Scottish SPCA Privacy Notice
The Scottish SPCA will NOT sell your personal data to any third party.
At the Scottish Society for the Prevention of Cruelty to Animals (also known as the Scottish SPCA and the SSPCA), we are committed to protecting and respecting your privacy.
Please read this Privacy Notice, together with any other privacy notice that we provide to you, as it contains important information about how we collect, manage, use and share (collectively, process) your personal data.
This Privacy Notice applies to personal data we process of:
- Individuals who access www.scottishspca.org (the “website”);
- Individuals who support us; and
- Any other individual who interacts with us (excluding volunteers, applicants and employees as we provide separate privacy notices).
Please check this Privacy Notice frequently to ensure you are aware of the most recent version and the date that it was last updated.
This Privacy Notice was last updated 5 July 2023.
If you have any questions regarding this Privacy Notice or about our privacy practices, please contact us at: 03000 999 999, email@example.com or by writing to us at Scottish SPCA, Kingseat Road, Halbeath, Dunfermline, Fife, KY11 8RY and marking your query for the attention of the Data Protection Officer, Mike Flynn.
2.1 Who are we?
When we say ‘Scottish SPCA’, ‘we’ or ‘us’ in this Privacy Notice, we are referring to the Scottish Society for the Prevention of Cruelty to Animals which is a registered charity in Scotland (Scottish Charity No. SC 006467) and a company limited by guarantee registered in Scotland (Company No. SC201401) with its registered office at Kingseat Road, Halbeath, Dunfermline KY11 8RY.
This also includes our charitable trading company – Braehead Enterprises Limited, a company registered in Scotland (Company No. SC184953) with its registered office at Kingseat Road, Halbeath, Dunfermline KY11 8RY together with any other entities we add to this group in the future.
The Scottish SPCA is a " controller" of the personal data that you provide to us. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
2.2 What personal data do we collect?
Personal data you give us directly:
- Information that we collect from you may include, but is not limited to, your name, address, email address, phone numbers, gender, date of birth, veterinary surgeon, emergency contact details and financial and credit card information.
- You may give us such information directly by filling in forms on our website or donation leaflets or by corresponding or speaking with us by phone, email, letter, visiting one of our sites or otherwise. This includes information you provide when you access or otherwise use our website, register as a member, register to adopt or foster an animal, contact us in regards to a wildlife animal and/or in regards to its release back into the wild, when you use one of our services such as microchipping or neutering or register for our Assured Puppy Breeder scheme, register to receive or use our email newsletter submit a query, make a donation, purchase a product, provide us with feedback or when you report a problem with the website.
Personal data we collect about you:
- Reasons given by a Scottish SPCA inspector for the rejection of your application to our fostering scheme or the issuing of an improvement notice.
- Other information generated or received by us in connection with your participation in the fostering scheme, including complaints and investigations relating to you.
- Information received in connection with an investigation for the purposes of the prevention, investigation, detection or prosecution regarding the health or welfare of animals.
- Information required for you to donate to us, including information to allow us to process your gift aid donation.
- Contact information, so that we can contact you about events you have shown an interest in and enrolment details for events you want to participate in.
- If you have previously been banned from having an animal, we will retain this data for your lifetime, to ensure that we don’t rehome another animal to you.
- We collect your full name and e-mail address, when you subscribe to our e-mail newsletters.
- Other information generated or received by us in connection with your application to rehome an animal.
- If you visit one of our sites, including our Wildlife Rescue Centre or one of our Animal Rescue and Rehoming Centres, we may collect CCTV recordings – you can find out further details on our CCTV Policy
Personal data we receive from other sources:
- If you use any of the other websites we operate or the other services that we provide, such as the ‘Say no to puppy dealers' site, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.
- In the course of administering the fostering scheme. Where you have provided details of your veterinary surgeon, we will contact, and request information from, your veterinary surgeon.
- From Local Authorities in relation to any licences or authorisation that you have been granted by a Local Authority. We may also receive information about you from members of the public.
- Third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) we may receive information about you from them.
- If you are a politician or stakeholder, we may collect your name and contact details which are made available in the public domain so that we can contact you about animal welfare matters.
- Where you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal data, you should check their privacy notices carefully.
- Publicly available sources (where possible) to keep your information up to date, for example, from the Post Office’s National Change of Address Database.
- Third parties in connection with an investigation for the purposes of the prevention, investigation, detection or prosecution regarding the health or welfare of animals,
- From animal chipping providers to contact you for the purposes of animal reunification
- Through the purchase of contact details of people who might be interested in hearing from us. Before purchasing such information, we will check with the vendor that your information, was originally collected in a compliant manner, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
- Through partner websites, such as ‘Active,’ who run events that our fundraisers participate in.
2.3 How we use your information
There are a number of lawful reasons for us to process your personal data. Most commonly, we will use your personal data in the following circumstances:
- To perform the contract between us: Where we need to perform the contract we are about to enter into or have entered into with you.
- Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) where your interests and fundamental rights do not override those interests.
- Legal obligation: Where we need to comply with a legal obligation, (such as enforcing the Animal Health and Welfare (Scotland) Act 2006), or to establish and defend our legal rights, or to prevent and detect crimes such as fraud. In addition, as the only animal charity in the UK recognised as a reporting agency to the Crown Office, we also investigate abuse and prevent cruelty to animals.
- Consent: Where you have given us your consent (for example, where you have agreed to receive email communications)
To perform the contract between us
- To manage and administer our relationship with you.
- To process any donations that you have made to us, carry out our obligations arising from any contracts entered into between you and us, for example, when you purchase products from our shop, and to provide you with the information, products and services that you request from us.
- To inform you of updates to the terms and conditions or changes to the administration of the fostering scheme.
- To contact and visit you to carry out checks to ensure that you meet the standard required to be a Scottish SPCA fosterer.
‘Legitimate interest’ means that we can process your personal data if we have a necessary and legitimate reason; and we have balanced this legitimate interest against your rights, freedoms and interests and concluded that your interests do not override those legitimate interests. Our goal is to rescue and rehabilitate animals before finding them loving new homes or releasing them back into the wild. We also play a vital role in supporting and educating the public on animal welfare issues. Whenever we process your personal data for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection law.
- To provide you with information about and allow you to sign up for or enquire about our activities and appeals.
- To notify you about changes to our service.
- To ensure that content from our website is presented in the most effective manner for you and for your device.
- To understand our donor demographic.
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To provide and improve our site to ensure that content is presented in the most effective manner for you and for your device.
- To allow you to participate in interactive features of our service, when you choose to do so as part of our efforts to keep our site safe and secure.
- To measure or understand the effectiveness of our appeals, and to deliver relevant advertising to you.
- To keep our fostering scheme records up to date.
- If you contact our helpline to ask about our services or to provide us with information about an animal health or welfare matter, this may include recording your call.
- To keep our animals, people and premises safe and secure by using CCTV
- To allow us to investigate complaints regarding fostering, and report criminality, or suspected criminality, for the benefit of animal welfare and the wider benefit of society.
- Personalising our service / communications offering to you.
- Analysing your personal data for the purposes of donor analysis, assessment, profiling and direct marketing.
- To determine the effectiveness of our campaigns and advertising.
- In your interests, for example, to ensure that our systems are secure.
- Sometimes we will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
- We may use your personal data to contact you as a landowner in regards to collecting a wild animal for health/welfare purposes and/or releasing an animal back into the wild
- For the purposes of the establishment, exercise or defence of legal claims.
- To allow us to investigate complaints regarding fostering, and report criminality, or suspected criminality, for the benefit of animal welfare and the wider benefit of society.
- To respond to you in regards to a request to exercise your rights under data protection law (for example, if you ask us to provide you with a copy of your personal data which we process)
- To send you marketing information.
- To deploy cookies as detailed within our Cookies Policy
Sensitive Personal Data
"Special categories" of particularly sensitive personal data, such as information about your health, race, ethnic origin, religious or philosophical belief, trade union membership, genetic or biometric data, sex life or sexual orientation require higher levels of protection. Criminal convictions and offence data also requires a higher level of protection. We will only process this more sensitive personal data where we have the legal bases for doing so, including:
- To exercise our functions for the prevention, investigation, detection and prosecution of individuals
- Where processing is necessary for reasons of substantial public interests, such as for the purpose of safeguarding of children and individuals at risk or preventing or detecting unlawful acts or for equality of opportunity or treatment
- Where you have given explicit written consent
- Where processing is necessary for the establishment, exercise or defence of legal claims
2.4 Our Marketing
We will, with your consent, text or email you to provide you with information about our activities and appeals or provide you with our email newsletter, which is used to inform you about appeals, products and services supplied by us. You can unsubscribe at any time through an automated system. This process is detailed at the footer of each email. If an automated unsubscription system is unavailable, clear instructions on how to unsubscribe will be detailed instead.
We will occasionally, with your consent, call you to provide you with information about our activities and appeals or provide you with information about products and services supplied by us. You may unsubscribe to calls by instructing the person calling you or by contacting the Scottish SPCA at any time on the details set out in the ‘Contact Us’ section of this notice.
We will also communicate with you through postal marketing when it is in our legitimate interests to do this and when these interests do not override your rights. Those legitimate interests include providing you with information on our appeals, membership, services, products, fundraising, newsletter requests, feedback, competitions and other activities and those of other carefully selected organisations. However, you have the right to contact us at any time and opt out of receiving postal communications.
We may use profiling and screening methods to produce relevant communications and provide you with a better experience. To do this we use additional external sources of data to increase and enhance the information we hold about you. This includes obtaining details of changes of address, date of birth, other contact details as well as information related to your wealth.
We may conduct research internally, using publicly available information such as the Companies House database or press articles. We may also do this externally, using trusted companies.
As set out in the section above, our legal basis in relation to this activity is legitimate interest. This is because we consider it necessary to better understand our supporters. Should we estimate a donor’s gift capacity, we do so to understand the connection between donor and cause so that we can present the most appropriate options to making a difference. Profiling can help us understand our donor demographic and target our resources more effectively, which donors tell us is a key priority for them.
Please contact our Data Protection Officer if you do not wish for your information to be used in this manner and would like to opt-out of profiling.
If you have any queries about how we use your information, you can contact us on the details provided in the ‘Contact Us’ section of this notice.
2.6 How long will we hold your information for?
We will hold your personal data on our systems for as long as is necessary for the relevant activity.
Therefore, some information may be kept for more or less time depending on how long we reasonably feel it is required for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
We review our retention periods for personal data on a regular basis and have a record’s retention policy in place.
2.7. Who we might share your information with
We will NOT sell your personal data to any third parties.
Certain personal data is shared with our trading company, Braehead Enterprises. This information is collected when someone buys a product from our website and we need to share it for tax purposes.
The selected third parties we share your data with are as follows:
- When we use other companies to provide services on our behalf, e.g. processing, mailing or delivering orders, answering customers’ questions about products or services, sending mail and emails, customer and donor analysis, assessment and profiling, when using auditors or other professional advisors or processing credit/debit card payments.
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site. To find out more information about cookies, please see our Cookies Policy.
- IT service providers.
- Organisations that we engage for the purposes of co-ordinating donor appeals.
- If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register.
- Law enforcement agencies and the Crown Office and Procurator Fiscal Services where it is for the prevention, detection, investigation and prosecution of criminal offences
- If we merge with another organisation or form a new entity, your personal data may be transferred to that new entity.
- If you are taking part in the Scottish SPCA fostering scheme we may share your personal information with local authorities, law enforcement agencies and veterinary surgeons.
Where we use third party data processors (such as providers of an IT system) to provide services on our behalf they will act on our instructions in the ways we have agreed with you and we ensure that they provide a similar level of security in compliance with data protection law.
The reasons for which we disclose your personal data to third parties are as follows:
- Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies.
- When a report is submitted to the Crown Office and Procurator Fiscal Service to assess whether court proceedings are appropriate or where we contact a law enforcement agency in regards to the prevention, detection, investigation and prosecution of crime
- Protect the rights, property, or safety of us, our employees, donors, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- Allow the third party to provide us with business-critical services such as IT and other professional services including accounting and legal services.
- We may also share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business, including a merger or transfer of the Scottish SPCA's activities to another organisation.
- We may also need to share your personal data with a regulator or to otherwise comply with the law.
- We may use your email address and phone number to match to your account on Facebook, Instagram or other social media sites in order to show you Scottish SPCA content while using these services. We only do this where you have opted in to marketing emails or phone calls and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
- In addition, we may also use your email address and phone number to link to Facebook, Instagram or other social media sites in order to identify other users of these sites whom we believe would be interested in Scottish SPCA, and we may then show them Scottish SPCA content. No personal data we hold about you is retained by the third party.
- If you wish to prevent this use of your data, you can either contact us to opt out of such use or you can do this through the social media site. Please be aware that opting out of such communications does not guarantee that you never see Scottish SPCA content on social media, since the social media site may select you based on other criteria and without your data having been provided by Scottish SPCA.
International transfers of personal data outside the United Kingdom
The following details the circumstances in which your personal data is transferred outside the UK, together with the transfer mechanism we use to safeguard the transfer:
We use MailChimp to send our newsletters and selected campaigns which involves processing personal data in the USA. We safeguard your data by including standard contractual clauses with UK Addendum in the contract with MailChimp and also by minimising the amount of data provided to them (which consists only of name and email address). MailChimp has an ISO 27001 certification.
2.9 Your rights
You have a number of rights. If you would like to exercise any of these rights, please contact us using the details set out below in the ‘Contact Us’ section. If you request to exercise any of these rights, we may ask for proof of identity and sufficient information about your interactions with us so that we can locate your personal information. If we agree that we are obliged to provide personal information to you (or someone else on your behalf), we will provide it to you or them free of charge except in exceptional circumstances.
You also have the right to lodge a complaint with the data protection regulator, the Information Commissioner’s Office, if you have concerns about how we use your personal information. You can contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/.
Your rights include:
- transparency over how we use your data and to make a subject access request (right of access);
- a right to have your personal data updated and corrected (right of correction / rectification);
- a right to ask us to delete your information (right to be forgotten);
- a right to ask us to stop processing your information (right to restriction);
- a right to object to (i) processing based on our legitimate interests; (ii) processing of your information for direct marketing purposes; and (iii) automated decision making and profiling (right to object);
- a right to receive a copy of your information, or have this sent to a third party (right to data portability); and
- a right to claim compensation for material or non-material damage caused if we breach the data protection rules (right to compensation).
If you would like to find out more about your rights, you can visit the Information Commissioner’s Office website (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr).
2.10 How you can access and update your information
We strive to maintain accurate, complete and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you can ask us to correct it. It is important that the personal information we hold about you is accurate and current.
2.11 Security precautions in place to protect against the loss, misuse or alteration of your information
We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration and disclosure. Details of these measures can be obtained on request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our security measures are regularly reviewed.
2.12 Contact Us
If you have any questions regarding this Privacy Notice or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Data Protection Officer at:
Data Protection Officer
Kingseat Road, Halbeath
Telephone: 03000 999 999