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Introduction

On these pages you will find details of Glasgow Life's Privacy Statement - how we collect information and what we do with it which is guided by our approved high level Information Use and Privacy Policy and our Website Privacy Policy which details how we operate our websites.

Privacy Statement: this is how we generally use information collected or obtained for various Glasgow Life services (being updated on an ongoing basis).
Website Privacy Policy: this is how we operate our websites we control and how we handle any personal information collected or obtained through our websites. It also covers the use of Cookies and other technologies on our sites.

Information Use and Privacy Policy: these are our high level principles about how we use personal information we have collected or obtained that informs our policies and procedures.

You can read our Disclaimer which relates to content on websites we may link to, but do not operate.
You can also view our Copyright Statement which relates to information on this site (and our other sites we operate) and our policy on reproducing any of that information.

You can also view our Policy on Re-Use of Public Sector Information which relates to information held by Glasgow Life which is available for reuse by the public and the conditions which will apply to such re-use.

If you want to see how Glasgow Life treats any information you submit via our websites or how cookies and other technologies are used, please view our Website Privacy Policy and Information on Cookies.

The Short Version

This privacy statement is the privacy notice for all Glasgow Life services. We will use your details to provide you with the service(s) which you or someone else (with your CONSENT) have asked us to provide. We will also use your personal details for purposes of crime prevention and crime detection and/or when required by law and will share it with other public bodies for that purpose.

The Longer Version

Culture and Sport Glasgow is a Scottish charity (No SCO37844) incorporated under the Companies Acts and limited by guarantee, registered in Scotland with Company No SC313851 having its registered offices at 220 High Street, Glasgow G4 0QW and operating under the name “Glasgow Life” (“CSG”).  CSG is registered with the Information Commissioners Officer (“ICO”) under Notification No. Z9838695. 

Culture and Sport Glasgow (Trading) CIC (“CSG CIC”) is a trading subsidiary of CSG.  CSG CIC, a community interest company, is registered in Scotland with Company No SC313850 having its registered offices at 220 High Street, Glasgow G4 0QW and registered with the ICO under Notification No. Z9838741

CSG and CSG CIC are collectively referred to by CSG’s operating name “Glasgow Life” (“we” or “us”) for the purposes of this Privacy Statement.

In terms of the Data Protection Act 1998, Glasgow Life is the data controller of any personal information provided to or gathered by us.

Glasgow Life’s approved Information Use and Privacy Policy sets out the high level principles we adhere to when using an individual's personal data. This privacy statement describes how we presently translate those principles into practice in terms of what we will and will not do with the information we hold about you. It sets out the general approach we take, in each case with additional information relating to particular areas of our activity.

 

General Approach

Glasgow Life does not sell or rent your personal details to any external organisations.

For most purposes, we will only process your information with your CONSENT. In most cases, we will presume that by providing us with your details in order to obtain a service from Glasgow Life, you are CONSENTing to us using those details in order to provide that service to you. Except as set out in this privacy statement, we will not use your personal details for any other purpose without first obtaining your CONSENT to that other purpose or purposes (you may have been asked to provide this additional CONSENT at the time when you originally contacted us, for example in an additional section on an application or other form).

The main exception to the rule that we will not use your details for other purposes relates to the prevention of fraud. Glasgow Life is under a legal obligation to safeguard public funds and so in all cases we reserve the right to check the information you have provided for accuracy or in order to detect fraud. This may involve data matching exercises where we compare different sets of data which we hold (or share with or are shared from other agencies, including Glasgow City Council (“the Council”)) for unusual matches or discrepancies; this may also include matching our data with external data sources such as information held by credit reference agencies.

We also participate in anti-fraud data matching exercise carried out by other agencies such as the National Fraud Initiative (operated on behalf of Audit Scotland) and the Housing Benefit Matching Service (conducted on behalf of the Department for Work and Pensions). We have a duty to manage public funds properly. As a result, we will use the information you provide to make sure all amounts we are owed are paid on time (for example, by identifying people who have not paid Glasgow Club fees). In relation to outstanding money owed, we may also share your information with Debt Management Partners and the Courts. We may also share your information for the same purposes with other public organisations, including the Council, neighbouring councils that handle public funds, and with the Police. We may also share your details with other organisations, including credit reference agencies, for the purposes of prevention and detection of fraud and confirming who is living at a particular address.

By law we are obliged to provide information to certain other public bodies such as the Department for Work and Pensions, HM Revenues and Customs, courts, tribunals, hearings and other formal bodies dealing with legal processes, and various external regulatory bodies. We also have an obligation to assist in the prevention of crime and we will therefore generally supply specific information which we are asked to provide to the police or other crime detection agencies, provided we are satisfied that the request is connected to an investigation and that disclosure would be lawful and proportionate.

We work closely with a large number of other public bodies, for example with the Council. Information will generally only be shared with these partner bodies with your CONSENT and you should always be made aware when services are to be provided to you on a joint basis.

External contractors are appointed to process information on behalf of Glasgow Life and under its instructions. All contractors which do this are appointed under written contracts requiring them to keep the personal information safe and prohibiting them from doing anything with the personal data they process for us other than following Glasgow Life's instructions.

Glasgow Life carries out statistical analyses of the information which it holds in order to monitor its performance in various areas and in order to improve service delivery. These anonymised statistics, once they cannot identify any individuals, may be published or shared with other organisations or individuals. Glasgow Life also conducts research and assists other bodies to conduct research using the information we hold. If an individual elects to make public statements relating to Glasgow Life and Glasgow life holds information showing that these statements are incorrect, we may publicise the fact that we hold information contradicting that version. We may also seek your CONSENT to publish the contradictory information; if you decline to give us this CONSENT, we may make your refusal of this CONSENT public.

Use And Disclosure Of Staff Information

Staff information is primarily held by Glasgow Life in order to carry out its duties as an employer.  In connection with this we hold information on staff relating to ethnic background, disability etc. in order to comply with our obligations relating to monitoring equality of opportunities and discrimination legislation.  Where applicable we will hold information on trade union membership to allow for payment of union subscriptions deducted from pay and will share this information with the relevant unions to allow union these subscriptions to be collected.  We also share information where applicable with other recipients of payroll deductions such as Glasgow Credit Union or suppliers of salary sacrifice schemes such as child care voucher providers.  Earnings information is supplied to HMRC as required by law to allow for deduction of PAYE and national insurance contributions.

Staff information is used internally for data matching exercises to prevent and detect fraud, particularly in connection with benefits administration and collection of council tax, and will be shared with external bodies including the National Fraud Initiative in Scotland and Housing Benefit Matching Service run by the Department for Work and Pensions for the same or similar anti-fraud purposes.  Statistical analysis of employee information is carried out to support business management forecasting and workforce planning.  Information will generally be released to the police and other criminal investigation agencies on request in relation to specific investigations; provided Glasgow Life is satisfied that legitimate grounds exist for doing so.  It will also be released to government agencies able to compel disclosure such as the Child Support Agency if we receive an appropriate request.  Information will be released to courts and employment tribunals in relevant cases and may be shared with external legal advisers in these cases.  It will also be released in response to an order from a court with competent jurisdiction to make such an order.  It may also be released (without CONSENT) in response to investigations by external regulators such as Audit Scotland, the UK and Scottish Information Commissioners and Scottish Public Services Ombudsman.

The Council also holds information on behalf of, and as a data processor for Glasgow Life.  Glasgow Life is responsible for determining how to use such information, including making decisions on whether to release it. The Council may be required to release such information in response to a court order even where it holds it on behalf of Glasgow Life; Glasgow Life will be informed of any such court orders.  Information relating to staff disciplinary cases will be shared between the Council and Glasgow Life, where relevant, such as where someone is employed by both the Council and Glasgow Life.  Where relevant, information acquired by investigatory sections within Glasgow Life will be shared with the Council and Glasgow Life may also receive similar information from the Council.

If Glasgow Life receives a freedom of information (“FOI”) request which includes information relating to staff, then as a general rule such requests will be refused (or the staff information removed/redacted from the response) unless it relates to more senior members of staff.  For this purpose, staff on grade 9 or above (defined by Glasgow Life as its leadership grades) count as more senior staff, those on lower grades do not  However, each request will be considered on its own merits and in line with guidance issued by the Information Commissioner and Scottish Information Commissioner.  Even for more senior staff, we will not release information which does not directly relate to that member of staff’s work activities, so information such as home address will not generally be released.  Staff will be consulted ahead of any decision to release their personal data in response to an FOI request.  The same principles apply to information relating to former members of staff (subject to the caveat that Glasgow Life may be unable to readily contact such individuals to seek their views on disclosure and will generally reach a decision without making contact).

Information Sharing With the Council and Arms Length External Organisations

The Council has established a network of wholly and partly owned Arms Length External Organisations (“ALEOs”) which now provide services to and on behalf of the Council.  Each of these is registered as a data controller in its own right and has its own privacy statement describing how it uses personal information.  While ALEOs have operational independence from the Council, it is expected that their privacy statements and policies will align to those of the Council.

In order to provide services, it is necessary at times for Glasgow Life to share information with the Council and, potentially, it’s ALEOs.  Each ALEO will generally act as a data controller of information it needs to provide these services although in some cases (most notably for Service Glasgow LLP, trading as ACCESS, which provides IT services to the Council) the ALEO will be acting as a data processor to the Council, with the Council remaining responsible for decisions on how and why information is processed.  Service users should be informed whenever their information will be passed to the Council or an ALEO (other than one acting as a data processor on behalf of Glasgow Life) and their CONSENT sought for this in most cases.   Glasgow Life, the Council and it’s ALEOs will share information with each other without CONSENT for purposes related to the prevention and detection of fraud or other crime, and some staff information may also be shared without CONSENT (see the section on Use and Disclosure of Staff Information above for more information on this).  Some information relating to service users will also be passed to the Council in order to allow the Council to monitor the activities of Glasgow Life, although where possible this will be done using aggregated and anonymised information.

The Council also acts as a data processor on behalf of Glasgow Life in relation to back office functions such as payroll and other HR services.  In these cases, Glasgow Life remains responsible for determining how to use such information, including making decisions on whether to release it. The Council may require to release such information in response to a court order even where it holds it on behalf of Glasgow Life; Glasgow Life will be informed of any such court orders.  

Media Enquiries

Glasgow Life has a press office and deals with significant amounts of queries from the press and media.

In responding to these queries, our press officers apply the same rules as all other officers of Glasgow Life and will only release information about individuals in line with this privacy statement and Glasgow Life's approved Information Use and Privacy Policy. In terms of this approach, personal information held by Glasgow Life will only be released to the media if there are compelling reasons for doing so.

If it appears to us that a journalist is in full possession of the facts regarding a particular issue, then Glasgow Life may, where appropriate, confirm to the journalist that the story is indeed correct (or we will correct any inaccuracies, provided that the inaccuracies are not so large as make us reasonably suspect that the journalist is merely guessing what has happened and does not have all the information.) We will not, as a general rule, release personal data where the journalist is merely speculating as to what might have happened. However if a member of the public approaches the media about an issue relating to Glasgow Life, it is assumed that they are willing to have their case dealt with publicly and Glasgow Life will respond accordingly.

If an individual elects to make public statements relating to Glasgow Life and Glasgow Life holds information showing that these statements are incorrect, we may publicise the fact that we hold information contradicting that version. We may also seek the CONSENT of that person to publish the contradictory information; if they decline to give us this CONSENT, we may make their refusal of this CONSENT public.



CCTV

Glasgow Life’s properties are covered by a variety of CCTV (closed circuit television) systems. These systems are designed primarily to protect the buildings from theft or vandalism; some systems are also intended to help protect staff.

Many of the cameras are connected to an alarm receiving centre operated on behalf of Glasgow Life by Community Safety Glasgow. Community Safety Glasgow do not use the footage from these cameras for any purpose other than to assist Glasgow Life in safeguarding its property and protecting the people within the buildings in question, and Glasgow Life remains data controller of this information. Glasgow Life-operated CCTV systems are all clearly labelled with distinctive black on yellow signage with the image of a CCTV camera, Glasgow Life's mark, and the caption "Preventing Crime. Promoting public safety."

Glasgow life has adopted a CCTV policy that stipulates that CCTV Recordings (“Recordings”) will normally be retained for a period of 7 days, unless there is a particular reason for specific Recordings to be retained for longer.  There is, however, an exception to this policy for museums (and some other sites), for which Recordings will normally be retained for 31 days.  It is therefore important that there are no unnecessary delays in processing requests for Recordings to ensure they are not deleted in the period between the request being received and actioned.

Where a request for Recordings is received within the normal retention period the individual must provide sufficient information to enable the Recordings to be located i.e. location of camera and date of recording.  The individual should also be informed that a fee of £10 may be charged (this is not refundable even if no Recordings are located).  Where the individual has been asked to make their request in writing or provide proof of identification, they should be informed that, as the normal retention period for Recordings is 7 days (or, in the case of museums and some other sites, 31 days), the Recordings will be kept for a further 14 days only from the date of the request for identification.  Failure to submit a valid subject access request with the necessary identification within 14 days will result in the Recordings being wiped.

An individual has a right of access to their own personal data but does not have any rights to Recordings of other individuals.  Therefore any images or data relating to other individuals captured in the same Recordings must be digitally removed by pixellation or blurring of the images.  External companies normally carry this out and payment for this is the responsibility of Glasgow Life.

Police officers or the courts may request access to Recordings for evidential purposes.  The courts are not required to complete a form demonstrating the right to request the footage although police officers are required to complete and submit Glasgow Life’s standard Section 29 Release form for approval before they will be given CONSENT to view or remove Recordings.  The relevant Glasgow Life staff member will determine whether or not they are satisfied that the justification provided by police officers is sufficient to allow access to the Recordings. 

All queries regarding public space CCTV should be directed to Community Safety Glasgow.

RESEARCH  

Glasgow Life undertakes significant amounts of research internally where we analyse the data we hold in order to measure our performance (and/or the performance of our contractors or partner organisations). We also allow external organisations and academic researchers access to information to allow them to undertake research. In each case we carefully assess the request to access our data and assess the request against our Information Use and Privacy Policy. If access is granted we ensure that agreements are put in place with the researchers covering security and use of the information, and we only pass the minimum information to allow the research to be carried out. This generally means we will not disclose personal identifiers such as name or address, but in many cases there is still sufficient information to create the possibility that someone could be identified from the data released. We therefore approach the release of this information as though the information contained personal identifiers and put safeguards around the disclosure appropriate to the release of personal data.

Some of the research we are undertaking or involved in requires active participation. In these cases those involved in the research will have been contacted directly to seek their CONSENT both to involvement in the research and to the exchanges of information associated with the research. However some research is population-based and seeking CONSENT would fatally undermine the research methodology. In these cases we do not seek CONSENT. Details of the research will be publicised on Glasgow Life’s website and where possible an express reference to the research will be included in communications issued by Glasgow Life to those affected.  There are no planned external research projects at this time.

TICKETING AND BOX OFFICE

FUNDRAISING

EVENTS

SPORT

COMMUNITIES AND LIBRARIES

MUSEUMS

YOUNG GLASGOW (YOUNG SCOT/KIDZ CARD)

COMMUNITIES

ARTS, MUSIC AND CULTURAL VENUES

CONVENTION BUREAU

MARKETING

What is ‘DIRECT marketing'? What is ‘DESTINATION marketing'?

Direct marketing is marketing which is directed at specific individuals as opposed to, for example, a newspaper advertisement which would be marketing but not direct marketing as it isn't directed at you as a particular individual.

Controlling your personal information for direct marketing purposes:

You may choose to restrict the collection or use of your personal information for direct marketing purposes in the following ways:

•Whenever you are asked to fill in a form on the website or on an application or competition form or otherwise, look for the box that you can click to indicate that you do not want the information to be used by anyone for direct marketing purposes   
•If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us. Every email we send has an unsubscribe option.

E-Mailing (ALSO SEE WEBSITE PRIVACY POLICY)

When you send us an email, we use your email address to thank you for your comment and/or reply to your enquiry, and we will store your communication and our reply for any future correspondence in accordance with our data retention policy. Beyond our initial reply, we will never use your email address to send you any unsolicited message or information, nor will we share it with or sell it to anyone else for such use.

When you accept to receive information about our services, promotions, newsletters, press releases, and/or offers, we use your email address and any other information you give us to provide you with the information or other services, until you ask us to stop (using the 'unsubscribe' instructions provided with each email communication and/or on the site where you signed up, and/or as we otherwise provide), or until the information or service is no longer available.

Competitions, Promotions and Offers

From time-to-time we may provide you the opportunity to participate in various promotions, offers or competitions eg our website, emails, newsletters, magazines or through our Social Media platforms. If you participate, we will request certain personal information from you. Participation in these promotions, offers or competitions is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name, address, telephone and or card/membership number where the competition is open to individual services cardholders/members only).  We use this information to be able to inform the prize winner of the promotion, competition or offer and for cardholders/members to verify their eligibility and to update our cardholder/member contact records accordingly.

 

Customer Relationship Management

Glasgow Life provides many services within a number of supporting systems. Each of the systems has marketing preferences. To provide the most efficient service to all our customers on all our services we can offer, we have integrated all our marketing customer data into a single solution marketing system. This allows us to view and maintain a more complete and accurate individual customer record of contact information, transaction history, improved marketing permissions management, and more robust customer interaction history. It can also help meet our requirements of fulfilling the Data Protection Act when providing information for Subject Access Requests.

Social Media

Some of our website(s) use the social plugin "like” button, widgets such as “share this” button, or Facebook Pixels, provided by the social network facebook.com, operated by Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA ("Facebook"). The plugin is identifiable by the bluish and white Facebook logo "f".

By visiting our website(s) your browser (and in some cases your mobile device) establishes a connection to Facebook servers. Facebook directly transfers the plugin, widget or other similar technologies (like pixels) content from your browser (or mobile device), enabling Facebook to receive information about you having accessed the respective page of our website(s). We have no direct influence on the data gathered by these technologies.

If you are logged into Facebook, your visit can be assigned to your Facebook account. If you interact with the plugin by clicking “Like” the corresponding information is transmitted from your browser directly to Facebook and stored by it. Even if you are not logged into Facebook, there is possibility that the plugin transmits some data eg your IP-address to Facebook.

For the information on the purpose and scope of data collection and processing by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook's privacy policy: http://www.facebook.com/policy.php or  https://www.facebook.com/about/privacy/advertising

If you are a Facebook member and do not want Facebook to connect the data concerning your visit to our website with your member data already stored by Facebook, please log out of Facebook before entering our website(s).

Glasgow Life does not intentionally upload any personal information to Facebook for the purposes of targeted marketing e.g. using Facebook services like Custom Audiences.

For more information about how online behavioural advertising works and what you can do to manage your privacy, please visit the pan European Interactive Digital Advertising Alliance (EDAA) website: Your Online Choices (www.youronlinechoices.eu).

Filming and Photography   (this is relevant to the event filming notice)

Glasgow Life uses photographs and video footage of a wide range of people in all and any media to promote the services, mainstream activities and facilities that it provides (the “Specified Purposes”).  Such media include (but are not limited to) posters, leaflets, printed publications, display stands and banners, reports and pages on the Glasgow Life website. None of the materials are produced for sale, and the photograph or video clip of you/your child will only be used in materials produced or commissioned by Glasgow Life for the Specified Purposes and in accordance with data protection legislation from time to time in force.  Glasgow Life shall only store copies of the photograph or video clip for the Specified Purposes

CONSENT 

If you agree that Glasgow Life may use photograph/video footage of you or your child (and you confirm that you are the parent/carer of the child) for the Specified Purposes in our CONSENT form, we will store your contact details on our database in case we need to contact you.  The contact details you provide will only be used in the event of a query regarding the photograph or video footage. Your details will not be used for any other purpose and will not be disclosed to anyone outside of Glasgow Life except where you also signify agreement on our CONSENT form to us submitting photographs to local and national press to generate publicity for an event or service.

Some of our events we provide are attended by large numbers of people. To obtain individual CONSENTs for photography or video footage in these cases would be almost impossible. Where we film or photograph at these locations, we will instead display notices that this location is being used for photography/filming.  By entering these locations you give CONSENT to being included in any of our filming or photography activity and that any images of you captured may also be used by us or any of our partner organisations for promotional purposes.  If you have any concerns you can raise this with our staff on site.

Your Rights under the Data Protection Act 1998

You have a number of Rights under the Data Protection Act 1998 (“the DPA”) in regards to how your data is processed. As a minimum you should be given ‘fair processing’ information which is sometimes referred to as a ‘privacy’ notice or statement. Glasgow Life’s online ‘privacy statement’ constitutes our general approach to how we process personal information in accordance with our approved Information Use and Privacy Policy. There may be other more specific privacy notices or statements you will have been given or made readily available for a service you are obtaining from us, e.g. in an online or offline form, public notice or orally, etc. You have the following fundamental rights in respect to how your data is being processed. 

Subject Access Requests (Requests for copies of your personal data that we hold)

  • The right to request (in writing) a copy of your personal data held by us, given to you in a permanent form. You are entitled to be given if requested:

    • A description of the personal data being processed

    • A description of the purposes for which it is being processed

    • A description of any likely recipients

    • Any information on the source of this data

    • Where any automated decisions have been taken, the ‘logic’ behind these decisions

Automated Decisions

  • You have the right, by notice, to prevent any automated decisions.

Direct Marketing

  • You have the right to request in writing to cease, or not begin, processing of your personal data, for the purpose of direct marketing.

 

Preventing Processing

  • You have a right to request to cease processing personal data if you believe it would cause you ‘damage’ or ‘distress’.

Rectification, Blocking, Erasure & Destruction

  • By order of a court, you have the right to have any inaccurate personal data or expression of opinion which appears to be based on that inaccurate data, to be rectified, erased, blocked or destroyed.

Complaints to the Commissioner

  • You have the right to ask the Information Commissioner to carry out an ‘assessment’ of the processing of your personal data if you believe it directly affects you (causes ‘damage’ or ‘distress’) to determine whether the processing is undertaken in accordance with the law.

Compensation for Damage/Distress

You may be entitled to compensation if you suffer ‘damage’ or ‘distress’ as a result of a contravention of any provision of the Data Protection Act 1998 in regards to the processing of your personal data.

How do I make a Subject Access Request?

You must:

  • make the request in writing (you can use our form here)

  • supply information to prove who you are (to eliminate risk of unauthorised disclosure)

  • supply appropriate information to help us to locate the information you require.

The request should include details and provide evidence of who you are (e.g. driving licence, passport, birth certificate, utility bills). You should also provide as much detail as possible regarding the information you wish to access (e.g. where and by whom information is believed to be held, specific details of information required).

This list is not exhaustive and other forms of identification may be acceptable.  At least one form of identification should contain the same signature that is on your application form or letter and one must include a photograph. Please note that Glasgow Life will not be able to comply with any requests received unless satisfactory proof of identification is provided.

You can attend the Mitchell Library (Tel: 0141 287 2999, address below) with your original documents and we will be happy to take copies while you wait.  If you would prefer to send us copies of your documentation, please provide us with certified copies to either address below.  A professional person or someone well respected within your community, such as a solicitor, social worker, teacher or police officer, can certify documents by signing and dating them.

You are not required to state WHY you wish to access the information: the details we require are merely those that will aid the efficient location and retrieval of information.

Once we receive a Subject Access Request, all efforts will be made to fully comply within 40 days. In any event, you will receive all the information that has been located and can be released within 40 days and an explanation for any information that cannot be provided at that time.

Upon receipt of a request, we must provide:

  • information on whether or not the personal data are processed

  • a description of the data, purposes and recipients

  • a copy of the data

  • an explanation of any codes/jargon contained within the data.

We must respond to Subject Access Requests within 40 days.

 

DATA PROTECTION AND INFORMATION RISK OFFICER,

Glasgow Life,

220 High Street,

Glasgow G4 0QW

OR

FAO: DATA PROTECTION AND INFORMATION RISK OFFICER

Glasgow Libraries,

The Mitchell Library,

North Street,

Glasgow G3 7DN

(If you would like to bring your documentary evidence in person rather than post certified copies an address above, you can take them to the Mitchell Library to be copied)

Website Privacy Policy

You may also wish to read our Data Protection Statement

Our websites are operated and controlled by Culture and Sport Glasgow, a Scottish Charity (No SCO37844) incorporated under the Companies Acts and limited by guarantee (Registered Company No SC313851), having its registered office at 220 High Street, Glasgow G4 0QW and operating under the name ‘Glasgow Life’.

In terms of the Data Protection Act 1998, Culture and Sport Glasgow (referred to in this privacy policy as "Glasgow Life", "we" or "us") is the data controller of personal data (information relating to identifiable living individuals) collected or obtained by or through our websites.

Any personal data collected through our websites will be treated as confidential under the principles of the Data Protection Act 1998.

Glasgow Life is registered under the Data Protection Act 1998 and as a data controller (notification number Z9838695); the register entry can be inspected at www.ico.org.uk

Our websites do not automatically capture or store personal information, other than logging the user's IP address and session info such as the duration of the visit and the type of browser used. This is recognised by the Web server and is only used for system administration and to provide statistics which Glasgow Life uses to evaluate use of the site.

You will be asked to provide some personal information if you wish to register with our websites and take advantage of the additional features that registered users can access. This information will be restricted to details which may help us provide better services to you through our websites. Our registration process includes, but is not limited to, the following: your name, address, telephone contact number and e-mail address (this may vary depending on the nature of the services you are registering for). By providing this information you CONSENT to Glasgow Life using these details to help provide you with services, answers to queries or information about events and other programmes which may be of interest to you as appropriate. All marketing information will include an option for you to opt out of any future, similar correspondence. We do not contact children under 12 without the CONSENT of a legal parent or guardian.

You will be required to agree to Glasgow Life using your details in this way when you complete the registration process. Similarly, if you wish to contact Glasgow Life through our websites you may be asked to provide some limited personal information to enable us to respond to your question or comment. Comments may be submitted without providing personal details - we will not, however, be able to respond to you unless you provide a means of contact. You do not need to provide us with personal information simply to browse the site.

Information Security

We believe that keeping personal information secure is one of our most important responsibilities.

We maintain all necessary physical, electronic and procedural security to help safeguard personal, sensitive and payment data against loss, misuse or alteration. Third parties that provide us with support or services may also receive personal, sensitive or payment information, and we require them to maintain security measures similar to ours with respect to such information.

When we request customers to enter sensitive information via a form on a web page we operate, such as credit card number, it is encrypted and protected with SSL encryption and processed through a reputable payment processor.

While on a secure page, such as our customer data capture forms, the lock icon at the bottom or top of web browsers, e.g. Mozilla Firefox or Microsoft Internet Explorer, becomes locked, as opposed to unlocked or open, when you are just 'surfing'.

While every effort is made by us to secure transmission of data eg using SSL we cannot be held responsible for the security of your data while it is being transmitted over the internet and through servers that are out of our control. We strive to protect your personal information but we cannot ensure or warrant the security of any information you transmit to our website or services. Any data transmissions you make over the internet are done so at your own risk. Once we receive your data transmission, we make are responsible for ensuring the security and privacy of your personal data on our systems.

 

Email Newsletters

We offer an email newsletter service (subscription service via our websites and other available external channels e.g. online or offline application form, etc), which is provided to inform you about selected services and offers we make available. Users can subscribe through our online automated process (or our other offline communication channels) should they wish to do so but do so at their own discretion.

Subscriptions to our email campaign newsletters are taken in compliance with the Privacy and Electronic Communications Regulations 2003 (as amended). All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties (except our approved contracted email service provider; with your explicit CONSENT; or where required or permitted by law) nor shared with companies / people outside of Glasgow Life. Under the Data Protection Act 1998 you may request a copy of personal information held about you. 

Email marketing campaigns published by Glasgow Life contain tracking facilities within the actual email. Subscriber activity is tracked and stored in our Customer Relationship Management system which manages our email newsletter campaigns for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity. This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.

In compliance with the Privacy and Electronic Communications Regulations 2003 (as amended) subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign.

Social Media Platforms (Facebook, Twitter, etc)

Communication, engagement and actions taken through external social media platforms that we utilise, and users participate on, are bound to the terms and conditions, and the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. We will never ask for personal or sensitive information through social media platforms, and encourage users wishing to discuss sensitive details to contact us through our standard primary communication channels, such as by telephone or in writing.

Some of our websites use social plugins which help share web content directly from web pages to the social media platform in question. Users are advised before using such social plugins we utilise that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Payment Facilities

If you use the online payment facilities offered on any of our websites, the details you provide will be stored on a secure server operated by Glasgow Life's online banking partner. Glasgow Life does not have access to these details. The banking partner will only inform Glasgow Life about the identity of the person making payment and the nature of the payment.

Under 12

If you are aged 12 or under, please get your parent or guardian's permission before you provide personal information on any of our websites

Content Accuracy on our Websites

The information provided on our websites is believed to be accurate at the time of writing but Glasgow Life accepts no liability for the contents and anyone relying on these contents does so at their own risk. Nothing on our websites is to be construed as binding Glasgow Life or constituting an offer on behalf of Glasgow Life.

Scope of Policies

This privacy policy only covers the Glasgow Life website at www.glasgowlife.org.uk (and the other websites operated or managed by us where they link back to this privacy policy) Links within this site to other websites are not covered by this policy and individuals should check the terms of the privacy policy of those other sites for their terms. Glasgow Life is not responsible for the content of external websites.

 

List of our websites we Operate or Manage

Glasgow Life operates a number of websites and use social media platforms that may refer back to this privacy statement. The websites we currently manage include:

  1. Glasgow Life – www.glasgowlife.org.uk

  2. Celtic Connections – www.celticconnections.com

  3. Aye Write – www.ayewrite.com

  4. Merchant City Festival – www.merchantcityfestival.com

  5. Glasgow Mela – www.glasgowmela.com

  6. World Pipe Band Championships – www.theworlds.co.uk

  7. Glasgow Loves Christmas – www.glasgowloveschristmas.com

  8. Tramway – www.tramway.org

  9. Emirates Arena – www.emiratesarena.co.uk

  10. Glasgow Concert Halls – www.glasgowconcerthalls.com

  11. Tickets Glasgow – www.ticketsglasgow.com

  12. Glasgow Venue Hire  - www.glasgowvenuehire.org.uk/

  13. Altogether Glasgow - www.altogetherglasgow.com

  14. Family History – www.glasgowfamilyhistory.org.uk/

  15. Velocity - www.velocityglasgow.org.uk/

  16. Glasgow Club - www.glasgowclub.org

  17. Glasgow Club bookings - www.gcbooking.glasgowcitycouncil.co.uk

  18. Glasgow Club social media posts - www.glasgowsporthub.com

  19. Glasgow Museums Collections Navigator –http://collections.glasgowmuseums.com

  20. Glasgow Life Photo Library – www.csgimages.org.uk

  21. Glasgow Life Virtual Mitchell – www.mitchelllibrary.org

  22. Glasgow Libraries Catalogue – http://libcat.csglasgow.org

  23. Kelvin Hall – www.kelvinhall.org.uk

The above list may be amended or added to from time to time to take account of changes in the websites we operate and/or manage.

Domain Names we Own

There are a number of domain names we manage that also refer back to our main website at: www.glasgowlife.org.uk

Changes to this Website Privacy Policy

Any changes to this Privacy Policy will be posted on our websites (at www.glasgowlifeorg.uk).

 

Cookies

What is a Cookie?

Cookies are small data files which are placed on your computer, mobile or other handheld devices as you browse through our websites. On our websites, cookies are used to remember information about your browsing history, for example, the on-line resources you use, the pages you visit and how often you visit them.  

Types of cookies

  • ‘Session’ cookies remain in your browser during your browser session only, ie until you leave the website.

  • ‘Persistent’ cookies remain in your browser after the session (unless deleted by you).

  • ‘Performance’ cookies collect information about your use of the website, such as webpages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous. Performance cookies are used to improve how a website works.

  • ‘Functionality’ cookies allow the website to remember any choices you make about the website (such as changes to text size, customised pages) or enable services such as commenting on a blog.

How we Use Cookies on our Websites

Our websites uses cookies to help improve the users experience while visiting our websites. Where applicable our websites use a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user's computer / device.

Our websites use cookies to collect anonymous information about how well the site is performing via Google Analytics.

Some of our site(s) also uses Google Remarketing cookies to provide us with information on visitor demographic and interests, and Facebook cookies, which are used to deliver relevant adverts to Facebook users. We may also use Facebook pixels to learn whether someone who has seen an ad on Facebook has later visited our website as well as Twitter widgets to tailor the content of our site with recent Twitter feeds. We do not use cookies which collect data that makes your personally identifiable, or that collect any personal information without your express permission to do so.

Google Analytics

Please note – We do not collect personal information via Google Analytics.

Our websites use Google Analytics, a web analytics service provided by Google, Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating your use of our websites, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our websites.

By using our websites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Facebook

Our websites use Facebook plugins and pixels provided by Facebook Inc., 1601 S. California Avenue, Palo Alto, CA 94304, USA ("Facebook").

We sometimes use Facebook plugins and pixels on our websites, however we do not store this information; it is stored by Facebook. The information is stored in such a way that information about individuals is not tracked, nor can individuals be targeted directly.

For the information on the purpose and scope of data collection and processing by Facebook, as well as your rights in this respect and settings options for protecting your privacy please visit Facebook's privacy policy: http://www.facebook.com/policy.php or https://www.facebook.com/about/privacy/advertising.

Twitter

Please note - We do not collect personal information via Twitter.

Our websites use Twitter widgets, a social plugin service provided by Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (“Twitter”).

We sometimes use Twitter widgets on our websites, however we do not store this information; it is stored by Twitter. The information is processed in such a way that information about individuals is not tracked. The Twitter website widget is a social plugin that enables us to tailor content on our site(s), either by one or more of the following Twitter plugin features:

  • showing recent tweets on our site(s)

  • showing followers and counts

  • showing interactive follow button

  • help tailor content and suggestions

For the information on the purpose and scope of data collection and processing by Twitter, as well as your rights in this respect and settings options for protecting your privacy please visit Twitter’s links below:

Twitter supports Do Not Track

About tailored suggestions

Twitter’s use of cookies and similar technologies

Twitter Privacy Policy

Please note - if you decide not to accept cookies you will need to up-date your cookies preferences before you will be able to enter the Glasgow Life site(s) - see below for further information on how to do this. You will only be asked to do this once but can amend your preferences at any time. Restricting your browser cookie settings could affect the functionality of our website and other external websites you may visit on the internet.

Disabling Cookies

If you would prefer to disable Cookies you need to change the browser settings on your computer to reject Cookies.

Microsoft Internet Explorer

  1. Choose “Tools” from the menu at the top of your browser

  2. Click on “Internet Options”

  3. Click on the “Privacy tab”

  4. Select the setting that best suits your needs

For Mozilla Firefox

  1. Choose “Tools” from the menu at the top of your browser

  2. Click on the “Privacy” icon

  3. Select the setting that best suits your needs

Google Chrome

  1. Click the spanner icon on the browser toolbar.

  2. Select “Settings”

  3. Select “Show advanced settings”

  4. Select the setting that best suits your needs

Safari

  1. Choose “Preferences” from your toolbar

  2. Select “Privacy”

  3. Select the setting that best suits your needs

Further information:

Scottish Information Commissioner's page on cookies

Information Commissioner's Office

All About Cookies

Copyright

The contents of these pages are copyright © Culture and Sport Glasgow 2016.

You may download to a local hard disk and print extracts from our websites for your personal use. You may also re-copy downloaded extracts to others provided you do not do so for profit. Reproduction of part or all of the contents in any form is prohibited unless for personal use.

None of the content of our websites may be copied or otherwise incorporated into or stored in any other websites, electronic retrieval system, publication or other work in any form (whether a hard copy, electronic or other).

For the avoidance of doubt, framing of this site or any part of it is not permitted without express permission.

 

Disclaimer

Glasgow Life makes no warranties, representations or undertakings about:

  • any of the content of our websites (including, without limitation, the quality, accuracy, completeness or fitness for any particular purpose of such content); or

  • any content of any other websites referred to or accessed by hypertext link through our websites ("third party site")