Who We Are
Scotland’s Towns Partnership
Scotland's Towns Partnership is Scotland’s largest towns’ collective; representing and promoting the diversity of our towns and places, and supporting those organisations and groups that have an interest in or ownership of them.
In order to be able to undertake our work and inform our network about the activities and resources available to support towns, we make use of personal information – almost wholly basic contact details – which users provide us with. In this notice you can read how we collect and use personal information, as well as your rights in relation to this. If you have any questions, please don’t hesitate to contact us.
Importantly, any personal data collected through this website and held by STP, Brightstar Scotland or its associates is treated in line with the principles of the General Data Protection Regulation 2016. The website for Scotland’s Towns Partnership is created with NationBuilder, a trading name of 3DNA Corp. 3DNA Corp complies with the EU-US Privacy Shield Framework regarding data protection requirements.
Processing and Use of Personal Information
Lawful Basis for Processing Personal Data
GDPR Art 6 (1) (a) Consent: the individual has given consent to the processing of his or her personal data for one or more specific purposes.
Where users have previously bought or solicited products or services from STP, ‘legitimate interests’ (GDPR Art 6 (1) (f) may also act as a basis for legal processing and communication.
Purposes of Data Processing and Storage
To inform about news, events, projects and other initiatives related to the work of Scotland’s Towns Partnership.
To inform our members of information regarding membership benefits and the annual member renewal process.
To hold and process invoices sent by users to Scotland’s Towns Partnership for membership or event booking payments.
Communication from Scotland’s Towns Partnership may take the form of direct email correspondence, or bulletins sent via our Nation-Builder account. Notices may also include information about the activities of our member and partner organisations. For a list of these, see: http://www.scotlandstowns.org/our_members
Data Retention and Rights of the Data Subject
Scotland’s Towns Partnership will keep personal information as long as it is necessary for the purpose for which it was obtained, in compliance with existing regulations and unless asked to delete it at an earlier time. Data subjects have the following rights, including the right to erasure (the ‘right to be forgotten’) as set out in GDPR Articles 12-23.
It is the responsibility of the Joint Controllers to observe these rights and act upon requests in relation to these rights from individuals whose personal data is held by STP.
Data Controllers and Processers
The Joint Controllers and Processors of personal data on behalf of Scotland’s Towns Partnership are Brightstar Scotland and associates. The lead Joint Controller is Elaine Bone, contactable at: [email protected].
A complete list of data processers and Brightstar associates with access to personally identifiable data is listed in STP’s GDPR data audit, available upon request.
Data Storage and Protection
Personal information may be stored in one of the following locations: STP Dropbox Folder; STP NationBuilder Account; STP Gmail Accounts; STP Google Drive Shared Folder; Brightstar Scotland Amazon File Storage; Brightstar Associate hard-disk or connected OneDrive / Google Drive account, and Xero.
Under GDPR regulations, STP staff, Data Controllers and Data Processors have a duty to report any data breach to the UK Information Commissioner’s Office.
Scotland’s Towns Partnership retains an audit of the type of personal information held, where this data is held, and the purpose and legal basis for processing this data. This can be provided upon request.
Information Sharing and Third Parties
Scotland’s Towns Partnership does not share personal information with third party organisations. Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our web site.
Information We Collect
You can provide us with information about yourself, such as your name and e-mail address, by registering via www.scotlandstowns.org (including by “following,” “liking,” linking your account to www.scotlandstowns.org on a third party website or network). If you correspond with us by email, we may retain the content of your email messages, your email address and our responses. We may also retain any messages you send through www.scotlandstowns.org.
Newsletter and Website Registration
A user does not have to register to use Scotland’s Towns website, but a user must register if they wish to receive information and updates via email.
We use a third-party provider, NationBuilder, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see NationBuilder’s privacy notice.
The registration information we require to allow a user to register is the full name and email address of the user if they wish to receive email updates. This information is stored securely on our database until such time as a user chooses to unsubscribe from receiving news stories. Users who no longer wish to receive our newsletters and other updates may opt-out of receiving these communications by clicking unsubscribe option on any email communication received or by contacting the Joint Controllers or STP via the ‘contact us’ form on our website.
Event Ticketing and Membership Subscriptions
Event bookings, event ticketing and membership subscription requests made via www.scotlandstowns.org are routed through STP’s NationBuilder account.
Those wishing to book for an event must complete the RSVP form detailing first name, last name and email address. Optional information may be provided by the user as displayed. To “pay by invoice”, users will also need to enter either an email address for an email invoice, or a postal address for a hard copy invoice.
As stated above, STP’s appointed accountants, Soroban, will also have access to the necessary personal information for the processing of invoices, including name, email or postal address, and bank account and sort code if submitted by the user.
We typically provide an attendee list of names and organisational affiliation at our events to aid delegates with networking. Furthermore, we take photographs of proceedings in order to highlight or showcase Scotland’s Towns Partnerships activities. You will be asked to provide consent for this use of your data in this way when signing up for events, and are freely able to refuse to provide this.
From time-to-time we may request information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and address), and geographic information (such as postal code). Contact information will not be shared with any third parties unless we give prior notice and choice. Though we may use an intermediary to conduct these surveys or contests, they may not use users' personally identifiable information for any secondary purposes.
Information Sharing - Legal Disclaimer
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our web site.
Website and Third Parties
Scotland’s Towns Ltd (hereafter, “Scotland’s Towns Partnership”, or “STP”) seeks to ensure that the information published on its website is up to date and accurate. However, the information on the website does not constitute legal or professional advice and STP cannot accept any liability for actions arising from its use. STP cannot be held responsible for the contents of any pages referenced by an external link.
Any personal data collected through this website and held by STP, Brightstar Scotland or its associates will be treated in line with the principles of the General Data Protection Regulation 2016. The website for Scotland’s Towns Partnership is created with NationBuilder, a trading name of 3DNA Corp. 3DNA Corp complies with the EU-US Privacy Shield Framework regarding data protection requirements.
When you visit www.scotlandstowns.org, NationBuilder may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and lets NationBuilder help you log in faster and enhance your navigation through www.scotlandstowns.org. A cookie does not collect personal information about you. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of www.scotlandstowns.org may not function properly if the ability to accept cookies is disabled.
You can read more about how the NationBuilder service interacts with and protects your information at nationbuilder.com/privacy and nationbuilder.com/confidentiality.
Cookies and Website Traffic Analysis
When users enter Scotland’s Towns website their device will automatically be issued with 'cookies'. Cookies are text files which identify users' computers to the Scotland’s Towns server. The website then creates "session" cookies to store some of the preferences of users moving around the website, e.g. retaining a text-only preference. Cookies in themselves do not identify individual users but identify only the device used and they are deleted on departure from the website. Many websites do this to track traffic flows, whenever users visit those websites.
Scotland’s Towns website uses third-party cookies to measure use of the website including number of visitors, how frequently pages are viewed, and the city and country of origin of users. This helps to determine what is popular and can influence future content and development. For this purpose, Scotland’s Towns website uses Real-time Analytics to measure and analyse usage of the website. The information collected by Scotland’s Towns will include IP Address, pages visited, browser type and operating system. The data will not be used to identify any user personally.
Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised services cannot then be provided to that user.
Log files stored on the Scotland’s Towns Forum web server allow the recording and analysis of users' use of the website. Log files do not contain any personal information.
This Website contains links to other sites. Please be aware that Scotland’s Towns is not responsible for the privacy practices of such other sites, and additionally cannot verify the accuracy of the information contained on external sites - by linking to them, we are not endorsing them. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every Website that collects personally identifiable information. This privacy statement does not apply to information collected by other websites.
Online Meetings and Events (Zoom)
STP uses the Zoom video communications platform to hold online events and meetings. Personally-identifiable information from our online events may be shared publicly online (including recordings, screenshot images, names, and information left in chat comments) unless any identifiable person in the meeting (such as a panellist or other active participant) requests that they would prefer this material not to be made publicly available.
In the unlikely event that STP would seek to make an online meeting publicly available, prior explicit consent would be requested from all participants in the meeting.
For information about how your data is protected within a Zoom meeting, please consult Zoom’s privacy statement and GDPR compliance statement (click links to view).
Changes and Notifications
Access and Changes to Your Personal Information
You have the right to request, change, or delete personal information we hold about you (such as postal code, phone, email or postal address). This can be done by sending a request to [email protected] or contacting Scotland’s Towns Partnership via its website.
Under the General Data Protection Regulation, individuals whose personal data is held by Scotland’s Towns Partnership have the right make a subject access request for their personal data processed by Scotland’s Towns for stated purposes. As stated earlier in this notice, data subjects have the following rights, including the right to erasure (the ‘right to be forgotten’) as set out in GDPR Articles 12-23.
Notification of Changes
Policy last updated: July 2020