4.0 – How we process your personal information
4.1 Submitted data
Data submitted to us for processing will be securely retained within our secure IT system. All data within this system is subject to additional password protection and encryption.
We retain only the basic data required to deliver our services to you. This is typically:
- Name
- Address
- Email address
- Subscription start/end details
- Contact opt-in details
Where you have applied for financial assistance as part of your application you may be required to provide information about your personal finances, your family or household, your health, any disabilities, your eligibility for other financial support services, details about your employment, your employment history and your CV. We may also process your bank account details for the purposes of making a payment to you. We may use identity documents you provide for the purposes of verifying your identity.
We may process information about your transactions with us if you donate to us or we make a payment to you.
4.2 Opt-out list
We also maintain a list of people who have opted out of receiving communications from our organisation.
If you opt-in having opted out previously, your subscription preferences will be automatically changed in HubSpot, you still have the option to opt-out using the unsubscribe link at the bottom of our marketing emails.
All mailings will be screened against our opt-out list.
4.3 Right to be forgotten
We fully support your right to be forgotten which can be applied by writing to our Data Protection Officer at section 9.0 giving your identifying details and requesting removal of all material from our data systems. Our DPO will conduct a full sweep of all systems and remove your personal data, this includes our opt-out lists. Once complete the DPO will advise you of this action. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4.4 Identity Verification
Where we or our sub-processors use an identity verification service to verify your identity as part of a grant making process, we may collect information about you from such service provider, further details of which can be found in section 6.7. The information we or our sub-processors share with such service providers includes:
- Name
- Address
- Date of Birth
- Mobile phone number
The information provided to us or our sub-processors by such service providers includes:
- Name
- Address
- Date of Birth
- Mobile phone number
4.5 How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we have entered into a contract with you or made a grant to you or you have made a donation to us, or in each case we or you are considering doing so.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
For business contacts who are classed as “corporate subscribers” under data protection law we consider that we have a legitimate interest in sending direct marketing messages from the Charity by email in order to raise funds to further our charitable aims and objectives. We consider that our legitimate interest in contacting business contacts in this way falls within the reasonable expectations of such individuals and does not unduly impact their data protection rights. If you are a business contact and do not wish to receive further marketing messages by email you can exercise your right not to receive such messages in the future by opting out using the “manage preferences” or “unsubscribe” links at the bottom of all our marketing messages.
Where you have provided sensitive personal data (usually as part of a survey or, usually limited to personal data about your health, in respect of a grant application), we will only process the data with your consent or, where permitted under the DPA and the GDPR and where consistent with our charitable objectives.
Where you have applied for a grant we will use the information you have provided (described in section 4.1) to assess your application.
4.6 Your legal rights
Under certain circumstances, you have rights under the DPA and GDPR in relation to your personal data to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it as further described in section 4.2.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer, referred to in section 9.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated
4.6 How Long Your Personal Data is Stored for
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
