In keeping with new General Data Protection Regulation, it's important that we make clear how and why we use your personal data. This policy sets out all you need to know but please always feel free to give us a bell or drop us an email if you want to chat it through.
In a nutshell, the SMP works on the basis that it has a legitimate interest to use the data provided by its members to support members' links with Malawi. Members can choose at any time how much information on their Malawi link is publically available on the SMP website, and how we communicate with them.
The privacy and security of personal data is very important to us and we take the responsibility seriously.
The SMP exists to inspire the people and organisations of Scotland to be involved with Malawi in an informed, coordinated and effective way to the benefit of both nations.
The SMP (the data controller) is a not-for-profit company, limited by guarantee, registered in Scotland: SC294378. We are a registered charity in Scotland: SC037048. Any reference to ‘us', ‘we', ‘our', ‘data controller' is in reference to the SMP.
We collect personal data in connection with specific activities such as registration or membership requests, booking onto an event, volunteering, conducting research, employment etc.
Personal Data collected may comprise:
- Your title
- Your name
- Your contact details which include email, postal address and telephone number
- Individuals applying for youth membership will be asked for their date of birth, but this is purely to establish that they are in the correct membership category
- Your SMP membership number, once assigned to your member record, is personal data
- Your payment details where necessary
Personal data provided by you
This is information you give when interacting with us, for example when joining as a member or registering for an event, applying for a job, taking part in research on our website or through other social media functions on our website, entering a competition, promotion or survey, or by corresponding with us (by phone, email or post). We will only ask for relevant information to enable us to fulfil our obligation to you or provide the service requested. The exact type and quantity of information we collect and how we use it depends on why you are providing it.
For members, we only ask for information relevant to our work and to the membership category applied for. For example we ask for details about the work carried out in Malawi so that we can help establish connections both in Scotland and in Malawi.
Personal data created by your involvement with us
Your activities and involvement with us will result in personal data being created. This could include details of how you’ve helped us by volunteering or being involved with our campaigns and events.
Sensitive Personal Data
This includes, but is not limited to, racial or ethnic origin, political belief, sexual orientation. At times we’ll collect sensitive personal data for Equal Opportunities monitoring but this is only ever analysed at an aggregate level.
We may request data from you specifically related to volunteer activities you undertake (e.g. references, criminal records, details of emergency contacts, medical conditions etc.). The data requested will be related to the activity undertaken. The information will be retained for legal or contractual reasons as per our Retention policy.
Children's Personal Data
Youth membership is open to those aged 14-24. Details of youth members under the age of 18 are not published in the online member directory.
Youth members under the age of 18 will not receive direct marketing. We will send items related to membership such as member updates or youth-focused events or competitions.
Personal data provided to us will be used for the purpose or purposes at the time of collection or registration where appropriate, in conjunction with any preferences you express. If asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may need to provide your personal data.
Prospective SMP Members
When we receive an application, an online membership profile is created and this normally contains the identity of the applicant. We will only use the information we collect to process the application and to provide further information about subscriptions and services after the application is successful. Prospective members can cancel their membership application at any time by emailing .
Ineligible members will have their data permanently deleted within 6 months of an application being made. Eligible members who have not been successful in their application will have only the necessary information stored as needed to document this decision by the Board. The data will be kept in accordance with our Retention Policy and then deleted.
Current SMP Members
Current members have an online membership profile which can be accessed and edited at any time by logging on to their profile. We will use the information we collect to administer members and process payments, to provide services and to keep members informed of Scotland-Malawi news and related matters, not limited to but including:
- Welcome email with details of how to activate your Membership page on the SMP website
- Any required information about payment notifications such as Standing Orders
- Weekly bulletins containing Scotland-Malawi related news, events and updates from the SMP and our members
- Relevant forum updates based around Areas of Partnership, such as Health or Education
- Renewal notices and administration to do with your membership, including any changes to the terms and conditions of your membership e.g. price changes
- Information we are obligated to sending you detailed in the Memorandum and Articles of Association, such as information related to our Annual General Meeting
- Research and surveys related to your membership experience and updates on benefits
- We will occasionally contact you with information, via email or post, related to our news, events, campaigns or issues we feel our members may be interested
Former SMP Members
Once a person’s membership with the SMP has ended, we will retain the membership profile in accordance with the requirements of our retention schedule and then delete it.
Non-members who use SMP products, services and activities
We have to hold the details of the people who have requested a service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might send information about people who have registered for an event to the venue for the event so they know who is at the venue in case of an emergency.
When people do subscribe to our services or register for our events, they can cancel their subscription or registration at any time and are provided with an easy way of doing this.
The SMP Online Membership Database
The SMP Online Membership Database (“Database”) is a central, online resource of our members.
The purpose of this Database is to facilitate communication between members in Scotland. Contact details of members are published in this Database as feedback has suggested members find this very useful, but this is not mandatory for membership. When applying for membership we ask permission to publish your name, email address and contact telephone number in the directory. Not giving this permission does not affect the membership in any way.
Consent for this information to be shared publicly can be given, amended and taken away at any time. You may also opt out of appearing in this Database altogether. Please email or call 0131 529 3164 to amend your preferences.
Recruitment and employment
In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including ‘sensitive’ personal data, from job applicants and employees (see Sensitive Data section above). In certain circumstances, we may process personal data or sensitive personal data without explicit consent. Further information on what data is collected and why it is processed is given in the SMP Staff Handbook.
In order to process your information we must have a lawful reason for doing so. The four most common reasons why we process your data are as follows;
- Legitimate interest
- Legal Obligation
We will only use your personal data on the relevant lawful grounds as detailed above. We will use your data in accordance with the lawful basis we collected it. Below are the main uses of your data which depend on the type of relationship we have with you and how you interact with our services, websites and activities.
The SMP relies upon Legitimate Interest to help us provide the services linked to your membership and to keep you abreast of information and events pertaining to your membership and the Partnership. The SMP considers that, as a network celebrating and supporting civic links between Scotland and Malawi, members will be interested in Scotland-Malawi news and related matters. Each communication channel has a clear Opt Out option and preferences can also be updated by emailing .
Single Issue Use
We may request your personal data in order for us to provide you with a single use service. This may include, but is not limited to, information about an event or campaign. We will contact you about this specific use and may send you reasonable further communications about this single issue. We may also request explicit consent for other items such as contacting you about membership or other products.
Subscribers to our bulletin will only be contacted with relevant Scotland-Malawi content such as, but not limited to, campaigns, events, news and member benefits. We will never pass your personal data, outside of contracted services, to any third party outside of the SMP.
Partners working in relevant Areas of Partnership may be sent information relevant to a particular Forum or focus group. It is possible to opt out of these communications at any time through the provided Opt Out option on the communication or by emailing .
In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with one or more third party supplier, for example, to pension providers and HM Revenue & Customs.
In most cases, personal data will not be disclosed without consent, except where it is in the interests of the data subject and other situations as required by law e.g. the prevention and detection of crime.
We may be required to pass your data on to a third party to carry out a service, for example our weekly bulletin platform, but will only do this when necessary and the security of your data can be guaranteed.
You can update your personal data at any time. This includes the right to withdraw your consent to any of our marketing communications and to any of your membership details being displayed on our website.
If you want to update or amend your personal data or marketing preferences you can do so in the following ways:
Online: Visit https://smp.thirtyninesteps.co.uk/login/ and sign in.
Call us: (Office opening hours week days 9am to 5.30pm) 0131 529 3164. We can amend your contact details. Communication preferences must be done in writing or by yourself online.
Scotland Malawi Partnership
(We will update your member record within 10 days of receipt of request)
Information system and data security is imperative to us to ensure that we are keeping our customers, members, volunteers, employees and contractor safe. Your membership is managed by SMP staff only and your data transferred to third parties for processing only when necessary to fulfil membership or service requirements.
Certain necessary personal information that we collect from our members or service users will be transferred to, and stored at, third parties outside the UK (such as our newsletter provider Mailchimp). This is necessary to supply our service to you and is only retained as long as is necessary for the membership or service.
We will keep your personal information for limited and appropriate periods of time and as long as is required by applicable law/contractual obligations.
The SMP does not have any Closed Circuit Television (CCTV). However we run a number of events in locations that are not owned by us and their CCTV is managed by those properties. This includes events taking place within the Edinburgh City Chambers.