Privacy Information Notice 

About this Notice
We hope you will take the time to read this Notice carefully.
This notice provides you with the information necessary to understand what Personal Data we collect, why we collect it and how we use it. 
Our Products and Services
Scottish Business Network is an independent international membership organisation for Scottish entrepreneurs and business leaders.  Scottish Business Network was created to facilitate greater communication, connectivity and support within the international Scottish business community.

The aim of Scottish Business Network is to create the largest network of Scottish business leaders in the world, making us the go-to network for businesses with the passion and ambition to export goods and services from Scotland.  In addition to hosting regular events, Scottish Business Network proactively assist and support Scottish based companies to expand internationally.

Data Controller
For the purposes of Data Protection laws, the Scottish Business Network is the Data Controller of Personal Data covered by this Notice.

You may contact Christine Esson (christine@sbn.scot) about all issues related to this Policy, your Personal Data and to exercise your rights under Data Protection laws. 

Why you should read this Policy
The Scottish Business Network (we, us or our) takes the privacy of its visitors, members and clients,(you, you or your) very seriously. We ask that you read this policy carefully because it contains important information about how we collect and use your personal data. 
Our Commitments
Transparency
We are committed to you understanding and controlling the processing of your Personal Data. 
Security
We are committed to maintaining and enhancing the privacy and confidentiality of your Personal Data. We take various steps to protect the information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.
What - Personal Data We Collect 
We collect and processes different types of personal data. There are three basic categories of personal data we collect:
•	Personal Data you give us
•	Personal Data we get when you use our Product(s)
•	Personal Data we get from third parties in relation to the Product(s)

Personal Data you give us 
As part of the sign up process to become a member of the Scottish Business Network, we collect the following Personal Data about you: Name, email address, your Location and Linkedin Profile.
This personal data is captured as it is necessary to allow our network members to interact with each other on our site.
If you have consented to marketing, personal data may also be disclosed to other Recipients including Business Partner, Business Affiliates and Third Parties for the purposes of providing information on our products, services and offers that may be of interest to you.
Information we get when you use our services(s)
In some instances, as part of our consulting services, we may gather Personal Data from our client organisations. 
The reason we capture this data is to assist us in supporting your business development.

Information we get from Third Parties in relation to the Services
As part of our membership sign up protocol, it is a requirement that we gather Personal Data on our members. In additon, we may indirectly capture additional Personal Data about our members from third parties with whom you have placed your Personal Data.
The reason we capture this data is in order to assist us in supporting your business development . 

Who - Sharing Your Personal Data
In support of our business operations and to further business growth, we may share information about you with the following Recipients:
•	Business Partners:	
Much of the interaction that occurs between our members will occur through our Business Partner, Very Connect. This involves the exchange of your Personal Data, for the purposes of setting up your profile. It is a requirement from the proper functioning of the Scottish Business Network that we do so and, is done in the course of our legitimate business.		
•	Third Parties: 
We take the protection of your data extremely seriously. Accordingly, we do not share any of your Personal Data with any third parties.

How - Using your Personal Data
We comply with the EU General Data Protection Regulation and UK Data Protection Legislation. We only collect, utilise and share personal data in strict adherence with Data Protection laws and principles. Your personal data has only been collected, utilised or shared by Scottish Business Network if:
•	you have consented to the processing
•	the processing is necessary for the performance of (or entering into) a contract
•	the processing is a result of an existing legal obligation to which we are subject
•	the processing is in your vital interests
•	the processing is in the public interest
•	the processing is in our legitimate interests

Your Consent 
In certain situations, we may obtain, collect and process your Personal Data to send you marketing communications about our offers, services and products. We will only send you these materials if you have consented and in accordance with your preferences for receiving marketing communications.
You have the right to withdraw your consent at anytime for any processing activities that you have consented to. 
Contractual Necessity
In order for us provide you with the Product(s) you have requested, it will be necessary for us to capture Personal Data to process your request. 
To fulfil the contractual obligations between you and us, it is also necessary to process Personal Data in order to perform the contact.
In this regard, we may use Personal Data to process your application and to liaise with you about this. We also need to administer contracts and agreements between you and us in relation to the Product(s).
Legal Obligations
We obtain, collect and process your Personal Data in order to comply with all our legal obligations.
Your Vital Interests
We may process Personal Data where it is deemed to be in your vital interests. This is an extremely rare circumstance for processing Personal Data and usually only occurs when essential for the life of the data subject or that of another. 
Our Legitimate Interests
We may process Personal Data where it is within our legitimate interests to do so. We process Personal Data on this basis for financial and statistical analysis
Where we process your Personal Data on this basis for direct marketing (including profiling related to direct marketing), you have a right to object to us processing your information. Your right to object is detailed below in this policy and can be exercise at anytime, free of charge, where applicable.
Your Data Protection Rights
You have rights which allow you to address any concerns or queries regarding the processing of your Personal Data
Right of Access
You have the right to access and obtain a copy of the Personal Data that we hold about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.  
Right to Rectification
You have the right to request that we correct any inaccuracies in the Personal Data stored about you.  
Right to Erasure
In certain circumstances, you have the right to request that we erase your Personal Data.  For example, you may exercise this right in the following circumstances: 
•	your Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us; 

•	where you withdraw consent and no other legal ground permits the processing; 

•	where you object to the processing and there are no overriding legitimate grounds for the processing; 

•	your Personal Data have been unlawfully processed; or

•	your Personal Data must be erased for compliance with a legal obligation. 


Where we store your Personal Data for statistical purposes, we may not be able to comply with such a request where it would likely impair such statistical purposes or where we require your Personal Data for compliance with a legal obligation or in connection with legal proceedings.    
Right to Restriction
You have the right to restrict our processing of your Personal Data where any of the following circumstances apply: 
•	where you feel that the Personal Data which we hold about you are not accurate. This restriction will be in place for a period to enable us to verify the accuracy of your Personal Data; 

•	where the processing is unlawful and you do not want your Personal Data be erased and request the restriction of its use instead; 

•	where we no longer need to process your Personal Data (e.g. any of the Purposes outlined above have been completed or expire), but we require it in connection with legal proceedings; 

•	where you have objected to our processing of your Personal Data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms.

Where you exercise your right to restrict our processing of your Personal Data, we will only continue to process it with your consent or in connection with legal proceedings or for the protection of the rights of other people or for reasons of important public interest. 
Right to Communication
Any rectification or erasure of personal data or restriction of processing shall be communicated by us to any Recipient of your Personal Data. You will be informed about these Recipients should your request.
If a breach or loss of your data occurs you will be notified immediately by us.
Right to Data Portability
To further strengthen your control over your Personal Data, you have a right to receive and transfer the Personal Data that you provide to us in a structured, commonly used and machine readable format where we process your Personal Data on the legal bases of: a) your consent; or b) where it is necessary to perform our contract with you and such processing is carried out by automated means. Where you make such a request, we will directly transfer your Personal Data on your behalf to another controller of your choice (where it is feasible for us to do so).
Right to Object to Processing
In certain circumstances, you have a right to object to our processing of your Personal Data where we process it on the legal bases of: a) our legitimate business interest (e.g. the statistical purposes outlined above), including profiling based on our legitimate business interests; or b) your consent to marketing. We may not be able to comply with such a request where we can demonstrate that there are compelling legitimate grounds for us to process your Personal Data which override your interests, rights and freedoms or where the processing of your Personal Data is required for compliance with a legal obligation or in connection with legal proceedings.  
Right to Object to Automated Decision-Making, including Profiling  
You have a right not to be subjected to decisions based solely on automated decision-making, including profiling, which produce legal effects concerning you or similarly significantly affects you. 
We may not be able to comply with such a request where we rely on the legal bases of: a) your explicit consent; or b) where it is necessary to enter and perform our contract with you (as detailed in section 2 above). You will however be entitled to have a person from our team review the decision so that you can query it and set out your point of view and circumstances to us.
Enforcing Your Data Protection Rights
If you feel that the processing of your Personal Data is not in line with our data protection obligations, you can complain to a data protection supervisory authority. 
Our Data Protection Supervisory Authority
You can contact the UK Data Protection Commissioner offices at:
Telephone:				Lo Call Number:		
+44 303 123 1113			0303 123 1113			
					
Postal Address:			E-mail:					
Wycliffe House, 			casework@ico.org.uk.
Water Ln, 
Wilmslow 
SK9 5AF, 
UK

Data Retention – How long do we keep your Personal Data
We will not retain your Personal Data longer than is necessary to fulfil the purposes for which it was collected. However, we may be required by applicable laws and/or regulations to hold your personal data longer than this period. If no contradicting legal obligation exists, Scottish Business Network will delete your Personal Data in line with our Retention Policy or when you request that your Personal Data be erased and no longer processed by us. Additionally, where there is a contradicting statutory obligation for us to retain your Personal Data, we will restrict/block further processing and then erase the relevant Personal Data when we no longer have a requirement to retain it.

Notification of a Data Breach
If a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify you as soon as possible and later report the action we took in response to any breach. 
Where We Send and Store Your Personal Data
We will make reasonable efforts to ensure that your data is not transferred outside the European Economic Area (EEA). Where we use data servers that may transfer data out of the EEA we will take steps to ensure adequate protections are in place to ensure the security of your information and give you remedies in the unlikely event of a security breach. 
However, certain Recipients (our third party service providers) who process your Personal Data on our behalf may transfer your Personal Data outside the EEA to a country that does not have an Adequacy Decision of protection to your Personal Data. Where such transfers occur, we ensure that: a) they do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Data. If you would like to find out more about any such transfers, please contact our Data Protection Officer. 
Changes to this Policy
We may change this Policy from time to time, in whole or part, at our sole discretion or to fulfil a legal obligation. We encourage you to check our website to view the most recent version of this Policy. You may also request a copy of the most recent version of this Policy by contacting us.

 
If, at any time, we decide to use your Personal Data for a purpose that is different from the original purpose of collecting your Personal Data, we will contact you regarding this changes