The type of personal information Birthlink collect
We currently collect and process the following information:
- Personal identifiers, contacts and characteristics (name, address, email address, date of birth, place of birth, and telephone numbers, identification which may contain e.g., passport details, driver’s license details)
- Customer payment information, where necessary.
- Online identifiers such as IP address and location data.
How we get the personal information and why we have it
We process personal information provided to us directly by you. We also seek and hold personal information that is in the public domain, and (under certain conditions) other information held with public authorities.
Under General Data Protection Regulations (2018), the legal basis for us holding personal information is with explicit consent, contractual reasons, legitimate interest, and to comply with legal obligations.
How we use your personal data
We collect the minimum information required to provide you with a service. Without this information we would be unable to provide this service.
Sharing your personal data
We will not share any information with any other organisations or individuals, unless with your explicit consent in relation to the service you request, or where we are required to do so by law.
How we store your personal information
Your information is securely stored with restricted access within our systems. It is only available to staff who need it to deliver your service. Access is removed when no longer needed for the intended purpose.
Legitimate Interests Assessment
The majority of the current engagement with service users is governed within GDPR on the legal basis of explicit consent, contractual reasons and to comply with legal obligations. Some information we have is controlled and processed under the legal basis of legitimate interest. We have undertaken an assessment on this basis and confirm that:
- We undertake to hold, process, and share this data in ways that subjects would reasonably expect, which have minimal privacy impact and where there is a compelling justification.
- We take extra responsibility to consider and protect peoples’ rights and interests where processing cannot be achieved in any other way to deliver a service.
- We take full cognisance of the sensitivity of the information we hold, and decision making around sharing is undertaken on a case-by-case basis, with professional emotional support given.
- We consider impact on third parties in all our information processing practice.
- We have firm protocols around mediation between adoptees and family members.
- We encourage people to contact us to discuss their data we hold, and how they wish it to be processed. This safeguard will enable us to reduce the impact where possible.
Your data protection rights
Under data protection law, you have rights including:
- Your right to be made aware of how your data will be used – this policy outlines how your data will be used. However please contact us at any time to discuss.
Your right of access – You have the right to ask us for copies of your personal information and for this to be shared in a way you understand.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to withdraw consent – You have the right withdraw your consent at any time without being asked to explain your reasons.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to make a complaint – please see below.
You are not required to pay to exercise your rights. If you make a request, we will respond to you within one calendar month.
How to update personal data and/ or change marketing preferences:
If you need to update your name, address, email address or contact numbers or you wish to change or unsubscribe from marketing information, please contact us at firstname.lastname@example.org , call us on 0131 225 6441 or write to:
Birthlink, 21 Castle Street, Edinburgh, EH2 3DN.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at:
Data Protection Officer, Birthlink, 21 Castle Street, Edinburgh, EH2 3DN.
You can also complain to the Information Commissioners Office if you are unhappy with how we have used your data.
You can contact:
The Information Commissioner’s Office – Scotland
Queen Elizabeth House
Telephone: 0303 123 1115