Privacy

Housing First Academy and/or Training Provision

This Privacy Notice tells you about Turning Point Scotland (“TPS”) a charity registered in Scotland, charity number SC028827, with our registered office at: 

7 West George Street, Glasgow G2 1BA  (This is not for DPO requests, please see further below for DPO contact details)

“we” or “us” or “our” means TPS;
“you” or “your” means a party that visits and/ or uses the Website.

“Website” means the whole or any part of the website controlled or operated by TPS and located at www.turningpointscotland.com or any other TPS controlled domain name (such as the website Rosie’s www.rosiesenterprises.com), or sites that we are contractually in partnership with to provide a service on our behalf. This website is operated by Turning Point Scotland (TPS).  

We take your privacy seriously and we ask that you read this privacy notice carefully, as it contains important information about:

• The personal information we collect about you
• What we do with your personal information
• Who your personal information might be shared with

Who we are

Turning Point Scotland (TPS) specialises in supporting people facing the most complex and challenging situations. Our ‘people centred’ ethos places the people we support first in our thinking and ensures that our staff convert their passion into great services. TPS delivers improvement in Scotland’s social care sector through high quality services, leadership and innovation.

TPS is registered as a data controller with the Information Commissioner’s Office (ICO) for the United Kingdom.
Our registration number is Z6723595

As the data controller of the personal information we collect from you, we are responsible for how we collect, store and use your personal information.  It means we have to comply with data protection laws, i.e. The Data Protection Act 2018 (DPA2018) and the General Data Protection Regulation (GDPR).

Personal information is anything which enables us to identify you in some way: 

• your name, your date of birth, your ‘phone number, your image etc.  

In addition to Personal Information, there is ‘Special Category’  (sensitive) personal information that concerns your:

• racial or ethnic origin, political opinions, religious beliefs, sexual life, physical or mental health, trade union activities or details of any criminal offences.

You may be asked to provide personal information through the Website. If you provide any personal information to us, we shall at all times comply with the DPA2018 and the GDPR.

When we collect information

When you visit our website, we collect personal information when you:

• Join our mailing list (Mail Chimp manage our mailing lists - mailchimp.com/legal/privacy);
• Complete an online enquiry form;
• Correspond with us by email;
• Sign up to our Blog;
• Enrol to participate in a Communities of Practice event;
• Make a complaint to us; 
• Take part in any of our training;
• Register for any of our events;
• Complete a survey;
• Sign up to receive our e-newsletter
• Submit an email to us using one of the email addresses featured on our websites

We don’t want there to be any surprises or worries for you and we will not use your personal data for any purpose that you wouldn’t reasonably expect under the circumstances.

COOKIES

We may also collect information about you via the use of Cookies.  

A cookie is a small text file that is placed on to your computer (or other access device) when you visit our website.  We use cookie files for analytics purposes to gather statistical information on your use of our website. The information we obtain from our use of cookies will not usually contain your personal information. Although we may obtain information about your computer or other access device, such as your IP address, your browser and / or other internet log information, this will not usually identify you personally.

The table below provides more information about the cookies we use and why:

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.

MARKETING

Turning Point Scotland is a registered charity. We will never use your personal details for any other reason other than the reasons stated. We won’t sell or pass them on to a third party for marketing or commercial reasons. We will only contact you to promote our work, our events or any other promotional activity if we have your consent to do so.

SURVEYS / CUSTOMER FEEDBACK

Turning Point Scotland may send surveys to ascertain training or course evaluations and/or obtain customer feedback regarding our service(s). Consent is not required to undertake this activity under data protection law. Completion of any survey is purely voluntary.

Any information provided can be anonymous, unless you choose to provide your name etc.

PHOTOGRAPHY / VIDEOS

We will only use your image/video on our website and social media if you have given us consent. If you no longer wish your image/video to be used*, please contact:

Communications Department
Turning Point Scotland
54 Govan Road
Glasgow
G51 1JL
0141 427 8200
communications@turningpointscotland.com

* Please be aware, that in the event you decide to withdraw or revoke consent, we will remove your image/video from our websites and/or our own online publications. We will NOT be able to remove your details from already printed and/or distributed materials. Equally, we will not be able to remove your details from other Social Media channels over which we have no control.

Why we use this information

We use such personal information to:

• Provide you with the services that you have requested from us;
• Communicate with you, including in response to any of your enquiries;
• Improve our services and respond to changing needs;
• Handle and resolve complaints made by / against you;
• Keep the personal information that we hold about you accurate and up-to-date (if you provide any new personal information to us via the website); and
• To support future training course development and/or content

We may not be able to provide the above services to you if you do not provide us with sufficient personal information to allow us to do so. If you make a request for further information, on or through the Website, the data submitted by you as part of such request will only be retained by us as long as necessary in order to respond to your query.

Our legal bases for processing your personal information

Data protection laws require us to have a legal reason for collecting, storing and using your personal information.

In some circumstances, we may rely on your consent as the legal basis.  

By providing us with your personal information and sensitive personal information (relating to your health, racial or ethnic origin, religious or other beliefs or sexual orientation) or the personal information and sensitive personal information of a family member or other person it relates to, via our website, you:

• Consent to it being used by us as described within the ‘when we collect information’ section above; and
• Confirm that you have informed the family member or other person it relates to, over the age of 12 years old of the content of this notice and they have provided their consent to their personal information and sensitive personal information being used by us as described above.

You and your family member or other person it relates to have the right to withdraw your consent to us storing and using your and/or their personal information and sensitive personal information by contacting us. Once you/they have withdrawn your/their consent, we will no longer use your/their personal information and sensitive personal information for the purpose(s) set out within the ‘when we collect information’ section of this notice, which you originally agreed to, unless we have another legal reason for doing so.

Our other legal reasons for holding and using your personal information are:

• (As a Data Processor and Controller) contractual obligations to local authorities and funders
• Legal and regulatory obligations which apply to us as a registered social charity and legal organisational entity;
• Protection of your vital interests; and
• Our legitimate interests –in handling and using your personal information, including sharing it with our service providers (‘who we share it with’), for the purposes described within the ‘when we collect information’ section of this notice. – unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Who we share it with

We may share your personal information with the following organisations for the purposes described within the ‘when we collect information’ section of this notice:

• Partner organisations we are authorised or required by our Data Controllers to share data with for analysis and/or auditing purposes;
• organisations providing benefits advice and support; and
• Police Scotland and the local authority anti-social behaviour department in relation to complaints involving anti-social or other criminal behaviour, and in the case of missing persons.
• Government(s) where required (Scottish and UK).
• Academics for the purpose of research.
• We sometimes receive external funding and/or grants to facilitate the services described above, expenditure has to be justified and some statistical reporting might also be required by our funders and/or local councils – this will usually be anonymised so you can’t be identified from it

How long do we keep it

We will only keep your personal information for as long as we need to for the purpose(s) described within the ‘when we collect information’ section of this notice, including meeting any legal, accounting, reporting or regulatory requirements.  

More information is contained in our data retention policy, which is available by contacting our Data Protection Officer (DPO). Details follow later within this privacy notice.

How we keep it secure

The security of your personal information is of paramount importance to us and we use technical and organisational measures to safeguard your personal information.

However, while we will use reasonable efforts to safeguard your personal information, the use of the Internet is not entirely secure and, for this reason, we cannot guarantee the security of any personal information that is transferred by or to you via the Internet.  

We also cannot guarantee the security of personal information shared with us via social media. We will NOT share personal information via social media. If you have any concerns about the security of your personal information, please contact our DPO for more information.

LINKS TO OTHER SITES

The Website may include links to other websites that are not owned or controlled by us.  This privacy notice does not cover the links to third party websites located on the Website or websites accessed through any such links and any use of such website by you is at your own risk.

Your rights

It is important that the personal information that we collect, store and use about you is accurate and current.  Please keep us informed of any changes by contacting our DPO.  In certain circumstances, the law gives you the right to request:

• A copy of your personal information and to check that we are holding and using it in accordance with legal requirements.
• Correction of any incomplete or inaccurate personal information that we hold and use about you.
• Deletion of your personal information where there is no good reason for us continuing to hold and use it. You also have the right to ask us to do this where you object to us holding and using your personal information (please see contact details provided).
• Temporarily suspend the use of your personal information, for example, if you want us to check that it is correct or the reason for processing it.
• The transfer of your personal information to another organisation.
• You can also object to us holding and using your personal information where our legal basis is legitimate interest (either our legitimate interests or those of a third party).

Please contact our DPO if you wish to make any of the above requests.  When you make a request, we may ask you for specific information to help us confirm your identity for security reasons.  You will normally not need to pay a fee when you make any of the above requests, but we may charge a reasonable fee or refuse to comply if your request for access is clearly unfounded or excessive.

Feedback and complaints

We welcome your feedback on how we hold and use your personal information, and this can be sent to our DPO, Annette Lowther:

DPO
Turning Point Scotland
54 Govan Road
Glasgow
G51 1JL
dpo@turningpointscotland.com
0141 427 8200

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection, if you believe we have infringed your rights or breached data protection laws.  The ICO website is https://ico.org.uk/ and complaints can be made here.

If you would like to receive this notice in alternative format, for example, audio, large print or braille, please contact our DPO (see above).

Updates to this notice

We may update this notice at any time, and you should check occasionally to ensure you are aware of the most recent version that will apply each time you access our website. If we make any significant changes, we will publish a separate notice on our website, so this is clear to all visitors.

Privacy Notice Updated – 25/6/2020