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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 informationHow 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 youTo 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 youTo 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 youTo perform the employment contract including employment related benefits, eg private medical insurance, life assurance and pensionTo 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 OfficeTo 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 administratorsTo 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 UnumTo 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 youTo 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 appliedFrom you and the DBS or Disclosure ScotlandTo 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 procedureTo 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 youFrom you, from colleagues (volunteers, employees, workers) and from consultants we may engage in relation to the conduct procedureTo 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 reviewsFrom 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 recordsFrom 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 youTo 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 recordsLegitimate 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 LinkedInFrom relevant websites and applicationsLegitimate 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 applicationsLegitimate 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 employeesTo 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 AZ 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.