which a website sends to your device, to make a website remember you when you visit. These are designed to improve your experience of using a website and help us to understand how many visitors we receive, and how they are using our site. We use this information to make our website as easy for you to use as possible. If you prefer not to allow this, you can adjust your browser settings.

We also use Hotjar to improve the performance of our website and better understand how users interact with it in order to make it easier to navigate. To see how Hotjar processes visitor data see the Hotjar Privacy Policy.

You can see your information if you want

You are also entitled to access a copy of the information we hold on you. You will be required to send proof of identification, before we can release this to you. We try our best to make sure that the data we are holding is always accurate. If you should change address or any other contact details, please do let us know so we can update our records accordingly.

Your communication preferences

Being able to communicate with you is important, as your support will help us care for and work with vulnerable children, young people and their families.

Aberlour will only contact you to keep you up to date on our work and how your support is making a difference, or let you know of ways in which you can support our work.

We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information (post, email, SMS and phone). We will not send you marketing material if you tell us that you do not wish to receive it.

You are in charge of how we contact you

You can change your communication preferences at any time or choose to stop hearing from us altogether.

We promise that we will only communicate with you in the way you wish us to and we will always respect your privacy. You can change your mind at any time and it’s quick and easy to let us know that you no longer want to hear from us by phoning 0800 0856 150; or emailing hello@aberlour.org.uk or by writing to us at the address below.

Aberlour
Kintail House
Forthside Way
Stirling, FK8 1QZ

We will always respond to your wishes in a sensitive, timely, courteous and professional way. Please be assured that we will take appropriate measures to keep your personal information safe and secure and we promise not to contact you more than necessary. We will never pass your personal information on to other organisations for them to use for their own marketing purposes.

What the Law Says

The data protection laws say we must have a valid lawful basis in order to process your personal information. Aberlour will process your information on the lawful base of legitimate interest. The legitimate interest is that we would not be able to facilitate your support for Aberlour without processing your personal information. We would rely on legitimate interest to contact you in ways that you have told us you prefer to be contacted.

We have carried out a Legitimate Interest Assessment (LIA) that shows that we use personal data proportionately, our use has minimal impact on privacy and supporters would not be surprised or likely to object to receiving marketing information from us.

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Foster Carers Information

Why we keep and use information about you

We collect and use your personal data in relation to your position as a foster carer, member of the fostering household, your role as a support member or a person applying to foster; we collect this data because the law requires us to do so.

Before we are allowed to approve you as a foster carer, we must assess you to consider whether you are suitable to look after children and young people. This involves us collecting and recording a lot of personal information about you, your family, and persons in your household. The law requires us to keep this information for a number of years, whether or not you end up being approved.

We will only use your information to fulfil legal obligations as a fostering service, for the following reasons:

• assessing your suitability to be a foster carer;
• matching you with children who need to be fostered;
• supporting and supervising your activity as a foster carer;
• reviewing at least annually your continued suitability to foster;
• maintaining your application if approved as a foster carer;
• meeting legal obligations and fostering regulations.

We need to process data to ensure that we are complying with our legal obligations such as to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.

The information we hold about you

We collect and process personal data relating to Foster Carers to support applicants to become a Foster Carer and to support foster carers and children once placements have been made.

In addition, we may ask for information to understand how we can provide better services to foster carers and children and families and to understand how we can encourage more people to become foster carers. We are committed to being transparent about how we collect and use that information and to meeting our data protection obligations.

Information collected as part of the fostering assessment:
If you continue to the assessment process, we collect information to assess your suitability to become a foster carer. This includes;

• Information about your identity such as your full name, title, ethnicity, sexuality, disability, marital status, date or birth, gender, languages spoken. We also verify your identity by requesting a copy of your passport, National Insurance Number, marriage certificate (if applicable), proof of address and Driving Licence;
• Data about your background such as childhood, personality family and other relationships including current and past marital status/relationships, qualifications, skills, education experience, employment/voluntary history, finances, address history and any previous fostering/adoption experiences;
• Details about your lifestyle such as your household accommodation, community, support network, your schedule (days of work and working hours);
• Information about medical or health conditions, including whether you have a disability for which we need to make reasonable adjustments;
• Details about your capacity/suitability to be a foster carer, i.e., caring for children, providing structure, resilience, working with others, diversity, and safer caring.
• Details of any complaints and concerns or investigations in which you have been involved, including any warnings issued to you and related correspondence;

Your social worker will explain the assessment process to you and show you the forms we use to record these details.

We also collect ‘Criminal Records Data’ including details of any spent convictions, cautions or warnings. You will be asked to give written consent to us taking up Disclosure and Barring checks, medical and other checks, and personal and other references. We are required to hold this information in your case record.

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Employees’ and Job Applicants’ Information

Aberlour collects and processes personal data relating to its employees to manage the employment relationship. Aberlour is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

The Information we hold about you

Aberlour collects and processes a range of information about you.

This includes:

• your name, address and contact details, including email address and telephone number, date of birth and gender;
• the terms and conditions of your employment;
• details of your qualifications, experience and employment history, including start and end dates, with previous employers and with Aberlour;
• information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
• details of your bank account and national insurance number;
• information about your marital status, emergency contacts;
• information about your nationality and entitlement to work in the UK;
• information about your criminal record;
• details of your schedule (days of work and working hours) and attendance at work;
• details of periods of leave taken by you, including holiday, sickness absence, family leave and career breaks, and the reasons for the leave;
• details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
• assessments of your performance, including supervision, performance reviews, training you have participated in, performance improvement plans and related correspondence;
• information about medical or health conditions, including whether or not you have a disability for which Aberlour needs to make reasonable adjustments; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

Aberlour collects this information in a variety of ways. For example, data is collected through application forms; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment; from correspondence with you; or through interviews, meetings or other assessments.

In some cases, Aberlour collects personal data about you from third parties, such as references supplied by former employers and information from criminal records checks permitted by law.

Data is stored in a range of different places, including in your electronic personnel file, in Aberlour’s HR & payroll system and in other IT systems (including Aberlour’s email system).

Why we keep and use information about you

Aberlour needs to collect and process your information to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer your pension entitlements.

In some cases, Aberlour needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee’s entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled. For Aberlour, it is also necessary to carry out criminal records checks to ensure that individuals are permitted to undertake the role in question.

Sharing Information

Your information will be shared internally, including with members of the HR team (including payroll), your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles.

Aberlour shares your data with third parties in order to obtain pre-employment references from other employers and obtain necessary criminal records checks from the Disclosure Scotland. Aberlour also shares your data with third parties that process data on its behalf, in connection with the provision of pension benefits and the provision of occupational health services. Aberlour will not transfer your data to countries outside the European Economic Area.

Storing your information safely and securely

Aberlour takes the security of your data seriously. Aberlour has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

Where Aberlour engages third parties to process personal data on its behalf, they do so based on written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

What the law says

As a data subject, you have a number of rights. You can:

• access and obtain a copy of your data on request;
• require Aberlour to change incorrect or incomplete data;
• require Aberlour to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• object to the processing of your data where Aberlour is relying on its legitimate interests as the legal ground for processing; and
• ask Aberlour to stop processing data for a period if data is inaccurate or there is a dispute about whether your interests override Aberlour’s legitimate grounds for processing data.

The data protection laws say we must have a valid lawful base in order to process your personal information; Aberlour will process your information on the lawful base of legitimate interest. The legitimate interest is that we are not able to support your application process or your employment without processing your personal information, during and after the end of the employment relationship.

Processing employee data allows Aberlour to:

• maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
• operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
• operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
• obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, and meet its obligations under health and safety law;
• operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that Aberlour complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
• ensure effective general HR and business administration;
• provide references on request for current or former employees;
• respond to and defend against legal claims;
• respond to requests from regulators such as the Scottish Social Services Council or Care Inspectorate; and
• maintain and promote equality in the workplace.

Where Aberlour relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

Where Aberlour processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that Aberlour uses for these purposes is anonymised or is collected with the express consent of employees, which can be withdrawn at any time. Employees are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Aberlour will hold your personal data for the duration of your employment. The periods for which your data is held after the end of employment are set out in the Data Protection Policy appendices.

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Volunteers’ and Volunteer Applicants’ Information

As part of any recruitment process and supporting Volunteers when they are active in Aberlour, we collect and processes personal data relating to volunteer applicants and volunteer activities once they commence. Aberlour is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

The information we hold about you

Aberlour collects a range of information about you. This includes:

This includes:

• Your name, address and contact details, including email address and telephone number, date of birth and gender;
• Details of your qualifications, skills, experience and work history;
• Information about your emergency contacts;
• Information about your nationality;
• Information about your criminal record;
• Details of your schedule (days of work and working hours);
• Details of any complaints and concerns or investigations in which you have been involved, including any warnings issued to you and related correspondence;
• Assessments of your performance, including supervision and training you have participated in;
• Information about medical or health conditions, including whether or not you have a disability for which Aberlour needs to make reasonable adjustments; and
• Equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

Aberlour collects this information in a variety of ways. For example, data might be contained in application forms, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online tests.

Aberlour will also collect personal data about you from third parties, such as references supplied by former employers and information from criminal records checks.

Data will be stored in a range of different places, including on your volunteer file, Raiser’s Edge and on other IT systems (including email).

Why we keep and use information about you

Aberlour needs to process data to take steps at your request prior to becoming a volunteer and to support your activities once you have become a volunteer.

Aberlour has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process.  Processing data from  volunteers and volunteer applicants allows Aberlour to manage the recruitment process, assess and confirm a volunteer’s suitability for the role and support volunteer activities once they have commenced. Aberlour may also need to process data from volunteers and volunteer applicants to respond to and defend against legal claims.

Aberlour processes health information if it needs to make reasonable adjustments to the recruitment process for volunteer applicants who have a disability or to a volunteering role once this has started.

Where Aberlour processes other special categories of data, such as information about ethnic origin, sexual orientation, health or date of birth, this is for equal opportunities monitoring purposes.

Aberlour is obliged to seek information about criminal convictions and offences. Where Aberlour seeks this information, it does so because it is necessary to carry out its obligations and exercise specific rights in relation to safeguarding.

Sharing Information

Your information will be shared internally, including with members of the volunteering and HR teams, your supervisor, managers in the service area in which you work and IT staff if access to the data is necessary for performance of their roles.

Aberlour shares your data with third parties in order to obtain references and obtain necessary criminal records checks from Disclosure Scotland.

Aberlour will not transfer your data to countries outside the European Economic Area.

Storing your information safely and securely

Aberlour takes the security of your data seriously. It has internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our staff in the proper performance of their duties.

What the Law says

As a data subject, you have a number of rights. You can:

• Access and obtain a copy of your data on request;
• Require Aberlour to change incorrect or incomplete data;
• Require Aberlour to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
• Object to the processing of your data where Aberlour is relying on its legitimate interests as the legal ground for processing; and
• Ask Aberlour to stop processing data for a period if data is inaccurate or there is a dispute about whether your interests override Aberlour’s legitimate grounds for processing data.

The data protection laws say we must have a valid lawful basis in order to process your personal information; Aberlour will process your information on the lawful base of legitimate interest.

Aberlour has a legitimate interest in processing personal data before, during and after the end of the volunteer relationship. Processing volunteer information allows Aberlour to:

• maintain accurate and up-to-date volunteer records and contact details (including details of who to contact in the event of an emergency);
• operate and keep a record of your supervision and support provided to you;
• obtain occupational health advice, to ensure that Aberlour complies with duties in relation to individuals with disabilities, and meet its obligations under health and safety law;
• provide references on request for current or former volunteers;
• respond to and defend against legal claims;
• respond to requests from regulators such as the Scottish Social Services Council or Care Inspectorate; and
• maintain and promote equality in Aberlour.

If your volunteer application is unsuccessful, Aberlour will hold your electronic application on file for 12 months after the end of the relevant recruitment process, other data and copies of personal information will be deleted 6 months after the end of the relevant recruitment process. At the end of these periods your data is deleted or destroyed.

If your volunteer application is successful, personal data gathered during the recruitment process will be transferred to your volunteer file and retained during your volunteering. The periods for which your data will be held will be provided to you in a new privacy notice.

Where Aberlour relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of volunteers and has concluded that they are not.

Where Aberlour processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring. Data that Aberlour uses for these purposes is anonymised or is collected with the express consent of volunteers, which can be withdrawn at any time. Volunteers and Volunteer Applicants are entirely free to decide whether or not to provide such data and there are no consequences of failing to do so.

Aberlour will hold your personal data for the duration of your volunteering. The periods for which your data is held after the end of your volunteering are set out in the Data Protection Policy appendices.

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