THE ORGAN DONOR REGISTER AND THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you have registered to donate organs or tissue via the registration form on this site or registered not to donate organs or tissue via the opt out registration form (or used the relevant forms to update your details or to remove your registration to donate), your data is sent to NHS Blood and Transplant (NHSBT) in order to ensure the correct information about you and your donation decisions is stored in (or removed from) the NHS Organ Donor Register (ODR).
NHSBT is a special health authority that provides blood and organ donation services to the NHS, looking after donation services across the UK. NHSBT operates the ODR and has been formally delegated by Scottish Ministers as the organisation responsible for the register in Scotland under the Human Tissue (Authorisation) (Scotland) Act 2019.
The majority of NHSBT’s data processing is necessary under Article 6(e) and 9(h) of GDPR, which allows NHSBT (a public authority) to process personal data for the performance of its functions or in the public interest and for the provision of health care. NHSBT also has obligations under The Human Tissue (Quality and Safety for Human Application) Regulations 2007 and The Quality and Safety of Organs Intended for Transplantation Regulations 2012, to ensure that all organ transplants are fully traceable from donor to recipient. This is an essential requirement to deliver safe clinical care.
Additionally, the Human Tissue (Authorisation) (Scotland) Act 2019 governs the sharing of data from the register and means that information held on it can only be disclosed to people involved in the donation process, such as medical staff, and people who are consulted about the donor’s views, who are usually family members.
Registration on the Organ Donor Register is based on your explicit consent. This means you can remove your consent at any time should you change your mind.
1. WHO WE ARE
The Scottish Government is the devolved government for Scotland and has headquarters at St Andrew’s House, Regent Road, Edinburgh, EH1 3DG.
2. HOW WE USE YOUR INFORMATION
This privacy statement explains how the organdonationscotland.org website collects and uses personal information about you to provide you with services. In general terms, organdonationscotland.org collects and uses personal information about you to:
- provide you with services, activities or online content, to provide information about them and to deal with your requests and enquiries.
- provide you with the most user-friendly online navigation experience.
- we may also show you relevant advertising on third party sites.
- use IP addresses and device identifiers to identify the general location (country or city) of users to block disruptive use, and to establish the number of visits from different countries.
- for analysis and research purposes so that we may improve the services offered by organdonationscotland.org. This can include using geo-demographic information from external sources, where this helps us ensure we are making something for everyone.
- we may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
2.1 WE COLLECT FROM YOU WHEN YOU:
- visit our website (including cookies, IP addresses, hostnames and search engine).
- use the registration forms to join or leave the Organ Donor Register (see top of page).
- send us a story for online use.*
- use our social media channels (Twitter, Instagram, Youtube and Facebook).
- If you contact us, we collect your email address, contact phone number and any other personal data contained in your message. If you contact us asking for information, we may need to contact other public bodies to find that information. Once you have received a reply, we will keep a record of your message for a maximum of three months for reference and audit purposes, after which it will be deleted unless otherwise required in order to stay in contact with you about supporting the work of organdonationscotland.org.
The data submitted will be recorded and stored securely in the website databases.
*This data will be used solely to display the related content on the website. Your data will not be used for any contact or marketing purposes, unless by your express permission and will not be passed on or shared with third parties in any way.
2.2 LINKS TO THIRD PARTY WEBSITES
2.3 GOOGLE ANALYTICS & DOUBLECLICK
At an advertiser's discretion, Google Analytics data may be examined in concert with data about organdonationscotland.org advertisements that have been shown using the Google Display Network or DoubleClick for Advertisers. Thus, organdonationscotland.org can understand how anonymous users interacted with the advertiser's website after seeing organdonationscotland.org advertisements.
Organdonationscotland.org may use this data to inform and optimise our advertising or awareness raising campaigns. Users may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or visitors may opt out of our use of Analytics by visiting the Google Analytics Opt-out page.
2.4 GOOGLE ANALYTICS & REMARKETING
Third party vendors, including Google, may show organdonationscotland.org advertisements on sites on the internet.
We may also use analytics data to serve advertisements based on a user's prior visits to our website, as well as to develop remarketing lists for customised campaigns (Remarketing Lists for Search Ads).
2.5 SOCIAL MEDIA
Organdonationscotland.org uses a variety of social media channels and any data captured by organdonationscotland.org via these channels will be done with your consent.
Social channels we use can be found below:
We use the Facebook Tracking Pixel fbp on this website. This Cookie is placed by Facebook. It enables the website to measure, optimise and build audiences for advertising campaigns served on Facebook. In particular, it enables us to see how our users move between devices when accessing the website and Facebook, to ensure that the Facebook advertising is seen by our users most likely to be interested in such advertising by analysing which content a user has viewed and interacted with on the website. To opt-out please see https://www.facebook.com/ads/preferences.
3. WHEN WILL ORGANDONATIONSCOTLAND.ORG CONTACT ME?
Organdonationscotland.org may contact you in relation to any service, activity or online content to ensure that organdonationscotland.org can deliver services or in relation to any correspondence we receive from you or any comment or complaint you make to organdonationscotland.org.
4. YOUR RIGHTS
You have a right of access to any personal data we hold about you, by making a Subject Access Request (SAR).
In addition, if you believe that the data we hold is inaccurate or incomplete you can ask us to update our records. If you are unhappy with the way in which we process your personal data you can request that we stop or restrict the processing we complete using your personal data or ask us to delete the personal data we hold about you.
In some circumstances we may not be able to comply with your request. This is because some of these rights are conditional and can only be applied in certain circumstances and/or where there is no compelling reason to continue to process your personal data.
The Data Protection Officer
Data Protection and Information Assets Team
You can also report any concerns here: https://ico.org.uk/concerns/handling/.