Privacy Policy

Better Local LImited Privacy Notice

Who are we?
BETTER LOCAL LIMITED
(“we,” “our,” “us”, “Better Local”), a company registered in Scotland (Company Number: SC704709), recognise the need for appropriate protections and management of your personal data.

When we collect and use your personal data in the way set out in this Privacy Notice, we are the controller for the purpose of Data Protection Legislation (defined below) and are responsible for your personal data.

This Privacy Notice sets out the way in which your personal data will be used by us. This Privacy Notice applies whenever we collect your personal data. For the most part this Privacy Notice refers to the activities of Better Local but where your personal data is collected by, shared with and/or used by another organisation, this is explained within the notice.

Key Terms
For the purposes of this Privacy Notice, the terms controller, processor, data subject, personal data, and processing shall have the meaning given to them in the UK GDPR.

Data Protection Legislation
means the Data Protection Act 2018 and the UK GDPR.

Personal Data is information that can be used to identify or contact a specific individual, such as a name, address, telephone number, email address, etc., and also online identifiers and location data such as IP addresses and mobile device IDs.

Special Category Data
is personal data revealing your racial or ethnic origin; political affiliations and opinions; religious or philosophical beliefs; or trade union membership; and genetic data; biometric data; data related to your health or data concerning your sex life or sexual orientation; and criminal convictions or involvement in criminal proceedings.

UK GDPR means the UK General Data Protection Regulation as defined in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018.

Websites means the whole of any part of the website controlled or operated by Better Local and located at www.local-recovery.com.

Contact Us
If you have any questions regarding this Privacy Notice you can contact us at:

Better Local Limited
Abercorn House
79 Renfrew Road
Paisley
PA3 4DA 

or e-mail us at info@local-recovery.com  

or call us at 0131 564 0119 

If you are unhappy with how we handle your personal data you can contact us using the contact details noted above and / or notify the Information Commissioner’s Office (ICO) (please see: https://ico.org.uk/concerns/ for more information). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Third party links
Please note that our websites and other digital platforms may contain links to third party websites/digital platforms which are provided for your convenience and to allow us to fulfil the objectives of a campaign or project.

Better Local is only responsible for the privacy practices of our own websites and digital platforms. We recommend that you refer to the privacy notice of each website/digital platform you visit.

Changes to this Privacy Notice
We keep our Privacy Notice under regular review and the most current version can be found on our website or requested from us on the contact details given above.

This Notice was last updated on 3 February 2022 and supersedes all previous versions.

Collecting Your Personal 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, last name or similar identifier (such as date of birth or ID).

Contact Data includes personal or business address (postcode), personal or business e-mail address and personal or business telephone numbers, social media account name, and contact preferences, date of birth, geographic location, photograph or image, and information about relationships including spouses, partners, or other family members. We may also make photo or video recordings of you where you attend our events.

Financial Data includes bank account and payment card details as well as gift aid registration details.

Technical Data includes internet protocol (IP) address, geographic location, 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. Where possible, we use aggregated data or anonymous information which does not identify individual visitors to our website.

Profile Data includes interactions and communications made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website and services and includes information about your service preferences and survey responses (where applicable).

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Health Data includes information about your health, for example any relevant medical conditions, accessibility or mobility concerns that you have and/or dietary requirements.

Employment Data includes information about your employment qualifications, and experience.

And any other data you provide to Better Local Limited.

We may from time to time collect Special Categories of Personal Data about you (this could include details about your race or ethnicity, primarily religious or philosophical beliefs, political opinions and beliefs, health, sex life, sexual orientation, political opinions, trade union membership).

We may collect your personal data in the following ways:

Direct interactions. You may give us your personal data directly by filling in our forms (online and offline), engaging with our social media accounts or by corresponding with us or by speaking with us in person, participate and/or attend one of our events, complete a survey or a questionnaire, request marketing or other communications to be sent to you.

Indirect interactions. We may also receive personal data about you indirectly from our systems, from publicly available sources and databases, and from third parties. For example:

  • Your named referees;
  • From your use of our IT systems;
  • Electoral Register and/or Electoral Commission;
  • Publicly available data such as census information and election results;
  • Occupational Health and other health providers;
  • From third parties, for example, including but not limited to, consumer checks, Companies House, terrorist activities global watch checks, security screening and recruitment agencies; and
  • Any other third party service providers that we engage in the course of business.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

  • analytics providers such as Google based outside the EU; and
  • social media platforms such as Twitter, Facebook, LinkedIn or Instagram in regards to your interactions with us through those platforms.

We may occasionally supplement your data with other publicly available information. This may include information such as your parliamentary constituency or the characteristics of your local area to inform campaigning and requests for support, to ensure our communications are relevant. We may store relevant information about you that you voluntarily share with us in our surveys or questionnaires. 

We use your personal data on the following legal bases:

  • 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 have a contract with you or are taking steps to enter into a contract with you including employment contract and relationship.
  • Where you have given your consent to the use of your data.
  • Where it is necessary for the establishment, exercise or defence of legal claims.

If we are processing Special Category Data we may also rely on the following conditions in addition to the legal bases above:

  • Where you have given your consent to the use of your data.
  • Where we are required to process your data in the public interest for the purposes of safeguarding of individuals at risk or regulatory requirements relating to unlawful acts and dishonesty.
  • Where we are required to process your data in the public interest for the purposes of equal opportunities or treatment.
  • Where it is necessary for the purposes of exercising our rights (or your rights) in the field of employment, social security, social protection law,or a collective agreement in so far as it is authorised by law.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activity Type of data Lawful Basis
Website Users

To provide you with the best experience on our website, to answer your queries and ensure our services meet the needs of our customers/supporters.

To tailor our website so that you see content relevant to you, to collect statistics, reports, responses to surveys and questionnaires and to analyse traffic patterns and related site information

To provide you with the services and/or information that you have requested.
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Aggregated
(f) Other data

We aggregate this data and it does not identify any website users (except where you contact us with a question/query). We use this for our research analysis, testing, monitoring, risk management and administrative purposes and may disclose Aggregated data to third parties for advertising, marketing and promotional purposes.
We rely on our legitimate interests in operating and managing our website and online services and answering any queries you have.

Your consent is sought for use of cookies when you access our website.
Applicants (volunteers and staff)

To review your application or CV.

To inform you of volunteering opportunities.

To provide you and your community causes with our support, share news updates about the work that Better Local are doing, and keep you up to date on our work.

To review your suitability for the role for which you have applied and comply with any regulatory or legal requirement.

To train you and provide you with support as a volunteer or staff.

Maintain records of staff and managing our employment relationship.
(a) Identity
(b) Contact
(c) Employment
(d) Health
(e) Special Category Data
(f) Profile Data
(g) Other Data
We use (a) to (e) on the basis of contract and we are legally obliged to process information about your right to work in the UK and we may ask for a copy of your ID as evidence of your right to work if we interview you after you apply to any of our job or volunteer advertisements. We are legally obliged to make reasonable adjustments for you if you have a disability.

For (d) we are requesting information in relation to your health to ensure you can attend an interview, our events and that we have made any necessary adjustments to accommodate you – when we are collecting this information we will ask for your consent.
  
Once you start volunteering/working with us we rely on legitimate interests and contract to process your information – this enables us to send you information about volunteering opportunities we think will be of interest to you, and to use your information to investigate complaints or serious incidents too. We also need to process your information to run the volunteer scheme and any events in the community. We may ask for your opinions or thoughts on matters via surveys and/or questionnaires.
Consultants/Service Providers/Suppliers

To engage with you to provide goods and/or services to us.
(a) Identity
(b) Contact
(c) Financial
Based on the contract we have with you to provide goods and/or services to us.
Purpose / Activity Type of data Lawful Basis
Supporters/Event Participants/Community Supporters/Donors
  To communicate with current and prospective supporters.
  
To provide you and your community causes with our support,  share news updates about the work that Better Local are doing, to process your donation and keep you up to date on our work.
  
To share your story/experience to promote our activities, events, raise awareness and we may ask for your feedback.
  
To register and administer your participation in events in your local area. To gather and request feedback on Better Local events and fundraising opportunities, which may be recorded.
  
To promote Better Local fundraising campaigns.
  
We welcome and encourage donations and support from others to achieve our mission. From time to time, we may contact supporters with fundraising material and communications. This might be to suggest ways you can raise funds.
  
For compliance with our legal obligations.
  
For health and safety assessments (including any requirements to record visitors for the purpose of managing the Covid-19 pandemic) or to make dietary adjustments.
(a) Identity
(b) Contact
(c) Health
(d) Financial
(e) Marketing and Communications
(f) Special Category Data
(g) Profile Data
(h) Other Data
We rely on our contract with you or on our legitimate interests for (a), (b), (c) and (d) in maintaining records, managing our donations and informing of and running events or when you sign up to our campaigns and/or our newsletters/updates. We have a legal obligation to retain some of the donation information.

We use (c) on the basis of your consent - as this is a special category of personal data.

We only use (b) to send you non-electronic forms of communication (post and live calls), based on our legitimate interest to achieve the objectives of any of Better Local’s campaigns and projects, and we will only send you digital communications (email and text) with your explicit consent or to respond to your queries via the medium you have contacted us.
  

We may ask for your thoughts and opinions via surveys and/or questionnaires. For (f) we are carrying out processing on the basis of your consent, in seeking your views on matters in surveys and questionnaires.
  
You will always have the option to opt out of any of our marketing communications at any time. Please note, if you don’t choose to receive this information, we will be unable to keep you informed of news, events or fundraising opportunities that may interest you.
Research

To communicate with current and prospective supporters, understand their views and opinions conducted via face-to-face focus groups, surveys online and by telephone.
(a) Identity
(b) Contact
(c) Marketing and Communications
(d) Special Category Data
(e) Profile Data
(f) Other Data
We rely on our contract with you or on our legitimate interests for (a), (b), (c) and (d) in maintaining records, managing our supports, gathering views, and informing of and running events or when you sign up to our campaigns and/or our newsletters/updates.

We use (d) on the basis of your consent - as this is a special category of personal data.

Where we are relying on contractual obligation and/or legal obligation as a legal basis for collecting and processing your personal data, we will not be able to offer our services to you if you choose not to provide us with this information or not be able to perform the contract we have entered into with you.

Marketing  
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.

We may use your contact details and any enquiry information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

You will receive marketing communications from us only if you have requested information from us and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a volunteer position or contacted us to enquire about our services, donated to our campaigns or other transactions.

Research and profiling
We carry out research and analysis on our supporters, donors and volunteers, to determine the success of campaigns and appeals, better understand behaviour and responses and identify patterns and trends. This helps inform our approach towards campaigning and make Better Local a stronger and more effective organisation. Understanding our supporters, their interests and what they care about also helps us provide a better experience (e.g. through more relevant communications). 

In order to better target our communications, we may use data from publicly available third-party sources to assess your political and community interests and whether you may be inclined to get involved in our campaigns. We or our trusted partners also may use profiling and screening techniques to ensure that the communications we send are relevant to you. This allows us to provide an improved experience for our supporters.

When building a profile of our supporters we may analyse geographic, political and demographic information, media coverage, previous charitable contributions, previous research responses, lifestyle, hobbies/interests, information associated with your postcode, estimate of age, as well as your online behaviour to better understand your interests so we can contact you with relevant messages. An example of this would be looking at your location so we can share information about relevant campaigns, projects, events or volunteering opportunities in your area and connect you with like minded people.  

We may profile supporters in terms of financial and practical support. For example, we may keep track of the amount, frequency and value of each person’s support with Better Local. This information helps us to ensure communications are relevant and timely. 

We may aggregate and anonymise personal data so that it can no longer be linked to any particular person. This information can be used for a variety of purposes, such as recruiting new supporters, or to identify trends or patterns within our existing supporter base.  This information helps inform our actions and improve our campaigns, services and materials. 

How Do We Keep Your Personal Information Up-To-Date?
Please contact us at the contact details above as soon as possible after there is any change to your personal details, including your contact details.

Do We Share Your Personal Data?
Unless stated otherwise, your personal data will be kept secure within Better Local using appropriate technical controls to protect your details. We will not sell, trade or lease your personal data to others. As an exception to the above, please note that your personal data, including political opinion data, will be made publicly available where this is required by law such as in the case of donors whose donations are above a certain threshold.

The following third parties may have access to your personal data and, in some circumstances, your special category data (if applicable):

  • Our relevant linked groups and organisations based on personal data you provide to us in our communications so that they can send you the communications;
  • Any other person who is authorised to act on your behalf;
  • Volunteers working on behalf of Better Local;
  • Social media providers;
  • IT, software and communications service providers and other technology providers, document processing service providers, document and information storage providers some of whom may store personal data in cloud based data centres. We engage several IT service providers.
  • Our server provider, who provide our subscriptions and hosting services, who is currently Google Workspace whose servers are located in the EEA and in non-EEA locations;
  • Regulators, government departments, law enforcement authorities, tax authorities, police, regulatory bodies or legal advisors and insurance companies including the Electoral Commission;
  • Our digital marketing partners who may process data in the EEA and outside the EEA, including in the USA and/or Canada;
  • Our online survey development company, Momentive.ai. Please note that personal data collected and shared with Momentive.ai will be stored in the USA;
  • Our service providers who help us in general advertising marketing, promotional, fundraising activities (e.g. organising assisting us with our events, issuing of updates / bulletins, events and/or business development and networking opportunities);
  • Our third party payment processing provider who assists us in providing payment services for donations;
  • Any relevant dispute resolution body or the courts;
  • Persons in connection with any sale, merger, acquisition, disposal, reorganisation or similar change in our business; and
  • Third parties providing a reference about you, where you have agreed that we can request this or have asked us to request it.

Please note this above list is non-exhaustive and there may be other examples where we need to share personal data with other parties in order to provide our services.

How we protect your information 
We have in place administrative, technical and physical measures designed to guard against and minimise the risk of loss, misuse or unauthorised processing or disclosure of the personal data that we hold. 

As a condition of employment, our employees are legally obliged to respect the confidentiality of your data as are any companies acting as approved data processors for Better Local. 

Cookies
In common with many other website operators, we use standard technology called “cookies” on our websites. Please see our cookies policy explaining the cookies we use on our websites. 

International transfers
Many of our external third parties, processors and sub-processors are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK or EEA. If you live or work outside of the UK or the EEA, we may need to transfer your personal data outside of the UK or the EEA to correspond with you. We also may transfer data outside the UK or the EEA where our service providers host, process, or store data outside the UK or the EEA. Where we do this, we will ensure that the transfer is to a country covered by an adequacy decision of the European Commission or the Secretary of State and/or the ICO or is otherwise made in circumstances where we have put appropriate safeguards in place to protect your data in accordance with the Data Protection Legislation (e.g. using standard contractual clauses, etc.).

Data Retention
We will not hold your personal information for any longer than is necessary for the uses outlined in the Notice, unless we are required to keep your personal data longer to comply with the law and any regulatory requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For example, we would store your personal data until the relevant project in the area, in relation to which we collected your personal data, is complete but you may sign up to another project and data may be retained for longer, or for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

Details of retention periods for different aspects of your personal data are available in our Retention Policy which is available upon request.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Data Subject Rights 
You have certain rights under the Data Protection Legislation which can be exercised by contacting us at:

Better Local Limited
Abercorn House
79 Renfrew Road
Paisley
PA3 4DA 

Phone   0131564 0119

Email    info@local-recovery.com

including:

  • The right to access the personal data held about the you by making a subject access request in accordance with the Data Protection Legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive;
  • The right to have your personal data rectified if it is inaccurate or incomplete;
  • The right to request to have your personal data deleted in certain specific circumstances as set out in the Data Protection Legislation;
  • The right to request to restrict the processing of your personal data in certain specific circumstances as set out in the Data Protection Legislation;
  • The right to ask us notto process your personal data for marketingpurposes or for purposes based on our legitimate interests in certainspecific circumstances as set out in the Data Protection Legislation;
  • The right to ask us to not undergo automated decision making; and
  • Where you have provided consent, the right to withdraw such consent at any time.

Further details about your rights can be found on the ICO’s website at https://ico.org.uk/

There are some exemptions to the above rights that are permitted under the Data Protection Legislation. If you have any queries as to what these are then please get in touch.

Please note that if you choose to exercise your rights to have personal data restricted or deleted, then we may not be able to provide you with a full service. 

We may need you to provide identification in order to comply with your request to exercise your rights. Once we have received your information request, and your identification, we will respond within the required timescales unless a permitted exemption applies.