Data Protection Concerns or Complaints Privacy Notice

Glasgow Life is the operating name of Culture & Sport Glasgow, a Scottish Charity (Scottish Charity Number SC037844) and having its registered address at Commonwealth House, 38 Albion Street, Glasgow G1 1LH, is the controller of personal information collected for our processing purposes. See below for our contact details and our Data Protection Officer.

You are giving us your personal information to allow us to:

• to receive, assess, investigate and respond to data protection complaints in line with our legal obligations under data protection law and applicable complaints handling requirements;
• where your complaint indicates a potential personal data breach, your information may also be used to assess and manage that breach in accordance with our legal obligations;
• we need to process your personal information if you chose to escalate your complaint to the Information Commissioner’s Office (ICO).

We also use your information to verify your identity where required, contact you by post, email or telephone and to maintain our records.

The information we have received from you consists of the following:

• name, address, and contact details, along with details of your data protection concern or complaint.

We rely on the following legal bases for processing your personal information:

• Necessary for compliance with a legal obligation to which Glasgow Life is subject.
• Necessary for the performance of a task carried out in the public interest by Glasgow Life.

Some of the above legal bases for processing may overlap and there may be several grounds which justify our use of your personal information.

If you do not provide sufficient information, we may not be able to fully investigate or respond to your complaint.

We are legally obliged to safeguard public funds so details will be checked internally for fraud prevention and verification purposes and may be shared with other public bodies for the same purpose. We are legally obliged to share certain data with other public bodies such as HMRC and will do so where the law requires this; we will also generally comply with requests for specific information from other regulatory and law enforcement bodies where this is necessary and proportionate. Information is also analysed internally in order to provide management information, inform service delivery reform and similar purposes. This is in accordance with our Information Use and Privacy Policy and the Privacy Statement set out in full on our website.

Specifically: 
 
Because data protection complaints may relate to services delivered by Glasgow City Council or by organisations working on its behalf, including Arm’s Length External Organisations (ALEOs) such as Glasgow Life, where necessary to investigate and respond to your complaint, your information may be shared with the organisation responsible for the service you are complaining about.

Each organisation involved will process your personal data in accordance with its own data protection obligations as a data controller. Responsibility for handling and responding to your complaint will rest with the organisation identified as the relevant controller for the issue raised.

Where necessary, information may also be shared with the Office of the Data Protection Officer for independent review, and with the Information Commissioner’s Office if you choose to escalate your complaint. Your information will only be used for the purposes of managing your complaint and will not be used for any unrelated purpose, unless required by law.

In order to provide services to you, we may need to appoint other organisations to carry out some activities on our behalf. These may include, for example, payment processing organisations, delivery organisations, mailing houses and contractors or consultants providing services to Glasgow Life (or directly to service users) where we need to provide them with personal information to allow them to provide these services on our behalf. We select these organisations carefully and put measures in place to make sure that they only follow our instructions when processing your personal information.

Following recommendations from the Scottish Public Services Ombudsman, Glasgow City Council has adopted a unified complaints handling system. As part of this system, the Council will handle complaints relating both to core Council services and to ALEOs which include Glasgow Life, and will process personal data relating to those complaints on behalf of the ALEOs.

This information will only be used in connection with the complaints handling processes (which may involve sharing the data with the SPSO's office if you take your complaint to them) and will not be used for any other purpose save where we are required to do so by law.

We will not sell or rent your information to any third-party organisations. 

Almost all Glasgow Life data is held within the UK.  Any overseas data transfers require additional internal approvals and we only send data overseas where we have been able to put in place measures to make sure that your personal information is as safe and respected in the overseas country, or countries in question, as it is in the UK. We will always respect your privacy and security if we transfer your data abroad.

With effect from April 2025, the support model for council ICT services has included an offshore element meaning that IT professionals based in India may need to access council and Glasgow Life data in order to provide support services to us.  All data is still hosted in the UK, and we have ensured that stringent safeguards around this access have been put in place.

Glasgow Life makes use AI (Artificial Intelligence), most notably Microsoft Copilot.  These AI systems are used as productivity assistants, and they do not make decisions for Glasgow Life.  All AI-generated content requires to be manually checked/verified before it is used operationally.

We only keep your personal information for the minimum period amount of time necessary. Sometimes this time period is set out in the law, but in most cases it is based on the business need. Glasgow Life maintains a records retention and disposal schedule which sets out how long we hold different types of information for. This is available on our website at www.glasgowlife.org.uk/rrs.

If you have provided anyone else’s details on this form, please make sure that you have told them that you have given their information to Glasgow Life. We will only use this information to respond to your data protection concern or complaint. If they want any more information on how we will use their information they can visit our web site at: www.glasgowlife.org.uk/privacy

Access to your information – you have the right to request a copy of the personal information that we hold about you.

Correcting your information – we want to make sure that your personal information is accurate, complete and up to date. Therefore 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 think that we no longer need to hold the information for the purposes for which it was originally obtained
• you have a genuine objection 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 tell us to stop using your personal information for direct marketing purposes.

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 that we hold about you or we are assessing the objection you have made to our use of your information. This 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 realistically applied will mean that 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.

Please contact us if you wish to exercise any of these rights.

For general enquiries, queries or exercising your data protection rights, you can contact Glasgow Life by:

• Post: 38 Albion Street, Glasgow, G1 1LH
• Telephone: 0141 287 4350
• Email: info@glasgowlife.org.uk

We aim to resolve all complaints about the way Glasgow Life processes your personal information. You can contact our data protection officer about any data protection matter but you also have the right to complain to the Information Commissioner’s Office (ICO). Contact details for our data protection officer and the ICO are available on our website at www.glasgowlife.org.uk/privacy/data-protection-concerns.

Please note if your complaint is not about a data protection matter or concerns the handling of your personal information, please contact us using the complaints procedures in place at www.glasgowlife.org.uk/commentsandcomplaints.

• You can find more details for Customer Comments, Compliments and Complaints at: www.glasgowlife.org.uk/contact-us
• To learn more about how we handle your personal information, please visit: www.glasgowlife.org.uk/privacy
• If you need help in another format, such as large print, braille or audio, please ask a staff member, contact us or visit: www.glasgowlife.org.uk/accessibility

Glasgow Life (and its sub-brands) are operating names of Culture and Sport Glasgow (“CSG”) a Scottish charity (No SCO37844) incorporated under the Companies Acts and limited by guarantee, registered in Scotland with Company No SC313851. Culture and Sport Glasgow (Trading) CIC (“CSG CIC”) is a trading subsidiary of CSG, a community interest company, registered in Scotland with Company No SC313850. CSG and CSG CIC (registered office at 38 Albion Street, Glasgow, G1 1LH) are collectively referred to by CSG’s operating name “Glasgow Life” for the purposes of our Privacy Statement and privacy notices (available at www.glasgowlife.org.uk/privacy). Glasgow Life delivers cultural, sporting and learning activities on behalf of Glasgow City Council, inspiring Glasgow’s citizens and visitors to lead richer and more active lives.