West Lothian Bike Library Privacy Policy 
Last Updated 24 Jan 2019
West Lothian Bike Library CIC (WLBL) is a not for profit, community interest company registered in Scotland 573140.
Our main purpose is to help people get active and make cycling available and accessible to all.
The personal data we collect from/process on you may include:
Personal identification, contact details, skills, bike request requirements, support requirements, IP address.
Our purpose for collecting and storing your personal data
The Personal and Special Category Data that we collect from you is used for:
- Processing your request to us and providing cycling services related to that request.
- Operating volunteer led services, providing training, paying expenses and keeping you updated about our services and events.
- Responding to your enquiries and communications.
- Your interaction with our website, blog and social media pages.
- Keeping you informed of our Activities
WLBL will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR) 2018 and the Data Protection Act 2018. We are committed to ensuring the information we collect and use is the minimum required and appropriate for this purpose, and does not constitute an invasion of your privacy.
We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Our legal basis for processing for personal data
- Contractual obligation:
– When you contact WLBL ask us to assist or provide a service. We will collect personal and special category data required from you to identify you and your request and be able to provide the service or fulfil the request.
– When you register to Volunteer with WLBL. We will collect and process your personal data to:-
* Communicate with you
* Provide training
* Operate work schedules
* Process expenses
* Operate the services of WLBL pertaining to your specific volunteer role
* Keep you updated on our services and events.
The special category of personal data concerned is: Health.
The condition for processing this special category data is that it is necessary to provide the service or request made.
- Legitimate Interest:
– When you interact with us via our website, blog or social media pages. We may collect personal and statistical data via
* Optional Contact and Survey Forms
* Plugins, cookies and other storage technologies
We collect data in a way that is reasonably expected, as part of day to day operating of websites, blogs and social media pages. For example, we may collect and Log IP addresses for analysis of our website usage.
Please refer to our Media & Cookies Policy for more details.
- Consent:
– When you supply us contact details to be kept informed of our Activities and Services. You may unsubscribe from this service at any time by emailing your wish to do so to Info@WLbikelibrary.co.uk
Sharing the personal data with third parties
We will normally not share your data with third parties. However, we use an email and web hosting provider, LCN and an online document and storage provider, Microsoft. All data is managed and securely stored on EU based Servers by WLBL.
| Third Party Provider | Product | Location | Privacy and Security |
| LCN | LCN Email & Web Hosting | UK Based Servers | https://www.lcn.com/about
|
| Mircrosoft | Microsoft Office 365 with OneDrive Cloud Storage | EU based Servers | https://privacy.microsoft.com/en-gb
|
We may receive your personal and special category data through third-party referrals from Health Professional or Support Agencies and may communicate with you back through these agencies, as appropriate.
We may receive your personal and special category data through third-party referrals from Health Professional or Support Agencies and may communicate with you back through these agencies, as appropriate.
We provide options via third parties on our website to:
- pay for services or make a donation using Paypal services.
The third parties are to be considered as independent data controllers within the meaning of the General Data Protection Regulation. We recommend that you read the privacy statements of these companies.
https://www.paypal.com/uk/webapps/mpp/ua/privacy-full?country.x=GB&locale.x=en_GB
Retention of the personal data collected
WLBL is required to retain information in accordance with the law and to fulfil our accounting and reporting requirements. The time-period for which personal data will be processed and retained is determined by the purpose for which it was collected. These time periods are shown below.
| Purpose | Retention period |
| Processing data to respond to your request for services or a product, including requests via Contact Forms on our Website. | Data will be retained one year after the product has been provided or service terminated |
| Processing your data to keep you informed of our Activities. | Data will be retained for one year after you have withdrawn consent. |
| Processing your data to enable you to operate as a volunteer | Data will be retained one year after your volunteer contract has been terminated |
| Processing data and statistics and survey details collected via interaction with our website, blog and social media pages | Survey Results, Comments and published articles may be held Indefinitely.
|
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data what we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review – if WLBL refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain please see our Complaints section below.
Data access requests
At your request, WLBL can:
- Confirm what personal information we hold about you and how it is processed.
- Consider deletion of some of your personal information from our computer systems and paper files. This does not include and data we are obliged to keep for administrative, financial, legal or security purposes.
Requests must be made in writing to WLBL and be accompanied by two forms of identification.
The following forms of identification are accepted:
- Passport
- Driving licence
- Birth certificate
- Utility bill (from last three months
Requests must be made in writing to:
Project Co-ordinator
West Lothian Bike Library CIC
Crofthead Community Centre
Templar Rise
Livingston
EH54 6DG
Complaints
If you have a complaint about:
- How we are collecting/processing your personal data or about your rights of access
- How your complaint has been handled by WLBL
then you can lodge a complaint to the Project Coordinator at the address above.
If you remain unhappy with our response, you can complain to the Information Commissioners Office (ICO).
Details of how to do this and a complaint form are available at the ICO website https://ico.org.uk/ or by calling their helpline on 0303 123 1113 or writing to them at:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF