Our Policy is set out in sections as follows:
1. The types of information we collect
The type of data we collect will of course depend on the purposes for which you contact or engage with us and we have categorised the types of personal information as follows:
Biographical Data: gender, marital status, date of birth.
Communication Data: details of your enquiry, complaint, and other information included within your communications with us.
Contact Data: your name, home or work address, email address, telephone number, job title and name of your organisation (if applicable).
Financial Data: name, payment card details, donation amount, gift aid instruction and whether you’re tax payer or not.
Fund Award Data: the name of your charity organisation or project (in addition to your contact data).
Fundraising Data: the activity or event you are organising or are otherwise involved or taking part in and fundraising amounts.
IVR Data: call recording and transcript (where you use our automated telephone donation line)
Marketing Data: your marketing permissions
Payment Card Data: name, card number, CVC, expiry date, donation amount, gift aid amount
Publication Data: your photos or video images, background and health information (if applicable).
2. How we obtain personal information
We obtain personal information from you when you contact us to find out more about us, to ask or tell us about fundraising initiatives, seek funding for your charity or charitable projects or send a comment or complaint. We also obtain personal information from you when you make a donation by text, phone, or online through our website, and when you feature in our promotional materials.
We also receive personal information relating to you from other sources if you have given them permission to share your information with us. For example, we receive information from various Charity Fundraising Platforms (for example JustGiving, Virgin Money Giving, Facebook, EverydayHero) and Event Partners (for example Kiltwalk) when you open a fundraising page to donate to STV Appeal, or select STV Appeal as your charity of choice and where you have given them permission to share your information with us.
Where you are a business contact, we receive your details directly from you and from other businesses and charities who are engaged with STV Appeal. We also obtain business contact details from MINT (a third party database which provides company information) where you have agreed (or not objected) that it can be shared with us. And, we obtain contact details from your business website on the internet and from other public sources such as Companies House from time to time.
3. Our processing purposes
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.
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.
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 thankQ) 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 and Worldpay) 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 and Worldpay are Data Controllers – their privacy policies set out how they process your personal data.
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 email@example.com.
Do we use any data processors? We work with data processors that provide e-mail communication and management services (Accoustic) to communicate with our fundraisers, and our Customer Relationship Management system (thankQ) for database record management purposes. We also work with STV Central Limited who provides support and assistance with our fundraising activities.
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.
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 (thankQ) 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).
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 firstname.lastname@example.org. 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 email@example.com.
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 (Accoustic), text communication services (OMG), and our Customer Relationship Management system (thankQ) 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 (thankQ) 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 5 and 7) 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 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 7) 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 (OMG, Accoustic, Upward Comms, and thankQ) services for record keeping and database record management purposes. We also use the office and administration services of STV Central Limited.
4. Security measures
STV Appeal takes the security of your information very seriously. We use appropriate procedures and technical security measures (including encryption) to safeguard your information across our computer systems, websites, and storage solutions.
5. Cookies and other tracking technologies
6. Your data protection rights
Under Data Protection Law you have rights including:
Your right of access: You have the right to ask us for copies of your personal information.
Your right to rectification: You have the right to ask us to correct personal information you think is inaccurate or to complete information you think is incomplete.
Your right to erasure: You have the right to ask us to delete your personal information in certain circumstances. This does not apply, for example, where data is processed to comply with a legal obligation or a public task.
Your right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances, for example, to stop processing your data until it is corrected.
Your right to object to processing: You have the right to object to the processing of your personal information in certain circumstances. This right does not apply, for example, when data is processed to comply with a contractual or legal obligation.
Your right to object to Direct Marketing: You have a right to object to the processing of your personal data for direct marketing purposes at any time by contacting us at firstname.lastname@example.org.
Your right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. For example, where we process data electronically, with your consent, or as part of a contract we have with you.
Should you wish to contact us to exercise your rights or if you have any worries or complaints about the way we use your information, please don’t hesitate to get in touch with us. We will do our very best to re-assure you and correct anything that is incorrect. For example, if you feel we’re not meeting the standards we expect of ourselves and we have not been able to give you the re-assurance you need, you are within your rights to contact the UK Information Commissioners Office.
7. STV Appeal (“Appeal”) and STV (“STV”)
STV Appeal works closely with STV Central Limited and STV Studios and we appoint STV Central Limited as a service provider and a Data Processor to process personal data on our behalf from time to time. , The personal data STV (Central) process on our behalf is kept separate from any other personal data collected by STV and it is only used in accordance with our instructions for STV Appeal purposes.
STV Central Limited is also a broadcaster and producer who partners with and dedicates programmes to the STV Appeal from time to time. The broadcaster is independent from STV Appeal and it must comply with its own regulatory obligations. STV maintains editorial independence and control over all of the programmes it commissions producers to make for it, including STV Studios (producers). STV Appeal may be asked to help source contributors for STV programmes and where you agree, we will share your details. However, STV (the broadcaster and/or producer) will enter into a separate agreement with you as a programme contributor and will process data in accordance with their own production privacy policies.
8. Links to other sites
9. Contact details
Data Controller: STV Appeal SCIO
Charity No: SC042429
Address: Pacific Quay, Glasgow, G51 1PQ