Privacy & Cookies Policy

Revision 1 – issued 14^th May 2018

DRiNKLiNK is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your relationship with the charity, in accordance with the General Data Protection Regulation (GDPR). It applies to all individuals supporting the charity.

DRiNKLiNK is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees and volunteers. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely

The kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person’s health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

We will collect, store, and use the following categories of personal information about you:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
• Date of birth and gender
• Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
• Compensation history.
• Performance information.
• Disciplinary and grievance information.
• Photographs

We may also collect, store and use the following more sensitive types of personal information:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions.
• Information about your health, including any medical condition, health and sickness records
• Information about criminal convictions and offences.

How is your personal information collected?

We collect personal information about employees and volunteers through the application and recruitment process, directly from candidates.

How we will use information about you

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Where we need to comply with a legal obligation.
• Where it is necessary for a legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
• Where we need to protect your interests (or someone else’s interests).

Situations in which we will use your personal information

We need all the categories of information in the list above primarily to allow us to fulfil our relationship with you and to enable us to comply with legal obligations. The situations in which we will process your personal information are listed below.

• Making a decision about your recruitment or appointment.
• Determining the terms on which you support the Charity.
• Conducting performance reviews, managing performance and determining performance requirements.
• Assessing qualifications for a particular job or task
• Gathering evidence for possible grievance or disciplinary hearings.
• Making decisions about your continued engagement.
• Making arrangements for the termination of our working relationship.
• Education, training and development requirements.
• Complying with health and safety obligations.
• To prevent fraud.
• Equal opportunities monitoring.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How we use particularly sensitive personal information

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

• In limited circumstances, with your explicit written consent.
• Where it is needed in the public interest, such as for equal opportunities monitoring

Our obligations as a Charity

We will use your particularly sensitive personal information in the following ways:

• We will use information relating to leaves of absence, which may include sickness absence or family related leaves, to comply with legislation.
• We will use information about your physical or mental health, or disability status, to ensure your health and safety whilst on Charity business.
• We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.

Do we need your consent?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

Less commonly, we may use information relating to criminal convictions where it is necessary in relation to legal claims, where it is necessary to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so

Data sharing

We will not share your data with any other 3^rd party organisation, unless required by law.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no supporting the Charity we will retain and securely destroy your personal information in accordance with our data retention policy.

Rights of access, correction, erasure, and restriction

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Under certain circumstances, by law you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.

Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Secretary in writing.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Secretary. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you have any questions about this privacy notice or how we handle your personal information, please contact the Secretary. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.]

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please contact info@drinklink.org.

Confidentiality Policy

Revision 1 – issued 14th May 2018

The DRiNKLiNK charity is responsible for ensuring that legal responsibilities are met regarding confidentiality in relation to Disclosure Scotland Checks, the Data Protection Act 1998, compliance with the General Data Protection Regulations (GDPR) and any current or subsequent human rights legislation which guarantees a right of privacy.

DRiNKLiNK has developed a Privacy Notice which describes how we collect and use personal information and which is available on request.

The Privacy Notice and this Confidentiality Policy is relevant to any person involved in furthering the aims of DRiNKLiNK.

The Board of Trustees will review the operation of this Confidentiality Policy regularly and will ensure that all relevant people are aware of their responsibilities under the policy.

The Privacy Notice explains data protection principles, the kind of personal information that we will hold, how the information is collected and how that information will be used. It gives details of the usage of particularly sensitive information and your rights of access, correction ,erasure and restriction.

Information is kept securely, with access strictly controlled and limited to those who are entitled to see it as part of their duties. Any details of a personal nature must only be disclosed with the consent of the person involved. You should not discuss personal information given to you by clients, volunteers, members or staff with anyone unless it is vital that the information is passed on for compliance with legal obligations.

The Board of Trustees ensures that only authorised individuals are allowed access to personal data and records.

Information is only used for the specific purpose for which it was requested and for which the applicant’s full consent has been given.

Information is not kept for any longer than is necessary and once the retention period has elapsed, the DRiNKLiNK Secretary will ensure that any information or personal data is immediately destroyed by secure means.

Cookies notice

You should be aware that when you use our websites, mobile sites, or mobile apps, we may collect information by using ‘cookies’.
If you’d like to learn how to manage these cookies and ‘opt in’ and ‘out’ of different types, please see our privacy policy and cookie FAQ.

What are cookies and how do they work?

Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.

What do you use cookies for?

Cookies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall into four main groups:

(i) Cookies that are needed to provide the service you have asked for

Some cookies are essential so you can move around the website and use its features. Without these cookies, services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.
Here are some examples of essential cookies:

• Keeping you logged in during your visit; without cookies you might have to log in on every page you go to.
• When you add something to the online shopping basket, cookies make sure it’s still there when you get to the checkout.
• Some are session cookies which make it possible to navigate through the website smoothly. However these are automatically deleted after you close your web browser.

(ii) Improving your browsing experience

These cookies allow the website to remember choices you make, such as your language or region and they provide improved features.
Here are a few examples of just some of the ways that cookies are used to improve your experience on our websites:

• Remembering your preferences and settings, including marketing preferences.
• Remembering if you’ve filled in a survey, so you’re not asked to do it again.
• Remembering if you’ve been to the site before. If you are a first-time user, you might see different content to a regular user.
• Restricting the number of times you’re shown a particular advertisment. This is sometimes called ‘frequency capping’.
• Showing you information that’s relevant to products of ours that you have.
• Enabling social media components, like Facebook or Twitter.
• Showing ‘related article’ links that are relevant to the page you’re looking at.
• Remembering a location you’ve entered such as weather forecasts.

(iii) Analytics

We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and if they get ‘error messages’ from web pages.

This group of cookies, often called ‘analytics cookies’ are used to gather this information. These cookies don’t collect information that identifies you. The information collected is anonymous and is grouped with the information from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity. Analytics cookies only record activity on the site you are on and they are only used to improve how a website works.

Some of our websites and some of the emails you might get from us also contain small invisible images known as ‘web beacons’ or ‘tracking pixels’. These are used to count the number of times the page or email has been viewed and allows us to measure the effectiveness of its marketing and emails. These web beacons are anonymous and don’t contain or collect any information that identifies you.

We also use ‘affiliate’ cookies. Some of our web pages will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is sometimes used to tell that other site that you came from one of our sites. That other site may then pay us a small amount for the successful referral. This works using a cookie. Learn how to manage your analytics cookies.

(iv) Showing advertising that is relevant to your interests

We sell space on some of our sites to advertisers. The resulting adverts often contain cookies. The advertiser uses the browsing information collected from these cookies to:

1. restrict the number of times you see the same ad (frequency capping);
2. and help show other ads that are relevant to you while you’re on our websites. This is often called online behavioural advertising (OBA). OBA is a way of using information about your web-browsing activity, collected by using cookies, to group you with other users into interest groups and show you advertisements based on those interests. The OBA data collected from cookies you get when you’re on our sites is only used to show relevant ads on our sites, not on other websites.

Sometimes our websites contain ads for our own services and products. These ads use cookies in the same way as described above.

So how does OBA work? Let’s look at an example. Imagine you visit a website about travel. That website shows an advert and with that advert you receive a cookie. Imagine you then visit one of our websites which has an advert from the same advertiser you saw on the travel site. The advertiser will give you a new version of the cookie you received on the travel site. The advertiser can then use that cookie to recognise that you’ve previously been to a travel site and show you a relevant ad.

Although the OBA data collected uses your browsing activity to understand your interests, the data is anonymous and isn’t linked to you as a person. Even if you log in to our websites, the OBA data is still not linked to you.

Neither we, nor the companies who show ads on our sites sell data collected from cookies to any other organisations.

Device Identifiers

A Device Identifier is a tool with an equivalent function to that of a cookie which is used to target and track the effectiveness of content and advertising delivered to users of our mobile applications.

You can reset your Device Identifier at any time through the Advertising settings on your iPhone, or opt out of sending this information by setting the ‘Limit Ad Tracking’ option located in the on your iPhone.