Face Covering Exemption Card Survey – Privacy Policy

Data Controller contact details

Name: Scottish Government

Address: 2 Regent Road, Edinburgh EH1 3DG

E-mail: dpa@gov.scot

Privacy notice completed 28/01/2021


You may recall that when you applied for your Face Covering Exemption Card you opted to be contacted at a future date to enable an evaluation of the scheme to be carried out.  Your opinion and experience is important for the service to be reviewed and if required improved. 

To this end, we invite you to share your experience with us in the form of a questionnaire.  The questionnaire asks for your personal details, however, this is optional.  For peace of mind, please be assured that The Scottish Government takes the security of your personal data very seriously.This statement sets out what information we will gather, why we need it, who we share it with, how we will use it and how it will be disposed of.

Why do we need to collect this data?

As stated above, the purpose for which we are processing your personal data is to assist with the review of the Face Covering Exemption Card scheme. 

Information will be gathered via Smart Survey (a third party website) with Disability Equality Scotland acting as data processor on behalf of the Scottish Government.  

You may agree for Disability Equality Scotland to contact you again regarding your experience of using the card. In which case you will be asked to provide your name and email address.    

Your data will not be used for any other purpose.

What data will we collect?

Along with your responses to the questions, we will collect the following personal data if you choose to provide it:

  • your name (only required if you agree we can get back in touch with you again about use of the exemption card);
  • an email address (only required if you agree we can get back in touch with you again about use of the exemption card);

In order to understand what demographic differences may exist when accessing the exemption card service or using the card, we are asking the following:

  • Local Authority Area (optional) to understand demographic differences ;
  • Gender (optional); and
  • Age (optional).

However this data is optional.

Customer health information will not be requested or stored.

Who will we share your data with?

  • Your data will be gathered by Smart Survey as the third party data collector. This data will be shared with and managed by Disability Equality Scotland.
  • Scottish Government and Disability Equality Scotland will not process your information outside the EEA.
  • This privacy policy is specific to the exemption cards survey, you can review other privacy policies for the other organisations involved here:
  • We are committed to doing everything we can to keep your data safe. Disability Equality Scotland will perform regular security tests to make sure our systems and processes are secure.

What is our Lawful Basis for processing this data?

This data is being processed under Article 6 (1)(e) as Public Task.  This means that processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. The relevant legislation in this case is Scottish Ministers powers under section 1A of the NHS (Scotland) Act 1978.

How we store your personal information

Your information is securely stored on password secure databases processed on Disability Equality Scotland’s server, accessed via VPN, Username and Password access. 

If you agree to your details being stored for future evaluation, we will store this for up to 1 year or until the exemption card service is no longer required (whichever is sooner). We will then dispose of your information by deleting it from the location it has been securely stored in by Disability Equality Scotland and, sub-processor, SmartSurvey.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

To make a data request, please contact:

Data Protection Officer

Victoria Quay

Commercial Street




How to complain

If you have any concerns about our use of your personal information, you can make a complaint to admin@disabilityequality.scot or

Data Protection Officer

Victoria Quay

Commercial Street




You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.The ICO’s address:           

Information Commissioner’s Office

Wycliffe House

Water Lane




Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

You can also report any concerns