2. Important information and who we are
Full name of legal entity: The Lotteries Council
Postal address: 1 Dechmont Gardens, Uddingston, G71 6DR
3. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where no person can be identified (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 your first name, maiden name, last name, title, position held, username or similar identifier, date of birth, type of registration, name of organisation you are affiliated with or employed by and registered company or charity number.
- Contact Data includes registered office, billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment details collected by debit mandates, online payment or cheque.
- Transaction Data includes details about subscription 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.
- Profile Data includes your username and password, type of registration, membership details, preferences, feedback, information supporting your application and survey responses.
- Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
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.
4. How is your personal data collected?
We use different methods to collect data from and about you including through direct interactions. You may give us your Identity and Contact and Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- become a member;
- create a member login on our website;
- subscribe to our updates and publications;
- request marketing to be sent to you; or
- give us feedback or contact us.
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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
5. How we use your personal data and basis of processing
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to process your membership subscription and to send you information and advice from time to time on our activities.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have legitimate interests in conducting and managing the Lotteries Council organisation to enable us to give our members the best information, advice and support and to represent their interests effectively. Our objectives are to promote the views and aspirations of those connected with fundraising lotteries and competitions; and to promote co-operation between people and organisations engaged in activities connected with lawful lotteries and competitions. It is necessary for us to process your personal data to pursue these legitimate interests.
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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
6. If you fail to provide personal data
Where we need to collect personal data by law, or under our internal rules and procedures, and you fail to provide that data when requested, we may not be able to provide the membership rights, facilities and support you signed up to receive.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you as a member of our organisation. This is how we decide which membership services and promotional materials may be relevant for you (we call this marketing). We will get your express opt-in consent before we share your personal data with any other third party company for the purposes of marketing.
You will receive marketing communications from us if you have requested information from us or purchased a membership and have not opted out of receiving marketing materials.
8. Third party access to data
We may share your personal data with certain third parties set out below:
- Third party suppliers who provide services to us; and
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our sub-processors or third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.
We use the services of Mail Chimp to communicate electronically with our members. All information is held on secure servers. https://mailchimp.com/about/security/
We will also disclose your personal information to third parties:
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to protect the rights, property or safety of The Lotteries Council, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Our conference and regional meetings are managed by Eventologist (https://www.eventologists.co.uk/). Information is used by Eventologists to enable them to interact with you as a member.
9. Opting out
Where you opt out of receiving marketing messages, the opt-out will not apply to personal data you provided to us as a result of a membership purchase.
10. Change of purpose
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
11. Third-party links
The following cookies are used on our website https://www.lotteriescouncil.org.uk/.
|[Randomly generated key]||Created by Joomla(website system) and stores the session id of the user, it’s also used to prevent automated attacks against forms||Yes|
|_ga||Google analytics, *no personal information is stored||Yes, unless we remove google analytics from the website|
|NID||reCAPTCHA on contact form||Yes|
|jsCookieCheck||Remembers the user choice of closing agreeing to the cookie message||Yes|
13. International transfers
From time to time we may use data processors based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; and
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
At the date of our policy our supplier, MailChimp, based in Atlanta, USA, processes personal data outside the EEA to provide us with services. Mail Chimp operates under the Privacy Shield. We only provide Mail Chimp with the email addresses of our members and do not provide Mail Chimp with any other data.
A link to its data processing addendum is attached below:
14. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We will notify you and any applicable regulator of a breach where we are legally required to do so.
Our membership database is securely stored on Microsoft One Drive with a strict access policy. More information is available here - https://products.office.com/en-gb/onedrive-for-business/online-cloud-storage
In addition, we limit access to your personal data to employees, agents, sub-processors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
15. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event of a cancelled membership we may contact you or your organisation up to six months following the date of cancellation by telephone or post. We will confirm that the cancellation is correct and give organisations the opportunity to update or review payment information if they wish to re-join.
16. Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
- Request access to your personal data;
- Request correction of your personal data;
- Request erasure of your personal data;
- Object to processing of your personal data;
- Request restriction of processing your personal data;
- Request transfer of your personal data; and
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.