Privacy & Cookies

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Cookies, MG ALBA and your privacy

MG ALBA is committed to preserving the privacy of all visitors to www.mgalba.com (the “Website”). We know that you care how information about you is used and shared and we appreciate your trust in us to do that carefully, sensibly and lawfully.

Please read the following privacy policy to understand how we use and protect the information that you provide to us (together with any other privacy policy/notice we may provide).

By using the Website, you agree to the collection, use and transfer of your information under the terms of this policy. If you do not accept the terms of this policy you must leave this Website immediately and you may not use any of the services we provide on the Website.

This Website is not intended for children and we do not knowingly collect data relating to children.

Important Information and who we are

Data controller: MG ALBA

MG ALBA is the operating name of Seirbheis nam Meadhanan Gàidhlig (the Gaelic Media Service) a body established pursuant to section 183 of the Broadcasting Act 1990 and section 208 of the Communications Act 2003. We are the data controller and responsible for your personal data.

Data Protection Officer

We have an appointed data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Our full details are:

Full name of legal entity: Seirbheis nam Meadhanan Gàidhlig (the Gaelic Media Service)

Email addressdpo@mgalba.com

Postal address: DPO, MG ALBA, 54 Seaforth Road. Stornoway, Isle of Lewis, HS1 2SD

Telephone number: 01851 705 550

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

The information we collect

Information that we collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect:

  • Device and technical information

For example, as you interact with our Website, we may automatically collect: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website (“Technical Data”) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

  • Information you give to us (and when you talk about us)

We will collect further personal data (including name, username, email address, phone number, address, work address and similar data) if you contact us by phone, email, through one of our social media platforms or otherwise.

If you mention MG ALBA out with the Website (such as on a social media platform, on other websites or media), we may collect that information.

In certain circumstances we collect “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). This could be, for example, where you provide dietary information or access requirements ahead of attendance at an event. This sort of personal data may also be provided by you in communications made to us, when you participate in an MG ALBA project, or are photographed or video is made of you in an audience or at an event.

We do not usually collect any information about criminal convictions and offences (unless you provide this information to us, or it is required for our safeguarding, employment and/or contractor procedures).

Changes to the Privacy Policy

We keep our Privacy Policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

How is your personal data collected?

 

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms (online of offline) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • interact with us, such where you enquire about MG ALBA or our services;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey;
    • attend an event;
    • participate in one of MG ALBA’s projects;
    • appear on our CCTV; or
    • give us some feedback.
  • Automated technologies or interactions. As stated above, we may also collect data from and about you through automated technologies or interactions. For example, as you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our section on cookies below [LINK TO COOKIES SECTION] for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including analytics providers based outside the UK.

How we use your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where it is necessary for reasons of public interest.
  • Where it is necessary for archiving purposes.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us via email or phone.

It may also be the case that an “exemption” applies when we process data. For more on this please see your rights below in the Legal Rights section.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Lawful basis for processing

To manage our relationship with you, which could include, for example: to deal with your requests, complaints and enquiries; to deliver our services and provide you with information about them;  to notify you about changes to our terms or privacy policy

(a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests and obligation to fulfil a task or perform a function in the public interest (including to keep our records updated and to study how our programmes and services work and are used) (d) Necessary for reasons of substantial public interest (e) Consent (in limited circumstances and only where appropriate)

To carry out MG Alba’s statutory purpose (to secure the broadcast or transmit of high quality programmes in Gaelic) and/or any of its statutory functions

(a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests and obligation to fulfil a task or perform a function in the public interest (d) Necessary for reasons of substantial public interest (e) Consent (in limited circumstances and only where appropriate)

To administer and protect our organisation and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security, to prevent fraud and in the context of a reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Necessary for our legitimate interests and obligation to fulfil a task or perform a function in the public interest (including to keep our records updated and to study how our programmes and services work and are used; to develop our organisation and the programmes created; to study how our programmes/services are being used, to develop them, and to inform our marketing strategy) (b) Consent (in limited circumstances and only where appropriate)

To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our organisation and staff, and to inform our marketing strategy)

To help us understand what kind of services you might use; to make suggestions and recommendations to you about goods or services that may be of interest to you

(a)Necessary for our legitimate interests (to develop our programmes/services and grow our organisation) (b) Consent (in limited circumstances and only where appropriate)

Purpose/Activity Lawful basis for processing

To process data from CCTV

Primarily necessary for our legitimate interests and obligation to protect members of the public and our staff, and to act in the public interest in assisting the detection and prevention of crime.

To research and innovate

(a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests and obligation to fulfil a task or perform a function in the public interest (d) Necessary for reasons of substantial public interest (e) Consent (in limited circumstances and only where appropriate)

To archive and preserve content

(a) Performance of a contract (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests and obligation to fulfil a task or perform a function in the public interest (d) Necessary for reasons of substantial public interest

More Information About Our Privacy Policy

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will get your express opt-in consent before we share your personal data with any company external companies for marketing purposes.

Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our section on Cookies below.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

International Transfers

We do not usually transfer your personal data outside the UK. Whenever we do transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for persona data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Disclosures of your personal data

We may share your data with the parties set out below (for the purposes set out in the table “Purposes for which we will use your data” above):

  • Internal third parties (other entities within MG ALBA who act as joint controllers or processors)
  • External third parties such as:
    • Service providers (such as those providing IT, archiving and systems administration services);
    • Professional advisers (including lawyers, bankers, auditors and insurers);
    • OFCOM, HM Revenue & Customs, the Scottish Government, regulators, the police and other authorities;
    • Parties with whom we are working on projects and initiatives to further our statutory purpose (for example, the BBC);
    • Parties from who we receive funding.
  • Where MG ALBA is re-structured or parts of our organisation are merged or transferred into another organisation.
  • The public (but only when you make something public or an exemption applies, such as the journalism, academia, art and literature exemption).

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example we will retain recorded footage indefinitely, as this is required in the interests of preserving unique footage which is of cultural significance and is in accordance with our statutory aim.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

  • request access to your personal data.
  • request correction of your personal data.
  • request erasure of your personal data.
  • object to processing of your personal data.
  • request restriction of processing your personal data.
  • request transfer of your personal data.
  • withdraw consent.

For more information on your rights please visit the Information Commissioner Officer’s website (www.ico.org.uk)

If you wish to exercise any of the rights set out above, please contact the MGA DPO on dpo@mgalba.com or by phone on 01851 705 550.

 

Please be aware that it may also be the case that the law details we are unable to help you exercise your rights. This typically occurs if an “exemption” applies when we process your personal data. An example exemption is where if data is processed for journalistic, academic, artistic or literary purposes – this relieves MG ALBA from certain obligations under UK GDPR.

 

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

What are cookies?

Cookies are small text files left on your computer by many websites. They are generally used to provide you with a good experience when you browse our Website, and also allow us to improve our site. In some cases they are used so that sites can remember you as you move around on the internet. For instance, when you add books to your basket on Amazon, a cookie is used to make sure those are the books you end up buying when you move to the check-out. Some cookies, however, are used by sites in ways which may affect your privacy. They may (for example) allow you to be tracked across the internet and use information about your browsing habits to show you certain targeted adverts.

MG ALBA makes very sparing use of cookies.

Essential and non-essential cookies

Essential

MG ALBA uses some cookies that are necessary to help make our website function (for example to determine whether or not a visitor to our website has accepted the cookie consent box or whether or not a visitor to our website is a robot).

Non-essential

MG ALBA also uses cookies that are not essential to the site’s functioning (for example Google Analytics). If you are using cookie-blocking software you may block these cookies; although some minor functionality may be affected.

We use three third-party services that may leave cookies on your site: Google Analytics, Twitter and Facebook.

Google Analytics is widely used by many sites. MG ALBA use it to find out how many people come to the site each week, what pages they visit, and (just as importantly) don’t visit. It is done anonymously: we have no way of identifying who you are, what you’re called, where you live (although we do get an indication of which countries our users come from) or any other “personal” data.

Since we embed content from Twitter and Facebook within our sites, you may also have cookies from these two companies set on your computer as a result of visiting MG ALBA. These cookies are governed by the policies of Twitter and Facebook, and they pass no information about your online activities to MG ALBA. They can easily be identified by the domains from which they originate.

At any time you may prevent these non-essential cookies being set by using the “privacy settings” button which can always be found at the bottom right of our pages.

More info

For any questions or concerns you may have about our use of cookies, please email the MG ALBA webmasters at comms@mgalba.com