Data Protection and Privacy Laws permit us to collect and use your personal data on a limited number of grounds. In which case, we will collect and use your personal information lawfully, fairly and in a transparent manner. We may, from time to time, communicate information about our services that could be received by individuals under the age of 18 (for example, via schools, organisations, or general mailing lists). Where this occurs, we take reasonable steps to ensure such communications are appropriate, responsible, and compliant with applicable laws. 

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Our lawful bases depend on the services you use and how you use them. This is a non-exhaustive list of the lawful bases we use: 

 

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Consent From You  

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. When you contact us, we assume your consent based on your positive action of contact, therefore you consent to your name and email address being used so we can respond to your enquiry. 

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Where you agree to receive marketing communications from us, we will do so based solely on your indication of consent or until you instruct us not to, which you can do at any time. 

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While you may request that we delete your contact details at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy. 

 

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Performance of a Contract or Transaction 

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.  

 

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Our Legitimate Interests 

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests. 

 

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Compliance with Law 

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. For example, we are required to keep financial records for a period of 7 years. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy. 

 

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Your Data Subject Rights 

 

Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests. 

 

Right to Object: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information. 

 

Right to be Informed: You have the right to be informed with how your data is collected, processed, shared and stored. 

 

Right of Access: You may request a copy of the personal information that we hold about you at any time by submitting a Data Subject Access Request (DSAR). The statutory deadline for fulfilling a DSAR request is 30 calendar days from our receipt of your request. 

 

Right to Erasure: In certain circumstances, you can ask for your personal data to be erased from the records held by organisations. However this is a qualified right; it is not absolute, and may only apply in certain circumstances. 

  

When may the right to erasure apply? 

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• When the personal data is no longer necessary for the purpose for which it was originally collected or processed for. 

• If consent was the lawful basis for processing personal data and that consent has been withdrawn. SCG relies on consent to process personal data in very few circumstances. 

• SCG is relying on legitimate interests as a legal basis for processing personal data and an individual has exercised the right to object and it has been determined that SCG has no overriding legitimate grounds to refuse that request. 

• Personal data are being processed for direct marketing purposes e.g. a person’s name and email address, and the individual objects to that processing. 

• There is legislation that requires that personal data are to be destroyed.  

 

Right to Portability: Individuals have the right to get some of their personal data from an organisation in a way that is accessible and machine-readable, for example as a csv file. Associated with this, individuals also have the right to ask an organisation to transfer their personal data to another organisation.  

 

However, the right to portability:

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• only applies to personal data which a person has directly given to SCG in electronic form; and 

• onward transfer will only be available where this is “technically feasible”. 

 

Right to Rectification: If personal data is inaccurate, out of date, or incomplete, individuals have the right to correct, update or complete that data. Collectively this is referred to as the right to rectification. Rectification may involve filling the gaps i.e. to have to have incomplete personal data completed – although this will depend on the purposes for the processing. This may involve adding a supplementary statement to the incomplete data to highlight any inaccuracy or claim thereof. 

 

This right only applies to an individual’s own personal data; a person cannot seek the rectification of another person’s information. 

 

Notification of data breaches: Upon discovery of a data breach, we will investigate the incident and report it to the UK’s data protection regulator and yourself, if we deem it appropriate to do so. 

 

Complaints: You have the right, at any time, to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details below. Please provide us with as much information as you can about the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. 

 

 

Automated Decision-Making 

We do not carry out automated decision-making or profiling that produces legal or similarly significant effects on individuals.