VisitScotland Privacy Policy

 

Our pledge to you:

  • Is to hold your data securely;
  • Share only where you agree;
  • Use your data to tailor the information we provide you and improve our services;
  • Put you in control by allowing you to update, delete and access your data.

This privacy policy tells you:

  • The information we collect (personal or not)
  • Why we collect it
  • How long we store it
  • Our legal basis for processing your personal data
  • Who if anyone we disclose your personal data to
  • Your rights and how you can see, update or delete your personal data
  • To make it easy to understand what data we collect about you we have grouped this policy into how you and others get information from us/ interact with us
  • Our digital services. This includes our website and apps, managed by us.
  • Services we use to communicate like social media 
  • Contact us directly, via email, phone, letter 
  • Meet us in person at events.

1. Who are we?


VisitScotland is the national tourism organisation for Scotland. Our main aim is to contribute significantly to the advancement of Scottish tourism by giving it a real presence in the global marketplace and benefiting the whole of Scotland.


Our website, www.visitscotland.org is the corporate website for VisitScotland. The aim of the website is to assist businesses, travel trade, and other such organisations with how we can work together.

 

This policy covers how we (VisitScotland) collect, use, disclose, transfer and store data for business and some consumer data. This policy also covers this website (www.visitscotland.org) and the following assets which are managed by VisitScotland:

This privacy policy covers how we handle business data within VisitScotland and on this website. It gives you information on how VisitScotland collects and processes your personal data through your use of our website, including any data you provide through this website when you sign up to our newsletters.


This privacy policy should be read together with any other privacy notice or fair processing notice VisitScotland provides on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not intended to override them.


We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out at the bottom of this privacy policy.


Third Party Links 


Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2. What personal information will VisitScotland collect about me?

 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
 
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
  • Contact Data includes billing address, delivery address, email address and telephone numbers
  • Financial Data includes bank account and payment card details
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website
  • Enquiry Data includes data you provided us with when you contact us for customer service assistance (by any means of communication including written communications or via our website(s), support forums, telephone, email, SMS, or our social media channels) or when you visit us at a public event, such as a trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may record all customer service communications and keep information about the particular communication, including your name, the product(s) you bought, the reason why you contacted us, and the advice we gave you so we can track the resolution of any customer service issues and for customer service training purposes
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses We may also receive content that you choose to upload or post, such as your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details, product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive
  • Usage Data includes information about how you use our website, products and services, as well as the frequency and pattern of your service use
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
 
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

How we collect your information


We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    -  apply for our products or services;
    -  create an account on our website;
    -  subscribe to our service or publications;
    -  request marketing to be sent to you;
    -  enter a competition, promotion or completing a survey; or
    - give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies, this Technical Data may include:
    -  Details of your usage patterns, the content (including any advertisements) that you view and interact with including information on the services and applications you are using in-device to personalise services to your specific needs. For example, when you use our websites, we may collect information about your visit, such as your browser software, which pages you view and which items you ‘clicked’ on or added to your shopping basket.
    -  Service, product or server logs, which hold technical information about your use of our service, product or websites, such as your IP address, device ID(s), domain, device and application settings, errors and hardware activity. We may use your IP address to determine your location/country of origin.
    -  Device Information such as your device ID(s), including information about where your device is physically located. For example, when you are using a geo-location service or application and you have given consent to your location being shared.
    -  Interests and preferences that you specify during set up or registration of any product or service.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    -  Financial and Technical Data from parties such as:
    a) analytics providers based outside the EU;
    b) advertising networks based inside the EU; and
    c) search information providers based outside the EU.
    -  Contact, Financial and Transaction Data from providers of technical, payment and delivery services based outside and inside the EU.
  • Identity and Contact Data from data aggregators and other specialist agencies based inside or outside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  • Identity and Contact Data from social media if you (i) interact with any of our social network pages or applications; or (ii) you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance:
    - Logging in: If you log-in to one of our websites, applications or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings; however, they might include your social network ID, name, profile picture, gender and location.  
    - Interactions: If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you.

3. How we use your personal data

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation.

Set out below are a range of purposes/activities that we may use the personal data you provide to use for. This includes the type of data we will collect, the lawful basis for processing and the retention periods.


Complaints


When you make a complaint to us, you can do so via an online form, email, telephone, letter or at an iCentre. The complaint is logged on a complaints system. where a VisitScotland complaints officer will review and respond to it.
A complaint can be made anonymously. However if you do provide personal data, we request your Identity Data and Contact Data. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.


By giving us your Identity Data and Contact you consent to us processing it. We retain personal data obtained from complaints for five years and then confidentially destroy it.


If a complaint is made by or about a business, this information is usually retained on our Stakeholder CRM where it becomes part of the business record. It will be retained until the business ceases to work with us, plus an additional 3 years.


Give us feedback (unprompted)


You do not need to include your Identity Data or Contact Data in order to provide us with general feedback or information about any technical problems on this site. You will however need to include an email address if you want us to reply to you. For some enquiries, contact details will be required.


We will only use any personal information provided to deal with your request and will not share it with other organisations.  This data is stored for six months after we respond to your feedback, in case you ask for more detail or have other feedback you'd like to make.


We reserve, however the right to use non-personal information for business, research and marketing purposes. Uses include:

  • An internal report listing technical problems on the website and solutions
  • Marketing literature using quotes drawn from feedback about the site

Our legal basis for processing this data is legal obligation.


Give us feedback (when we ask you)


We may ask you for feedback whilst on the website. You only need to include an email address if you want us to reply to you or you would like to be included in future research.


By giving us your Contact Data, you consent to us processing it. We will store it securely for a maximum of 14 months. 


We may share this data with a research agency who conduct the research on our behalf and destroy the personal data when the research is complete.

 

Marketing communications


We may use your Identity, Contact, Technical, Usage and Profile Data to provide you with product and service updates, newsletters and other communications about existing and/or new products and services by post, email, telephone, in-device messaging and/or text message (SMS).


You will only receive marketing communications from us (i) if you have requested information from us; or (ii) purchased goods or services from us; or (iii) if you provided us with your details when you entered a competition or registered for a promotion and, in each case, if you have opted in for receiving such marketing.


We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
 
Opting out of marketing communications


You can ask us or third parties to stop sending you marketing messages at any time by clicking the "unsubscribe" button at the bottom of the emails or by contacting us or such third parties at any time.


Where you opt out of receiving these marketing messages, such opt out will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Please note that we may occasionally send you important information (including via email) about our products and services that you are using or have used including essential software updates, changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations to provide warranty or after sales repair services. These important product and/or service communications are not affected by your opt-out of any marketing communications.


4. When you use our digital services


Website Analytics


We use website log files, cookies, digital analytics (Google) and heat mapping software, to gather information about how people use this site (www.visitscotland.com).


We do not collect or store your personal information (e.g. your name or address) in our website analytics. However, we can recognise that behaviours belong to a single person. The information collected helps us investigate whether each website meets its users' needs as well as to evaluate how each website can be improved. We store information about what pages you visit, how long you are on the site, how you got here and what you clicked on. 


If we were ever to obtain your personal data via the routes in this policy, we may combine website analytics data with your personal data. For more information please see the section on Joining data and Profiling.


Website log files collect your Technical Data, e.g. IP address, when you visited the site and the pages you visited. An IP address is a numeric code assigned to a device based on your geographical location.  If for example you are in Edinburgh your IP address will be the same as other users accessing the internet from Edinburgh.


Cookies are small text files which are delivered onto your computer by websites that you visit. Our use of cookies is integral to both the current visitor experience and how we shape and grow our web-based services in the future.  You can read more about how we use cookies on our cookies page.


When enabled heat mapping software will record mouse clicks, mouse movements, scrolling activity.  It logs that you entered text but not the information entered. This software uses Cookies. You can read more about how we use cookies on our cookies page.


Digital Analytics & Doubleclick


Digital analytics tools such as Google Analytics and DoubleClick may be used to record anonymous user's interaction with VisitScotland websites. This data may then be used to retarget users through advertising on other websites, therefore an individual's behaviour on one of our websites may result in them being retargeted with advertising related to the pages they visited or actions they took on the site.


You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt out of our use of Analytics by visiting the Google Analytics opt-out page.


Remarketing/ Remarketing Lists for Search Ads (RSLA)


Third party vendors, including Google, use cookies to serve ads based on a user's prior visits to VisitScotland website(s).


We may also use Cookies to serve ads based on a user's prior visits to our website, as well as to develop remarketing lists for customised campaigns (Remarketing Lists for Search Ads).


Users may opt out of Google's use of cookies by visiting the Google advertising opt-out page. In addition, you may also opt out of third party vendor's use of cookies by visiting the Network Advertising Initiative opt out page.

 

5. When you provide personal data


Complaints

 

When you make a complaint to us you can do so via an online form, email, telephone, letter or at an iCentre. The complaint is logged on a computer system. A VisitScotland complaints officer will review and respond to it.


A complaint can be made anonymously. However, if you do provide personal data, we request your full name, address, telephone number and email address. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.


By giving us your personal data you consent to us processing it.  If you are a consumer, we retain personal data obtained from complaints for 5 years and then confidentially destroy it.


If you are a business, we will retain complaints as part of an ongoing business record.  We retain for 3 years after a business has ceased to work with us.  


Events for tourism businesses


When you are aware of an event that you think tourism businesses may want to attend, you may submit it using a form on our website(s). These events can include workshops, training events, seminars, conferences, and awards. Once submitted the VisitScotland team will check over the details before making it live on the site.

 

The only personal data we may collect are if the organiser provides a name, email address and telephone number. As this information is provided as part of a business activity, we consider this stakeholder data. The legal basis for collecting this data is legitimate interest. We retain for 3 years after a business has ceased to work with us.  

 

Growth Fund

 

VisitScotland supports collaborative tourism marketing projects through the Growth Fund. These projects focus on growth in the tourism sector by helping groups build their digital capability, market and measure outputs and success more effectively.

 

Applications must come from constituted groups of tourism businesses. The VisitScotland Growth Fund team will support you through the application process and provide advice around monitoring and evaluation.


When your group completes an application on the website, we consider this stakeholder data.

 

The only personal data we may collect is from the group representative making the application. This data will be a title, first name, surname, daytime telephone number and email address. This information is provided as part of business and financial activity. The legal basis for collecting and managing this data is financial legislation, and we hold onto this for as long as finance data is required.

 

Once the Growth Fund form is submitted, we hold the application files in a secure folder that only the Growth Fund Team has access to.

 

We may share your details with partner agencies to discuss what further support or funding may be available to support the project. However, we will only do this if you consent to your and your group’s data being used in this way.

 

New business form

 

We collect information from you when you want to do business with us, by completing the ‘New customer enquiry’ form on our website(s).

 

We will treat all the information you provide to us as personal data. However data provided for the purposes of publicising your tourism business may be published on a website, in a brochure, or in other marketing materials.

 

The personal data we will collect from you will be title, first name, surname, email address, mailing address and telephone. If you also provide a contact address that is different from your business address, we will treat this as personal data.

 

The legal basis for collecting data is contract. We will retain this data for seven years. If the business ceases to work with us, we will hold the data for three years afterwards.

 

We currently hold this data in a Business CRM system.

 

Themed Year Logos

 

Logos are designed every year to help celebrate and mark the year’s special theme. They are designed to be downloaded for use in your marketing collateral and communications channels by completing a form on our website(s).

 

The only personal data we may collect are if you provide a first name, surname, and email address. One of the reasons we collect this is in case there has been a breach of the brand guidelines so we know who to contact.

As this information is provided as part of a business activity, we consider this stakeholder data. The legal basis for collecting this data is legitimate interest. We will retain this information for three years after you cease a relationship with us.

 

A second reason we ask for this information is in case you would like further information and/or support about logos and themed years. We will only use the information for this purpose if you ‘opt-in’. The legal basis for collecting this data is consent. We will only retain the data until you with draw consent.

 

We anonymise the data so we can monitor logo use and review statistics.

 

VisitScotland Information Partner (VIP)

 

The VisitScotland Information Partner (VIP) programme is open to all Quality Assured businesses, as well as community groups and social enterprises at no cost.
 
We collect information from your business, community group or social enterprise when you complete the ‘VisitScotland Information Partner’ form on our website(s).

 

The legal basis for collecting data is legitimate interest. Once a business, community group or social enterprise ceases to work with us, we will hold the data for 3 years afterwards.

 

We currently hold this data in a Business CRM.


6. When you use other services (like Facebook) to interact with us

 

When you use a social media platform, details about how your personal information is held, is described within the relevant social media policy, such as Facebook or Twitter.  

 

Forms on social media

 

We use a third party provider, to manage our social media interactions.

 

If you send us a private or direct message via social media the message will be stored by our provider for 3 months and then confidentially destroyed. It will not be shared with any other organisations.

 

Our legal basis for processing this information is contract and we do so to fulfil a service to you.

 

You can sign up for enewletters via social media, please see ‘request an enewsletter’ and the terms presented in the service at the point of signup.  

 

7. When you contact us directly

 

When you phone us

 

Details of communications with you will be added to your business record on our computer system. This will be retained while a business relationship with you exists, plus an additional three years.

 

The legal basis for collecting this information is contract.

 

When you email or write us

 

When you contact us via email or letter, details of our communication with you will be added to your business record on our computer system. This will be retained while a business relationship with you exists, plus an additional three years.

 

The legal basis for collecting this information is contract.


8. When we meet in person

 

We meet businesses in order to further the ends of tourism.  We undertake grading visits,  provide business advice, and attend industry events. Information will be added to your business record on our computer system. This will be retained while a business relationship with you exists, plus an additional three years.

The legal basis for collecting this information is contract.


9. Security of your personal information


While we cannot guarantee that unauthorised access will never occur, we can assure you that we take great care in maintaining the security of your personal data to prevent unauthorised access to it, through the use of appropriate technology and internal procedures.

 

What we do to protect your information


We take a number of steps to protect your information from unauthorised access, use or alteration and unlawful destruction, including where appropriate:

  • Using Secure Sockets Layer (SSL) encryption when collecting or transferring sensitive information, such as credit card details (SSL encryption is designed to make the data unreadable by anyone but us)
  • Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access)
  • Putting in place physical, electronic, and procedural safeguards in line with industry standards.

What you should do to protect your information


As general best practice on the Internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:

  • Do not use trivial passwords (such as single dictionary words
  • Do not use the same password for multiple accounts
  • Do use very long passwords (at least 10 characters, but preferably much longer)
  • Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc
  • Do keep passwords securely (never written down, or shared with anyone) and changed periodically.

 

10. Sharing your personal information


We may have to share your personal data with the third parties set out below for the purposes set out in the table in paragraph 3 above.
 
(a) our our payment/collections service providers for services relating to our website and services to which you have subscribed to which may be handled by our payment services providers, such as, without limitation, Worldpay. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.worldpay.com/uk/privacy-policy (link is external).
 
(b) one or more of the selected third party suppliers of goods and services identified on our website to which you have specifically consented to share your personal data with for the purposes set out in such consent or to fulfill our contractual obligations. Each such third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
 
(c) our authorised data processors and service providers for the purposes of providing certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include evaluation and research agencies, billing and fulfilment partners, data analytics providers who process information on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide customer services. When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.
 
(d) our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
 
(e) to government bodies such as the Department for Digital, Culture, Media & Sport and law enforcement agencies to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies.


11. When we contact you

 

Email


We will email you to provide business advice and information. We will also contact you on transactional matters such as to pay an invoice, and to let you know that we have updated our terms and conditions.


This data will be retained while a business relationship with you exists, plus an additional three years.

 

The legal basis for collecting this information is contract.


12. When you use images


Digital Media Library
 
At VisitScotland we hold a non commercial image library for tourism related purposes. Images can only be used to promote Scotland as a tourism destination.


Once you complete the online application form, we store this data on external software, called Digital Asset Management Software. The personal data we collect is: name, email address, postal address, and telephone number.


You may decide not to provide your personal information to us. However, if you do not provide it, we may not be able to provide you with access to certain information.


We consider this stakeholder data and retain it until you cease your relationship with us. At the point, your data will be deleted. The legal basis for this data is contract.

 

Scotland is Now Toolkit

 

Once you complete the registration form for the Scotland is Now toolkit, we store this data on Brandkit (which is the software that runs the Toolkit and stores all information collected). The only personal data we collect is: email address.


We consider this stakeholder data and retain it until you cease your relationship with us. At the point, your data will be deleted. The legal basis for this data is contract.


13. When you are employed by us


When you apply


We will collect the following data from you: your name, telephone, email and postal contact details, NI number, previous and current employment history, educational background, contact details for referees and equality and diversity data and, if applicable, additional information to support any criminal reference checking.


The data will be stored, processed, used and disclosed by us in the following ways: To provide our recruitment services to you and to facilitate the recruitment process; to enable you to submit your CV and/or application form, apply online for jobs; to improve our customer service and to make our services more valuable to you (including tailoring our website and our group companies websites when you log on to enrich your personal online experience); to answer your questions and enquiries; to share with third parties where we have retained them to provide services that we or you have requested including health assessments, references and qualifications, verification of the details you have provided from third party source, psychometric evaluation or skill test; to use your information on an anonymised basis to monitor compliance with our equal opportunities policy; to carry out our obligations arising from any contracts entered into between you and us; to undertake statistical analysis of anonymised data (equality and diversity) and internal reporting through a candidate’s recruitment journey.

From time to time we will seek your consent to process, use or disclose your information for any other purpose not listed above. We reserve the right to transfer your information to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company, provided that the third party agrees to adhere to the terms of this Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and we will seek your consent.


Unsuccessful candidates’ data will be securely destroyed 12 months after the decision is made that your application has been unsuccessful adhering to the statutory requirement to retain information for a select period to allow candidates to challenge recruitment decisions. Submissions made online through JobTrain may remain accessible for up to 14 months due to candidate archiving processes. Successful candidates’ information required for employment purposes will be retained throughout your employment.

 

When you take up a post


If you take up a position in VisitScotland, we will create a personnel file relating to you. It will include sensitive data and will only be accessible to restricted staff. Once your employment has been concluded, we will retain the file for seven years and then confidentially destroy it.

 

14. Joining data and profiling


We want to provide the best possible service to you. To achieve this we, where possible, join anonymous and personal data.


When you provide personal data via a form on the website, we collect a unique ID assigned to you by Google. We use this to combine your personal information with information from Google. The information we collect from Google includes how you reached our website and your behaviour whilst on the site. This applies to visits where you submit a form, previous and future visits, if available. 


We may use this information to improve our service to you and to tailor the information we provide in future.  We may also use it to understand the success of our marketing and make improvements to our services overall.  Personal data is stored for as long as the purpose intended (see section: 'When you provide personal data').


Profiling is defined as under the General Data Protection Regulations as the automated processing of personal data to evaluate certain things about an individual.  Profiling can be part of an automated decision-making-process. Automated decision-making is making a decision solely by automated means without any human involvement. 


We may use these techniques to make the information in our emails, website or app more relevant to you. We therefore process this data in your legitimate interest.  If you do not want us to use your data in this way, please email gdpr@visitscotland.com. Likewise if you would like to see the data that we use for this purpose contact us.


15. Your rights


Under the General Data Protection Regulations, you have rights as an individual which you can exercise in relation to the information we hold about you.


You have the right to:
 
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
 
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
 
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
 
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
 
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
 
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
 
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


Read more about your individual rights on the Information Commissioner's Office website.


16. Access to personal information


VisitScotland tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making an 'right of access' request under the General Data Protection Regulations. If we do hold information about you we will:

  • Give you a description of it;
  • Tell you why we are holding it;
  • Tell you who it could be disclosed to; and
  • Let you have a copy of the information in an intelligible form.

You can request a copy of the personal data that we hold on file by sending a subject access request to gdpr@visitscotland.com.


17. Changes to this privacy policy


We keep our privacy notice under regular review. This privacy notice was last updated on 25 May 2018.


Since this policy is under regular review, you may wish to check it each time you submit personal information. If you do not agree to these changes, please do not continue to use VisitScotland websites to submit personal information. If material changes are made to the Privacy Policy, for instance affecting how we would like to use your personal information, we will provide a more prominent notice.


You can access this policy at any time through the link at the bottom of our websites and from any e-newsletters you are subscribed to.


18. How to contact us


VisitScotland tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.


This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of VS's collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.


Email us gdpr@visitscotland.com


Telephone: 0131 472 2222


Or write to:
VisitScotland
Head Office
Records Management and Data Protection Officer
Ocean Point One
94 Ocean Drive
Edinburgh
EH6 6JH

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