Carolyn Glen - Disclosure Services (CGDS) is an Umbrella Body of Disclosure
Scotland (DS). We process criminal records checks applications under Part V of the
Police Act 1997 and the Protection of Vulnerable Groups (Scotland) Act 2007 (PVG).
ting on behalf of Scottish Ministers.
We recognise the importance of protecting the privacy of the users of our services,
including our website and online application service.
This privacy statement relates to the personal information we collect about you when
you use our website and other services. This statement explains what personal
information we collect about you when you use our website pages (at https://
carolynglendisclosureservices.co.uk) and other services, why we collect it, and what
we do with it.
The privacy statement will be reviewed and updated at least once a year. If we make
any substantial changes, we will notify you by posting on our social Media pages, or
through your contact details held by us.
Collection of personal information
The Data Protection Act (DPA) 2018 provides a right of access to any personal
information that we hold about you. These rights are subject to certain exceptions
and exemptions under the Data Protection Act 2018.
We collect, hold and process personal information because the processing is
necessary for the exercise of our functions as an Umbrella Body as outlined in
legislation that governs criminal records checks. This is a legitimate condition of
processing as outlined under the Data Protection Act 2018. Read the full Act at http://
CGDS collects personal information that you provide, by email, telephone or other
methods of communication, or via online application and paper application form(s).
CGDS is committed to ensuring all personal information is collected and processed
in accordance with the Data Protection Act 2018 which requires information to be:
• handled fairly and lawfully
• is only kept and used for limited purposes
• is adequate, relevant and not excessive
• accurate and kept up to date
• will not be kept for longer than necessary
• will be processed in line with the data subjects’ rights
• will be held securely
• will not be transferred to other countries without adequate protection
Why we collect your Information
Our primary objective is to assist with applications to Disclosure Scotland services
which enhances public safety through enabling safer recruitment decisions.
Our core function is to contribute to the safety of the vulnerable in our society by
providing criminal history disclosure information to organisations and potential
employers to assist them to make safer and more informed recruitment decisions,
and by maintaining barred lists of those individuals unsuitable to work with children
or protected adults.
For the application process, we require information from you. It will only be disclosed
to legitimate organisations who have a legal right to have access to this information
under Part V of the Police Act 1997, the Protecting Vulnerable Groups Act 2007, or
can display a legal right to do so.
What Information do we collect about you?
We collect, hold and process personal information so that we can manage and
support legitimate and legal applications for disclosure information. We collect
information in a variety of ways including paper and online forms, email, telephone
The type of information required for disclosure applications includes:
• personal information: name, name at birth, (if different from name use), date
of birth, full postal address, email, home phone number, mobile number,
National Insurance number
• some third-party data might be collected (eg security questions, mother’s
• UK residency details such as: country of birth, nationality, country you
normally live in
Documentation and evidence
To support an application, we may also require evidence to prove identity, so we ask
for copies of documentation. This can include copies of documents such as
passport, driving licence, birth certificate, council tax statement etc. The documents
we may need will depend on your particular circumstances. If we require additional
information, we will tell you what to send when you are making your application to
What happens to your Information?
When applying for a disclosure application, you supply us with personal information
in support of your application. This personal information may be used in a number of
ways by DS:
• assessing eligibility and entitlement to certain levels of disclosures
• prevention, detection and investigation of crime
• checking Police Criminal History Systems for any relevant convictions you
• the Rehabilitation of Offenders Act 1974 and its updated/revised schedules
• audit purposes
• statistical analysis and research
• improving service levels
• for members of the PVG Scheme, the ongoing monitoring of members for
CGDS will use your personal information to process your application, which may be
done automatically by DS systems or by individuals who work for DS.
How do we keep your information secure?
Your data is protected in line with commercial best practice of ISO 27001, UK
government information security standards and data protection legislation. The data
is contained in a secure locked cabinet. The CGDS web site has an SSL certificate.
All staff processing CGDS applications have been background checked before they
are allowed access to the services. All staff are trained and made aware of their
All information that you provide to us is stored in our secure cabinets and online
servers and have IT security measures in place.
What if your information changes?
If any of your personal or contact details change, it is important that you tell us
straight away so we have the most up-to-date information to communicate with you
about your application and other services.
You can contact us:
• by phone: 0131 654 9070 – Monday to Friday 8.30am to 8pm,
• by email: firstname.lastname@example.org
Retaining your personal information
We retain personal information in line with the Data Protection Act 2018. This
involves only retaining the personal information we need for business, regulatory or
legal reasons. Once personal information is no longer needed, it is securely
CGDS have a requirement to retain records of applications and applicants until the
certificate has been issued by DS.
How to request personal information
Under the Data Protection Act 2018, you have a legal right to access the personal
information CGDS holds about you. This is known as a Subject Access Request
(SAR) and we aim to process them within one calendar month.
Subject Access Requests must be made in writing and anyone making an oral
request will be asked to complete a Subject Access Request form which will be
Please send your Subject Access Request form along with a copy of your proof of
identity in writing to:
Carolyn Glen - Disclosure Services
7 Redcroft Street
Individuals have the right to see a copy of the information that CGDS holds about
This right of access means that an individual who makes a written request, along
with proof of identification, is entitled to be given a copy of the information.
Please note that the police service is the data controller for criminal records. Subject
Access Requests about this are not for CGDS to answer, and applicants should refer
to the relevant police authority.
We will aim to meet your request within the specified one calendar month.
*Please note that you do not have to complete the form to make a Subject Access
Request (SAR). You can make a request in writing or via email. However, completion
of the form can assist in gathering all necessary information to aid the processing of
Individuals can obtain a copy of their full criminal record information by submitting a
Subject Access Request to Police Scotland.
Please note, an enforced subject access request cannot be used for employment
Our social media site is public and can be assessed by anyone. Any personal
information you chose to share via social media sites could be assessed by the
wider public. This includes revealing personal information if you communicate with
us through social media, such as posting comments. We advise that you do not
share personal information in public areas of social media.