When we collect your Personal Data 

We collect Personal Data about you in a number of ways, such as:  

• When you register as a user, you will be asked to complete a registration form on our External Learning Platform. 
• When you complete learning on the External Learning Platform, we will gather learning attainment data linked to your personal profile. 
• We will also use your personal data to create anonymous activity statistics, from which you cannot be identified. 

What types of Personal Data we hold 

Here are some examples of the type of information we may process about you. 

• Personal details e.g. name, email address 
• Your employment details specifically the name of your employing organisation or school
• Learning attainment data 

Why we need your data

Scottish Water needs to process data to create a user account on our external learning hub to enable you to access and complete the learning content.  

Who can access it

• We ensure all access to Personal Data within our systems is restricted to the appropriate people where relevant to their job e.g. SW External Learning Platform Administrator 
• Our Internal Audit function has unrestricted access to all Personal Data where appropriate, such as during a fraud investigation; 
• Privileged access to Personal Data is enabled for approved staff where they are required to provide systems administration, data management, analytics, security or access management; 
• Robust privileged access controls are in place and verified on a regular basis; 
• Personal Data sent outside Scottish Water by email has attachments secured. 

How we process Personal Data  

• We digitally capture your Personal Data and process it in our systems e.g. user registration form; 
• We use your Personal Data digitally through email and communication tools (most typically via the External Learning Platform) 
• We process your Personal Data digitally through unstructured files such as learning attainment spreadsheet reports; 
• Verbally when we are interacting with you; 

Who we share your data with

Scottish Water will need to share certain personal data, as appropriate. Your information will only be shared if it is necessary or required for example;

• We will generate and share learning attainment data with relevant internal Scottish Water project teams where this information is required to authorise access, for example to a system or site. It may also be shared with your named employing organisation or school as part of your full learning attainment record. This will be the organisation or school you enter and maintain within your personal profile. 
• In order to verify access to a SW system or to demonstrate learning completion around incident learning. 

How long do we keep hold of your data

• We aim to retain Personal Data only for as long as we need it for the purpose it was provided; 
• We aim to retain Personal Data for inactive users for no longer than 4 years and will request your explicit consent if we wish to retain your data for longer; 

You can request to remove your user profile and personal data held on our external learning platform at any point by emailing SwExtlearnhub@scottishwater.co.uk. 

Transfers of personal data outside of the EU.

We aim to never share your Personal Data with any third party that is not within the EU but where we do we ensure that the agreements contain robust contractual clauses so as to protect the data.  We do have individuals who are out with the EU who can access our systems that contain Personal Data. This access is only approved for the purposes of system maintenance and support.

We host our data within Scottish Water data centres or out with Scottish Water on other UK or EU data centres. We have robust contractual arrangements with third parties addressing data protection.

Changes 

From time to time, we may amend this notice to reflect changes in our business, changes in the law, to make it easier to find, or for other reasons. We will do this by posting the amended notice on our External Learning Platform. You will be notified of the change when you next logon and required to acknowledge the Privacy Notice prior to continuing into the platform.  

Your Rights 

Individuals to whom data relates are called “data subjects” and have rights that include: 

• to request from us a copy of any Personal Data we hold about you; 
• to fix Personal Data that is not accurate; and 
• to remove Personal Data in certain circumstances, where this does not breach any legal, regulatory, safety, security or core operational requirement. 

We aim to meet all data subject rights requests within a 30 day period and we will not charge you for this. 

You have the right to make a formal complaint to the Information Commissioner’s Office (ICO).  The ICO is the UK data privacy regulator, you can find out more information on your rights on their web page https://ico.org.uk/your-data-matters/

Contact Us Regarding your Data

• Email us:  – corporatedatacompliance@scottishwater.co.uk 
• Write to us: – Head of Corporate Data & Compliance, Scottish Water, Castle House, Carnegie Campus, Dunfermline, KY11 8GG 
• If you have an informal complaint write to: Data Protection Officer, Scottish Water, Castle House, Carnegie Campus, Dunfermline, KY11 8GG or email DPO@scottishwater.co.uk