Privacy Policy

Who We Are

Scotland’s Towns Partnership 

Scotland’s Towns Partnership is Scotland’s largest towns’ collective; representing and promoting the diversity of our towns and places, and supporting those organisations and groups that have an interest in or ownership of them. 

In order to be able to undertake our work and inform our network about the activities and resources available to support towns, we make use of personal information – almost wholly basic contact details – which users provide us with. In this notice you can read how we collect and use personal information, as well as your rights in relation to this. If you have any questions, please don’t hesitate to contact us. 

Importantly, any personal data collected through this website and held by STP, Brightstar Scotland or its associates is treated in line with the principles of the General Data Protection Regulation 2016. 

Scotland’s Towns Partnership also manage the following websites and campaigns: Scotland Loves Local, Town’s Toolkit and Understanding Scotland’s Places. The data processed by Scotland’s Improvement Districts under the responsibility of Scotland’s Towns Partnership is held in separate files and folders in the details mentioned below. Personal Information data associated with these sites are managed by Scotland’s Towns Partnership. 

Processing and Use of Personal Information

Lawful Basis for Processing Personal Data

GDPR Art 6 (1) (a) Consent: the individual has given consent to the processing of his or her personal data for one or more specific purposes.

Where users have previously bought or solicited products or services from STP, ‘legitimate interests’ (GDPR Art 6 (1) (f) may also act as a basis for legal processing and communication. 

Data will be held in compliance with the GDPR as set out in our privacy policy, and used in accordance with the specified purposes as set out in this policy. 

Purposes of Data Processing and Storage

To inform about news, events, projects and other initiatives related to the work of Scotland’s Towns Partnership. 

To inform our members of information regarding membership benefits and the annual member renewal process. 

To hold and process invoices sent by users to Scotland’s Towns Partnership for partnership, membership or event booking payments.  

Communication from Scotland’s Towns Partnership may take the form of direct email correspondence, or bulletins sent via our Mailchimp account.  Notices may also include information about the activities of our member and partner organisations. 

Data Retention and Rights of the Data Subject

Scotland’s Towns Partnership will keep personal information as long as it is necessary for the purpose for which it was obtained, in compliance with existing regulations and unless asked to delete it at an earlier time. Data subjects have the following rights, including the right to erasure (the ‘right to be forgotten’) as set out in GDPR Articles 12-23.

It is the responsibility of the Joint Controllers to observe these rights and act upon requests in relation to these rights from individuals whose personal data is held by STP.

Data Controllers and Processors

The Joint Controllers and Processors of personal data on behalf of Scotland’s Towns Partnership are Brightstar Scotland and associates. The lead Joint Controller is Elaine Bone, contactable at: elaine@brightstarscotland.co.uk. 

Furthermore, Scotland’s Towns Partnership’s appointed accountants, Soroban, will have access to the necessary personal data, such as membership subscription or event signup status, name and email address, as required for the purposes of processing event and membership invoices. Your can read their privacy policy here. 

A complete list of data processers and Brightstar associates with access to personally identifiable data is listed in STP’s GDPR data audit, available upon request. 

Data Storage and Protection

Personal information may be stored in one of the following locations: WordPress, Mailchimp, Eventbrite, JotForm, STP Dropbox Folder; STP Gmail Accounts; STP Google Drive Shared Folder; Brightstar Scotland Amazon File Storage; Brightstar Associate hard-disk or connected OneDrive / Google Drive account, Stripe and Xero.

Users are encouraged to read the privacy and data protection policies of our data storage services, which can be found here: WordPress Privacy Policy, Mailchimp Privacy Policy, Eventbrite Privacy Policy, JotForm Privacy Policy, Dropbox Privacy Policy; Google Privacy Policy; Amazon Web Services Privacy Policy; Microsoft Privacy Statement, Stripe Privacy Policy, and Xero Privacy Policy.  

Under GDPR regulations, STP staff, Data Controllers and Data Processors have a duty to report any data breach to the UK Information Commissioner’s Office.

Data Audit

Scotland’s Towns Partnership retains an audit of the type of personal information held, where this data is held, and the purpose and legal basis for processing this data. This can be provided upon request. 

Information Sharing and Third Parties

Scotland’s Towns Partnership does not share personal information with third party organisations. Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our web site.

Information We Collect

Scotlande’s Towns uses the Mailchimp platform as our customer relationship management system (CRMS) to organise our community of contacts. Our service to send out email bulletins is also Mailchimp. You can read more about their features and policies at www.mailchimp.com. You can also access their Privacy Statements and Terms and Conditions here: Mailchimp Privacy and Terms and Conditions.   

User-Provided Information

You can provide us with information about yourself, such as your name and e-mail address, by registering via www.scotlandstowns.org. If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. We may also retain any messages you send through www.scotlandstowns.org. 

Newsletter and Website Registration

A user does not have to register to use Scotland’s Towns website, but a user must register if they wish to receive information and updates via email.

We use a third-party provider, Mailchimp to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s Privacy Policy.  

The registration information we require to allow a user to register is the full name, organisation and email address of the user if they wish to receive email updates. This information is stored securely on our database until such time as a user chooses to unsubscribe from receiving news stories. Users who no longer wish to receive our newsletters and other updates may opt-out of receiving these communications by clicking unsubscribe option on any email communication received or by contacting the Joint Controllers or STP via the ‘contact us’ form on our website.

Event Ticketing and Membership Subscriptions

Event bookings and event ticketing are routed through Scotland’s Town’s Eventbrite account. Those wishing to book for an event must complete the ticket order form detailing first name, last name and email address. Optional information may be provided by the user as displayed. To “pay by invoice”, users will also need to enter either an email address for an email invoice, or a postal address for a hard copy invoice. 

Website users have the option to purchase membership subscriptions via an invoice request through Stripe or via PayPal. Users submitting financial information are encouraged to read the Privacy Policy for Stripe and Privacy Policy for PayPal Services.

As stated above, STP’s appointed accountants, Soroban, will also have access to the necessary personal information for the processing of invoices, including name, email or postal address, and bank account and sort code if submitted by the user.  Financial information for invoice requests for events is held on Xero Accounting Software, and is accessed by the Data Controller and our appointed accountant. More information on Xero can be found in the Xero Privacy Policy.

Events

We typically provide an attendee list of names and organisational affiliation at our events to aid delegates with networking. Furthermore, we take photographs of proceedings in order to highlight or showcase Scotland’s Towns Partnerships activities. You will be asked to provide consent for this use of your data in this way when signing up for events, and are freely able to refuse to provide this. 

Online Meetings and Events (Zoom)

STP uses the Zoom video communications platform to hold online events and meetings. Personally-identifiable information from our online events may be shared publicly online (including recordings, screenshot images, names, and information left in chat comments) unless any identifiable person in the meeting (such as a panellist or other active participant) requests that they would prefer this material not to be made publicly available. 

Some events are recorded and uploaded to the Scotland’s Towns Youtube account. Only the host or co-hosts can enable a recording on their local computers. If the conference is recorded, a notice will show on the screen. Participants will enter the call muted and without video showing, unless they enable these features themselves.

For information about how your data is protected within a Zoom meeting, please consult Zoom’s privacy statement and GDPR compliance statement (click links to view).

Surveys

From time-to-time we may request information from users via surveys or Awards. Participation in these surveys or awards is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and geographic information (such as postal code). Contact information will not be shared with any third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users’ personally identifiable information for any secondary purposes.

Our surveys are conducted via Jotform, for more details on their Privacy Policy, please see here. 

Information Sharing – Legal Disclaimer

Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our web site.

Website and Third Parties

Disclaimer

Scotland’s Towns Ltd (hereafter, “Scotland’s Towns Partnership”, or “STP”) seeks to ensure that the information published on its website is up to date and accurate. However, the information on the website does not constitute legal or professional advice and STP cannot accept any liability for actions arising from its use. STP cannot be held responsible for the contents of any pages referenced by an external link.  

Any personal data collected through this website and held by STP, Brightstar Scotland or its associates will be treated in line with the principles of the General Data Protection Regulation 2016. The website for Scotland’s Towns Partnership is created with WordPress (WordPress Privacy Policy). 

Web Services

When you visit www.scotlandstowns.org, WordPress may send one or more cookies – a small text file containing a string of alphanumeric characters – to your computer that uniquely identifies your browser to help you log in faster and enhance your navigation through www.scotlandstowns.org. A cookie does not collect personal information about you. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of www.scotlandstowns.org may not function properly if the ability to accept cookies is disabled. 

Google Analytics

Scotland’s Towns Partnership uses Google Analytics to help understand use of www.scotlandstowns.org. This service collects the information sent by your browser as part of a web page request, including cookies and your IP address, and their use of it is governed by their Privacy Policy. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Google analytics will not track users until they click ‘accept’ on the cookie banner. 

Log files

Log files stored on the Scotland’s Towns Forum web server allow the recording and analysis of users’ use of the website. Log files do not contain any personal information.

Links

This Website contains links to other sites, including social media feeds and embedded content. Embedded content from other websites behaves in exactly the same way as if the visitor has visited the other website directly. Please be aware that Scotland’s Towns is not responsible for the privacy practices of such other sites via links, and additionally cannot verify the accuracy of the information contained on external sites – by linking to them, we are not endorsing them. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Website that collects personally identifiable information. This privacy statement does not apply to information collected by other websites.

Changes and Notifications

Access and Changes to Your Personal Information

You have the right to request, change, or delete personal information we hold about you (such as postal code, phone, email or postal address). This can be done by sending a request to alison@scotlandstowns.org or contacting Scotland’s Towns Partnership via its website. 

Under the General Data Protection Regulation, individuals whose personal data is held by Scotland’s Towns Partnership have the right make a subject access request for their personal data processed by Scotland’s Towns for stated purposes. As stated earlier in this notice, data subjects have the following rights, including the right to erasure (the ‘right to be forgotten’) as set out in GDPR Articles 12-23.

Notification of Changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, and other places we deem appropriate so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.  If, however, we are going to use users’ personally identifiable information in a manner different from that stated at the time of collection we will notify users via email or by posting a notice on our Web site for 30 days.

Contact Information

If users have any questions or suggestions regarding our privacy policy, please contact Ewan Robertson at alison@scotlandstowns.org

Policy last updated: June 2023