Data Protection Policy

Introduction

The Scottish Stockbrokers Benevolent Fund (“SSBF”, “we, “us”, “our”) gathers and processes your personal information in accordance with this privacy notice and in compliance with the relevant data protection laws and the General Data Protection Regulation(“GDPR”) which is applicable from 25 May 2018. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

SSBF is a small charity without an office, comprising five volunteer trustees and a part-time paid secretary, and utilises for its correspondence, the secretary’s personal address, 0/1, 23 Polwarth Street, Hyndland, Glasgow, G12 9UD. We are a registered charity in Scotland with the Charity number in the header. We are not registered with the Information Commissioner’s Office Register because we are so small, but we act as the data controller when processing your data. Again, we are too small to need a Data Protection Monitor, but one of the trustees specifically oversees this aspect of our work.

The Privacy Notice (and any amendments thereto) will be displayed on our website at www.ssbf.org.uk/privacy

Information that we collect

SSBF processes your personal information to meet our legal, statutory and charitable obligations and to provide our members and beneficiaries with our service. We will not collect unnecessary personal data from you, and will not process your information in any way, other than as specified in this notice. The personal data that we collect from potential beneficiaries includes, but is not limited to: names, contact details (address, email address and telephone number), date of birth, dependents, information such as your job, or former job, bank account details, passport number, family circumstances, next of kin, income, expenditure, long term medical conditions.

We may collect information from you in a number of ways, including:

·         When you contact us in respect of help we can provide, by letter, telephone or email

·         When you make an inquiry, or interact with our website

·         When we visit you – we like to visit our beneficiaries – and you provide personal data to us

·         When we call you, or you call us

How we use your personal data

SSBF takes you privacy very seriously and, save as set out below, will not disclose, share or sell you data without your consent, unless required to do so by law or regulation. We only retain your data for as long as necessary and for the purposes specified in this notice.

We may use your personal data for the following purposes (“the Permitted Purposes”)

·         Providing services to you

·         Administering these services

·         Managing our charitable relationship with you, including payment processing, accounting , independent examination, taxation if applicable, and other support services

·         Ensuring compliance with our legal and regulatory obligations (for example anti money laundering, financial and credit checks, financial crime prevention and detection)

·         Managing our premises, It and Communications systems, websites and other systems

·         Monitoring compliance with our policies

·         Providing you with information which we have assessed to be beneficial to you as a beneficiary, and in your interests. Such information will be non-intrusive and processed in accordance with our legitimate interests

·         To follow your specific instructions

We may share your personal data with all trustees and, potentially, with the Stock Exchange Benevolent Fund, a larger English based charity with similar objects, on a confidential basis where necessary, to provide mutual support and services to you.

Your Rights

You have the right to access any personal information that SSBF processes about you and to request information about:

·         What personal data we hold about you

·         The purpose of the processing

·         The categories of personal data concerned

·         The recipients to whom the personal data has or will be disclosed

·         How long we intend to store your personal data for

·         If we did not collect the data directly from you, information about the source

If you believe that we hold and incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information, and we will strive to do so as quickly as possible, unless there is a valid reason for not doing so, at which point you will be informed.

You also have the right to request erasure of your data or to restrict processing (where applicable) in accordance with the data protection laws. We do not use automated decision making.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

Please direct any requests of this nature to the Secretary.

Sharing and disclosing your information

We do not share or disclose any of your personal information other than for the Permitted Purposes or where there is a legal or regulatory requirement or with your consent.

Safeguarding Measures

SSBF takes your privacy seriously and takes every reasonable technical and organisational measure and precaution to keep your personal data confidential and secure. WE work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have layers of security measures in place.

International

All our data processing occurs entirely in the UK for the time being, and we are governed by Scottish Charity Legislation.

Consequences of not providing your data

You are not obliged to provide your personal information to the SSBF; however, as this information is required for us to provide you with our service, we may not be able to offer our benefits without it.

Legal basis for processing your data

Depending on the specific circumstances, we may process your personal data on one or more of the following legal grounds:

·         The processing is necessary for the evaluation of competing interests of different beneficiaries

·         To ensure compliance with our legal and regulatory obligations

·         The processing is necessary for the purposes of our legitimate interests, provided that such interests have been weighed against your interests, fundamental rights or freedoms. We shall ensure that any processing conducted in accordance with our legitimate interests is proportionate, appropriate and in accordance with our Permitted Purposes. We acknowledge your right to object to such processing at any time.

·         With consent

How long we keep your data

SSBF retains personal information for as long as is necessary and we have a Retention and Erasure Policy in place to meet these obligations.

Special Category Data

Owing to the nature of the service we provide, SSBF sometimes needs to process sensitive personal information (known as “special category data”) about you, to ensure compliance with our regulatory and legal obligations (such as anti-money laundering, and financial crime prevention and detection). Where we collect such information, we will only request and process the minimum necessary for the Permitted Purpose and identify a compliant legal basis for doing so (in accordance with Article 9(2) of GDPR).

Lodging a complaint

SSBF only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection regulations and laws. However, if you wish to raise a complaint regarding the processing of your personal information or are unsatisfied with how we have handled your information, you have the right to lodge a complaint with the supervisory authority. For further details please see the Information Commissioner’s Office website (www.ico.org.uk).

Policy updated 26 May 2018, DC/DB