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
Guest lists are supplied by the organiser of events held at the Scottish Parliament to facilitate the registration process for guests on arrival at the parliament by Scottish Parliamentary Corporate Body (SPCB) Visitor Services. Details of guests who are invited to attend major events at the Scottish Parliament, such as the Opening Ceremony of a new session, are held in order to facilitate the event planning process.
Categories of information processed
The data used is normal category data such as the title, name, the name of the organisation the guest is representing where applicable and contact details.
We may also process *special category data for the purposes of facilitating access to the Parliament building and/or in relation to any dietary requirements for guests who are attending at an event.
*Special category personal data includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
Source of the information
Information regarding guests is provided directly by individuals themselves or by the event organiser via submission of a completed Guest List form, which is available on our website.
Legal basis for processing
Data protection law states that we must have a legal basis for handling your personal data.
The legal basis for the processing as described above is that it is necessary for the purposes of the legitimate interests of the SPCB to provide event management that facilitates secure access to the building for guests (Article 6(1)(f) UK GDPR).
For special category data, the processing is necessary for reasons of substantial public interest. The public interest is compliance with statutory equality requirements in terms of Article 9(2)(g) UK GDPR and section 10(3) and paragraph 6(1) of Part 2 to Schedule 1 to the DPA and s29(7) Equality Act 2010.
For the transfer of data to the National Records of Scotland, the legal basis is that it is necessary for archiving purposes in the public interest (Article 6(1)(e) UK GDPR, section 8(d) DPA or Article 9(2)(j) UK GDPR, section 10(1)(e) and paragraph 4 of Part 1 to Schedule 1 to the DPA).
Data sharing
Data may be shared internally where necessary with other departments and employees of the Scottish Parliament Corporate Body.
Retention of data
Guest lists for MSP-sponsored events are normally deleted 5 working days after an event has been held.
For major events, guest lists are retained until the end of the calendar year in which the event took place plus 4 years in accordance with the Scottish Parliament records management policy.
Certain significant events will go on to form part of the public record. Personal information contained within a public record will be retained in accordance with the Scottish Parliament records management policy and may be transferred to the Scottish Parliament archive at National Records of Scotland, where it will be publicly available at a point when any applied restrictions have expired.
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.
Request personal information about you that we hold
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 4 May 2023.
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 5281
(Calls are welcome through the Text Relay service or in British Sign Language through contactSCOTLAND-BSL.)
Email: dataprotection@parliament.scot
Please contact us if you require information in another language or format