Introduction Advice Direct Scotland (ICO Registration Z9035412) (“ADS”) takes your privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries you may have about your personal data.
If you contact us through the Home Heating email address, or use services provided through https://www.homeheatingadvice.scot, the controller of your data will be ADS.
Our personal information handling policies and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC), the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.
Statement of Policy As a responsible and ethical organisation, we recognise that we have an obligation to conduct our business activities with due skill care and diligence in a way which maximises the positive impact on our workforce, on our community and on our environment.
As such we are committed to the establishment, development and continuous improvement of business strategies, and their associated processes and procedures, which reflect our core values in direct alignment with our sense of corporate social responsibility.
What information do we collect? We collect and process personal data about you when you interact with our advisers or automated services. The personal data we process includes: • Name • Address • Contact telephone number • Email address • Energy services used • Meter type • Energy supplier • Energy account number • Supplier bank account number and sort code • Notice if household is located on remote island • Household details: • Any over 75’s • Average bill costs • Effect of COVID-19 on income • Disability within household (requires statement of proof) • Ill health within household (requires statement of proof) • Confirmation that applicant has been provided with relevant advice • Current fuel debt • Next estimated fuel bill
Under the situation where ADS is acting as the referral partner for your application, we will also require and collect evidence of your circumstances. Where your referral partner is a third-party, the third-party will collect and store your evidence, and ADS will not store it.
What is the source of this information? We collect this information directly from you, our personnel and through referral from selected partners, including Home Energy Scotland.
How do we use this information and what is the legal basis for this use?
We process the data listed above for the following purposes:
to assist you in your enquiry to provide relevant and applicable guidance, advice and information
(GDPR, Article 6(1)(f)) – We need to process your data to provide you with our services
to administer your application
Legitimate Interests (GDPR, Article 6(1)(f)) – We need to process your data to provide you with this service
protecting ADS’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation)
With whom and where will we share your personal data? Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws.
How long do we keep your personal data? We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
If you contact us through any of our services, we will keep your information for as long as is necessary to administer your application and for 6 years after the application is completed if the application is successful, and for 6 months if the application is unsuccessful.
We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require ADS to hold certain information for specific periods other than those listed above.
How we keep your data secure? As a controller of personal data, we have in place appropriate technical and organisational measures to ensure we implement the data protection principles outlined.
Our approach to data protection is monitored by a core team involving both Senior and Junior Management. Guided by our ISO/IEC 27001:2013 accredited Information Security Management System and delivered by all personnel, our data protection approach is designed to ensure that our operations are resilient. All data we hold is stored in Tier 3 and Tier 4 Data Centres with multiple redundancies and extremely strict access requirements, within the European Economic Area (“EEA”).
If any personal information is stored on a third party, cloud-based solution, we ensure that the third party complies with data protection principles when processing your data.
What are your rights in relation to your personal data? If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.
You also have the right, with some exceptions and qualifications, to ask us to providea copy of any personal data we hold about you.
You have a right to be “forgotten”. You can ask us to delete all personally identifiable data stored about you.
Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.
If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) if you object to the use of your personal data and we don’t have a good reason to continue to use it; or (d) if we haven’t handled your personal data in accordance with our obligations.
Cookies help us track various aspects of user visitations to our website. This includes the length of a user visit, their geographic location and patterns of user navigation on our site.
You can switch off cookies on your computer, although this may result in a loss of functionality when accessing our website.
Therefore, we strongly advise that you read the privacy notices of other sites, even if they are accessed using links from our website.
Advice Direct Scotland ensure that this policy is kept under regular review. Any updates or amendments to the document will be posted on our website.
Where can you find more information about ADS’s handling of your data?
If you have any outstanding questions or requests regarding this policy or our privacypractices in general, you can contact us by email through this website. Alternatively, you can write to us at:
Data Protection Officer Advice Direct Scotland Mercantile Chambers 39 – 69 Bothwell Street Glasgow G2 6TS
If you are not happy with our response or require further information regarding data processing rules and regulations, you can contact the Information Commissioner’s Office: https://ico.org.uk/.
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