Privacy Policy

1.  Introduction

This Privacy Notice applies to all personal data processed by Loch Insh Old Kirk (LIOK). LIOK is a Scottish Charitable Incorporated Organisation which is administered and regulated by the Office of the Scottish Regulator (OSCR).  Its registration number is SC054632.

If you have any questions about your personal data or its use, please contact Pete Lockyer via the contact form on the website.

2. Purpose of this Privacy Notice

The purpose of this Privacy Notice is to set out in detail how and where we collect your personal information through your use of this website and otherwise, how we use it and why. It states your rights to access your data and to control how it is used. It also refers to the relevant UK data protection legislation, currently the General Data Protection Regulation ((EU) 2016/679) (GDPR) and describes the steps that we are taking to ensure that we comply with it regarding your personal data.

Our Privacy Notice is founded on three main principles:

Transparency: We are committed to giving you clear and detailed information on when and why we collect your personal information and how we use and store it.

Lawfulness: We are committed to protecting data by collecting, using and storing personal information in a way that complies with the law.

Fairness: We are committed to fairness in all our dealings with personal information. Your trust is very important to us, and we will do our utmost to keep your data safe and secure. We will never sell your personal details to anyone or to share them without your knowledge or consent.

Our approach to data privacy can help you to make informed decisions about whether and how you wish to engage with us and to be in control of how your data is held.

3. The Processing of your Personal Data

This policy provides information about how the LIOK uses (or "processes") personal data about individuals including:

- Friends and Members of LIOK

- families who have relations buried in the cemetery and their friends

- staff, including employees, contractors, casual workers, and volunteers

- donors and supporters

- visitors and other individuals connected to the LIOK and the wider community.

4. What data LIOK processes

As part of its operations, LIOK may process a wide range of personal data about individuals, including by way of example:

- names, addresses, telephone numbers, email addresses and other identifying contact details;

- preferred method of communication, which includes your preferences as to how you would like us to communicate with you;

- event attendance;

- bank account and payment card details

- transaction and donation data which includes details about payments from donors and methods of donating, for example, Direct Debit donations and Gift Aid claims;

- correspondence with friends, members, event participants, contractors, and volunteers;

- profile data, which includes particular interests, feedback and survey responses and other information about how you use our website, and our events and products;

- images of individuals attending events, and your preferences regarding photographs used on social media and other publicity materials.

5. How the LIOK collects personal data

Generally, LIOK receives personal data from the individual directly. This may be via a form (on-line or hard copy), or simply in the ordinary course of interaction or communication.  Otherwise, data can be provided by third party service providers who credit and identity check donors and their source of funds for money laundering purposes. Data may also be collected from publicly available resources, for example as part of donor wealth screening or from research carried out on Charitable Trust and Foundation boards.      

6. Why LIOK needs to process personal data

LIOK needs to process (and where appropriate share with third parties) personal data about individuals for several purposes as part of its operations.

- To organise and manage meetings, events and social engagements for the community, visitors to the Spey Valley, and other interested parties.

- To record dietary requirements of event attendees;

- To maintain relationships with the community and donors, including direct marketing of fundraising activity;

- For the purposes of donor due diligence, and to confirm the identity of prospective donors and their background, including donor wealth screening;

- To promote LIOK and its activities;

- To inform of any change to our website or services;

- To make use of photographic images and videos;

- For security purposes, including storing CCTV footage;

- For regulatory and legal purposes and to comply with its legal obligations;

- For regulatory record keeping/compliance purposes.

7. Who has access to personal data and third parties

For the most part, personal data collected by LIOK will remain stored on the LIOK database and will be processed by appropriate individuals only in accordance with access protocols (i.e. on a ‘need to know’ basis).  Data may include:

- appropriate contractors;

- professional advisors (e.g. lawyers and insurers);

- government authorities (e.g. HMRC)

On occasion we will include links to third parties on our website or in other communications, such as newsletters. Where we provide a link it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any personal data.

Finally, in accordance with Data Protection Law, some of LIOK processing activity is carried out on its behalf by third parties, such as IT systems, web developers, researchers, or cloud storage providers.

8. How we keep personal data

The LIOK will retain personal data securely and only in line with how long it is necessary to keep for a legitimate and lawful reason.

We do our utmost to ensure that all reasonable steps are taken to make sure that your data is treated and stored securely, either electronically or printed.

Typically, the legal recommendation for how long to keep files is up to 7 years. A limited and reasonable amount of information will be kept for archiving purposes, for example data of historic value and interest, such as photographs, lists congregation and records of baptisms, weddings, and funerals, and attendees at events. Where you have requested, we no longer keep in touch with you, we will need to keep a record of your request in order to fulfil your wishes (called a "suppression record").

Please contact [email protected] if you have any questions about record retention or archiving.

9. When we may disclose your information

We will not disclose your personal information to any other party other than in accordance with this Privacy Notice and in the circumstances below:

- Where we are required by law to disclose your personal information.

- To further fraud prevention and reduce the risk of fraud.

10. Keeping in touch and supporting LIOK

LIOK will use the contact details it has been given by friends and members of the community to pursue our legitimate interests for the purposes of running LIOK, and where these interests are not overridden because processing your Personal Data prejudices your interests or fundamental rights and freedoms under data protection law.

We will use data to keep individuals updated about the activities of LIOK, including by sending updates and newsletters by email and by post, and by making contact by telephone and on social media.

The way we keep in touch will be by:

- Contacting friends and members by post, e-mail, telephone, or in person to promote and raise funds for LIOK;

- Collecting information from publicly available sources about individuals’ occupations and activities, to maximise LIOK’s fundraising potential. We do this carefully and do not use solely automated processing or profiling, to respect individuals’ rights under data protection law.

You can update your contact preferences (for example, by post, phone, or email) via the link in emails from LIOK, or by contacting Pete Lockyer via the contact form on the website.

11. Your rights under data protection law

Data protection law gives you various rights. These are:

- Access: to obtain access to, and copies of, the personal data that we hold about you;

- Rectification: to require us to correct the personal data we hold about you if it is incorrect;

- Erasure: to require us to erase your personal data;

- Restriction: to request that we restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);

- Portability: to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller;

- Object: to object, on grounds relating to your situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights, including a right to object to fund-raising or direct marketing purposes.

12. Data accuracy and security

LIOK will keep all personal data as up-to-date and accurate as possible. Please tell the LIOK of any changes to important information about you, such as contact details or changes in tax status in relation to donations, as soon as possible.

The LIOK will take appropriate technical and organisational steps to endeavour to ensure the security of personal data it holds about individuals. All volunteers with access to the database, and in some cases, with restricted access, will be made aware of this Policy and their duties under Data Protection Law.

13. Queries and complaints

If you have any queries or comments, or you believe that LIOK has not complied with this policy or data protection law, please contact the data controller by contacting Pete Lockyer via the contact form on the website or by writing to: Data Protection, LIOK SCIO, Peter Lockyer, Banchor Mains, Newtonmore, PH20 1BP.

If your comments or queries are not resolved, you can also contact the ICO, although the ICO recommends that steps are taken to resolve the matter with the SCIO first: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone: 0303 123 1113 Website: https://www.ico.org.uk.

LIOK Privacy Notice - October 2025
Next Review - October 2027