All information will be stored securely and is disposed in a secure manner when no longer required. Your information will be held for a specific time in order to comply with law and regulations or for any contractual obligation we may have under a Government contract which can be for a period up to seven years from the date the data was last used to process a transaction. SafeDeposits Scotland will hold data for as long as reasonably required in order to; - Comply with applicable law or respond to a valid process; - Protect the rights of our customers.

All individuals are entitled under the Data Protection Act to request a copy of the information an organisation holds on them. An individual who makes a written request and pays any fee applicable is entitled to: - Information on what data SafeDeposits Scotland hold for you - Clarification on whether any personal data is being processed - Reasons why any personal data is being processed - A copy of the data held SafeDeposits Scotland will deal with any subject access requests within 30 days in accordance with GDPR. To make a subject access request please send your full name to the following email: info@safedepositsscotland.com To make a complaint or for further information regarding personal information held by SafeDeposits Scotland on yourself, please email: info@safedepositsscotland.com; or contact us by post at SafeDeposits Scotland, Lower Ground, 250 West George Street, Glasgow G2 4QY.

When registering a tenancy deposit for protection, SafeDeposits Scotland will collect the name, telephone number, address and email address of both the agent and landlord. At the end of the tenancy, SafeDeposits Scotland will collect the necessary information to allow us to either repay the deposit or resolve any dispute. Parties are invited to respond to any request for information. Parties are also given the opportunity to submit evidence in the event of a dispute which can be accessed and viewed by the parties to the dispute and also by employees of SafeDeposits Scotland. SafeDeposits Scotland will require you to submit bank details in order for payment of any deposit amounts due to you.

SafeDeposits Scotland will collect information provided by a prospective employee who may make an application to SafeDeposits Scotland including any CV or similar documents. SafeDeposits Scotland will not share any of the information provided to third parties for marketing purposes or for any other reasons. Your information will be stored securely and we will contact you using details you have provided to us. SafeDeposits Scotland may request further information including proof of identity or proof of qualifications as your application progresses.

When a deposit is registered by a SafeDeposits Scotland client, we will ask the client to provide the name of the tenant or tenants along with an email address or mobile number. In the event of a deposit dispute at the end of the tenancy, SafeDeposits Scotland will collect information provided to us through our online dispute portal. Parties are invited to respond to a dispute and will provide their personal details along with details relating to the tenancy. Parties are also given the opportunity to submit evidence which can be accessed by the parties to the dispute and also employees of SafeDeposits Scotland. SafeDeposits Scotland will require you to submit bank details in order for payment of any deposit amounts due to you.

SafeDeposits Scotland collects data in the following ways: - From any online form you fill out such as registering an account with SafeDeposits Scotland or a tenancy deposit repayment request, registering or responding to a dispute or collection of evidence forms - Through phone calls to our Customer Service Centre which are recorded and retained for a period of up to 6 months from the call date - Through our live chat service - Through messages received on our social media accounts - Through evidence provided by parties to a tenancy deposit dispute such as contact details within a tenancy agreement - Through email correspondence - Through the use of our various communications tools. - Through our SDS Resolutions product - Through any surveys or questionnaires which our customers choose to actively participate in - Any other situations where data is legally and voluntarily sent to SafeDeposits Scotland

SafeDeposits Scotland uses electronic communication media when sending correspondence to customers and parties to a dispute. SafeDeposits Scotland tracks the delivery of the communications (e.g. emails) sent to the parties to ascertain whether delivery is completed successfully. In the event that electronic communication are opened by the recipient, SafeDeposits Scotland are able to see how many times the email has been opened and on what date(s). SafeDeposits Scotland can also determine the location that these events occurred.

SafeDeposits Scotland collects personal information to fulfil its legislative role in providing for the protection of tenancy deposits, and also in performing its role in providing a dispute resolution service. As Tenancy deposit protection is mandatory, SafeDeposits Scotland must collect information such as names and contact details in order to be able to contact parties regarding the deposit protection and to comply with the legislation. SafeDeposits Scotland collects and stores data in order to contact our customers. SafeDeposits Scotland will request personal information from tenants in the event that an insurance claim is required due to their deposit being misappropriated by the deposit holder. SafeDeposits Scotland may use information to conduct surveys in relation to improving our services. SafeDeposits Scotland will not use personal data for marketing purposes unless our customers explicitly request that marketing content is sent to them.

SafeDeposits Scotland primarily holds data to provide relevant information to Government and professional bodies to comply with statute or the rules of that organisation. SafeDeposits Scotland will also use data for the following purposes: - To submit any details requested by any authorised body investigating a crime - To submit any details requested by Her Majesty’s Revenue and Customs or other government agency or local authority under the relevant legislation - To contact any tenant where the details of the tenanted property and the persons forming the tenant have been registered with the Tenancy Deposit Scheme - For use in contact with any interested third party who has provided the whole or part of the deposit as guarantor or in another capacity - To provide relevant details to the insurer of SafeDeposits Scotland to comply with their conditions - For use in contact with any landlord, tenant or agent who wishes to verify that a deposit has been protected with SafeDeposits Scotland - To contact named personnel at agent organisations - For use in contact with any relevant legal adviser - To contact you regarding information about your account or tenancy deposit protection - For use under our product SDS Resolution in order to facilitate negotiations between parties SafeDeposits Scotland will always ask for consent before using any information for a purpose other than those set out in this privacy policy. SafeDeposits Scotland processes personal information on our servers throughout the United Kingdom and the EU in accordance with current and upcoming legislation. SafeDeposits Scotland may therefore process personal information on a server located outside of the country where you live.

We do not share personal information with individuals or companies outside of SafeDeposits Scotland except inthe following circumstances: Consent Where you choose to engage in our independent adjudication service which consists of submitting personal information and evidence to an online portal, this evidence will be viewable by employees dealing with the case at SafeDeposits Scotland along with the agent, landlord(s) and tenant(s) who are party to the tenancy agreement, including any persons acting on their behalf. Legal reasons We retain the right to share your information with organisations or individuals if we reasonably believe in good faith that disclosure of information is necessary to: - Fulfil an applicable law, regulation or legal process - Fulfil an enforceable Government request - To protect vital interests of data subject (e.g. life or death situations, vulnerable situations) and performance of a task in the public interest - Address fraudulent activity including in the prevention or detection of it - Address a security issue - Address a technical issue SafeDeposits Scotland reserves the right to share non-personal information publicly and with our partners for educational purposes, publication of annual reviews or publication of statistics.

If you wish to update your personal information as held by SafeDeposits Scotland, you are able to do this by accessing your account. In the event that you are unable to update personal information, please contact SafeDeposits Scotland. In the event of a data breach which is likely to result in a risk to the rights and freedoms of individuals, SafeDeposits Scotland will notify an individual within 72 hours of such an event being discovered.

Under the General Data Protection Regulations (GDPR), you have a number of rights regarding the data we hold for you. SafeDeposits Scotland wants to ensure our customers are aware of their rights and how we ensure they are met: Right to rectification – Your right without undue delay to rectification of inaccurate personal data. Our customers are able to update their personal details online under their account or alternatively, can contact SafeDeposits Scotland for help updating details. Right to erasure – Your right to the deletion of your personal data. SafeDeposits Scotland will consider a request for data erasure on a case by case basis depending on whether SafeDeposits Scotland must retain the data for legislative purposes. Right to restrict data processing – Your right to obtain from us restriction of data processing. SafeDeposits Scotland will consider the GDPR circumstances that may be relevant around any request. Where processing restrictions are granted, such personal data will only be processed with consent or in relation to legal claims. Right to data portability – Your right to receive personal data in a structured, commonly used format. You are able to find your personal data under your account. Alternatively, SafeDeposits Scotland will provide all data held for you in a readable format. Right to object – Your right to object at any time to processing of personal data. SafeDeposits Scotland will only proceed with processing if we have compelling legitimate grounds for processing after an objection to processing. Right to not be subject to automated-decision making – SafeDeposits Scotland will not subject any individual to automated-decision making.

SafeDeposits reserves the right to vary the terms and conditions of the website from time to time and without prior notice. The User should check regularly as continuing use of the website constitutes acceptance of any variation.

This website, including all material, attachments and guidance notes, is the copyright of SafeDeposits.

1. All material presented on the website is provided without any warranty or representation either direct or indirect of its accuracy, fitness for purpose, quality, security, non-infringement of copyright or compatibility. 2. SafeDeposits is not liable for any direct, indirect or consequential loss, damage, expense, loss of profits or data arising from the use of in connection with the use of the website of SafeDeposits. 3. All information transmitted to or from the website of SafeDeposits cannot be guaranteed as totally secure. All transmissions are at the risk of the User. 4. The use of the website is not a substitute for independent professional advice. The User is urged to obtain advice relevant to their circumstances. 5. SafeDeposits has no liability or responsibility for any third party material displayed on this website.

These Terms and Conditions are governed by and shall be construed in accordance with the laws of Scotland. In the event of a dispute the Scottish courts shall have exclusive jurisdiction.

1. The User agrees to use the website only for lawful purposes and will not act in a way which will restrict or prohibit the use and enjoyment of any third party. Such actions include but are not restricted to any conduct which is unlawful, harasses, distresses or inconveniences any other person; and the broadcasting of obscene or offensive material; or which may cause obstruction or interference with the website. 2. The User is forbidden not air, transmit, or post any unlawful, defamatory, obscene, inflammatory, abusive, hateful, or outrageous material on the website which could be considered to be a criminal or civil offence or any breach of the law or which may encourage others in such actions. 3. Our site does not use cookies to collect personally identifiable information about you. You are able to block or restrict the use of cookies which are set as a result of visiting this website within your browser settings. Restricting or blocking cookies may impact the functionality of this website. Useful information about cookies and how to control them can be found at: www.aboutcookies.org

1. SafeDeposits has no liability to any User for any defect failure or malfunction of the computer system and software package used by SafeDeposits. 2. We cannot accept any responsibility for any loss, malfunction, disruption or damage to the computer system or any software data of the User. 3. While SafeDeposits endeavours to check and test all the material used on the website the User must take any precautions deemed necessary to protect the User from viruses, other computer interference or coding which may damage the computer system of the User when accessing the website. It is recommended that a suitable anti virus system is used for protection when down loading information from the internet.

SafeDeposits does not charge for the use of the website however the User may be charged by a mobile network for access to the internet direct from the User’s mobile telephone. The User should check charges direct as they may vary according to the network.

The Company has an open-door policy and all feedback is welcome in respect of both this policy and any other policy or practice within the business. Should you believe you have been subjected to any act of discrimination you are strongly encouraged to raise the issue under the Company’s Grievance Procedure.

The Company condemns any kind of discrimination or victimisation on the basis of a protected characteristic or association with a person who has a protected characteristic. Protected characteristics are sex, sexual orientation, marriage and civil partnership status, age, disability, pregnancy and maternity, gender reassignment, religion or belief, race, creed, colour, ethnic and national origins. Any person found to be discriminating directly or indirectly or victimising any employee, associate, contractor, customer or member of the public, will be subject to disciplinary action up to and including dismissal. The policy will be implemented in accordance with the appropriate statutory legislation in conjunction with Codes of Practice and guidance from the Equality and Human Rights Commission. We will maintain a neutral working environment in which no employee or worker should feel under threat or intimidated.

Job descriptions shall be drafted so to include only those requirements strictly relevant to the job. Recruitment advertisements shall be placed so as to attract the widest possible response. Where the applicant must be in possession of an occupational/professional qualification or relevant abilities/experience, this shall be clearly stated. All applicants shall receive fair treatment and be selected for interview solely on the basis of their possession of the relevant abilities and/or experience and/or qualifications. Successful interviewees shall be selected for employment based solely on their possession of the professional attributes necessary for the position concerned.

Promotions will be awarded solely on merit. Opportunities for training which are normally linked to skills and qualifications related to business needs, shall be available to all staff.

The Grievance Procedure as set out in the SafeDeposits company handbook shall apply equally to all employees. Senior management will pay particular attention to grievances which may result from discrimination or victimisation and it shall be their responsibility to ensure all staff comply with the requirements of this policy.

Senior management take responsibility for reviewing and monitoring employment records to ensure adherence to this policy. The results of any monitoring procedure will be reviewed at regular intervals to assess the effectiveness of the implementation of this policy. Consideration will be given, if necessary, to adjusting this policy to afford greater equality of opportunities to all applicants and staff.