Privacy Policy

The Northern Lighthouse Board (NLB) – Website Privacy Notice

This is the Privacy Notice of The Northern Lighthouse Board (NLB). In this document, “we”, “our”, or “us” refer to The Northern Lighthouse Board (NLB).

As the General Lighthouse Authority for Scotland and the Isle of Man, the NLB has responsibility, subject to certain provisions, for the superintendence and management of “all lighthouses, buoys and beacons” throughout Scotland and the Isle of Man including “the adjacent seas and islands….” within and beyond territorial waters.

The Commissioners of Northern Lighthouses consists of the Lord Advocate and the Solicitor General for Scotland; the Lords Provost of Edinburgh, Glasgow and Aberdeen, and the conveners of the Councils for Highland, and Argyll and Bute; the Sheriffs Principal of all the sheriffdoms in Scotland; a person nominated by the Lieutenant Governor of the Isle of Man and appointed by the Secretary of State; and up to five co-opted Commissioners.

Our head office is at 84 George Street, Edinburgh EH2 3DA

Introduction

  1. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
  2. We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
  3. We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
  4. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
  5. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read Data Protection – A guide to your legal rights to privacy
  6. Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
  7. If you are not happy with any of the information in this notice, please leave the website.
  8. The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.

If the basis changes, then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

  1. Information we process because we have a contractual obligation with you

    When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

    In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

    We may use it in order to:

    1. verify your identity for security purposes
    2. sell products to you
    3. provide you with our services

    We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

    Additionally, we may aggregate this information in a general way and use it to provide class information. For example, to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

    We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

  1. Information we process with your consent

    Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including making requests under the Freedom of Information Act, job opportunities, or our products and services, you provide your consent to us to process information that may be personal information.

    Wherever possible, we aim to obtain your explicit consent to process this information. For example, by asking you to agree to our use of cookies. For more information, please see our cookie policy.

    Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

    Except where you have given us your consent to use your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

    We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

    You may withdraw your consent at any time by instructing us at enquiries@nlb.org.uk. However, if you do so, you may not be able to continue to use our website or our services.

  2. Information we process because we have a legal obligation

    We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

    For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
    This may include your personal information.

Specific uses of information you provide to us

  1. Complaints regarding content on our website

    If you complain about any of the content on our website, we shall investigate your complaint.

    If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

    Free speech is a fundamental right, so we have to decide whose right will be obstructed: yours, or the person who posted the content that offends you.

    If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

  2. Job application and employment

  3. If you send us information in connection with a job application, we may keep it for up to one year in case we decide to contact you at a later date.

    If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment ends, we will keep your file for six years following the year in which your employment terminates, before destroying or deleting it.

  4. Sending a message to our support team

    When you contact us either by telephone, through our website by e-mail or via social media, we collect the data you have given to us in order to reply with the information you need.

    We record your request and our reply in order to meet the legal obligations of NLB.

    We keep personally identifiable information associated with your message, such as your name and email address so we can track our communications with you to provide a high quality service.

  5. Complaints

    When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.

    If your complaint means we need to contact another person, we may decide to give some of the information in your complaint to that other person. We do this as infrequently as possible, but it is ultimately our decision as to whether we give the information, and if we do, what that information is.

    We may use the information to provide periodic reports to management. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but we will never do this in a way that could identify you or any other person.

  6. Requests under the Freedom of information Act (FOIA)

    When we receive an FOIA request, we record all the information you have given to us. We use that information to answer your request.

    If your request means we need to contact some other person or organisation, we may decide to give some of the information contained in your request to that other person or organisation. We do this as infrequently as possible, but it is ultimately our decision as to whether we give the information, and if we do, what that information is.

    We may use the information to provide periodic reports to management. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but we will never do this in a way that could identify you or any other person.

    For more information, please see our FOIA policy on our website.

Use of information we collect through automated systems when you visit our website

  1. Personal identifiers from your browsing activity

    Requests by your web browser to our servers for web pages and other content on our website are recorded.

    We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

    We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

    If combined with other information we know about you from previous visits, the data could possibly be used to identify you personally, even if you are not signed in to our website.
    For more information, please see our cookie policy.

Disclosure and sharing of your information

– Access to your own information

  1. Subject Access Requests

    • 13.1. At any time, you may review or update personally identifiable information that we hold about you. You may send a request to our HR Department.
    • 13.2. On receipt of your request, without delay and at the latest within one month of receipt we will provide the required information, unless your request is too complex, requires additional time to access all sources or too numerous, when we might need to delay sending you the information by up to an additional two months.
    • 13.3. If we need to extend the deadline for provision, we will tell you of our intention within one month of receiving your request and explain why the extension is necessary.
    • 13.4. We may in very limited circumstances refuse to provide you with the information requested. If so we will, within a month, explain the grounds for not doing so, and remind you of your right to complain to a supervisory authority if you don’t agree.
  2. Removal of your information

    If you would like us to remove personally identifiable information from our website, please contact us at enquiries@nlb.org.uk. This means you might not be able to use our full service.

  3. Verification of your information

    When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

  4. Encryption of data sent between us

    We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

    Whenever information is transferred between us, you can check that it is done by using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

  5. How you can complain

    • 17.1. If you are not happy with our Privacy Notice or have a complaint, please email us the details at enquiries@nlb.org.uk and include ‘Complaint’ in the title of your email. We will then try to resolve it.
    • 17.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
    • 17.3. If you are still dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. You can do this at https://ico.org.uk/concerns/
  6. Retention period for personal data

    Except as otherwise mentioned in this Privacy Notice, we keep your personal information only for as long as required by us:

    1. to provide you with the services you have requested
    2. to comply with other law, including for the period demanded by our tax authorities
    3. to support a claim or defence in court
    4. for archiving in the public interest
    5. for scientific research
    6. for journalistic endeavours
    7. for statistical analysis
  7. Compliance with the law

    We have written this Privacy Notice so that it complies with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, please let us know.

    However, ultimately it is your choice as to whether you wish to use our website.

  8. Review of this Privacy Notice

    We may update this Privacy Notice from time to time. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

    If you have any questions regarding our Privacy Notice, please contact us at the following address:

    Compliance Officer
    Northern Lighthouse Board
    84 George Street
    Edinburgh
    EH2 3DA