Terms & Conditions

Data Protection Policy


1. Introduction


This Policy sets out the obligations of Parrot Trust Scotland data protection and the rights of its data subjects in respect of their personal data under EU Regulation 2016/679 General Data Protection Regulation (GDPR).

The GDPR defines personal data as any information relating to an identified or identifiable natural person (a data subject); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.



2. The Data Protection Principles


1. This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:



3. The Rights of Data Subjects

1. The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):



4. Lawful, Fair, and Transparent Data Processing

1. The GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The GDPR states that processing of personal data shall be lawful if at least one of the following applies:

2. If the personal data in question is “special category data” (also known as “sensitive personal data”) (for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation), at least one of the following conditions must be met:



5. Specified, Explicit, and Legitimate Purposes



6. Adequate, Relevant, and Limited Data Processing

6.1 The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed).



7. Accuracy of Data and Keeping Data Up-to-Date



8. Data Retention



9. Secure Processing

9.1. The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided.



10. Accountability and Record-Keeping

1. The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:



11. Data Protection Impact Assessments

1. The Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data [which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR].

2. Data Protection Impact Assessments shall address the following:



12. Keeping Data Subjects Informed

1. The Company shall provide the information to every data subject:

2. The following information shall be provided via access to the Privacy Notice which provides all of the information below i.e. a link to or hard copy:



13. Data Subject Access



14. Rectification of Personal Data



15. Erasure of Personal Data

1. Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

2. Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

3. In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).



16. Restriction of Personal Data Processing

1. Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

2. In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).



17. Objections to Personal Data Processing

1. Data subjects have the right to object to the Company processing their personal data based on legitimate interests, direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.

2. Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

3. Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.



18. Data Security - Transferring Personal Data and Communications

1. The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:



19. Data Security - Storage

1. The Company shall ensure that the following measures are taken with respect to the storage of personal data:



20. Data Security - Disposal

23.1 When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Process included within the Privacy Notice.



21. Data Security - Use of Personal Data

24.1 The Company shall ensure that the following measures are taken with respect to the use of personal data

24.1.1 No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from a nominated person

24.1.2 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of a nominated person

25.1 The Company shall ensure that the following measures are taken with respect to IT and information security:



26 Organisational Measures

26.1 The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:



27 Implementation of Policy

28.1 This Policy shall be deemed effective as of 16th July 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.