- Who Are We?
- What Data We collect and How We Use It?
- Storing and deleting
- Keeping Your Data Up-to-date and Safe
- Your rights
- Changes to this Policy
- 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 currently organise and run approximately 80 regular shared reading groups, some on of which also involve creative writing. We work with a diverse range of public and community individuals across Scotland.
In addition, we arrange visits for various groups to book festivals and other literary events. Individuals may also attend additional author visits and outings.
You can contact us at any time by writing to us at:
11 Tipperlinn Road,
By emailing email@example.com
Or by calling us on 07720052636
- What Data We Collect and How We Use It
What information do we collect about Participants?
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 Lead Reader who is a member of the Protection of Vulnerable Groups (“PVG”) Scheme. On occasion, a Lead Reader may hold email addresses of some Participants where the Participants have provided these.
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 the Open Book staff and Directors as part of a report on how the session went. We call these reports “Session Reports”.
Intermittently, Participants are asked to complete forms providing feedback. Such “Feedback Forms” do not request any identifiable information about the Participant (and indeed ask the Participant not to provide any).
From time to time information about the physical or mental health of a Participant (“Participant Health Information”) can sometimes be separately provided by the Participant him or her self, 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 information tends to be shared with Open Book where the Participant has particular concerns or needs.
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.
COVID 19 has meant that many sessions have been moved from in-person to run online through the Eventbrite platform. Other than asking Participants to book through Eventbrite (or to respond directly to Particpants in relation to their bookings, Open Book does not hold Participant email data in respect of these sessions but does have control of email address information in relation to those who sign up through Eventbrite. In relation to in-person sessions resuming during COVID 19, Participants do not “sign in” or register with Open Book at an Open Book Group session. In a small number of locations Particpants are asked to provide their full name and a contact number for Test and Protect purposes. This only happens where Test and Protect requirements are managed by Open Book rather than the host organisation. In those cases sufficient information to enable Open Book to contact Participants in the event of a requirement to do so for Test and Protect purposes are held for 21 days after which they are deleted. (“Test and Protect Information”).
If possible, we like to use photographs of Participants to promote Open Book and our work and help our campaigns and activity 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 and only if specific written consent has been provided.
Using and sharing Participant Information
Email addresses are used for the purpose of the Lead Reader providing information in relation to Group sessions, texts studied and third-party events the Participants may be interested in. They are not used for any marketing or promotional purposes, or as described above in relation to on-line sessions booked through the Eventbrite platform or if the Founding Directors are copied into email communications between a Lead Reader and Participants of his/her group for administrative and logistical purposes.
The Session Reports, Feedback Forms (neither of which include any personal data) and Participant Health Information are used for the purpose of organising and improving Open Book group sessions, outings or events. Lead Readers can use them to seek additional session support if required. They are also used to ensure that any necessary arrangements and support for the Participant and/or Volunteer or Consultant (who are described below) are in place at the sessions, outings or events.
Photographs are used as described above.
Our legal basis for using information about Participants is that it is for these legitimate interests and activities of Open Book. In relation to photographs, use is of course on the basis of consent.
The Session Reports, Feedback Forms and Participant Health Information are only made available within Open Book to such staff and Directors, relevant Volunteers and Consultants (and we explain who these are below) at Open Book as is necessary for the particular purpose.
The Participant email addresses are only held by the Lead Reader and are not shared with anyone else within or outwith the charity except as described above in relation to Eventbrite bookings
Personal identifiable information is not routinely shared with any third party. Participant Health Information is not shared on an identifiable basis with any third party unless the consent of the Participant is obtained.
What information do we collect about Friends?
“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. Information about Friends is 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 Newsletter through the Open Book website or by sending a request directly by email. Friends also include contacts from organisations that work or may wish to work with Open Book. 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.
Using and sharing Information about Friends
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.
Photographs of Friends are only used as described above.
Our legal basis for doing all of this is the consent of the individual.
The information is only made available to Open Book staff and Directors. It is not otherwise shared with anyone.
What information do we collect about Volunteers?
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 because they have offered to assist the charity in some way beyond being a Friend and thus provided their details or because they have submitted a completed “Volunteer Form” which we have provided.
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’. In the past, some of these Occasional Volunteers have completed a PVG application form and Open Book retains the resultant PVG documentation received by it from Disclosure Scotland. This PVG process is no longer carried out for Occasional Volunteers as such individuals do not actually perform “regulated work” in terms of the relevant PVG legislation.
Those 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’.
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.
Using and sharing Information about 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. Our legal basis for using it is that it is for these legitimate interests and activities or that it is to comply with a legal obligation. Photographs are used as described above and the legal basis for use is the consent of the individual.
Volunteer information is only made available to staff and Directors of Open Book.
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.
“Consultants” are individuals who provide services to Open Book on a paid contractual basis. Information about Consultants is firstly collected from Consultants themselves because they have indicated an interest in undertaking a Lead Reader role either in person, by submitting a completed Volunteer Form or because they have been approached by Open Book and asked to apply for the role.
These individuals 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.
In relation to certain Groups and certain types of session, the Lead Reader role is offered on a paid consultancy basis. If the Application Form, references and PVG documentation are satisfactory, that individual may be offered a paid consultancy role. If the individual accepts, that individual enters into a consultancy contract with Open Book and provides his or her bank account details to Open Book.
Again, as with Participants, Friends and Volunteers, if possible, we like to use photographs of Consultants to promote Open Book and our work and help our campaigns and activity come to life. Photographs of Consultants 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.
Using and sharing
Information about Consultants 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 Consultant is in place at the sessions or events or for paying the Consultant. Our legal basis for using it is that it is for these legitimate interests and activities, for the purposes of performing the contract with the Consultant or that it is to comply with a legal obligation. Photographs are used as described above and the legal basis for use is the consent of the individual.
Information about Consultants is only made available to staff and Directors of Open Book.
A Consultant’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 Consultant’s consent.
- 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. The Participant email addresses are stored only by the Lead Reader (who is asked to keep such addresses secure) or on Eventbrite as described above.
The information is subject to regular “weeding” and is deleted in accordance with the Open Book Records Management Policy:
which sets out how long information is stored and how it is deleted.
Should you wish to register 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 staff and Directors at Open Book or any third parties who are involved in resolving the complaint, for example, agencies that we have partnered with.
- Keeping your data safe and up-to-date
At Open Book we ensure that the most appropriate technical controls are in place to keep your data safely. Access to your data is regularly reviewed and only accessible to the relevant Directors, staff, Volunteers or Consultants and only to the extent required by them to discharge their duties.
Where we use external companies to collect or process data on our behalf, we carry out comprehensive checks to make sure they manage the data they may have access to in accordance with law.
Your data will be hosted on servers located in Europe.
- 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 or request a transfer of it or withdraw your consent to our use if it, please contact us at:
Please note that some of these rights only apply in certain circumstances.
If you are at any point unhappy with the way that we handled your personal data, please contact firstname.lastname@example.org. You also have the right to complain about how we use your personal information to the Information Commissioner’s Office.
To make other changes to how we contact you , please contact us at email@example.com
- Changes to this policy