Privacy policy

 

Who we are

The Scottish Digital Academy (“the Academy”, “we”, “our”, or “us) is part of the Directorate for Digital at the Scottish Government.

Purpose

This notice explains our approach to the personal information we handle in carrying out our duties as a provider and facilitator of professional learning and coaching to the public and third sectors.

Our commitment

We are fully committed to handling personal information in accordance with data protection legislation and best data protection practices. This means that your personal information will be:

  1. Processed lawfully, fairly, and in a transparent manner.
  2. Collected for specified, explicit and legitimate purposes.
  3. Only collected so far as required for our lawful purposes.
  4. As accurate and up to date as possible.
  5. Retained for a reasonable period of time, in accordance with retention policies.
  6. Processed in a manner which ensures an appropriate level of security.

Whether through this notice or otherwise, we hope to ensure that everyone has a good understanding of why we processes personal information and, where we do, the rights they may have.

Why do we need to process Personal Information

We facilitate and provide services that can be accessed by people out with the Scottish Government. There may be instances were individuals sign up to our products and services and where we collect your personal information. We take the privacy of your information seriously. This notice applies to all data processing within the Academy as well as to the www.digitalacademy.gov.scot website and governs data collection, processing and usage in compliance with the Data Protection Act 2018. By using the Website, you consent to the data practices described in this statement.

How do we collect your personal information?

Like most organisations that handle personal information, there are various ways in which the Academy collects information from the people we deal with.

  • Email and written correspondence.
  • Telephone discussions.
  • Visitors to the Academy website.
  • Social media.
  • Application forms and other information requests.
  • Direct contact through meetings and events.

In nearly all instances, it should be obvious to you that we are collecting your personal data.

What data do we collect?

We collect the following data:

  • Personal identification information (Name, email address, telephone number, etc.).
  • Organisational information (Organisation name, organisation address, organisation finance contact name, organisation finance contact email address).

What is the lawful basis for processing your information?

The Academy will only process personal information where we believe we have a lawful basis to do so. The basis for processing will vary from activity to activity. In some instances, processing may have more than one lawful basis.

The following information below summarises the basis on which we process personal information.

Processing is necessary for the Academy to meet its legitimate interests as a facilitator and provider of professional learning and coaching, including: the maintenance of our course records and the promotion and monitoring of our professional learning offer, stakeholder engagement and portfolio as part of the Scottish Government.

General administration when booking onto an event.

  • Maintaining the details of learners registering / booking to attend a course.
  • Corresponding with learners in respect of their registration / booking.
  • Providing information about future courses, coaching activities and events.

Consent – using your image or feedback provided after course attendance or in promotional materials. This includes sharing attendance lists for our courses and events, with employers or organisations where they make a group booking for employees.

How will we use your data?

We will share personal identification information necessary for delivering all or part of our service with the people that deliver the services you have requested. Information is shared with course facilitators via the Arlo for Mobile app. Course facilitators are those who have been engaged by the Academy to deliver services on our behalf. These may be permanent employees or employees of contracted organisations. We will only provide access to the Arlo for Mobile app and/or any necessary personal identification information once we have completed relevant security clearance processes. Some of the processing activities set out above require us to share personal information with third parties. Whenever we share personal data, we take all reasonable steps to ensure it will be handled appropriately and securely by the third party.

Using your image

The Academy, as part of Scottish Government, uses video and photography of participants as part of promoting the Scottish Digital Academy courses. These videos and images will be published online, promoted through our social media channels and shown at events. We ask your permission to use your data in this way when you book with us. By agreeing you are confirming your permission to allow the Scottish Digital Academy, as part of the Scottish Government, without expectation of compensation or other remuneration, now or in the future, to use your image and likeness and/or any interview statements in connection to the Scottish Digital Academy courses. This includes:

  • Permission to interview, film, photograph, or otherwise make a video reproduction of you and/or record your voice;
  • Permission to use your name; and,
  • Permission to use quotes from interview(s) (or excerpts of such quotes), film, photograph(s), or reproduction(s) of you, and/or recording of your voice, in part or in whole, in print and/ or electronic media.

How do we store your data?

The Scottish Digital Academy booking platform is provided by Arlo. All data in Arlo is encrypted at rest and stored in AWS, a provider that is fully compliant with GDPR. Please see AWS GDPR Center for more information.

Regular data extraction from the Arlo platform will occur for backup and reporting purposes. This data will be stored on the SCOTS network. The SCOTS network is connected to the Public Services Network and as such follows the requirements of its code of connection. In addition to this, Scottish Government aligns to the HMG Baseline Control Set. This control set aligns with ISO27001.

How long will we store your data?

Data will be kept only for the duration it is required. Personal data will be deleted after a minimum of 7 years. Once this time period has expired, we will delete your data in accordance with Arlo’s deletion policies and procedures, save to the extent that Arlo is required by any Applicable Law to retain some or all of the Customer Personal Data.

Transfer of your data outside of the EEA

Arlo shall not transfer Customer Personal Data outside of the EU Member States (or permit that to occur) unless: i) Arlo has first obtained the Academy’s prior written permission to do so; and ii) Arlo takes such measures as are necessary to ensure the transfer is in compliance with the Applicable Law. Such measures may include (without limitation) transferring the Customer Personal Data to a recipient in a Country which has been formally declared under the Applicable Law as having adequate protection measures in place for Personal Data, or to a recipient that has achieved binding corporate rules in compliance with the Applicable Law, or to a recipient in the United States that has certified its compliance with the EU-US Privacy Shield, or to a recipient that has executed standard contractual clauses adopted, approved or otherwise effective under the Applicable Law.

Where data is shared or stored out with the United Kingdom, we will take all reasonable steps to ensure that your personal information is properly protected.

Marketing

We would like to send you information about products and services of ours that we think you might like, as well as those of other public sector organisations.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop the Scottish Digital Academy from contacting you for marketing purposes or giving your data to other public sector service organisations.

What are your data protection rights?

The Scottish Digital Academy would like to make you fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request the Academy provide you with copies of your personal data.

The right to rectification – You have the right to request that the Academy correct any information you believe is inaccurate. You have the right to request the Academy to complete information you believe is incomplete.

The right to erasure – You have the right to request the Academy to erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that the Academy restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to request the Academy’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that the Academy transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Email us at: digitalacademy@gov.scot Call us: 0131 244 0029 Or write to us at: Scottish Digital Academy, 1G South, Victoria Quay, Edinburgh, EH6 6QQ

General

Privacy policies of other websites

The Academy website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

The Academy keeps its privacy policy under regular review and places any updates on this webpage. The privacy policy was last updated on 23 November 2021.

How to contact us

If you have any questions about our privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: digitalacademy@gov.scot Call us: 0131 244 0029 Or write to us at: Scottish Digital Academy, 1G South, Victoria Quay, Edinburgh, EH6 6QQ

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that the Academy has not addressed your concern in a satisfactory manner, you may contact the Information Commissioners Office.

Call: 0303 123 1113 Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Website: https://ico.org.uk/

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