1. |
Introduction and Important Information |
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Charitable Giving (“We” or “us”) are committed to protecting and respecting your personal data and privacy. This privacy policy relates to how we use and collect personal data from you when you use or purchase our services, or access our website. It also relates to our use of any personal information you provide to us by telephone (including SMS), in written correspondence (including letter and email) and in person. Please note that:
Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including but not limited to the Data Protection Act 2018 (DPA) and the UK General Data Protection Regulation (UK GDPR), described in this policy as the “Data Protection Laws”. This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page, so please check back regularly. |
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2. |
Who we are and how to contact us |
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2.1 |
For the purpose of the Data Protection Laws, the data controller is Charitable Giving a registered charity with registration number 1128013. We are a limited company registered in England and Wales under company number Our registered office is at C4 Union Mine Road, Pitts Cleave Industrial Estate, Tavistock, England, PL19 0NS. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below: FAO: Privacy Officer Email: mail@charitablegiving.co.uk Telephone: 01822 611180 and ask to speak to the Privacy Officer. |
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2.2 |
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. |
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3. |
The data we collect about you |
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3.1 |
We collect and process personal data. Typically the personal data we collect and process will include identity, contract, transactional, technical, profile, usage and marketing and communications data such as:
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3.2 |
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. |
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3.3 |
We only collect data from you directly or via third parties (see the section Third Parties below). |
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4. |
How is your personal data collected? |
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4.1 |
We use different methods to collect data from and about you including through:
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5. |
If you fail to provide personal data |
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Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of a service you have with us but we will notify you if this is the case at the time. |
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6. |
How your data will be used |
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6.1 |
We use information held about you to:
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6.2 |
We never sell your data to third parties or allow third parties to contact you without your permission. |
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6.3 |
We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below). We may process your personal data without your knowledge or consent where this is required or permitted by law. | |||||||||||||||||||||||||||
6.4 |
Where you have indicated to us that you are happy for us to do so, we will also use this information:
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6.5 |
We have set out below in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
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7. |
Lawful basis for processing |
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7.1 |
We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows: |
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7.1.1 |
Contractual obligation – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations. |
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7.1.2 |
Legitimate Interest - means in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process you personal data for our legitimate interests. Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our service. |
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7.1.3 |
Consent – We will seek to obtain your consent to process: a) your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above); and b) any special category data. |
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7.1.4 |
Legal obligation – We may process your data where we it is necessary for us to do so to comply with the law. |
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8. |
Third Parties and sharing information |
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8.1 |
We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct. |
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8.2 |
You should be aware that the third parties we work with, such as Professional Fundraising Organisations and your chosen charities, will have their own privacy policies and that once your information has been passed to them, they are in control of your information, and they then determine how it is used. We advise you to check third party privacy policies before you instruct us to share any of your personal data with those third parties. |
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8.3 |
Please see below the list which sets out the categories of recipients of personal data.
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9. |
Marketing |
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9.1 |
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).9.2 |
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9.2 |
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. |
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9.3 |
We strive to provide you with choices regarding certain personal data uses, namely around marketing and advertising. In particular: |
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9.3.1 |
We will always obtain your express opt-in consent before we share your personal data with any third party for marketing purposes; and |
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9.3.2 |
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to your or by contacting us at any time. |
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10. |
International Transfers |
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10.1 |
Your data is stored by us and our processors in the UK or the European Economic Area (EEA). However, several of our external third parties are based outside EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. We will either: |
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10.1.1 |
transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or | |||||||||||||||||||||||||||
10.1.2 |
ensure that standard contractual clauses (SCCs) are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data. |
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10.2 |
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. |
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11. |
Data Security |
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11.1 |
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. |
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11.2 |
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. |
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12. |
Data Retention |
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12.1 |
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. |
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12.2 |
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. |
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12.3 |
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. We may share information in fully anonymised form with the following: • your employer, so they know how many of their employees are using payroll giving; • the charities which you donate to using our services, so they know how many employees at different companies donate using payroll giving • Professional fundraising organisations, for the same reasons; and • HMRC approved payroll giving agencies, to promote payroll giving; |
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Please rest assured this type of sharing of data will only be in an anonymised format and you will not be identifiable from the collated data we disclose. Please see clause 3.2. |
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12.4 |
In some circumstances you can ask us to delete your data (see below for further information). |
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13. |
Your Rights |
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13.1 |
Under the data protection laws your rights are: |
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13.1.1 |
To be informed – We must make this privacy policy (sometimes referred to as a privacy notice) available to you and be transparent over how we process your data. | |||||||||||||||||||||||||||
13.1.2 |
Access – You are entitled to know what details we hold about you and why. We strive to be as open as we can be in terms of giving people access to their personal data. You can find out if we hold any of their personal data by making a formal request under the data protection laws. Such requests should be made using the contact details provided in this policy. If we do not hold information about you we will confirm this in writing at the earliest opportunity. If we do hold your personal data we will respond in writing. Our response will: a) confirm that your data is being processed; b) verify the lawfulness and the purpose of the processing; c) confirm the categories of personal data being processed; d) confirm the type of recipient to whom the personal data have been or will be disclosed; and e) let you have a copy of the data in format we deem suitable or as reasonably required by you. |
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13.1.3 |
Rectification – We are obliged to correct or update your details. We will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date. |
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13.1.4 |
Erasure – This is also known as the right to be forgotten. Under Data Protection Laws you have the right to require us to erase your personal data under specific circumstances. A request for your personal data to be deleted will be decided on a case by case basis and should be submitted in writing to the contact details provided in this policy. |
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13.1.5 |
Restrict processing – You have the right to ‘block’ or suppress the processing by us of your personal data. |
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13.1.6 |
Portability – You have the right to obtain the personal data that you have provided to us in a commonly used machine-readable format and reuse it with a different provider. |
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13.1.7 |
Object – You have the right to object to us processing your data in certain circumstances. You have an absolute right to stop your data being used for direct marketing, but in other circumstances we may still be allowed (or required) to process your personal data if we can show you that we have a compelling reason for doing so. |
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13.1.8 |
Rights in relation to automated decision making and profiling – We do not use automatic decision making or profiling. |
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13.1.9 |
Withdraw consent. Where you have given us consent to process your personal data, you can withdraw that consent at any time either by contacting us using the details set out in this policy, or by following the opt-out links in electronic messages where relevant. We do not penalise individuals who wish to withdraw consent and we act on withdrawals of consent as soon as we can. |
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13.2 |
Please note that you may need to provide identification in order to prove who you are if you wish to invoke any of your rights as provided by the data protection laws and as summarised above. |
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13.3 |
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. |
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14. |
Applications to work for us |
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If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy. |
Document No: P0014
Version: 2.0