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SRUC Privacy Notice

Who we are

SRUC, Scotland’s Rural College provides services either

  1. directly (for grant funded, non-commercial  work) or
  2. through its associate company, SAC Commercial Ltd (for commercial services)

Our registration information is noted below:

  • SRUC - Registered in Scotland No SC103046 VAT Registration Number GB 435 8828 17
  • SAC Commercial Ltd. - Registered in Scotland No SC148684 VAT Registration Number GB 435 8828 17
  • Registered address – SRUC, Peter Wilson Building, Kings Buildings, West Mains Road, EDINBURGH, EH9 3JG

SRUC receives grant-in-aid from the Scottish Government in support of certain of its activities, particularly those with public good implications.

SRUC is a Data Controller for the purposes of data protection law.  We are registered with the Information Commissioner’s Office under the following registration numbers:

  • SAC Commercial Limited No Z696983X
  • SRUC No Z7601788

How to contact us

If you have any questions about our Privacy Notice or the information we collect or use about you, please contact;

Contact Type 
Details
By e-mail
By phone
+44 131 535 4129
By post
The Data Protection Officer
SRUC, Scotland’s Rural College
Peter Wilson Building
Kings Buildings
West Mains Road
Edinburgh, EH9 3JG

Purpose of this Privacy Notice

SRUC is committed to protecting your personal data and your privacy.  This notice contains important information about:

  • what personal details we collect
  • what we do with that information
  • who we may share it with and why and
  • your choices and rights when it comes to the personal information you have given us

It is important that you read this Privacy Notice together with any other notice we may provide on specific occasions when we are collecting or processing personal data about you.

For example – when producing data for Research purposes you will be issued with additional information such as a covering letter.

This is so you are fully aware of how and why we are using your data. Any other notice will supplement (not override) this Privacy Notice.

The Structure of this Privacy Notice

Our Privacy Notice contains sections that apply to different categories of activities we undertake, and the people we deal with as part of this work:

  1. Academic & Student Services
  2. Consulting & Research
  3. Veterinary, Analytical & Health Planning Services
  4. Other services. For example - our Golf Clubs and Wigwam holidays or at our Conferences and Shows       

For details about what personal data we obtain and how we use it, please consider which of the categories apply to you.  It is possible that more than one category will need your consideration.

Please also refer to specific section that will expand on certain topic mentioned throughout the document.  For example – Cookies and Lawfulness of Processing.

All other sections of this Privacy Notice apply to everyone (all people with whom we interact, in our day to day business).

 

Academic & Student Services

How will we use your information

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

Purpose
Lawful Basis
(Lawfulness of processing)
Further detail regarding Legitimate interest (where relevant)
Student Applications, Student Administration, Student Funding, Safeguarding, Compliance with Legal or Regulatory requirements, Alumni Services
Consent
Legal Obligation
Performance of Contract
Legitimate Interest
Enables us to ensure your student experience is as efficiently conducted as possible. 
Without it we would not be able to process and progress students through their chosen courses of study
To provide the specific service or support not covered by the above
Consent
Performance of Contract
This information would only be collected with the express purpose of ensuring the student experience is as efficient as possible for both student and the college.
It may also enable us to communicate with and provide information to essential external agencies relevant to your student experience.

Information we collect and use

This can include:

Data Type
Examples
Identity Data
Name
Date of birth
Contact Data
Home and/or business address
Email addresses
Telephone numbers
Financial Data
Bank account and sort code
Transactional Data
Correspondence
CCTV - visual images collected via closed circuit television on visiting our campuses
Electronic Data
Cookies (e.g.  for website functionality)
Note – please see the ‘Cookies’ section of this document for further details
Third Party Data
Joint applicants
Funding information
Special Category Data (or Sensitive Personal Data)
Ethnicity
Religious beliefs
Equality information such as religious beliefs, gender identity, sexual orientation.
Criminal Data
Criminal Convictions or offences (e.g. Fraud, Modern Slavery)

Special Category Data (or Sensitive Personal Data) will only be collected and used where there are legitimate grounds for it to be collected or if it is required for example - to provide any special needs that you have identified to us in your relationship with SRUC.

Whilst Criminal Data is not classed as Special Category Data, it is reserved under the same rights and will only be processed in line with the appropriate official authority or where authorised by law.


Consulting & Research Activities

How will we use your information?

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information as follows:

Purpose
Lawful Basis
(Lawfulness of processing)
Further detail regarding Legitimate interest (where relevant)
To conduct research in land based and related disciplines including for example agriculture, animal & veterinary sciences, rural economy and environment
Consent
Performance of Contract
Legal Obligation
Legitimate Interest
Consent for personal data from individuals, companies and others to enable that research to gather data and information, depending on the nature and purpose of that research
To protect our client information
Legal Obligation
Performance of Contract
Legitimate Interest
 
To provide the specific product or service you have requested
Consent
Performance of Contract
 
To send you information about products and services offered by  SAC Commercial Ltd and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
Consent
Legitimate Interest
 
To pursue commercial objectives of running our business effectively and profitably
To send you information of key importance to your business, such as Animal or crop information.
Legitimate Interest
Legal obligation
Public good interest
To ensure you have appropriate information to safeguard your business, animals or crops
In order to manage our relationship, including;
  • Managing payments/fees
  • Debt recovery
  • Complaints
  • Notification of changes to our Privacy Notice
Performance of Contract
Legal obligation
Legitimate Interest
To exercise our financial rights under contract.
 
To inform you of your legal rights
In order to meet our legal or regulatory obligations or establish and protect the legal rights of our Customers and our organisation
Performance of Contract
Legal obligation
 
To improve and develop our services
Legitimate Interest
 This would include customer surveys, to gain valuable Customer insight in order to improve our service and become more efficient, and aggregating and anonymising personal data

Information we collect and use

This can include:

Data Type
Examples
Identity Data
Name
Date of birth
For Sole Traders:
  • BRN
  • Holding Number
Contact Data
Home and/or business address
Email addresses
Telephone numbers
Financial Data
Bank account and sort code
Transactional Data
Correspondence
CCTV - visual images collected via closed circuit television on visiting our campuses
Electronic Data
Cookies (e.g.  for website functionality)
Note – please see the ‘Cookies’ section of this document for further details.
Third Party Data
Joint applicants
Funding information
Special Category Data (or Sensitive Personal Data)
Ethnicity
Religious beliefs
Equality information such as religious beliefs, gender identity, sexual orientation.
Criminal Data
Criminal Convictions or offences (e.g. Fraud, Modern Slavery)

Special Category Data (or Sensitive Personal Data) will only be collected and used where it’s needed to undertake relevant research, provide the product or service you have requested or to comply with our legal obligations. 

Whilst Criminal Data is not classed as Special Category Data, it is reserved under the same rights and will only be processed in line with the appropriate official authority or where authorised by law.

Anonymised Aggregated Data - We also collect, use and share anonymised aggregated data such as statistical or demographic data for any purpose. Aggregated anonymised data may be derived from your personal data or third party personal data you provide to us but is not considered personal data in law as this data does not directly or indirectly reveal your identity or the identity of a third party. However, if we combine or connect anonymised 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. Where we anonymise your personal data or third party personal data you provide to us we do so on the basis of our legitimate interests in pursuing business aims and objectives. 


Veterinary, Analytical & Health Planning Services

How will we use your information?

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information as follows:

Purpose
Lawful Basis
(Lawfulness of processing)
Further detail regarding Legitimate interest (where relevant)
To participate in animal health related schemes such as:
  • Premium Cattle Health Scheme (PCHS)
  • Sheep & Goat Health Scheme (SGHS) and
  • Premium Assured Strangles Scheme (PASS)
Consent
Legal Obligation
Legitimate Interest
Public Interest
 
To provide analytic and diagnostic services
Consent
Legal Obligation
Legitimate Interest
 
To participate in, and receive, information relating to animal disease surveillance programmes
Consent
Legal Obligation
Legitimate Interest
Public Interest
 
To provide Continuous Professional Development services (CPD)
Consent
Legitimate Interest
Performance of Contract
 
To provide the specific product or service you have requested
Consent
Performance of Contract
 
To send you information about products and services offered by SAC Commercial Ltd and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
Consent  
Legitimate Interest
To pursue commercial objectives of running our business effectively and profitably
To send you information of key importance to your business. Such as Animal Health information.
Legitimate Interest
To ensure you have appropriate information to safeguard your business or animals
In order to manage our relationship, including;
  • Managing payments/fees
  • Debt recovery
  • Complaints
  • Notification of changes to our Privacy Notice
Performance of Contract
Legal obligation
Legitimate Interest
To exercise our financial and legal rights under contract
In order to meet our legal or regulatory obligations or establish and protect the legal rights of our Customers and our organisation
Performance of Contract
Legal obligation
 
To improve and develop our services
Legitimate Interest
To gain valuable Customer insight in order to improve our service and become more efficient

Information we collect and use

This can include:

Data Type
Examples
Identity Data
Name
Farm or Business Identifiers
 
Contact Data
Home and/or business address
Email addresses
Telephone numbers
Financial Data
Bank account and sort code
Transactional Data
Correspondence
CCTV - visual images collected via closed circuit television on visiting our campuses
Electronic Data
Cookies (e.g.  for website functionality)
Note – please see the ‘Cookies’ section of this document for further details.
Third Party Data
Joint applicants
Funding information
Special Category Data (or Sensitive Personal Data)
 
Racial or ethnic origin
Political, religious or philosophical beliefs
Criminal Data
Criminal Convictions or offences (e.g. Fraud, Modern Slavery)

Special Category Data (or Sensitive Personal Data) will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations. 

Whilst Criminal Data is not classed as Special Category Data, it is reserved the same rights and will only be processed in line with the appropriate official authority or where authorised by law.

Anonymised Aggregated Data - We also collect, use and share anonymised aggregated data such as statistical or demographic data for any purpose. Aggregated anonymised data may be derived from your personal data or third party personal data you provide to us but is not considered personal data in law as this data does not directly or indirectly reveal your identity or the identity of a third party. However, if we combine or connect anonymised 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. Where we anonymise your personal data or third party personal data you provide to us we do so on the basis of our legitimate interests in pursuing business aims and objectives.


Personal Data to facilitate use of other commercial services our Golf facilities, Wigwam holidays or to follow up as a result of Conferences and Shows

How will we use your information?

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information as follows:

Purpose
Lawful Basis
(Lawfulness of processing)
Further detail regarding Legitimate interest (where relevant)
To protect Client information
Legal Obligation
Legitimate Interest
 
To provide the specific product or service you have requested
Consent
Performance of Contract
 
To send you information about products and services offered by SAC Commercial Ltd and / or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
Consent
Legitimate Interest
To pursue commercial objectives
To send you information of key importance to you or your business such as CPD or conferences.
Consent
Legitimate Interest
To ensure you have appropriate information to safeguard yourself or your business
In order to manage our relationship, including;
  • Managing payments/fees
  • Debt recovery
  • Complaints
  • Notification of changes to our Privacy Notice
Performance of Contract
Legal obligation
Legitimate Interest
To exercise our financial  and legal+
 rights under contract
In order to meet our legal or regulatory obligations or establish and protect the legal rights of our Customers and our organisation
Performance of Contract
Legal obligation
 
To improve and develop our services
Legitimate Interest
To gain valuable Customer insight in order to improve our service and become more efficient
 

Information we collect and use

This can include:

Data Type
Examples
Identity Data
Name
date of birth
For Sole Traders:
BRN
Holding Number
Contact Data
Home and/or business address
Email addresses
Telephone numbers
Financial Data
Bank account and sort code
Transactional Data
Correspondence
CCTV - visual images collected via closed circuit television on visiting our sites
Electronic Data
Cookies
Note – please see the ‘Cookies’ section of this document for further details.
Third Party Data
Joint applicants
Funding information
Special Category Data (or Sensitive Personal Data)
Ethnicity
Religious beliefs
Equality information such as religious beliefs, gender identity, sexual orientation.
Criminal Data
Criminal Convictions or offences (e.g. Fraud, Modern Slavery)

Special Category Data (or Sensitive Personal Data) will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations. 


GENERAL INFORMATION

How is your personal data obtained?

 We may collect your personal information directly from you, or from a variety of sources, including:

Source Type
Examples
Direct Interactions with you
Post, email, social media
Meetings
Application data
Application forms
Registering for an event, training or webinar session
Research
Research Survey participation / workshops
On-line Services
Website
Mobile device applications (‘Apps’)
Third parties
Vet Practices
Authorised Sub Contractor details Professional Body such as the Scottish Government (Farm Business Survey)
Publicly available sources
Business directories
Public bodies such as the Electoral Register

Who do we share your personal data with?

We may share your information with third parties for the reasons outlined in ‘how will we use your information?'  These include:

Third Party Example
Examples / Additional Information
Scottish Government
 
Funding Bodies
 
Higher Education Statistics Agency (HESA)
 
Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers
Research, agricultural, consultancy or technology companies or organisations.
 
Regulators and Supervisory Authority
Information Commissioner’s Office (ICO)
Law enforcement, credit and identity check agencies for the prevention and detection of crime
 
Third Party Example
Examples / Additional Information
HM Revenue & Customs (HMRC)
Processing of tax matters such as VAT
Other UK Government or EU agencies such as the (European Union (EU), European Economic
Agencies (EEA) and European Free Trade Association (EFTA)
 
Project Collaborators
 

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

International Transfers

The majority of your information is processed in the UK and European Economic Area (EEA).

However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States, New Zealand and India.

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.

How long we keep your information

We will keep your personal information only where it is necessary to provide you with our products or services, or to undertake Research/Consulting activities according to the length of contract and specified periods of time (as specified in the contract or associated collaboration agreement) thereafter regarding results and outputs.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Automated Decision Making or profiling

We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:

  • Tailoring products and services e.g. placing you in groups with similar customers to make decisions about the products and services we may offer you to help meet your needs
  • When designing and enhancing our online services to help meet your requirements for ongoing guidance and support

Accuracy of Data

It is important that the personal data we hold about you is accurate and up to date.  Please keep us informed if your personal information changes during your relationship with us.

Failure to provide information

If you do not wish us to collect and use your personal information in the ways documented, it may mean that we will be unable to provide you with our products or services.

Lawfulness of Processing

Processing shall be lawful only if and to the extent that at least one of the following applies:

  1. The Data Subject has given consent to the processing of his or her personal data for one or more specific purposes;

Processing is necessary for:

  1. the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
  2. compliance with a legal obligation to which the controller is subject;
  3. in order to protect the vital interests of the data subject or of another natural person;
  4. for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
  5. for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which required protection of personal data, in particular where the subject is a child.

Your individual rights as a Data Subject

You have several rights in relation to how SRUC uses your information.  These are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a subject access request (SAR).

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

You can ask for your information to be deleted or removed if there is not a compelling reason for SRUC to continue to have it.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services.  In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.

Right to object

You can object to SRUC processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

Rights related to automatic decision making including profiling

You have the right to ask SRUC to:

  • give you information about its processing of your personal information
  • request human intervention or challenge a decision where processing is done solely by automated processes
  • carry out regular checks to make sure that our automated decision making and profiling processes are working as they should

If you wish to exercise any of these rights, please contact us using the details provided in the ‘How to Contact Us’ section.  We may need to request information of you to confirm your identity and ensure your right to access any personal data requested.  We may also need to contact you to ask for further information relating to your request to allow us to respond in a timely manner.

You will not normally have to pay a fee for any request however, we may charge a reasonable fee in circumstances such as repetitive or excessive requests for information.  We may also refuse to comply with a request in these type of circumstances.

 

How to make a subject access request (SAR)

An individual has the right to access their personal information. Please note that if your enquiry is concerned with general information (and not information personal to you), then a Request for Information under the Freedom of Information (Scotland) Act is appropriate.

Individuals can request their information by emailing the Data Protection Office (contact below).

SRUC will respond to a SAR within 30 days and will inform you if, for any reason, it is anticipated that the response to the SAR will take longer to fulfil.

All SARs will be treated in the strictest confidence and will only be processed by authorised staff in relevant departments.

Only information which is considered to be personal data will be released under a SAR. The anonymity of other individuals or other information which is not considered to be personal data may be protected, as appropriate, by redaction or omission in accordance with the DPA.

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please Contact the data protection officer, details below:

Data Protection Officer:
Email: dpo@sruc.ac.uk

Address:  Scotland’s Rural College (SRUC), Peter Wilson Building, Kings Buildings, West Mains Road, Edinburgh EH9 3JG
Tel: 0131 535 4432

If you are still unhappy, you can complain to our Supervisory Authority, the Information Commissioner’s Office. Their contact details are also below:

Information Commissioner's Office:
45 Melville Street
Edinburgh
EH3 7HL
Tel: 0303 123 1115
Email: scotland@ico.org.uk

Changes to this Privacy Notice

We may need to make changes to our Privacy Policies; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know.

This version of our Privacy Notice was last updated June, 2018.

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A cookie is a small file – it’s saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example - they will remember you've visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don't have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and market our products and services. They also help us track sales.

Persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire).

Session cookies - these expire when you close your web browser.

SRUC operates many different websites, where we use, store and process your information in a way that is specific to that application. As a consequence we have many different cookie policies and these can be accessed by clicking on the ‘Disclaimer’ link at the foot of each webpage.

Glossary of Terms

Processing - any action taken against personal data, automated or otherwise.  This can include collecting, recording, updating, storing or erasing.

Personal Data - information relating to an identified or identifiable natural person through information such as a name, identification number, location data, genetic, or social identity.

Special Category Data (or Sensitive Personal Data)  - information about racial or ethnic origin, health, sexual orientation or sex life, political, philosophical or religious beliefs, trade union membership and genetic or biometric data. Note - Criminal data is not classed as ‘special category’ data.  It’s categorised in its own right.

Data Controller - determines the purpose for which, and the manner in which, personal data is to be processed.

Data Subject - the person to whom the personal data relates.

Profiling - analysing or predicting patterns of data in relation to areas such as location or behaviour.

Legitimate interests - means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  

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