Some of the language used in privacy notices can be specialised. The Information Commissioner's website provides a useful introduction to key terms and concepts.
The purpose of the processing
We store and process journalists’ professional personal data for the purpose of sending targeted news releases and relevant information relating to the Scottish Parliament to specific audiences (journalists) to promote the work of the Scottish Parliament, in line with journalists’ professional function as correspondents reporting on the work of the Parliament.
We also process data relating to journalists when responding to general media enquiries, for the purpose of promoting the work of the Scottish Parliament. This in turn assists journalists in performing their professional functions.
We may also upload a journalist’s personal data to the platform provided by PRGloo. This is for the purpose of sending targeted news releases via email from within the PRGloo platform. Where these contact details are also publicly available, PRGloo may store and process this information in accordance with its commitments to the UK GDPR principles.
We may also hold and store the contact details of other relevant media professionals, including press officers (e.g. political party press officers, Scottish Government media relations teams etc.) and administrative staff. This is for the purpose of promoting the work of the Scottish Parliament, which in turn assists those workers in performing their professional functions.
Categories of information processed
Normal category data, as defined by the UK General Data Protection Regulation e.g. names, email addresses, publication titles, phone numbers and job titles of journalists/other business contacts.
Source of the information
Personal data is provided to us directly from several sources:
- By data subjects
- By two third party providers:
a. PRGloo – provider of a news release distribution service and media contact database. Sourced via publicly available sources.
b. Cision – provider of a media contact database. Sourced via publicly available sources or provided directly by journalists/their employers.
Data may also be acquired by searching publicly available sources where required (e.g. internet search).
Legal basis for processing
Data protection law states that we must have a legal basis for handling your personal data.
For the handling of general media enquiries and sending targeted news content to the media, the legal basis for the processing of personal data is that it is carried out in the legitimate interest of the Scottish Parliamentary Corporate Body (SPCB). The legitimate interest is engagement with the media and facilitating reporting relating to the Parliament (Article 6(1)(f) UK GDPR.)
During the course of our work we collect/use personal data relating to other media workers under the legal basis that it is carried out in the legitimate interest of the SPCB. The legitimate interest is the engagement with the media and facilitating reporting relating to the Parliament (Article 6(1)(f) UK GDPR.)
Data sharing
The personal data is only shared internally within the Media Relations Office and other departments within the Scottish Parliament where necessary.
Retention of data
Data is retained in electronic format or hard copy until we are notified that a journalist/media worker has left their post and/or no longer requires contact from the Scottish Parliament’s Media Relations Office.
Children and young people safeguarding and child protection
In line with the principles underlying the National Guidance for Child Protection in Scotland (2014), published by the Scottish Government, our staff may report a concern to the relevant authorities if they come across an issue during their work which causes them to think that a child may be at risk of abuse or harm.
Your rights
Data protection legislation sets out the rights which individuals have in relation to personal data held about them by data controllers. Applicable rights are listed below. You can exercise your data subject rights in particular circumstances depending on the purpose for which the data controller is processing the data and the legal basis upon which the processing takes place.
The following rights may apply:
Access to your information
You have the right to request a copy of the personal information about you that we hold.
Further information on how to make a data protection 'subject access request'.
Correcting your information
You have the right to ask us to correct the personal data we hold about you. We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
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 then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
- please note that the right to object to the processing of personal data does not apply where the data subject has consented to the processing, subject to the right to withdraw consent
- the right to object to the processing of personal data for the purposes of a public interest task is restricted if there are legitimate grounds for the processing which override the interest of the data subject
- the right of erasure and the right to object to processing of personal data do not apply where personal data is processed for the performance of a legal obligation. This will be considered on a case by case basis and depends on what personal data is involved and the risks further processing of that data could pose to you
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 above
- our use of your personal information is contrary to law or our other legal obligations
- please note that the right allowing for deletion or erasure of personal data (right to be forgotten) does not apply in cases where personal data is processed for the purposes of the performance of a task carried out in the public interest
- the right of erasure and the right to object to processing of personal data do not apply where personal data is processed for the performance of a legal obligation. This will be considered on a case by case basis and depends on what personal data is involved and the risks further processing of that data could pose to you
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 where there is no longer 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 to 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 purposes for which consent was given.
Please contact us in any of the ways set out below if you wish to exercise any of these rights.
Changes to our privacy statement
We keep this privacy statement under regular review and will place any updates on this website. Paper copies of the privacy statement may also be obtained using the contact information below.
This privacy statement was last updated on 22 March 2021.
Complaints
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner's Office online at: https://ico.org.uk/make-a-complaint.
Or by phone at: 0303 123 1113
Contact information and further advice
If you have any further questions about the way in which we process personal data, or
about how to exercise your rights, please contact the Head of Information Governance
at:
The Scottish Parliament
Edinburgh
EH99 1SP
Telephone: 0131 348 6913
(Calls are welcome through the Text Relay service or in British Sign Language through contactSCOTLAND-BSL.)
Email: [email protected]
Please contact us if you require information in another language or format