Privacy Policy

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The charitable purposes of STV Appeal include raising funds to help save lives and giving relief to those in need by reason of age, ill health, disability, financial hardship or other disadvantage.  We make grants, donations and gifts to beneficiaries such as other charities and voluntary bodies for the benefit of communities across Scotland.   Our supporters help us achieve this through donations, fundraising, volunteering, and otherwise getting involved in our charitable activities.  This means we must hold and process personal data for a number of reasons to achieve our charitable purposes.  In this section we have listed below our processing purposes and then, taking each in turn, we have set out how and why we use your information, our legal bases, who we share it with and how long we store it.       

Data protection and privacy laws permit us to collect and use your personal data on a limited number of grounds. These grounds include consent, to fulfil a contract we have with you, to comply with a legal or regulatory obligation, or where it is necessary for our legitimate interests and where your interests do not override our legitimate interests. 

1. DONATIONS

You can donate to STV Appeal by text (using one of our short text codes), post (by sending a cheque), online (when you click on the “Donate” button on our STV Appeal website to make a single or monthly recurring card payment) or over the telephone (where invited to do so on an STV Appeal advertisement or the STV Charity Appeal programmes).  You can also donate at a bank or by using Charity Fundraising Platforms such as JustGiving, Virgin Money Giving, Facebook, Everydayhero and others. You can include gift aid when you donate by completing the gift aid form on our website or at the time of your donation where it is available with the donation method.

Purpose and Lawful Basis:  When you donate to STV Appeal we process your personal information to deposit, manage and reconcile funds paid to STV Appeal, to claim gift aid (if applicable) and to contact you to acknowledge and thank you for your donation.  The lawful bases we rely on to process your personal information are article 6(1)(b) of the GDPR, which allows us to process personal data when it is necessary for the performance of our contract with you (your donation), article 6(1)(c) where it is necessary for compliance with a legal obligation (to comply with financial, banking and charity laws), and article 6(1)(f) where it is necessary for our legitimate interests (to contact you to acknowledge and thank you for your donation, to send you Appeal marketing updates by post, and for record keeping purposes).      

When your donation includes gift aid, your information may be requested by and shared with HMRC.  We will only share the minimal amount of information necessary and only where it is requested, necessary and lawful to do so to claim the gift aid.  We rely on article 6(1) (c) to process your information where it is necessary for compliance with our legal obligations.  More information about gift aid. 

When you donate using a third party Fundraising Platform they may ask whether you wish them to share your information with us in order that we may contact you to thank you and to send information about STV Appeal.  Where you agree, your personal data will be shared with us in accordance with the Fundraising Platform Privacy Policy.  Please read their Privacy Policy before you sign up with them to donate.  Once we receive your information the lawful basis we rely on to process your data is article 6(1) (a) with your consent.  Please see Section 4 on Communications below for more information 

What we need and why we need it:  We need financial, payment card, contact and IVR data to process and manage donations, to claim gift aid (where selected), to communicate with you and to keep records for management information and auditing purposes.  

What we do with it:  We store your information on our Customer Relationship Management system and use it to record and keep track of your inter-action with us, to help us understand more about our donors, for management information purposes, campaign planning and marketing purposes.  We use your postal address (where provided) to send you marketing updates about the Appeal (unless you have told us not to).  See our Communications Section 4 below for more detail.                  

How long do we keep it: we generally keep financial and payment card data, contact and IVR data for as long as necessary, for a period of up to 7 years. However, where you donate to the Appeal or otherwise engage with us on a regular basis we keep your information for as long as you continue to engage with us plus an additional 3 years.  We review our Customer Relationship Management system records regularly and delete information when it is no longer needed.  Where we have sent a donation receipt to you, we retain a copy of our communication to you for up to 2 years. 

What are your rights?   Please see your data protection rights section 6 below

Do we use any data processors:  We work with data processors and data controllers who provide and support our text-to-donate and online donation services (OMG) our automated telephone donation (IVR) services (Upward Comms), and our Customer Relationship Management system for database record management purposes.    We use call-centre services from time-to time, for example where we partner with STV Central (the broadcaster) to run the TV Telethon one-day a year. 

Where you use your credit or debit card to donate to us, we pass your card details directly and securely to our payment-processing partners as part of the payment process.   We do this in accordance with the Payment Card Industry Security Standard (PCI DSS compliance) and we don’t store the details on our website.   We work with global organisations (Stripe ) that are regulated by the Financial Conduct Authority to provide card payment services.   As these organisations operate globally, your data may be processed by them in the USA and other countries outside of the UK and your personal data may be subject to disclosure as required by such countries.   Appropriate safeguards, including standard contractual clauses have been put in place to ensure your data is kept secure.  Stripe is a Data Controller – its privacy policy sets out how it processes your personal data.

Google reCAPTCHA:

When you donate through our STV Appeal website, the Google reCAPTCHA tool runs on our donations webpage and you may be asked to confirm that you are not a robot. Google uses cookies to collect data about how you interact with our donations webpage so it can identify that you are human and not a bot. This allows Google to identify and block, fraudulent card payments made by “bots”, thereby protecting legitimate bank account holders and preventing the use of malicious software on our website. For more information about cookies on our website, please read our Cookie Policy. And, for more information about Google’s reCAPTCHA tool and the terms that apply, please read Google’s Terms of Use and Privacy Policy.

• FUNDRAISING

We appreciate all of your fundraising initiatives and thank you for your continued support.  We could not do the good work we do without your help.  

Purpose and lawful basis for processing:  When you contact us to let us know you are fundraising for STV Appeal we process your information to send you our fundraising pack and to keep in touch with you to check how you are doing and to provide support and encouragement.  The lawful bases we rely on to process your personal data are article 6(1) (a) with your consent (to keep in touch with Appeal marketing updates by email, text and phone) and article 6(1) (f) where it is necessary for our legitimate interests of keeping records of our supporters and managing fundraising activities and to keep in touch with Appeal marketing updates by post) and article 6(1) (f) where it is necessary for our legitimate interests of keeping records of our supporters and managing fundraising activities.

What we need and why we need it:  we need contact, biographical and fundraising data from you to make sure we send you the fundraising pack that’s appropriate to your activity.  For example, if you are fundraising at school, work, or you’re undertaking a personal challenge.  We keep records about fundraisers and fundraising activities to find out more about how supporters are raising funds for STV Appeal, how much is likely to be raised, to track progress and to keep in touch on a regular basis.  We may also contact you to ask if we can film your fundraising activity, or ask you send your own video recording to us, to help us promote our fundraising and charitable aims and, if you are under 16 and/or are fundraising at school, we will also need permission from your parent, guardian and your schools.  

What do we do with it:  We store the information on our Customer Relationship Management system and use it to record and keep track of fundraisers and fundraising activities.  We also use the information to contact you and to keep a record our communications and your instructions.  For example, where you have provided your postal address, we will send you marketing updates about the Appeal (unless you have told us not to), for other contact methods we will  only contact you where you have agreed to be contacted.  We will not  contact you if you have asked us not to. 

How long do we keep it:  We review our fundraising records each year and keep it for as long as you continue to engage with us and for a further 3 years for archive and management information purposes unless you have asked us to delete your information.     

What are your rights:  please see your data protection rights section 6 below.  You can ask us to stop contacting you at any time or to change your communication preferences by contacting us at stvappeal@stv.tv.

Do we use any data processors?  We work with data processors that provide e-mail communication and management services to communicate with our fundraisers, and our Customer Relationship Management system for database record management purposes.   We also work with STV Central Limited who provides support and assistance with our fundraising activities.  

• EVENTS

In this section, “events” include the events organised by STV Appeal, such as the Big Scottish Breakfast, as well as third party events such as Kiltwalk where you can sign up and raise funds for STV Appeal.  

Purpose and lawful basis for processing:  when you register and/or attend events we collect information, including your personal data, so that we can plan and manage the event and keep in touch with you about the event.  The lawful bases we rely on to process your information is article 6(1)(a) with your consent (for attendance, contact and direct marketing (by email, text and phone), catering, photo/video recording), article 6(1)(c) where it is necessary to comply with a legal obligation (including Health and Safety and Equality), and article 6(1)(f) where it is necessary for our legitimate interests (to promote our charity, to make sure guests enjoy the event, to keep records and to send Appeal marketing updates to you by post).  We also rely on article 9(2)(a) to process your special category (health) data with your consent (dietary) and article 9(2)(g) where it is necessary for reasons of substantial public interest (health and safety and equality).            

What we need and why we need it:  the data we need will depend on the specific event.  We need your information to plan and manage an event which everyone can participate in and enjoy.  We need contact data to contact you about the event, to make dietary and access arrangements and to send you follow up information about the event (including direct marketing).  We need publication data such as photographs, videos and personal background information (such as your personal story and the charitable organisation you work for or are associated with) to promote the event and the charitable aims of STV Appeal.

What do we do with it:  we store and record your information on our Customer Relationship Management system.  We use the information to contact you where you have agreed for us to do so (email, text and phone) and where you have not objected (including by post), to help us understand more about our fundraisers, beneficiaries and corporate partners, and to promote the event and the charity to the public on various media platforms (including our website, TV adverts, social media etc).    See our communications Section 4 below for more detailed information.   

How long do we keep it: we generally retain event information as long as necessary, for a period of up to 7 years (for example, for health and safety, risk assessment, and insurance purposes). However, where you engage with us on a regular basis we keep your information for as long as you continue to engage with us plus an additional 3 years. 

What are your rights:  please see your data protection rights section 6 below.  You can ask us to stop contacting you at any time by contacting us at stvappeal@stv.tv.

Do we use any data processors?  We work with STV Central Limited to help us manage, organise and facilitate our events from time to time.  We also work with data processors who provider our Customer Relationship Management systems for database record management purposes.  We do not use other data processors to manage events but we may partner with other Data Controllers such as Kiltwalk, and work together with them in their or our planned events from time to time.  

Live Events:  We publish bespoke supplementary privacy policies in advance of each of our events.

• COMMUNICATIONS (including direct marketing)

Where do we get your information:  we receive contact details from various sources include directly from you, from third parties, and from public sources.  We receive contact details from third party fundraising platforms (such as JustGiving) and event organisers (such as Kiltwalk) where you have given them permission to pass your contact details to STV Appeal and agreed that we can contact you.

We receive business contact details from various sources including directly from you, from other business associates, your business website, and from MINT (a database which holds company contact data provided by your organisation for B2B contact purposes).   

Purpose and lawful basis for processing:  We send communications to you for a variety of reasons, including notifying you about changes to our privacy policy, responding to grant applications, inviting you to events, encouraging, supporting and promoting fundraising initiatives, making arrangements to photograph and/ video you, sending you direct marketing communications to keep you up to date and asking you to support and donate to STV Appeal.  The lawful bases we rely on to process your personal information is article 6(1) (a) with your consent (for direct marketing by email, text and phone), to comply with our legal obligations (such as providing terms and conditions and privacy information) and article 6(1) (f) where it is necessary for our legitimate interests to promote the charity, keep records, and send direct marketing communications to you by post.  In addition, we rely on this legal basis to send direct marketing communications by all methods (post, email, text and phone) to corporate bodies to establish new business relationships and engagement.     

What we need and why we need it:  we need enough information to respond to your requests and to manage our relationship with you.  We send you information about STV Appeal which you would generally expect to receive from us.   We need contact data to communicate with you, communications data to respond to your requests, and we need marketing data to make sure we only send direct marketing communications where we have your permission (consent) to do so.  For business contacts, we need contact details to check the relevant preference services before we communicate with you. 

What do we do with it:   we store and record your information on our Customer Relationship Management system and use the information to manage our contact with you.  We use the information to make sure we only send you information you may be interested in, to make sure we don’t send you too many communications, and to make sure we don’t contact you if you have asked us not to.  We analyse data  to understand the types of communications our supporters enjoy most, which campaigns are most successful, and to help us understand more about our supporters to help our communications strategy which best support and promote the charity. 

How long do we keep it:   we retain your communication data for as long as you continue to engage with us.  We review the marketing data every year to make sure it is up-to-date and generally keep a copy of correspondence for up to 3 years.  We delete our suppression lists 3 years after you have either told us you do not want to be contacted and where you have not further engaged with us during that time.     

What are your rights:  please see your data protection rights section 6 below.  You can change your marketing preferences at any time and instruct us to stop sending marketing communications to you by any method by contacting us at stvappeal@stv.tv.  You can also withdraw consent and unsubscribe from direct marketing at any time by sending an email via the unsubscribe option at the foot of any marketing email, or by contacting us at stvappeal@stv.tv.

Do we use any data processors?  We work with STV Central Limited who provides support and assistance with our communication services.  We also work with data processors who provide e-mail communication and management services, text communication services, and our Customer Relationship Management system for database record management purposes.    

• AWARD GIVING

Where do we get your information:  we receive business contact details from various sources including directly from you, from your colleagues or other business associates, and from public sources such as your organisation’s website or social media channels.

Purpose and lawful basis for processing:  we send communications to you for a variety of reasons, including responding to grant applications, issuing grant award agreements and requesting completion of our grant award monitoring form.    The lawful bases we rely on to process your personal information is article 6(1) (b) contractual, where processing is necessary for the performance of a contract or to take steps prior to entering into a contract, to which you, or your organisation is a party.

What we need and why we need it:  we need enough information to respond to your requests and to manage our relationship with you.  We need contact details to communicate with you about any grant awards that have been granted by STV Appeal to your organisation. Where your organisation has received a grant award from STV Appeal, we will ask you to complete our grant award monitoring form and/or other forms of impact assessments which will capture your business Contact Data along with information about the impact that the grant award has had.

What do we do with it:   we store and record your information on our Customer Relationship Management system and use the information to manage our contact with you.  For business contacts of organisation that have received a grant award from STV Appeal, we will use the information that you provide to us in our grant monitoring form or other impact assessments to (i) analyse and evaluate our funding strategy going forward, and (ii) to prepare our interim and annual impact reports, which will be published on our website and shared with stakeholders. We may use your Contact Data to ask you follow up questions about the information that you provide. 

How long do we keep it:  We retain the grant information for 7 years.

What are your rights:  please see your data protection rights section 6 below. 

• Do we use any data processors?  We work with STV Central Limited who provides support and assistance with our communication services.  ScotPulse is an online survey administration service provided by STV Central Limited (with the support of data processors, including a supplier of the technical survey functionality) and we may use ScotPulse to collect and process the information that you provide in a grant monitoring form. We also work with data processors who provide our Customer Relationship Management system for database record management purposes.

APPEAL PROMOTIONS

In this section STV Appeal promotions includes any publicity material included in STV Appeal documents (for example made available on our website – such as fundraising packs), news, features and video content (for example published and broadcast on our own website and social media platforms as well as third party TV and digital platforms).   Appeal promotions in this regard does not include TV programmes (for example, programmes commissioned by STV Central Limited and produced by STV Studios Limited) which may be dedicated to, and broadcast in aid of a particular charity appeal  Whilst the broadcaster and the production team partners with STV Appeal, they are independent to the charity.    

Purpose and lawful basis for processing:    when you agree to feature in an Appeal promotion, we will enter into an agreement with you to process your personal information.  The legal basis we rely on to process your information is article 6(1)(b) which allows us to process personal data when it is necessary for the performance of a contract that we have with you (as a contributor). For contributors who are under 18 or are otherwise unable to enter into a contract (for example due to incapacity) we will enter into a contract with the relevant person with authority to act on your behalf (e.g. parent, guardian, doctor). We rely on article 6(1) (f) to process information where it is necessary for our legitimate interests to promote the charity and to keep records.       

What we need and why we need it:  the level of information we need will depend on the publication.  We need contact data to correspond with you.  Otherwise we may need biographical and publication data to share your fundraising activities and your personal stories to help us raise awareness, funds and support for the STV Appeal. With your permission, we may need to conduct some background checks about you for example to fact check any contribution you may provide.  If you are under 18, then we will want to make sure you fully understand the benefits as well of some of the issues that can come from being featured in promotional material on TV, in the newspapers or on social media and to ensure you and your family are happy to continue to be involved.     

What do we do with it:   we store photographs and video content and select and create content on a regular basis.  We keep your contact details in our Customer Relationship Management system so that we can keep in touch with you regularly and to follow up with you from time to time.  

How long do we keep it:  we review our promotional material every year and contact you if we would like to continue to use your contribution in any new publications.  We delete your information when we no longer need it or otherwise you let us know you no longer wish to feature in our promotional materials. 

What are your rights:  please see your data protection rights section 6 below.  

Do we use any data processors?  We work with producers and creative agencies (at STV as well as other independent operators from time to time) to produce content for inclusion in all of our promotional materials.  The production companies will contact you directly, on our behalf, to seek your permission to feature in an Appeal promotion.   We also work with data processors that provide Customer Relationship Management systems for database record management purposes.  

• DATA SHARING

Purpose and lawful basis for processing: our data processors have access to personal data in order to provide services which help us process, manage, protect, and analyse our data, as detailed in Section 3 (Processing purposes 1 to 6 and 8) of this policy.  Personal data is shared to help us promote our charity, provide communications and facilitate donations.

Otherwise, we only share data with others where it is necessary and as follows:  (i) with regulators where we are legally obliged to do so (for example HMRC (for gift aid) and advertising regulators (publicity materials)); or (ii) where you have given your permission to do so.  For example, where you give your permission to share your information with producers and creative agencies so that they can contact you directly and consider your contribution within STV Appeal publicity materials and TV programmes; or to share your contact details with specifically named event partners and/or partner charities so that they can contact you to send you marketing or other materials. 

The legal bases we rely on to share your personal data is article 6(1) (a) with your consent (to feature in editorial or commercial content and to share with partner organisations), article 6(1) (c) where processing is necessary to comply with a legal obligation (finance/charity laws), and article 6(1) (f) where it is necessary for our legitimate interests (of managing and promoting our charity, providing communications and facilitating donations).         

What are your rights:  please see your data protection rights section 6 below.

• RECORDS MANAGEMENT

Purpose and lawful basis for processing: when you contact or otherwise engage with STV Appeal we collect process (which includes storing) your information for a variety of reasons.  We retain data records to manage our charity, to promote our charitable aims, to communicate with you, to process and administer donations made to us, to analyse and evaluate our grant award process and funding strategy, to improve our supporter and fundraising relationships, to process funding applications, to conduct analysis about communications, fundraising and donations, and to process Gift Aid.  The legal bases we rely on to process your information is article 6(1)(c) where it is necessary for compliance with a legal obligation (to comply with financial, banking and charity laws), and article 6(1)(f) to process information where it is necessary for our legitimate interests (to keep records to manage, operate our charity, achieve our charitable aims, to understand donations made to us, to promote our initiatives and initiatives undertaken by our supporters and to encourage donations).           

What we need and why we need it:  we need to process all of the data categories referenced in C above (Our Processing Purposes) for our charitable purposes.  We need the data to maintain a database of donors, fundraisers, charity beneficiaries, including marketing preferences to understand and engage with our supporters and to manage our charity.  We need data to: (i) record campaign activities, donations, communications, and engagement to manage our communications (ii) review and analyse our records to make sure the information is kept up to date (where necessary); (iii) help us tailor and personalise our communications with you and to make ensure the data is relevant and to help us avoid sending duplicate information or too many/multiple communications to you; and (iv) to create and analyse statistics and reports to produce reports with meaningful management information which helps us run and manage our charity and ensure we comply with the relevant laws and regulations.

What do we do with it:   We store and combine all of the information collected for the processing purposes set out in Section 3 (1 to 8) above in our customer  relationship management and communications systems.  We monitor the data to ensure it is accurate and kept up-to-date (where necessary) and to ensure we still need to keep it.  We use the data to contact supporters, to create reports to analyse management information, and to plan our events, our fundraising activities and our marketing strategies. 

How long do we keep it:  we keep your information for as long as you continue to engage with STV Appeal plus an additional 3 years unless you ask us to delete your information.     

What are your rights:  please see your data protection rights section 6 below.  

Do we use any data processors?  We work with data processors that provide database and storage services services for record keeping and database record management purposes. We also use the office and administration services of STV Central Limited.