Privacy Notice

Who we are

The Royal Company of Merchants is a charitable organisation with over 500 members which provides, education, bursaries and grants for the young, housing  and grant support for the elderly. We operate from our office as the Merchant Hall at 22 Hanover St, Edinburgh, EH2 2EP. The Royal Company Merchants was granted the Royal Charter by Charles II and a list of its Institutions are below:

 

THE MERCHANTS’ HALL LIMITED (Registered Number. SC193385)

THE WIDOWS’ FUND OF THE COMPANY OF MERCHANTS OF THE CITY OF EDINBURGH

THE MERCHANT COMPANY ENDOWMENTS TRUST (Charity No: SC 002002)

MCET LIMITED (Registered Number: SC 215839)

THE ALEXANDER DARLING SILK MERCER’S FUND (Charity No. SC036724)

THE SANSON AWARDS (Charity No. SC036726)

THE MERCHANT COMPANY CHARITABLE TRUST (Charity No. SC022283)

THE JAMES SCOTT LAW CHARITABLE FUND –BEQUEST (Charity No. SC008878)

THE ELIZABETH C B ROSS BEQUEST (Charity No. SC024382)

THE MISS MARY DUNCAN BEQUEST (Charity No. SC012960)

THE DR THOMAS LYON BEQUEST (Charity No. SC010284)

THE BANK OF SCOTLAND TRAVEL SCHOLARSHIP (Charity No. SC022088)

EDINBURGH MERCHANT COMPNAY RETIREMENT BENEFITS SCHEME

THE MERCHANT COMPANY EDUCATION BOARD (Charity No. SC009747)

EDINBURGH MERCHANT COMPANY ENTERPRISE FUND LIMITED (Registered Number: SC 544235 & Charity NO. SC047319)

 

Purpose

This Policy explains when and why we collect personal information about people who visit our website, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

 

Our commitment

The Royal Company of Merchants is fully committed to handling personal information in accordance with data protection legislation and best data protection practices. This means that your personal information will be:

 

  1. Processed lawfully, fairly, and in a transparent manner.
  2. Collected for specified, explicit and legitimate purposes.
  3. Only collected so far as required for our lawful purposes.
  4. As accurate and up to date as possible.
  5. Retained for a reasonable period of time, in accordance with retention policies.
  6. Processed in a manner which ensures an appropriate level of security.

 

Whether through this notice or otherwise, we hope to ensure that everyone has a good understanding of why we processes personal information and, where we do, the rights they may have.

 

How do we collect personal information?

We obtain information about you when you use our website, for example, when you contact us about our events, hire of the Merchants Hall, membership of The Royal Company of Merchants to make an enquiry or donation to one of our charitable trusts. In addition, like most organisations that handle personal information, there are various ways in which we collect information from the people we deal with.

 

  • Email and written correspondence.
  • Telephone discussions.
  • Social media.
  • Application forms and other information requests.
  • Direct contact at our office and elsewhere.

 

In nearly all instances, it should be obvious to you when we are collecting your personal data.

 

What personal information do we collect?
The personal information most commonly collected is as follows:

 

  • Name.
  • Contact details (including home and business addresses, email, telephone number).
  • For visitors to our website – your IP address, and information regarding what pages are accessed and when.
  • If you contact us directly to make a donation or purchase a service from us, your card information is not held by us, it is collected by our third party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions, as explained below.
  • Records of enquiries, meetings and other direct engagement.
  • Copies of physical and electronic correspondence.

 

How is your information used?

We may use your information to:

 

  • process a donation that you have made;
  • process orders that you have submitted;
  • to carry out our obligations arising from any contracts entered into by you and us;
  • updating your membership details;
  • seek your views or comments on the services we provide;
  • notify you of changes to our services;
  • send you communications which you have requested and that may be of interest to you. These may include information about membership, events and fundraising activities and promotions of our charitable trusts; and
  • process a grant or job application.
  • purchase of tickets and merchandise.

 

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

 

 

What is the lawful basis for The Royal Company of Merchants’s processing activities?

We will only process personal information where we believe we have a lawful basis to do so. The basis for processing will vary from activity to activity. In some instances, processing may have more than one lawful basis.

 

The following information below summarises the basis on which we process personal information.

Lawful Basis Examples of processing activities
  • Processing is necessary for us to meet our legitimate interests, including:

 

  • the maintenance of our membership and customer  databases the promotion and monitoring of professional standards, and delivery of services we provide to members, beneficiaries and customers.
  • General administration for maintaining our membership database.
  • Corresponding with members, beneficiaries and customers in respect of the delivery of services within the terms of our specific contracts and membership activity
  • Regulatory activity (e.g. complying with the requirements of OSCR, Pension Regulator and fulfilling our responsibilities with regards applicable legislation).
  • Providing members and customers with relevant news and updates which may be of interest to them
  • Processing carried out in the public interest
  • Regulatory activity (e.g. complying with requirements of OSCR and fulfilling our responsibilities with regards applicable legislation).
  • Processing necessary for us to comply with our legal obligations.
  • Providing information to oversight regulators (including OSCR).

 

  • Providing information to statutory bodies (e.g. HMRC).
  • Providing information to law enforcement agencies.
 

  • Consent
 

  • Providing members and customers and donors with relevant news and updates, marketing and other information.

 

  • Use of financial and other information relevant to the delivery of services provided to our members, beneficiaries and customers.

 

Do we share personal data with third parties?

As a rule we will not sell or rent your information to third parties for marketing purposes.

 

In certain instances, some of the processing activities set out above require us to share personal information with third parties. Whenever we share personal data, we take all reasonable steps to ensure it will be handled appropriately and securely by the third party.

 

Third Party Service Providers working on our behalf: We may pass your information to our third party service providers, agents, advisors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

 

We may transfer your personal information to a third party if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our members and beneficiaries. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

 

The following is a list of the main third parties with whom we share personal information:

 

 

  • Oversight regulators and statutory bodies (e.g. HMRC,PENSION REGULATOR and OSCR).
  • Pension fund managers (applicable to members and beneficiaries of applicable charitable trusts)
  • Software and IT providers which allow us to operate efficient digital processes, including Sage (accounting software).

 

For practical reasons, this is an indicative, but not exhaustive list. Please also note that the list may be updated from time to time.

 

How long do we retain personal information?

The periods for which we retain personal information depends on the purpose for which the information was obtained but, in general terms, we will retain personal data for so long as required by law, or as may be required for record keeping and legal claims purposes.

The Merchant Company of Edinburgh is a historic organisation where our archives hold membership details dating back to 1670. We feel that there is a strong public and research interest in our archives and to maintain a historic record of our membership, both past and present, we would retain basic details only of our members indefinitely. However, members have the right to request that we delete any personal information that we hold about them. Appropriate physical and technical controls are in place to maintain the security and integrity of our membership lists. Such requests should be made in writing using the details provided under the Contact information and further advice section below.

Where do we store personal information?

Personal information is mostly processed by our staff at our premises in Edinburgh. To allow us to operate efficient digital processes, we sometimes need to store information in servers located outside of the European Union (‘EU’), but in the majority of cases your data will remain within the UK. By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

 

We may hold your information on our cloud based funding system where the servers are located in the United States. There is an adequacy decision by the European Commission in respect of the United States. This means that the United States to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

 

However, to ensure that your personal information does receive an adequate level of protection we have put in place the following appropriate measures to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU and UK laws on data protection: For example a binding service contract which includes data access, data security and information sharing clauses. If you require further information about these protective measures, you can request it using the contact details below.

 

IP addresses

We may collect information about the computer or device which is used to access our website. We use this information to improve the user experience and to help us better understand the ways in which our website is used. This may include information about:

 

  • The computer or device type.
  • IP address.
  • Operating system.
  • Browser type and version.
  • Time zone setting and browser plug-in types and versions.

 

This is statistical data about our users’ browsing actions and patterns. It is collected on an anonymous, aggregated basis, and does not identify individual users.

 

 

Security precautions in place to protect the loss, misuse or alteration of your information

When you give us personal information, we take steps to ensure that it’s treated securely.

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

Profiling

We may analyse the personal information which you have submitted to create a profile of your interests and preferences so that we can contact you with information relevant to you. We do not make use of additional information about you from external sources. In some circumstances we may use your personal information to detect and reduce fraud and credit risk.

 

 

Cookies

Our website makes use of cookie files to distinguish you from other users of our site, to provide you with a bespoke user experience tailored to your individual preferences. A cookie file (a small file of letters and numbers) will be placed on your computer or other access device each time you visit our site.

 

We also use analytical cookie files. These allow us to recognise and count the number of visitors to our site and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.

 

If you wish to delete any such cookie files, please refer to the instructions for your file management software to locate the file or directory that stores cookies. Our cookies will contain the domain name mcoe.org.uk within the file name.

 

You may refuse to accept cookie files when visiting our site, by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you choose this setting, you may not get an optimal web site experience and be unable to access certain parts of our site.

Other websites

Our website and emails may contain links to other websites. We are not responsible for the content or practices of these other sites and we recommend that you check their own privacy policies.

Your rights where we are processing your information

The law in the UK gives certain rights to individuals whose information is being processed by a third party. The following is a quick summary of these rights:

 

  • Access to your information – you have the right to request a copy of the personal information about you that we hold.
  • Correcting your information – we want to make sure that your personal information is accurate, complete, and up to date, and so you may ask us to correct any personal information about you that you believe does not meet these standards.
  • Deletion of your information – you have the right to ask us to delete personal information about you where:
    • You consider that we no longer require the information for the purposes for which it was obtained
    • We are using that information with your consent and you have withdrawn your consent – see ‘withdrawing consent to using your information’ below.

 

    • You have validly objected to our use of your personal information – see ‘objecting to how we may use your information’ below.
    • Our use of your personal information is contrary to law or our other legal obligations.
  • Objecting to how we may use your information – you have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest, or in exercising official authority vested in us then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
  • Restricting how we may use your information – in some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold, or assessing the validity of any objection you have made to our use of your information. The right might also apply if we no longer have a basis for using your personal information but you don’t want us to delete the data.  Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims, or where there are other public interest grounds to do so.
  • Withdrawing consent using your information – where we use your personal information with your consent, you may withdraw that consent at any time, and we will stop using your personal information for the purpose(s) for which consent was given.

 

Please contact us in any of the ways set out in the ‘contact information and further advice’ section if you wish to exercise any of these rights.

 

Changes to our privacy policy

We keep this notice under regular review and will place any updates on this website.  Paper copies of the privacy statement may also be obtained by emailing compliance@mcoe.org.uk or in writing to our office at Merchant Hall, 22 Hanover St, Edinburgh, EH2 2EP

 

This privacy statement was last updated on 13.5.2018.

 

 

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the events or services we offer then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.

 

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted. You can change your marketing preferences at any time by contacting us by email: pointofcontact@mcoe.org.uk or telephone on 0131 225 7202

 

 

Contact information and further advice

If you have any questions which are not covered in this notice, we suggest that you email us through pointofcontact@mcoe.org.uk.  To help us deal with your query as quickly as possible, we recommend that you include the following in the email subject ‘FAO Data Protection Officer’. If you would prefer to submit your questions in writing, please write to our office at Merchant Hall, 22 Hanover St, Edinburgh, EH2 2EP addressing your letter to the Data Protection Officer.

 

Complaints

While we seek to resolve directly all complaints about how we handle personal information, you also have the right to lodge a complaint with the Information Commissioner’s Office, whose contact details are as follows:

 

The Information Commissioner’s Office – Scotland
45 Melville Street
Edinburgh
EH3 7HL

Telephone: 0303 123 1115

 

Email – Scotland@ico.org.uk

 

Website – https://ico.org.uk/concerns