Open Book Privacy Policy

1. Who Are We?

Open Book is a Scottish charitable incorporated association (Charity Number SCO43827) with a registered office at 11 Tipperlinn Edinburgh EH10 5ET. We are governed by “Trustees” who have various legal duties under charity legislation. Some of these Trustees are also involved in the day-to-day operation of the charity (whether as an employee or otherwise) and are termed “Directors”. We employ a small number of permanent staff (“Employees”).

Each year we organise and run over 1,000 shared reading and creative writing sessions for a diverse range of participants across Scotland from a wide variety of different settings.

In addition, we arrange visits for various groups to book festivals and other literary events. Individuals may also attend additional author visits and outings.

We are one of the Scottish Government’s Multi-Year Funded organisations.

This Privacy Policy provides you with information on how Open Book collects and processes information about you.

You can contact us at any time:

Open Book
11 Tipperlinn Road
Edinburgh
EH10 5ET

By email: info@openbookreading.com
By phone: 07720 052636

2. What Data We Collect and How We Use It

a. Participants

What information do we collect about Participants, what do we use it for and who do we share it with?

Our “Participants” are people who attend our groups or come along to the outings or events we organise. We hold very little information relating to Participants. Open Book sessions are facilitated by a trained individual engaged by us who we refer to as a “Lead Reader” and who is also a member of the Protection of Vulnerable Groups (“PVG”) Scheme. Lead Readers process data on our behalf.

Attendance at and reporting on sessions

Participants do not “sign in” or register with Open Book at an in-person Open Book Group session. At each session, a list of just first names of the Participants is taken by the Lead Reader and provided to Open Book as part of a report on how the session went. We call these reports “Session Reports”. In a small number of locations, Participants are also asked to register with the host organisation (for example, a public library). Such a register is kept by the host organisation and is not shared with Open Book.

Intermittently, Participants are asked to complete forms (on a voluntary basis) providing feedback on either their attendance at sessions or at outings and literary events. Such “Feedback Forms” do not request any identifiable information about the Participant (and indeed ask the Participant not to provide any).

The Session Reports and Feedback Forms (neither of which include any personal data) are used for the purpose of organising and improving Open Book group sessions, outings or events.

Email addresses

Occasionally, Lead Readers hold email contact addresses for Participants in their in-person groups to allow them to provide Participants with information in relation to group sessions, texts studied and events the Participants may be interested in. They are not used for any marketing or promotional purposes. Such addresses are only supplied by Participants on a voluntary basis. They are supplied directly to Lead Readers and are not passed on to Open Book.

Open Book also runs an online programme through the Eventbrite platform. Open Book asks Participants to book such sessions through Eventbrite. Other than responding directly to Participants who have sent an email query in relation to online (or in-person) sessions generally or in respect of their Eventbrite bookings for online sessions, Open Book does not hold Participant email data in respect of these online sessions. It does however have access to email address information in relation to those who sign up for such sessions through Eventbrite.

Participant Health Information

From time to time, information about the physical or mental health of a Participant (“Participant Health Information”) can sometimes be separately provided to the Lead Reader or Open Book on a voluntary basis by the Participant themselves, by a friend or family member, support worker, or by another organisation with which the Participant is also involved and with whom Open Book liaises for the purposes of the group sessions or outings. This is not instigated by Open Book. Such Participant Health Information may be shared by the Lead Reader with Open Book where the Participant has particular concerns or needs which require assistance from, or to be dealt with by, Open Book Employees, Directors and/or other Trustees. This Participant Health Information is used to ensure that any necessary arrangements and support for the Participant and/or Volunteer or Freelance Service Provider are in place at sessions, outings or events.

Prison population

In relation to Participants from the prison population, Open Book is not advised of the particular convictions held by the various Participants. The Prison will provide a register for the Lead Reader to complete. It remains with the Prison at all times and will provide no more information to the Lead Reader than the name of the Participant.

Photographs

If possible, we like to use photographs of Participants to promote Open Book and our work, and to help our campaigns and activities come to life. Photographs may therefore sometimes be taken of Participants at a group session or Open Book outing or event if the individual is happy to be photographed. Such photographs of Participants are only used for this purpose if specific written consent has been provided.

What is our legal basis for using information about Participants?

Our legal basis for using information about Participants is that such use is necessary for the legitimate interests of Open Book described above. In relation to photographs, use is on the basis of consent. In relation to Participant Health Information, processing is also carried out in the course of our legitimate activities as a charity.

b. Friends

What information do we collect about Friends, what do we use it for and who do we share it with?

“Friends” of Open Book are people who support our work in a range of ways (for example, by keeping track of what we are doing, coming to our fundraising events or working with us to support groups) or those who have subscribed to the Open Book weekly newsletter. Friends also include contacts from organisations that work or may wish to work with Open Book.

Friends’ names and email addresses, telephone numbers and postal addresses are collected from Friends themselves because they have asked the charity to keep in touch with them, or because they have submitted a completed Volunteer Form or signed up to the Open Book newsletter through the Open Book website or by sending a request directly by email.

Information about Friends is collected for publicity and fundraising purposes and is used to contact Friends and keep them up to date on Open Book and its fundraising aims and activities. Should Friends not wish Open Book to contact them further, we will delete their contact details from our paper and electronic records within a month of their request. Their information is only made available to Open Book Employees and Directors. It is not otherwise shared with anyone.

As with Participants, if possible, we like to use photographs of Friends to promote Open Book and our work and help our campaigns and activity come to life. Photographs of Friends at an Open Book outing or event are taken if the individual is happy to be photographed and are only used for this purpose if specific written consent has been provided.

What is our legal basis for using information about Friends?

Our legal basis for doing all of this is the consent of the individual.

c. Donors

What information do we collect about Donors, what do we use it for and who do we share it with?

Open Book currently enjoys financial support from a number of individuals who provide financial support to the charity on a one-off basis, occasionally or regularly (“Donors”).

The name, email address and postal address of Donors is mainly collected from Donors themselves because they have made financial gifts to the charity and thus provided their details to Open Book as part of the process of making a donation. Where someone has set up a direct debit or standing order, Open Book will also hold bank details.

Information about Donors is used for the purpose of complying with Open Book’s financial, legal and accounting obligations to organisations such as OSCR and HMRC and to access and utilise the donations made to further its charitable purposes. Open Book uses a trusted third-party provider to deliver certain book-keeping and accountancy services (“Accountant”). Information about Donors may also be required if such donations are used as match funding or to allow Open Book to thank Donors.

Information about Donors is only made available to Employees and Trustees of Open Book as necessary, or to third-party funders in respect of match funding (where Donor consent is obtained).

What is our legal basis for using information about Donors?

Our legal basis for using it is that we have the consent of the Donor, that it is necessary to satisfy the legitimate interests of Open Book described above, or to comply with a legal obligation (such as filing our accounts).

d. Volunteers

What information do we collect about Volunteers, what do we use it for and who do we share it with?

Open Book currently enjoys support from a number of individuals who provide support to the charity on a voluntary basis either occasionally or regularly (“Volunteers”).

Information about Volunteers is mainly collected from Volunteers themselves. They may have offered to assist the charity in some way beyond being a Friend and thus provided their details to us, or perhaps contacted us directly in response to an advertised Volunteer opportunity. Alternatively, they may have submitted a completed “Volunteer Form” via our website. We collect name, address, telephone number and email address. Volunteers may also provide a photograph for storing on their Slack profile, or bank details for reimbursement of expenses. Open Book holds references and PVG documentation for Regular Volunteers (as described below).

i. Occasional Volunteers

Those who have indicated in person or via a completed Volunteer Form that they are willing to assist at group outings and events are classed as “Occasional Volunteers”. PVG documentation is no longer obtained for Occasional Volunteers and as such the number of certificates held will decrease naturally as they will not be renewed.

ii. Regular Volunteers

Those Volunteers who have indicated in person or via a completed Volunteer Form that they are willing to become a Lead Reader are asked to complete and submit an Open Book Lead Reader Application Form and provide two referees. They also complete a PVG application form and Open Book retains the resultant PVG documentation received by it from Disclosure Scotland. If the Application Form, references and PVG documentation are satisfactory, those individuals become “Regular Volunteers”.

Information about Volunteers is used for organising Open Book sessions, events or outings, to ensure that any necessary arrangements and support for the Participant and/or Volunteer is in place at the session, event or outing, and for the purpose of safeguarding Participants.

Volunteer information is only made available to Employees, Directors and, as required, Trustees of Open Book. It will also be provided to our Accountant in respect of repayment of expenses. Personal identifiable information about Volunteers is not routinely shared with any third party. A Volunteer’s mobile number may be passed on to a venue contact or a contact who is assisting a group of Participants for the purposes of liaising in relation to attendance and assistance at an event, but this is only done with the Volunteer’s consent.

As with Participants and Friends, if possible, we like to use photographs of Volunteers to promote Open Book and our work and help our campaigns and activity come to life. Photographs of Volunteers at a group session or an Open Book outing or event are taken if the individual is happy to be photographed and are only used for this purpose if specific written consent has been provided.

What is our legal basis for using information about Volunteers?

Our legal basis for using it is usually that it is necessary for our legitimate interests and activities. In some circumstances, our legal basis is that such processing is necessary to comply with a legal obligation. We sometimes also rely on the consent of the individual.

e. Freelance Service Providers

What information do we collect about FSPs, what do we use it for and who do we share it with?

“Freelance Service Providers” (“FSPs”) are independent, self-employed individuals who provide services to Open Book on a paid contractual basis. Information about FSPs is firstly collected from FSPs themselves because they have indicated an interest in undertaking a Lead Reader or other role, either in person, by responding to an advertised opportunity, or because they have been approached by Open Book and asked to apply for the role.

These individuals are asked to complete an application process which usually involves submitting a CV and covering letter, attending an interview and, if successful, arranging a reference from two referees. They also complete a PVG application form and Open Book retains the resultant PVG documentation received by it from Disclosure Scotland.

In relation to certain groups and certain types of session, the Lead Reader role is offered on a funded basis. If the application process, references and PVG documentation are satisfactory, that individual may be offered a paid role as an FSP. If the individual accepts, they enter into a contract for the provision of services with Open Book and provide their bank account details and may also provide name, address, telephone number, photo for Slack or website profile, and email address where applicable.

The information we collect about FSPs is used for the purpose of safeguarding Participants, for organising Open Book sessions or events to ensure that any necessary arrangements and support for the Participant and/or FSP is in place at the sessions or events, or for managing and paying the FSP.

Information about FSPs is only made available to Employees, Directors, other Trustees and Open Book’s Accountant as applicable. However, an FSP’s mobile number or email address may be passed on to a venue contact or a contact who is assisting a group of Participants for the purposes of liaising in relation to attendance and assistance at an event, but this is only done with the FSP’s consent.

As with Participants, Friends and Volunteers, if possible, we like to use photographs of FSPs to promote Open Book and our work and help our campaigns and activity come to life. Photographs of FSPs at a group session or an Open Book outing or event are taken if the individual is happy to be photographed and are only used for this purpose if specific written consent has been provided.

What is our legal basis for using information about FSPs?

Our legal basis for using it is that it is necessary for our legitimate interests as described above, for the purposes of performing the contract with the FSP, or to comply with a legal obligation. Processing may also be carried out in the course of our legitimate activities as a charity. In some situations, the consent of the individual is also relied upon.

f. Submitters

What information do we collect about Submitters, what do we use it for and who do we share it with?

“Submitters” are individuals who have responded to opportunities advertised by Open Book to have their work published as part of Open Book’s Unbound Programme. Submitters provide biographical information, social media contact information along with their entry to the submission process (the “Entry”). The Entry, if successful, and its use by Open Book, is governed by a copyright licence between the Submitter and Open Book.

Information about Submitters is used for the purpose of advertising their successful Entry to Open Book’s Unbound Programme.

Information about Submitters is only made available to Employees, Directors, Trustees and our Accountant as necessary.

What is our legal basis for using information about Submitters?

Our legal basis for using it is that it is necessary for these legitimate interests and activities described above, or that it is to comply with a legal obligation.

g. Role Applicants

What information do we collect about Role Applicants, what do we use it for and who do we share it with?

“Role Applicants” are individuals who have responded to opportunities advertised by Open Book to become Employees, Trustees or Volunteers. Role Applicants generally provide CVs and covering letters containing information that is protected by law. If successful, Role Applicants become Employees, Trustees or Volunteers and their data is then governed by Open Book’s provisions dealing with that category of individual.

Information about Role Applicants is used for the purpose of identifying and engaging someone in the advertised role and to advertise their success in attaining that position. Information about Role Applicants is only made available to Employees, Directors, Trustees of Open Book and our Accountant as applicable.

What is our legal basis for using information about Role Applicants?

Our legal basis for using it is that it is necessary for these legitimate interests described above, to take steps at the request of the Role Applicant prior to entering into a contract, or to comply with a legal obligation.

3. Other Situations Involving Our Use of Personal Data

As well as the legal bases for use of personal data described in Section 2 above, less commonly, there may also be situations where we have a recognised legitimate interest to use or share personal data where there are public interest reasons for doing so (such as preventing or detecting crime, safeguarding individuals, or sharing information with public bodies when they confirm it is necessary for their official functions). In addition, in rare situations, we may need to process data when it is in the individual’s vital interests or those of another person.

4. Storing and Deleting Information

Hard copy (paper) based information is kept at our Principal Office address (which is a locked, self-contained building). The building is alarmed. Electronic information (other than the Participant email addresses) is kept within the appropriate access-controlled folder within the charity’s document management system, Slack.

As highlighted above, Participant email addresses are stored only by the Lead Reader (who is asked to keep such addresses secure) or on Eventbrite as described above.

Information is subject to regular “weeding” and is deleted in accordance with the Open Book Document Retention Policy, which sets out how long information is stored and how it is deleted. Our retention periods are driven by both legislation and business need.

5. Complaints

If you are at any point unhappy with the way that we have handled information about you, you can:

We will acknowledge your complaint as soon as possible and will investigate it without undue delay. If you are dissatisfied with the outcome of your complaint you can email the Chair of the Board of Trustees at chair@openbookreading.com. You also have the right to complain to the Information Commissioner’s Office.

Should you wish to log a complaint about our use of information about you, we will collect your name, contact details and details about the complaint to enable us to deal with your complaint and improve the way our organisation handles personal information.

This data will be shared with Open Book Employees, Directors and other Trustees, or any third parties who are involved in resolving the complaint (for example, agencies that we have partnered with).

6. Keeping Your Data Safe and Up-to-date

At Open Book we work hard to keep your data safe. Access to your data is regularly reviewed and is only accessible to the relevant Employees, Directors and other Trustees, Volunteers, FSPs or our Accountant, and only to the extent required by them to discharge their duties.

Where we use third-party individuals or organisations to collect or process data on our behalf, we carry out checks to make sure they manage the data they may have access to in accordance with the law.

7. Your Rights

If you wish to request access to the data we hold about you, correction, deletion or restriction of it, to object to our processing of it, to request a transfer of it, or to withdraw your consent to our use of it, please contact us at:

info@openbookreading.com

Please note that some of these rights only apply in certain circumstances.

To make other changes to how we contact you, please also contact us at info@openbookreading.com.

8. Changes to this Policy

We may make changes to this Privacy Policy from time to time. If we make any changes in the way we use your personal information we will make this clear on the Open Book website (www.openbookreading.com) or by contacting you directly.

Reviewed for March 2026. Next review date: 2029.