When you trust us with your personal data, we have a responsibility to protect it and respect it. These obligations are outlined in the General Data Protection Regulation (GDPR), which governs data protection and privacy for all individuals in the European Union.
The GDPR protects each of us as individuals, because it stops companies using our personal data in a way that we’re unhappy with, or didn’t even know about. It also puts a responsibility on these companies to keep any data they hold about us up-to-date and secure.
These principles fall very much in line with our own values on how customers should be treated. The Scotch Whisky Association is committed to protecting your privacy when you use our services or website. In this policy, we explain how and why we collect your personal data through the use of our services or website, what we do with it and what controls you have over our use of it.
Your rights under the GDPR
The privacy information must be concise, transparent, intelligible, easily accessible, and it must use clear and plain language. If you feel that we haven’t met this standard, please let us know. There’s a lot of information to convey and we’ve done our best to make it readable, but we’re keen to keep improving.
You have the right to access the personal data that we hold on you, and to have inaccurate or incomplete data rectified. In certain circumstances, you have the right to have your personal data erased (also known as the ‘right to be forgotten’), to restrict processing and to request a copy of your data in a format that you can pass to another organisation (known as data portability).
You also have the right to object to direct marketing or any processing that is based on legitimate interests. To let us know that you object, please email firstname.lastname@example.org and explain exactly what data processing it is that you’re concerned about.
For any data processing that is based on consent, you have the right to withdraw your consent at any time. To withdraw your consent, please email email@example.com and explain exactly what data processing it is that you want to withdraw your consent for.
If you have a concern about how we use your information, you have the right to lodge a complaint with the Information Commissioner’s Office.
The Scotch Whisky Association is the controller and responsible for your personal data.
Sara Jackson, Chief Operating Officer: firstname.lastname@example.org
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
What personal data do we collect and how is your personal data collected
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data, i.e. data where the identity has been removed.
(a) Direct interactions
We collect the information when you register with us, ask us to contact you, contact us, request services or information. Collected information could include your name, title, e-mail address, telephone number and/or address.
(b) Automated technologies or interactions
As you interact with our website we will automatically collect technical data (this includes your internet protocol (IP) address, your log-in data, browser type and version, time zone setting and location, browser plug-in types and versions, operating systems and platform about your equipment, browsing actions and patterns). We collect this personal data by using cookies.
How we use your personal data
We will only use your personal data when the law allows us to. We will usually use the information you have provided in the following circumstances:
- to fulfil our contractual obligations in relation to providing the goods or services you have requested
- where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g. to keep our records updated, to advance the interests of our members, to study how our services are used and to develop them further, to inform our marketing strategy, to keep our website updated, to run our business, for the provision of administration and IT services and network security)
- where we need to comply with a legal obligation.
We refer to these as the lawful bases for processing your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data although we will send you details of our products, services or information where you have "opted in" to receiving such information from us. If at any time you do not wish to receive this information, please email us at email@example.com. Otherwise, click on the "unsubscribe" link in any of the emails received from us.
You are under no obligation to provide any information, but if you do not then we may not be able to provide you with certain services or personalise your experience and tailor our services for you.
Purposes for which we will use your personal data
The Scotch Whisky Association collects, stores and processes information about you for the following purposes:
- in order to manage our relationship with you
- to be able to provide the services or information that you have requested (including member services)
- to enable you to attend events organised by us
- to enable you to complete surveys
- to administer and protect our business and the business of our members
- to administer and protect our website and
- to use data analytics to improve our website, services, marketing and user experiences.
Cookies are small text files containing information sent by a web server to a web browser, and stored on your computer, tablet or mobile phone when you visit certain web pages. The information is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser.
Our website uses the following categories of cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to remember your preferences.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website more relevant to our users.
Some of the cookies we use are "session cookies" which keep track of you while you navigate our website, and will be deleted from your computer when you close your browser. Except for essential cookies, all cookies will expire after 30 days.
To learn more about the Cookies please see www.aboutcookies.org.uk
Here is a list of the cookies used by The Scotch Whisky Association and what they are used for:
Name of Cookie
Purpose of Cookie
Collects information about how visitors use our site in an anonymous form, including number of visitors to the site, where visitors have come to the site from and the pages they visited. We use the information to compile reports and to help us improve the site
Features for sharing via Twitter
Features for sharing via LinkedIn
Features for sharing via Instagram
Instagram Cookies Policy
If you prefer to restrict, block or delete cookies from our website, or any other website, you can use your browser to do this. Each browser is different, so check the 'Help' menu of your particular browser (or your mobile phone's manual) to learn how to change your cookie preferences. Most browsers allow you to reject cookies. Blocking cookies can have a negative impact upon the usability of many websites, including our website. If you block cookies, you will not be able to use all the features on our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
When you trust us with your personal data, you expect us to keep it safe. We know that we have an obligation to you, and in law, to ensure the confidentiality, integrity and availability of our systems and the data within them. We take this very seriously indeed.
We have a number of technical and organisational measures in place that are designed to guarantee the security of the data that we hold. We carry out regular information risk assessments to ensure that they remain appropriate, effective and up-to-date. This page gives some examples of measures we currently take and explains a little bit about them.
At the SWA, data protection is everyone’s responsibility. We cultivate a working environment where privacy and security are central to decision-making, and issues are never overlooked. Here’s how we do this:
- We choose our data processors carefully. We only work with trusted partners who have appropriate security credentials. We include GDPR clauses in our contracts with suppliers.
- Staff are expected to report any data breaches they become aware of, no matter how minor, so that we can respond appropriately.
- When we begin any new project we take a ‘privacy by design’ approach, meaning we make data protection a key consideration right from the start.
- We carry out data protection impact assessments whenever they’re needed.
- Our teams are encouraged to question why we do things, which helps us to identify when we no longer need to do a certain type of data processing.
- We employ a fulltime on-site IT Officer, who has the appropriate resources and authority to implement all necessary data security measures.
- We have appointed someone in our business to take overall responsibility for data protection and privacy.
It’s important that we prevent unauthorised access to our building and the data stored within it. We take a wide variety of measures in this area, from our alarm system to the way we dispose of hard copy files. Here are some examples:
- Our office has a secure entry system. Everyone signs in and out, and all entries and exits are logged.
- Visitors must have a pre-arranged appointment with a named member of staff before they will be permitted entry to the building.
- We have on-site CCTV cameras and a 24/7 security presence.
- Access to our in-house datacentre is strictly controlled.
- We have a policy of not printing personal data without a very good reason. Printouts must never be left unsecured.
- We store a very limited amount of data in hard copy. When it is no longer needed, paper containing personal data is shredded on-site by a professional shredding company.
We protect our hardware with appropriate security measures, so that no one can access any data on them without authorisation. These measures include:
- We use encryption on all devices that are used outside the office, e.g. mobile phones and laptops. We restrict the personal data that it’s possible to store on these devices.
- Anyone working from home or outside the office must use an encrypted business laptop and connect via a secure and encrypted Virtual Private Network (VPN).
- Old hardware is securely destroyed.
Systems and software
We have security measures in place to protect the data in our systems. We regularly review them to ensure they remain at an appropriate level for the types of processing that we do and the risks involved. Here are some of the steps we take:
- We use internal Data Loss Prevention (DLP) modules to monitor all systems that contain personal data.
- We house our customer facing websites within a demilitarised zone (DMZ) and segregate the network from internal systems.
- Our websites are secured with SSL, which provides an extra layer of security for anyone who transmits data to us via our website.
- We use appropriate permission levels to ensure that datasets can only be accessed by staff members who need it for their job.
- All of the SWA team are trained on how to recognise ‘phishing’ attempts.
- We use a password management tool. Staff do not know the passwords needed to log into systems and can only access them from our office.
- We regularly test our systems to identify potential risks and areas for improvement. An external company conducts regular penetration testing and all recommendations resulting from those are followed up. Our last penetration test confirmed that our security provision was solid.
- We have our own firewall which is constantly monitored for suspicious activity.
- We have deployed corporate level Anti-Virus and Anti-Malware detection.
- The passwords that employees use to log into their accounts are stored and encrypted using one-way encryption, meaning they can’t be decrypted.
We have a robust plan in place for restoring access to data in the event of a physical or technical incident that interrupts availability. We regularly test our disaster recovery plan.
If personal data were to be accidentally lost, altered or destroyed, we would do everything in our power to recover it as quickly as we could. We replicate our critical business systems to the Microsoft Azure Cloud, allowing data restoration up to 60 seconds previous to any outages. All backups are fully encrypted and stored off-site at regular intervals.
While we cannot ensure or guarantee that unauthorised loss, use, access, alteration or disclosure of personal data will not occur, we use our best efforts to prevent this.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the section What personal data do we collect and how do we use it?
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide legal, banking, accounting, insurance and consultancy services.
- HM Revenue & Customs, regulators and other authorities based who require reporting of processing activities in certain circumstances
Where is the information stored?
We use Microsoft as our hosting provider. Microsoft is one of the leading providers and adhering to applicable privacy law –. This is necessary in order to process the information and to send you any information you have requested.
Information processed by us may be transferred by us outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How long do we keep your personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights in relation to any of your personal data we process are:
(a) the right to request a copy of the information we hold about you;
(b) a right to correct data that we hold about you that is inaccurate or incomplete;
(c) in certain circumstances, a right to request that we erase your data from our records;
(d) in certain circumstances, the right to restrict our processing of the data;
(e) in certain circumstances a right to have the data we hold transferred to another organisation;
(f) a right to object to certain types of processing;
(g) a right to object to purely automated decision making, including profiling;
(h) a right to complain to the Information Commissioner's Office.
If you wish to exercise any of the rights set out above, please contact us as follows:
Address: The Scotch Whisky Association, 1st Floor, Quartermile Two, 2 Lister Square, Edinburgh EH3 9GL, UK
Tel: +44 (0)131 222 9258 between 9am - 5pm (GMT) Mon-Fri.
- No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
- What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
- Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We are committed to ensuring that your personal data is processed lawfully, fairly and securely. If you have any questions or concerns about the way in which we process your data please contact us at the address above and we will attempt to resolve any issues you have. If you remain unsatisfied you can contact the Information Commissioner's Office, the UK regulator for data protection issues.