LGBT Health and Wellbeing believes that privacy and data protection are core human rights. We understand that your privacy is important to you and that you care about how your personal data is used. We know that we have a duty of care to you and are liable to only collect and use personal data when absolutely necessary. This Privacy Notice outlines in a clear and transparent way, what information we might collect on you, how we collect it, how we use it and how we keep it safe.

Contents

About us 
What is personal data? 
Why do we collect personal data? 
What personal data do we collect? 
How do we collect personal data? 
How do we use personal data? 
Where do you store my personal data? 
How long do you keep my personal data? 
Your rights
How to make a complaint 
Changes to this policy 
Cookies
Links to other websites

About us

We are LGBT Health and Wellbeing (also known as The LGBT Healthy Living Centre) – a registered charity in Scotland (SC034216) working to promote the health and wellbeing of LGBT people in Scotland. References to ‘we’ and ‘us’ in this policy, mean LGBT Health and Wellbeing.

LGBT Health and Wellbeing
Address: 4 Duncan Place, Edinburgh, EH6 8HW
Email: admin@lgbthealth.org.uk
Phone: 0131 564 3970

What is personal data?

Personal data is “any information relating to an identified or identifiable person who can be identified, directly or indirectly, in particular by reference to an identifier” (UK GDPR). In other words, personal data is any information about you that can identify you. Personal data covers information such as your name, contact details, photography, sexuality, gender identity, ethnicity, employment and health history, IP address, etc… The personal data that we use is outlined in Part 4 below.

Why do we collect personal data?

LGBT Health and Wellbeing collects personal data on people who contact or access our services, as well as volunteers, community group leaders, employees and students on placement. The main reason why we collect personal data is to enable us to deliver and manage our services.

Depending on your relationship to us, we may use your personal data on the following basis:

• with your consent
• to deliver the service you have asked us to (contract)
• to comply with the law (legal obligations)
• to protect your life (vital interests)
• to run our organisation (legitimate interests)

Find more information about how we might use your personal data in Part 5 and 6.

What personal data do we collect?

Depending on your relationship with LGBT Health and Wellbeing, we may collect the following information:

• Name
• Contact details
• Background history
• Service use history
• Health history
• Access needs
• Sexual orientation, gender identity, race, religion (equality monitoring)
• Criminal offences
• Background or employment history (prospective volunteers, community group leaders and staff)
• Website usage
• Payment method (donations)

How do we collect personal data?

We collect information when you:

• Contact us by post, phone or email
• Refer to our support services (including counselling, 1-1 support, Telefriending)
• Use our LGBT Helpline Scotland (on the phone, or online using email or Livechat)
• Sign-up to our events
• Subscribe to our e-newsletters
• Apply to be a volunteer
• Apply to be a community group leader
• Apply to work for LGBT Health and Wellbeing
• Give feedback about our services or events
• Interact with us on social media
• Participate in our publicity photoshoot or photographed events (with your consent)
• Cookie information when you visit our website
• Make a donation to us, either by post (cheque), standing order or Direct Debit, online (using PayPal), over the phone or via SMS/text donation (using Donr), or when you raise funds through a third-party platform such as Give As You Live, Amazon Smile, Facebook Fundraiser or Yaldi Glasgow Community Lottery. We also collect information about you when you setup a fundraiser in memory or in celebration of a loved one using PayPal Giving Fund, or if you enquire about leaving a gift in your will.

LGBT Helpline Scotland
We collect personal data when you use our helpline. Depending on our interaction, this might be special characteristics such as age, location, sexual orientation, gender identity, and the nature of your enquiry. We will not collect your name or contact details so your information is anonymised. We collect this information for the purpose of research and evaluation, and to report to our funders. Knowing the profile of helpline users allows us to learn about the needs of our community and promote the needs of LGBT people in Scotland. We store this information on a secure Microsoft Access database for processing.

Support services
We collect personal data when you use our support services. When you enquire about our services, we usually collect your name and contact details so we can get back in touch about your enquiry. At this stage, we might collect information about other services you might have used and issues you are looking for help with so we can assess your needs and match you with the relevant support. If you go on to refer to our support services, whatever you disclose to help us support you will be strictly confidential. We will keep a record of this information to adapt our support and signpost where relevant, but it will be anonymised.

Website
We collect personal data when you browse our website through ‘cookies’. This usually includes your IP address, device type, device location, and how you use our website. We only use this information to improve our website so we can give you the best experience and information you need. For more detailed information on the cookies we collect, please see the “Cookies” information in Part 12.

Newsletters
When you subscribe to our e-newsletters, we collect your name and contact details so we can send you the e-newsletter of your choice. We send these to keep you updated about the work of our organisation, including events and opportunities for you to connect with the LGBT community in Scotland. We do not share or sell your contact details, and we won’t spam you. You can unsubscribe from our e-newsletters anytime you want. All you need to do is click the ‘unsubscribe’ button at the top of any e-newsletter we sent you. You can also contact us at admin@lgbthealth.org.uk and ask for your contact details to be removed from our mailing list.

Events
When you register to one of our events, we collect your name, contact details and other useful information so you can access and so we can help make it as accessible as possible to you. We use Eventbrite to collect and store attendees information. We will not transfer your contact details onto another mailing list and won’t use them for any other purpose than to communicate important information about the event. If you want to keep updated about our other events, you will have the option to opt-in our Eventbrite mailing list.

Donations
If you want to make a donation to us, we ask for your payment information like your card or bank details so the payment goes through. Your payment information is never disclosed to us but encrypted on one of the third party platforms that we use to collect donations (PayPal, Donr, Bank Transfer, etc…). The only information that we can see is your name, contact details and payment method. We will only use these to communicate with you about your donation.

Social media
When you interact with us on social media, we will have access to personal data disclosed on your public profile. This could be your name, location, image, workplace and any information that you share on your feed. The information available on your social media profiles is entirely up to you and we recommend you only disclose information you would be comfortable for strangers on the internet to see. We do not transfer your social media personal data on any of our internal systems, unless we have to register an incident where you have been abusive on our social media profiles.

Publicity
To make sure our publicity represents the community that we serve, we might collect images of community members to use in our publicity materials or resources. Images will either be collected at events or during publicity photoshoots and we will always ask for your consent beforehand. We will only images to promote our services, and commit to use them sensibly in a way that will not misrepresent the subject. Images will be stored securely and not shared with any third party, unless with explicit consent. You can withdraw consent for us to use your image at any time but it is your responsibility to notify us of any change in your consent. However, you need to understand that withdrawal may not be possible for publications already publicly available, such as printed publications. Withdrawal will be effective from the date you remove consent and for any future publicity.

Research and evaluation
Research and evaluation is central to the work of our organisation so we can make sure that we develop services responsive to the needs of our community and that we improve them. We also use research and evaluation to influence policy change, promote LGBT inclusion across Scotland, and secure funding to develop the services that LGBT people in Scotland need. One of our biggest pieces of research and evaluation is our annual Community Feedback Survey. If you take part in this survey, your response will be confidential and anonymous – we won’t collect your name or contact details (except if you want to take part in the prize draw in which case, your details will be separate from your response). We collect survey responses through a secure third platform called Survey Monkey.

Apply to work with us
When applying for a job with us, we ask for information to allow us to short-list and select the most suitable candidate for the role. We also ask for contact details so we can communicate with you about your application. We want to make sure that our staff team is representative of the diversity of our community. To help us achieve this, we ask candidates to fill in an equal opportunities monitoring form (optional) that we keep separate from their applications. These forms are used to collect the characteristics of people applying for our jobs so we can work to reach under-represented groups.

Apply to volunteer with us
When applying to volunteer with us, we ask for information to help us decide whether candidates have the skills, knowledge and/or experience to carry out a specific role. It also allows us to find the role that would best match what you have to offer. We also ask for contact details so we can communicate with you about your application. We want to make sure that our volunteer team is representative of the diversity of our community. To help us achieve this, we ask candidates to fill in an equal opportunities monitoring form (optional) that we keep separate from their applications. These forms are used to collect the characteristics of people applying to volunteer for us so we can work to reach under-represented groups.

How do we use personal data?

Depending on your relationship with LGBT Health and Wellbeing, your personal data may be used to:

Community members or people using our services

• Communicate with you including responding to enquiries by phone, email, post or on social media
• Assess your needs, match you with the appropriate support
• Refer you to other more appropriate support
• Get help if there is an immediate risk to life
• Monitor the quality of our services, and plan future services
• Report our activities to funders and our Board
• Communicate information about an event you have registered for
• Collect feedback about our services and events
• Send you updates about our services and events (with your consent)
• Manage your donation
• Improve our website
• Promote our services and events
• Include case studies in our report (data anonymised)
• Carry out research in the interest of our community (data anonymised)

Volunteers or people who apply to volunteer

Your personal data may be used to:

• Assess your suitability and allocate you to the appropriate role
• Conduct a background check (PVG checks)
• Monitor equal opportunities
• Communicate with you about your role

Community group leaders

Your personal data may be used to:

• Assess your suitability
• Conduct a background check (PVG checks)
• Monitor equal opportunities
• Communicate with you about your community group

Employees or people who apply to work for us

Your personal data may be used to:

• Select the appropriate candidate
• Conduct a background check (PVG checks)
• Monitor equal opportunities
• Deliver effective management (including supervision and annual appraisals)
• Comply with employment and company legislation

Where do you store my personal data?

We use a mixture of internal and external systems to collect, store and process personal data. By external, we mean that we use third party data processors to provide a service, and when we do so, we make sure they comply with legal data protection standards.

Here are the third party data processors that we use to help us provide our services:

• Microsoft Outlook to communicate by email
• Facebook, Twitter, Instagram and Meetup to communicate and share updates
• WordPress to host our website
• Google Analytics to improve our website
• LiveChat to provide our helpline live chat service on our website
• Mailchimp to send our newsletters
• Eventbrite or Zoom for event registrations
• Google Forms and Survey Monkey for our evaluation and research
• PayPal, Amazon Smile, Give As You Live for online donations
• Donr for text donations
• Canva and Adobe for publicity materials

Some of these online platforms store and process data outside of the UK and the European Economic Area (EEA), however we make sure they meet the EU data protection rules.

How long do you keep my personal data?

We will not keep your personal data for longer than is necessary, but we need to retain some information for several years to meet our duties as an employer, a company and a service provider.

People who use our services
Where we keep records of individuals using our services, we will retain information relating to you for 1 year after you stop using our services. This ensures that we can collate full and accurate statistics for our services each year. If you do not have contact with us for a period of 2 years, your record will be deemed as “closed”.  After a file is closed we will retain a summary record to allow us to track the use of our services over time – for example, we need to know whether a person has used our services before and for how long.

Recruitment
We will keep unsuccessful applications for employment for 1 year and volunteer posts for 3 years after the closing date or volunteer application was received. Application forms for successful candidates will be added to their employee file / volunteer file. We will retain employee records for 6 years after the person completes their employment with us. We will retain volunteer records for 3 years from end date of the person volunteering

Your rights

In relation to your personal data, under the UK GDPR you have the following rights:

• The right to know if we collect your personal data and how we use it. This Privacy Notice should give you all the information you need to know, and you can always contact us for more information using the details in Part 1.
• The right to access the personal data we hold about you.
• The right to ask for your personal data to be rectified if it’s inaccurate or incomplete.
• The right to ask us to stop using your personal data or to have it deleted.
• The right to object to us using your personal data for a particular purpose.
• The right to restrict how we process your personal data.
• The right to ask that we move your personal data to you or another service provider.

If you want to exercise any of your rights then contact us using the details in Part 1. We’ll then guide you through the process.

How to make a complaint

If you have a complaint about the way we process your personal data, please contact us using the details below.

Data Controller
LGBT Health and Wellbeing
Address: 4 Duncan Place, Edinburgh, EH6 8HW
Email: admin@lgbthealth.org.uk
Phone: 0131 564 3970

Data Protection Officer
Maruska Greenwood
Chief Executive
Address: 4 Duncan Place, Edinburgh, EH6 8HW
Email: maruska@lgbthealth.org.uk
Phone: 0131 564 3970

You can also complain to the Information Commissioner’s Officer (though they will always ask you if you raised it with us first) using the details below.

Information Commissioner’s Office Scotland
Address: Queen Elizabeth House, Sibbald Walk, Edinburgh, EH8 8FT
Email: Scotland@ico.org.uk
Phone: 0303 123 1115

Changes to this policy

This privacy policy may change from time to time in line with legislation or industry developments. We will not explicitly inform you of these changes unless they are significant. Instead, we recommend that you check this page occasionally for any policy changes.

Cookies

Cookies are text files which identify users’ computers to the website’s server.

Cookies in themselves do not identify individual users but identify only the computer used and they are deleted on departure from the website.

Many websites do this to track traffic flows, whenever users visit those websites.

www.lgbthealth.org.uk uses third-party cookies to measure use of the website including the number of visitors, how frequently pages are viewed, and the city and country of origin of users. This helps to determine what information is most popular and can influence future website content and development.

For this purpose, www.lgbthealth.org.uk uses Google Analytics to measure and analyse usage of the website. The information collected will include IP Address, pages visited, browser type and operating system. The data gathered will not be used to identify any user personally.

You can control your acceptance of cookies and/or disable them entirely in your web browser settings — and there is also a cookie warning when you first enter this site.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit: www.allaboutcookies.org

Links to other websites

www.lgbthealth.org.uk may contain links or references to other websites. Please be aware that we do not control these other websites and that, in any case, this disclaimer does not apply to those websites. We are not responsible for the privacy practices or the content of such websites, and we encourage you to read the privacy policy of every website you visit.