AEC Privacy Notice

Scope

This Privacy Notice explains how AEC collects, uses, stores, shares and protects your personal information, and the rights you have in relation to that information. This Privacy Notice applies to individuals who interact with AEC, including members, trustees, volunteers, beneficiaries, participants, donors, supporters, applicants, website users and individuals who contact us.

Contact Details

Email: admin@afghan-edinburgh.or.uk
Address: 16/8 Blacket Avenue
Edinburgh, EH9 1RS

What information we collect, use, and why
  • We collect or use the following information to provide our charitable activities, programmes and support, including where individuals are referred to us by third parties:
  • Names and contact details
  • Sex
  • Addresses
  • Date of birth
  • Emergency contact details
  • Photographs or video recordings
  • Criminal offence data where required for safeguarding, PVG checks, recruitment or other lawful purposes
  • Records of meetings and decisions
  • Payment details (including card or bank information for transfers and direct debits)
  • Information relating to compliments or complaints
    We collect or use the following information to receive donations or funding and organise fundraising activities:
    Names and contact details
  • Addresses
  • Payment or banking details
  • Donation history
  • Tax payer information (for Gift Aid purposes).
    We collect or use the following personal information for service updates or marketing purposes:
    Names and contact details
  • Marketing preferences
  • Recorded images, such as photos or videos
  • Records of consent, where appropriate.
    We collect or use the following personal information to comply with legal requirements:
    Name
  • Contact information
  • Identification documents
  • Financial transaction information
  • Any other personal information required to comply with legal obligations
  • Health and safety information
  • Safeguarding information
  • Criminal offence data.
    We collect or use the following personal information for recruitment purposes:
  • Contact details (eg name, address, telephone number or personal email address)
  • Date of birth
  • Copies of passports or other photo ID
  • Employment history (eg job application, employment references or secondary employment)
  • Education history (eg qualifications)
  • Right to work information
  • Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks ).
    We collect or use the following personal information for dealing with queries, complaints or claims:
  • Names and contact details
  • Witness statements and contact details
  • Relevant information from previous investigations
  • Customer or client accounts and records
  • Financial transaction information
  • Information relating to health and safety (including incident investigation details and reports and accident book records)
  • Correspondence.
Lawful bases and data protection rights

Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website.

Your right of access – You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.

Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.

  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.

    If you make a request, we normally respond to you without undue delay and in any event within one month. In some circumstances permitted by law, for example, where a request is particularly complex or where we receive multiple requests from you, we may extend this period. If we do so, we will inform you within one month of receiving your request and explain the reasons for the extension.To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

 

Where we get personal information from
  • Directly from you
  • Regulatory authorities
  • Family members or carers
  • Charities or voluntary sector organisations
  • Schools, colleges, universities or other education organisations
  • Councils and other public sector organisations
  • Suppliers and service providers
Our lawful bases for the collection and use of your data
  • Our lawful bases for collecting or using personal information to provide our charitable activities, programmes and support, including third-party referrals, are:
  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
    Our legitimate interests include providing and managing our charitable activities, supporting beneficiaries, members and volunteers, organising activities safely, maintaining accurate records, communicating with participants, and ensuring effective governance of the SCIO. Collecting and using personal information is necessary so that we can deliver our charitable activities and support, manage participation, protect the wellbeing of children and other beneficiaries, support volunteers, and operate the organisation effectively. We only collect information that is relevant and necessary for these purposes.
    For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. Our lawful bases for collecting or using personal information to receive donations or funding and organise fundraising activities are:
  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Our legitimate interests are to manage and administer fundraising activities, maintain accurate donation records, communicate with supporters, acknowledge donations, and support the financial sustainability of the SCIO.
    For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
  • Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Our legitimate interests are to keep our members, beneficiaries, volunteers and supporters informed about relevant activities, services and organisational updates, where appropriate.
    For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. Our lawful bases for collecting or using personal information to comply with legal requirements are:
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
    Our lawful bases for collecting or using personal information for recruitment purposes are:
  • Legal obligation – we may collect or use your information where required to comply with legal requirements, including safeguarding and safer recruitment requirements. This may include processing information relating to PVG scheme membership or other disclosure checks where required for a particular role. Where we process criminal offence data as part of PVG or disclosure checks, we do so in accordance with Article 10 UK GDPR and the relevant condition(s) in Schedule 1 of the Data Protection Act 2018. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Our legitimate interests are to recruit suitable people to support the work of the SCIO, assess applicants fairly, manage recruitment processes, and ensure that we select appropriate trustees, staff and volunteers. Processing personal information is necessary to administer recruitment, communicate with applicants, verify suitability where required, and support the effective operation of the organisation. We only collect information that is relevant and necessary for recruitment purposes and we protect applicants’ personal information.
    For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above. Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
  • Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
  • Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
  • Our legitimate interests are to respond to enquiries, manage complaints, investigate concerns, resolve issues, and maintain effective communication with beneficiaries, volunteers, members, supporters and other stakeholders. Processing personal information is necessary to allow us to address concerns, improve our services, maintain accurate records, and operate the SCIO effectively. We only use information that is relevant and necessary for handling queries, complaints or claims, and we take steps to protect individuals’ privacy.
    For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
How long we keep information

We keep personal information only for as long as it is needed for the purpose it was collected, to meet our legal and regulatory obligations, and to protect our legitimate interests. Different types of information are kept for different periods depending on the nature of the information, the purpose for which it was collected, and any legal, regulatory or safeguarding requirements. Our Record Retention Policy sets out the retention periods and criteria we use to determine how long different types of information are kept. For more information on how long we store your personal information or the criteria we use to determine this, please refer to our Record Retention Policy or contact us using the details provided above. 

Who we share information with
  • Data processors/service providers IT, website hosting, cloud storage, online forms, database, email and communication service providers. Our data processors may provide services on our behalf, including IT support, website hosting, cloud storage, online services, security and storage of organisational information. Online forms, database and administration system providers provide tools that allow us to collect, store and manage information relating to members, trustees, volunteers, beneficiaries, participants, supporters and activities. Email and communication service providers help us send organisational communications, service updates and newsletters where appropriate. Payment and donation processing providers process donations and payments securely on our behalf where applicable. Professional service providers, such as accounting, legal or IT support providers, may process information where required to provide specialist services.Our data processors may provide services on our behalf, including IT support, website hosting, cloud storage, online services, security and storage of organisational information. Online forms, database and administration system providers provide tools that allow us to collect, store and manage information relating to members, trustees, volunteers, beneficiaries, participants, supporters and activities. Email and communication service providers help us send organisational communications, service updates and newsletters where appropriate. Payment and donation processing providers process donations and payments securely on our behalf where applicable. Professional service providers, such as accounting, legal or IT support providers, may process information where required to provide specialist services.
    Others we share personal information with
  • Charities, voluntary organisations or partner organisations where necessary to deliver services, make referrals, coordinate support, or protect the wellbeing of participants.
  • Organisations we need to share information with for safeguarding reasons
  • Legal bodies or authorities
  • Local authorities or councils
  • Relevant regulatory authorities
  • External auditors or inspectors where required for regulatory, funding or assurance purposes
  • Organisations we’re legally obliged to share personal information with
  • Published on our website, social media or other communication channels where we have appropriate consent or another lawful basis.
Sharing information outside the UK

Where personal information is transferred outside the UK through our service providers, such as Google services or for the purposes of web hosting, we will ensure that the transfer complies with Chapter V of the UK GDPR and that an appropriate transfer mechanism is in place.
Google publicly confirms its commitment to adhering to privacy legislation across the world and is an active participant in the data privacy framework program. Please contact us if you require further information, using the contact details provided above.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:           
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint