Please read the following carefully to understand our practices regarding your personal data and how we will treat it. If you have any concerns or questions about your data or our practices please email email@example.com.
The rules on the processing of personal data are set out in the EU’s General Data Protection Regulation (the “GDPR”) which replaces the Data Protection Act 1988 on 25 May 2018.
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
The AITC is the data controller. This means we collect and manage your personal data in accordance with this policy. If you have any questions about your data or wish to have your data revised or removed please contact firstname.lastname@example.org.
3. The categories of personal data concerned
AITC holds and maintains the following personal data as provided by you (which may be your home or business contact details as determined by you):
• address and/or postcode
• email addresses
• phone numbers
We have obtained your personal data from detail that you have provided from opting in to receiving communications from us either as a member, a local business contact or as a subscriber or by entering a competition or prize draw. Due to the nature of our funding and for market research and other purposes we may on occasion provide anonomised data to partners. This data will never include the personal data set out here.
4. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
• To keep our Members, Business Contacts and Visitors informed
• To provide our Members with notification of events, meetings and offers
• To provide our Members with links to information, surveys and industry updates for onward distribution to their own contacts
• To provide up to date information on Industry business and legislation
• To provide a destination based marketing service on behalf of our Members for Visitors and Travel Trade
• To provide information regarding our destination and visits to Argyll & The Isles
• To provide information and news including competitions and special offers to our subscribers
You may give us information about yourself by filling in forms on our www.wildaboutargyllco.uk websites (our site) or by corresponding with us by phone, e-mail, social media or otherwise. This includes information you provide when you register to use features on our site, subscribe to our service, participate in social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. You must expressly opt in to receiving information from us.
5. What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR) Our lawful basis for processing your general personal data is based on your opt in consent for your data to be used to receive communications on industry news and updates from AITC and newsletter and promotional offers from AITC relating to the Argyll & The Isles destination. More information on lawful processing can be found on the ICO website.
6. Storing and sharing your personal data
Your personal data will be treated as strictly confidential. Subscriptions to newsletters and updates will be stored on Mailchimp and will be regularly checked for duplications and requests to unsubscribe. Member data will be held in spreadsheet format on private AITC Dropbox files which are only accessible by directors, the company secretary, AITC agents and our appointed data controller.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary. We only retain your data for the following purposes and use the following criteria to determine how long to retain your personal data: Term of Membership, Term of Subscription. When a membership is terminated we will delete all personal data associated with that membership. Visitor and Business subscribers will always have the option to unsubscribe at any point. Our subscription database will be reviewed annually to guage levels of interaction and overhauled at least every 2 years.
8. Providing us with your personal data
We require your personal data as it is a requirement of Membership or Subscription to allow us to contact you for the purposes of fulfilling the provision of member services as a member or information that you have subscribed to receive from us such as newsletters and updates. If you are a visitor and have elected to receive our updates we will offer you the option to continue to receive these newsletters at least every two years and provide you with the means to unsubscribe. We will not use your data for any other purposes without seeking your prior approval.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was your lawful basis for processing the data. • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We do not transfer personal data outside the EEA.
11. Automated Decision Making
We do not use any form of automated decision making in our business.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use for you to opt in prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact email@example.com. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.