2. Privacy Policy

2.1 Our approach

Privacy in everyday life is a central SCRIBE principle.

We therefore aim to collect as little personal information as reasonably possible and to avoid creating records merely because technology makes collection possible.

This policy explains what information SCRIBE may receive, why it may be used and what choices people have.

2.2 What this policy is

This policy is the privacy policy

2.3 Information you provide directly

If you contact SCRIBE by email or through a contact form, we may receive:

• your name;
• your email address;
• the contents of your message;
• attachments;
• any other information you choose to provide;
• technical routing information attached to the communication.

Please do not send unnecessary confidential, medical, safeguarding or otherwise highly sensitive information through ordinary email.

If SCRIBE later operates submissions, surveys, memberships, events or newsletters, this policy will be updated to describe the additional information collected.

2.4 Website analytics

SCRIBE may use website analytics to understand matters such as:

• how many people visit the website;
• which pages are viewed;
• broad referral sources;
• approximate device or browser categories;
• general website performance.

Depending on the analytics service and its configuration, technical information such as an abbreviated or complete IP address, device identifiers, cookie identifiers or approximate location may be processed.

SCRIBE intends to use the least intrusive reasonably available analytics configuration.

Where analytics uses non-essential cookies or similar device storage, SCRIBE will seek consent where required. Visitors should be able to reject non-essential analytics without losing ordinary access to the website.

2.5 Why we use personal information

SCRIBE may use personal information to:

• read and respond to enquiries;
• assess submissions or proposals;
• investigate correction requests or complaints;
• maintain security;
• understand website use;
• protect SCRIBE’s legal rights;
• comply with legal obligations;
• carry out another purpose clearly explained when the information is collected.

We will not use an ordinary enquiry to subscribe someone to marketing messages without an appropriate basis.

2.6 Lawful bases

Depending on the situation, SCRIBE may rely on:

• consent, where a person has freely agreed to a particular use;
• legitimate interests, such as responding to correspondence, operating the website, improving publications or protecting security;
• contract, where processing is needed to provide something a person requested or purchased;
• legal obligation, where the law requires processing;
• vital interests, in a rare emergency involving life or serious safety.

Where special-category information is received, SCRIBE will only process it where an additional lawful condition applies.

2.7 Sharing information

SCRIBE will not sell personal information.

Information may be available to service providers necessary to operate our communications and website, such as:

• email providers;
• website hosts;
• analytics providers;
• security services;
• professional advisers.

We may disclose information where:

• the person has asked or authorised us to do so;
• disclosure is required by law;
• it is reasonably necessary to establish or defend legal rights;
• there is a serious and immediate safeguarding or safety concern;
• organisational assets or services are transferred to a successor, subject to appropriate protections.

2.8 Retention

Ordinary correspondence may be retained for as long as reasonably useful for responding, maintaining records, resolving disputes or protecting legitimate interests.

Messages that have no continuing purpose may be deleted.

Analytics data is retained according to the provider and configuration identified above.

SCRIBE will periodically review retained personal information and remove information it no longer reasonably needs.

2.9 Your rights

Depending on the circumstances, you may have rights to:

• ask whether SCRIBE holds your personal information;
• receive a copy;
• correct inaccurate information;
• request deletion;
• restrict certain processing;
• object to certain uses;
• withdraw consent;
• receive portable information in relevant circumstances;
• complain to the Information Commissioner’s Office.

Rights are not absolute in every situation. SCRIBE may retain information where a lawful exception applies.

2.10 Analytics and identification

SCRIBE will try to honour valid requests concerning information that can reasonably be connected to the requester.

Some analytics information may be aggregated, anonymised, pseudonymised or stored under identifiers that SCRIBE cannot reliably connect to a named visitor. Where we cannot identify which analytics record belongs to a person, we may be unable to provide or delete that particular record.

We will not demand additional intrusive identification merely to search for data we cannot reliably connect to an individual.

Rejecting or deleting analytics cookies through your browser or the website’s consent controls may prevent or limit future analytics collection.

2.11 Children

SCRIBE’s website is intended as a general public-information resource and is not designed to collect personal information directly from children.

Children should not submit anything without appropriate support and a clear invitation from SCRIBE.

2.12 Security

SCRIBE will take proportionate measures to protect information. No email or internet service can be guaranteed completely secure.

2.13 Complaints

Privacy questions and requests should be sent to:

privacy@scribe.org.uk

2.14 Changes

This policy may be updated as SCRIBE’s services, providers or legal responsibilities develop. The current version and date will be published on the website.