Senior civil servants - register of interests: privacy notice

Privacy notice to inform family members of senior civil servants about the processing of their personal data in relation to the register of interests.

Who we are

The Scottish Government is the devolved government for Scotland. Its head office is located at St Andrews House, Regent Road, Edinburgh, EH1 3DG.

This privacy notice is to inform family members of senior civil servants about the processing of their personal data in relation to the register of interests. The register collects information from all Scottish Government staff and those carrying out work on its behalf.

Why we need your personal information 

All civil servants are required by the Civil Service Code to adhere to the core values of integrity, honesty, objectivity and impartiality. There is a UK-wide version of the Civil Service Code as well as a Scottish-specific version. Where an individual works for a non-ministerial department (a body accountable to officeholders rather than Scottish Ministers) then the UK version applies, otherwise the Scottish version is applicable.

The Scottish Government as part of its civil service management functions need to implement and operate measures, such as the register of interests, to ensure and promote compliance with the Civil Service Code. The register of interests is the mechanism by which conflict of interests are documented and recorded which may include, in certain cases, information about civil servants’ close family members interests.

Senior civil servants must declare to their department or agency any business interests (including directorships) or shareholdings or other securities/financial interests which they or members of their close family members hold, to the extent which they are aware of them. They must not misuse their official position, or information acquired in the course of their duties, to further their private interests or those of others, including close family members. Close family members means family members who may be expected to influence, or be influenced by a senior civil servant. Examples may include domestic partner and children, children of domestic partner, dependants or dependants of domestic partner. If the close family member has such an interest it does not necessarily disqualify a senior civil servant from continuing to act in any particular matter. However the Scottish Government must be in a position to determine the acceptability of that issue and it is not for the senior civil servant alone to decide.

This means that we may collect and store information about close family members of the senior civil service within the register of interests. This information may include:

  • name
  • relationship to the staff member
  • business interests such as directorships
  • shareholdings
  • other securities/financial interests

Information will be gathered as and when an interest arises, and in addition members of the SCS, will discuss as part of their mid-year and end-year performance appraisals. 

Lawful bases

The legal basis being relied on under of the UK GDPR is Article 6(1)(e) ‘Processing is necessary for a task carried out in the public interest’, and the Scottish Ministers in exercise of their powers under the Constitutional Reform and Governance Act 2010. The Civil Service Management Code (CSMC) is issued under the authority of Part 1 of the 2010 Act, under which the Minister for the Civil Service has the power to make regulations and give instructions for the management of the Civil Service, including the power to prescribe the conditions of service of civil servants. Scottish Government has a delegated function in the operation of the CSMC regarding the terms and conditions of service of civil servants.

Who we will share your information with

Your personal information will not be shared with any third party unless disclosure is required by law e.g. Freedom of Information (Scotland) Act 2002 (unless exempt under this legislation). Your personal information will only be accessed by Scottish Government staff who need to do so. Only specific People Directorate Human Resources staff and line management can access your data held in Scottish Government records and systems.


We only keep your personal information for the minimum amount of time necessary. Information registered on the register of interests will be kept until it is either superseded, or the senior civil servant leaves the employment of the Scottish Government, at which point it will be retained for a period of seven years.

A review of the register of interests policy and procedures is currently underway. When concluded, this privacy notice will be reviewed and updated. 

International transfers

All information will be stored within data centres located in the UK.

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 by emailing

For more information on the rights you have over how your personal data is handled, please visit Your data matters - ICO.

If you are dissatisfied with the way we handle your personal data, you can raise your concerns with our Data Protection Officer in the first instance. You can do this by e-mail to or write to: 

Data Protection Officer
Victoria Quay
Commercial Street

If you feel we have been unable, or unwilling to resolve your complaint, you have the right to lodge a complaint with the Regulator for data protection in the UK, the Information Commissioner's Office (ICO).

The Information Commissioner
Wycliffe House
Water Lane

Tel: 08456 30 60 60

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