Privacy Notice for Volunteers, Employees and Workers

This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during your employment and after it ends. We are required to notify you of this information under data protection legislation.

What information do we hold about you and why?

Please ensure that you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information?

The National Trust for Scotland is a ‘data controller’ and gathers and uses certain information about you.

Data protection principles

We will comply with the data protection principles when gathering and using personal information, as set out in our GDPR Data Protection Policy.

About the information we collect and hold

The table set out in the Schedule summarises the information we collect and hold, how and why we do so, how we use it and with whom it may be shared.

We may also need to share some of the categories of personal information set out in the Schedule with other parties, such as external contractors and our professional advisers and potential purchasers of some or all of our business or on a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We may also be required to share (with third parties such as with Her Majesty’s Revenue & Customs, for example) some personal information as required to comply with the law.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Who will have access to your data and who will we share it with?

Access to your personal data will be restricted to Trust employees and volunteers on a need-to-know basis only.

Where necessary or required, CCTV images may be shared with CCTV service providers, security organisations, and individuals or organisations making an enquiry under the appropriate sections of the Data Protection Act 2018. We will only provide access when we consider there to be a lawful basis for doing so and we have documented this.

We will share your information with third parties to support your employment or volunteering relationship with us, including:

Our electronic newsletter provider – for the purposes of delivering our newsletter
Our waste management contractor – for the purposes of confidential waste disposal
Our Human Resources Information System provider – for the purposes of recording individual and management information about our workforce
Our pensions providers – for the purposes of supporting pensions
Our occupational health provider – for the purposes of undertaking pre-employment medical assessments, routine health monitoring and ad hoc medical referrals
Our benchmarking and survey partners – for research and engagement purposes
Our employee benefits provider – for the purposes of enabling access to employee benefits
Our outplacement provider – for the purposes of supporting employees with any change programmes
Our Insights partner – for the purposes of helping employees to understand themselves, understand others, and make the most of the relationships that affect them in the workplace
Our online training provider – to enable access to mandatory and optional training modules
Our online learning provider – to enable access to key information about the Trust
Our payroll operator – for the purposes of administering pay and expenses
Our cycle to work scheme operator – for the purposes of managing any cycle to work scheme requests
Our mailing providers – for the purposes of issuing employee and volunteer cards
Our IT Helpdesk provider – for managing any IT requests from, or relating to our volunteers, employees and workers
Our reprographics supplier – for reprographics jobs that relate to volunteers, employees and workers

Where these third parties are acting as data controllers, they are required to handle your personal data in accordance with all applicable data protection laws. For further information about how they do this, please refer to their privacy policies.

Where the third parties are acting as data processors, processing personal data on behalf of the Trust, we have contracts in place with these third parties which require them to process your personal data on our instructions only. They will not process your personal data for any other purpose and they will retain it securely.

In some cases, your data will be processed outside of the UK. Where this is the case, we will ensure that there are adequate safeguards in place (for example, the use of Standard Contractual Clauses and International Data Transfer Agreements) for the protection of your personal data.

How long we keep your information

We keep your information during and after your employment for no longer than is necessary for the purposes for which the personal information is processed. Further details on this are available in the National Trust for Scotland Retention Schedule.

Your rights to correct and access your information and to ask for it to be erased

Please contact our Data Protection Officer (DPO), who can be contacted by email at dataprotection@nts.org.uk if (in accordance with applicable law) you would like to correct or request access to information that we hold relating to you or if you have any questions about this notice. You also have the right to ask our Data Protection Officer for some but not all of the information we hold and process to be erased (the ‘right to be forgotten’) in certain circumstances. Our Data Protection Officer will provide you with further information about the right to be forgotten, if you ask for it.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

If you have any queries or concerns about this notice or about our use of your personal information, please contact our Data Protection Officer.

If our Data Protection Officer is not able to address your query or concern, you can contact the Information Commissioner at ico.org.uk/concerns or telephone 0303 123 1113 for further information about your rights and how to make a formal complaint.

The Schedule

About the information we collect and hold

Swipe to view table

The information we collect	How we collect the information	Why we collect the information	How we use and may share the information
Your name, contact details (ie address, home and mobile phone numbers, email address) and emergency contacts (ie name, relationship and home and mobile phone numbers) ☐	From you	To enter into/perform the employment contract, the worker contract, or the volunteer registration Legitimate interest: to maintain employment records and good people management practice	To enter into/perform the employment contract, worker contract or volunteer registration
Details of salary and benefits, bank/building society, National Insurance and tax information, your age ☐	From you	To perform the employment contract or worker contract including payment of salary and benefits, and for the payment of legitimate expenses for volunteers, employees, and workers Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice	To ensure you receive the correct pay and benefits Information shared with our pension/benefits provider LEBC administrators and with HM Revenue & Customs (HMRC)
Details of your spouse/partner and any dependants ☐	From you	To perform the employment contract including employment related benefits, eg private medical insurance, life assurance and pension	To ensure you receive the correct pay and benefits Information shared with our pension/benefits provider LEBC administrators, income protection and life assurance insurers in the case of a claim, our childcare voucher partner The Co-operative and with HM Revenue & Customs (HMRC)
Your nationality and immigration status and information from related documents, such as your passport or other identification and immigration information ☐	From you and, where necessary, the Home Office	To enter into/perform the employment contract, the worker contract, or the volunteer registration To comply with our legal obligations Legitimate interest: to maintain employment records	To carry out right to work checks Information may be shared with the Home Office
[A copy of your driving licence ] ☐ where driving is a requirement of the role for which you undertake	From you. As verified through the DVLA digital license checking system.	To perform the employment contract, the worker contract, or the volunteer registration To comply with our legal obligations To comply with the terms of our insurance	To ensure that you have a clean driving licence Information may be shared with our insurer.
Details of your pension arrangements, and all information included in these and necessary to implement and administer them ☐	From you, from our pension administrators LEBC and (where necessary) from your own pension fund administrators	To perform the employment contract including employment related benefits To comply with our legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice	To administer your pension benefits AND/OR To comply with our auto-enrolment pension obligations Information shared with our pension administrators LEBC and with HMRC
Information in your sickness and absence records (including sensitive personal information regarding your physical and/or mental health) ☐	From you, from your doctors, from medical and occupational health professionals we engage and from our insurance benefit administrators LEBC and Unum	To perform the employment contract including employment related benefits To comply with our legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice, to ensure safe working practices	To maintain employment records, to administer sick pay entitlement, to follow our policies and to facilitate employment related health and sickness benefits To comply with our legal obligations to you as your employer Information shared with your doctors, with medical and occupational health professionals we engage and with our insurance benefit administrators LEBC For further information, see * below
Your racial or ethnic origin, sex and sexual orientation, religious or similar beliefs	From you	To comply with our legal obligations and for reasons of substantial public interest (equality of opportunity or treatment)	To comply with our equal opportunities monitoring obligations and to follow our policies For further information, see * below
Criminal records information, including the results of Disclosure Scotland and/or Disclosure and Barring Service (DBS) checks ☐where this is relevant to the role for which you have applied	From you and the DBS or Disclosure Scotland	To perform the employment contract, or worker contract, or volunteer registration To comply with our legal obligations For reasons of substantial public interest (preventing or detecting unlawful acts, and protecting the public against dishonesty)	To carry out statutory checks Information shared with DBS, Disclosure Scotland and other regulatory authorities as required For further information, see * below
Information on grievances or complaints raised by or involving you	From you, from other colleagues (volunteers, employees, workers) and from consultants we may engage in relation to the grievance procedure	To perform the employee contract, the worker contract, or the volunteer registration; To comply with our legal obligations Legitimate interests: to maintain volunteer, employment, worker records and to comply with legal, regulatory and corporate governance obligations and good people management practice	For people administration, to follow our policies and to deal with grievance matters Information shared with relevant managers, People Department personnel and with consultants we may engage
Information on conduct issues involving you	From you, from colleagues (volunteers, employees, workers) and from consultants we may engage in relation to the conduct procedure	To comply with our legal obligations Legitimate interests: to maintain people records and to comply with legal, regulatory and corporate governance obligations and good employment practice, to ensure safe working practices	For people administration and assessments, to follow our policies, to monitor staff performance and conduct and to deal with disciplinary and grievance matters Information shared with relevant managers, People Department personnel and with consultants we may engage
Details of your appraisals and performance reviews	From you, from other colleagues (volunteers, employees, workers)	To comply with our legal obligations Legitimate interests: to maintain people records and to comply with legal, regulatory and corporate governance obligations and good people management practice, to ensure safe working practices	For people administration and assessments, to follow our policies, to monitor staff performance and conduct and to deal with disciplinary and grievance matters Information shared with relevant managers, People Department personnel and with consultants we may engage
Details of your performance management/improvement plans (if any)	From you, from other colleagues (volunteers, employees, workers), and from consultants we may engage in relation to the performance review process	To comply with our legal obligations Legitimate interests: to maintain people records and to comply with legal, regulatory and corporate governance obligations and good employment practice, to ensure safe working practices	For people administration and assessments, to follow our policies and to monitor staff performance Information shared with relevant managers, People Department personnel and with consultants we may engage
Details of your time and attendance records	From you and from your manager	To perform the employment contract, the worker contract, or the volunteer registration; Legitimate interest: to monitor and manage staff access to our systems and facilities and to record people absences	For payroll and people administration and assessments, to follow our policies and to monitor staff performance and attendance Information shared with relevant managers, People Department personnel, and with consultants we may engage with
Information in applications you make for other positions within our organisation	From you	To enter into/perform the employment contract, the worker contract, or the volunteer registration; To comply with our legal obligations Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice	To process the application Information shared with relevant managers, People Department personnel [and with consultants we may engage]
Information about your use of our IT, communication and other systems	Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, remote access systems, email and instant messaging systems, intranet and internet facilities, telephones, voicemail, mobile phone records	Legitimate interests: to monitor and manage staff access to our systems and facilities; to protect our networks, and personal data of employees and customers/clients, against unauthorised access or data leakage; to ensure our business policies, such as those concerning security and internet use, are adhered to for operational reasons, such as maintaining employment records, recording transactions, training and quality control; to ensure that commercially sensitive information is kept confidential; to check that restrictions or restrictive covenants on your activities that apply after your employment or worker contract has ended, or volunteering has ceased	To protect and carry out our legitimate interests (see adjacent column Information shared with relevant managers, People Department personnel, and ICT personnel For further information, see ** below)
Details of your use of business-related social media, such as LinkedIn	From relevant websites and applications	Legitimate interests: to monitor and manage people access to our systems and facilities; to protect our networks, and personal data of employees, workers, volunteers, and customers/clients, against unauthorised access or data leakage; to ensure our business policies, such as those concerning security and internet use, are adhered to; for operational reasons, such as maintaining people records, recording transactions, training and quality control; to ensure that commercially sensitive information is kept confidential; as part of investigations by regulatory bodies, or in connection with legal proceedings or requests	To protect and carry out our legitimate interests (see adjacent column) Information shared with relevant managers, People Department personnel and ICT personnel For further information, see ** below
Your use of public social media (only in very limited circumstances (a) to check specific risks for specific functions within our organisation; you will be notified separately if this is to occur or (b) exceptionally, where justified and relevant to an alleged breach of employment contract or relevant policy)	From relevant websites and applications	Legitimate interests: to monitor and manage staff access to our systems and facilities; to protect our networks, and personal data of employees, workers, volunteer, and customers/clients, against unauthorised access or data leakage; to ensure our business policies, such as those concerning security and internet use, and representing the Trust, are adhered to; for operational reasons, such as maintaining people records, recording transactions, training and quality control; to ensure that commercially sensitive information is kept confidential to check that restrictions on your activities that apply after your employment or worker contract has ended, or volunteering ceased (post-termination restrictions or restrictive covenants) are being complied with; as part of investigations by regulatory bodies, or in connection with legal proceedings or requests	To protect and carry out our legitimate interests (see adjacent column) Information shared with relevant managers, People Department personnel [and with consultants we may engage] For further information, see ** below
Details in references about you that we give to others	From your personnel records, our other employees	To comply with a contract with you (where applicable in certain limited circumstances) Legitimate interests: to maintain employment records and to comply with legal, regulatory and corporate governance obligations and good employment practice To provide you with the relevant reference	To comply with legal/regulatory obligations Information shared with relevant managers, People Department personnel and the recipient(s) of the reference

You are required (by law or under the terms of your contract of employment, or in order to enter into your contract of employment or by law or under the terms of your contract as a worker, or in order to enter into your contract as a worker) to provide the categories of information marked ‘☐’ above to us to enable us to verify your right to work and suitability for the position, to pay you, to provide you with your contractual benefits, such as eg contractual sick pay and to administer statutory payments such as statutory sick pay (SSP). If you do not provide this information, we may not be able to employ you, to make these payments or provide these benefits.

* Further details on how we handle sensitive personal information and information relating to criminal convictions and offences are set out in our Criminal Records Checks (Disclosure Scotland) policy, available through the Employee Handbook A–Z on TrustNet, or where this access is not possible, from the People Department.

** Further information on the monitoring we undertake in the workplace and how we do this is available in our Social Media and IT Security policies available from the Policy Department.