CCLASP is committed to safeguarding your privacy. Contact us if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalised or not) – CCLASP
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited with a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
Data we gather
Information you have provided us with
- your name, address, email address, date of birth, phone number and gender
- we also ask CCLASP families to provide the same information about their family members and we ask for diagnosis and diagnosis date for the family member with a cancer diagnosis
- registration category e.g. family, friend, volunteer
- any other personal information you provide to us when contacting or corresponding with us, when requesting any products and services from us, when providing any products and services to us, or when signing up to, attending or participating in our events.
If you do not provide us with all of the personal information that we need to collect then this may affect our ability to offer the membership services and you may not be aware of CCLASP events.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
- Any information you provide to us when contracting or corresponding with us, either through social media, email or telephone.
- Your image (if filmed or recorded when attending our sites or events). Please note that filming and photography takes places at a number of our events. By participating and/or attending any event, you agree to your image being filmed, photographed or recorded, free of charge, for both CCLASP and its licensees to use such images in pictures and/or files (including publication on the internet and in social media).
How we use your Personal Data
We use your Personal Data in order to:
- provide our service to you. This includes for example registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your membership experience;
- fulfil an obligation under law or contract;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalised offers and updates (from us and/or carefully selected partners);
- to administer and analyse our membership base (service usage behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning member satisfaction;
- to register you on our membership database
- to raise awareness of CCLASP. Your personal information may also be used in images captured which we use for promotional purposes.
- to collect, where needed, personal information relating to criminal convictions or allege commission of criminal offences e.g. where you are required to compete a PVG check under the Protection of Vulnerable Groups (Scotland) Act 2007 (or any preceding legal act).
- to respond to and communicate with members regarding your questions, comments, support needs or complaints / concerns etc.
Where we process your personal information pursuit of our legitimate interest, you have the right to object to us using your personal information for the above purposes. If you wish to object to any of the above processing please contact us. If we agree and comply with your objection, this may affect our ability to undertake tasks for the benefit of you as a member or volunteer.
As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and opportunities / offers (from us and/or carefully selected partners);
- for other purposes we have asked your consent for.
We process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymised. We do not save your billing information.
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your membership experience.
We share your data with:
- If your personal information is included in images or videos taken by us, or accredited organisations or individuals, at events , or other CCLASP activities, we may share this with media organisations.
- We may be required to share personal information with statutory or regulatory authorities and organisations to comply with statutory obligations. Such organisations include the Information Commissioners Office, the Health and Safety Executive, Disclosure Scotland and Police Scotland.
- We may also share personal information with our professional and legal advisors for the purpose of taking advice.
- CCLASP employs third party suppliers to provide services, including IT, payments, media, etc. These suppliers may process personal information on our behalf as “processors” and only process that personal information under our instructions and to protect it.
In the event that we do share personal information with external third parties, we will only share such personal information strictly required for the specific purposes and take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.
Our processing partners:
Connected third parties:
We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we can not guarantee the security of information. However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
We collect data from you, about your children, in order that we can tailor services to meet their needs. Where we hold children’s data, we only communicate with the principal member of the family. We hold the children’s data so that we can identify appropriate events / goods.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, they might remember your name and e-mail in comment forms so you don’t have to re-enter this information next time when commenting.
- Analytics cookies – these cookies are used to track the use and performance of our website and services
- Advertising cookies – these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organisations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Any requests received by CCLASP will be considered under applicable data protection legislation. If you remain dissatisfied, you have a right to rise a complaint with the Information Commissioner’s Office.
Last modification was made 15/12/2021