GDPR Privacy Notice for Donors (current, past and prospective), Suppliers and Contacts of The Captain Tom Foundation
We ask that you read this Privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisor authorities in the event you have a complaint.
Who we are
This policy applies to the activities of The Captain Tom Foundation
The Captain Tom Foundation collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Glossary of Terms
What is personal data?
Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):
Names and contact information i.e. emails and telephone numbers
National Insurance Numbers
Employment history
Employee numbers
Credit History
Personal tax
Payroll and accounting data
What is sensitive personal data?
Sensitive personal data refers to the above but includes genetic data and biometric data. For example:
Medical conditions
Religious or philosophical beliefs and political opinions
Racial or ethnic origin
Convictions
Biometric data (e.g. photo in an electronic passport)
What is a Data Controller?
For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
The data controller is The Captain Tom Foundation, C/o Higgs & Sons Solicitors, 3 Waterfront Business Park, Brierley Hill, West Midlands, DY5 1LX
What is a Data Processor?
A “data processor” is a person or organisation which processes personal data for the controller.
What is Data Processing?
Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.
What information do we collect about you and how?
Information collected by us
In the course of our activities we collect the following personal information when you provide it to us:
Donors: Contact details (individual name, personal or business address, telephone numbers and/or email address) as provided to us by our Donors as well as any other information necessary for us to carry out our activities, as required. Third party personal information can only be disclosed on donor’s instructions.
Suppliers: Contact details of Suppliers who provide services to us as individuals or of employees in the course of their employer’s business.
Contacts: Contact details for individuals who are or have been in some way connected with our activities and have given personal information to enable us to stay in contact with them.
You agree that we are entitled to obtain, use and process the information you provide to us to enable us to discharge or charitable obligations and for other related purposes including;
Updating and enhancing donor records
Analysis for management purposes
Carrying out credit checks in relation to you
Statutory returns
Legal and regulatory compliance
Crime prevention.
Information collected from other sources
We also obtain personal information from other sources such as, but not limited to:
Credit reference agencies
Third party financial institutions
Where we are recommended by a third party;
Where we are instructed through a third party; or
Where we receive a recommendation to use a Supplier.
We collect information about you when you fill in any of the forms on our website i.e. sending an enquiry, signing up for an event, filling in a survey, giving feedback etc. Website usage information is collected using cookies.
When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.
Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity. For more information visit www.aboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some of our website features may not function because of this.
Analytics – e.g. how visitors use our website
We may use Squarespace and Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.
Squarespace and Google Analytics are third-party information storage systems that records information about the pages you visit, the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you e.g. name, address etc and we do not share the data.
Google – http://www.google.com/intl/en/policies/privacy/
Squarespace - https://www.squarespace.com/privacy
IP addresses
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. THE CAPTAIN TOM FOUNDATION do not have access to any personal identifiable information and we would never seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.
Internet Based Advertising
We use LinkedIn and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.
How we use your personal information
At The Captain Tom Foundation we take your privacy seriously and will only use your personal information to facilitate our charitable activities. We will only use this information subject to your instructions, data protection law and our duty of confidentiality.
We may receive personal data from you for the purposes of our money laundering checks, such as a copy of your passport. This data will only be processed for the purposes of preventing money laundering and terrorist financing, or as otherwise permitted by law or with your express consent.
Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and undertaking our charitable activities. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver our charitable services.
If you are a prospective donor we use your information as a record of your enquiry. We might also use your contact details to provide you with information about us and our services.
If you are a supplier we use the personal information you give us as a means of contacting you about the goods and services that you have supplied to us.
If you are a contact we use your information so that we can contact you occasionally with news and other information about our activities and events that we invite you to.
Who we share your personal information with
We do not routinely share personal information. We will only share personal information to the extent that is necessary in order to progress the matter or transaction that we are instructed about (e.g. information that has to be given to the other party to a transaction) or where the services we provide necessarily involve an identified third party supplier or outside organisation in which case we will take reasonable steps to ensure that any information shares will be limited to what is necessary for the specific purpose and will only be processed in accordance with GDPR principles.
We will share personal information with law enforcement and other authorities if required by applicable law.
We will not share your information with any other third party without the consent or instruction of the individual to do so.
Whether information has to be provided by you and why
Donors must provide us with personal information necessary for us to comply with our legal obligations under Money Laundering Regulations.
How long will we hold your data for?
Marketing: We will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
Contracted Services: We will hold your data for 7 years in line with our regulatory requirements and then indefinitely, subject to your agreement.
Our policy to retain information indefinitely is so that we can provide a full service. Quite often historic information is required to enable us to fulfil certain reporting requirements therefore if information is retained indefinitely we will have the required information and would not need additional information from you. By The Captain Tom Foundation retaining this information you would be able to request it as and when required.
We will however delete all personal information on your instructions outside of the 7 years if formally instructed to do so. All requests should be in writing.
Reasons we can collect and use your personal information
If you are a donor we rely on the fact that it is necessary for us to have and to use that information for the performance of our contract with you as the lawful basis on which we collect and use your personal data.
If you are a prospective donor we keep your information to assist with any follow-up enquiry and we rely on our legitimate charitable interests as the legal basis for doing so. Our legitimate interests are so that we can follow your enquiry and make you aware of how we might be able to assist you. Unless you instruct us to act for you in connection with your enquiry we will keep our record of your enquiry for no longer than 2 years, which we believe is appropriate to allow for any further or follow up enquiry relating to the same issue.
If you are a supplier we rely on our legitimate interests as the lawful basis on which we collect and use your personal data. Our legitimate interests in this regard are two-fold. Firstly, we might need to contact you about the work that you have done for us. Secondly, we might need to contact you about further work that we would like you to do for us.
If you are a contact we rely on our legitimate interests as the lawful basis on which we collect and use your personal data. Our legitimate interests are to keep you informed of our services and other information about our activities we reasonably consider might be of interest to you. This will be limited to information sent to you by email to your email address from which you can opt out of at any time by replying to the email. We have considered the risk of harm to your privacy rights and to your data security and have concluded that the risk is minimal given (i) the type of data (your contact details) that we process for this purpose, (ii) the method, volume and content of the communications that we might send to you (occasional emails, not more often than monthly, related to the services that you have previously ordered from us) and (iii) your right to opt out of further communications and to ask us to delete your information from our records at any time. Any unrequested contact by electronic communication to a personal account will respect your personal e-privacy rights by being restricted to the use of e-contact details that you provided to us.
Transferring your information outside of the UK
As part of our services we may utilise cloud based solutions to store and/or process your data. This cloud based data could be held anywhere within the world, the location of which we are unable to control. Based on this, the information which you give to us may be transferred to countries outside the UK. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing.
If you use our services while you are outside the UK, your information may be transferred outside the UK to give you those services.
Security precautions in place about data collected
When you give us personal information, we take steps to make sure that it’s treated securely. Any sensitive information (such as credit or debit card details) is not retained in any format.
Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Marketing
We would like to send you information about our activities which may be of interest to you. If you have consented to receive marketing, you may opt out at any point as set out below.
You have a right at any time to stop us from contacting you for marketing purposes. To opt out please email: privacy@captaintom.org
Access to your information, correction, portability and deletion
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us at the following address: The Data Controller, The Captain Tom Foundation, C/o Higgs & Sons Solicitors, 3 Waterfront Business Park, Brierley Hill, West Midlands, DY5 1LX. We will respond to your request within one month of receipt of the request.
We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing privacy@captaintom.org or writing to the above address.
Objections to processing of personal data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
Data Portability
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you please send a formal request to:
Email: privacy@captaintom.org, or
In Writing to: The Data Controller, The Captain Tom Foundation, C/o Higgs & Sons Solicitors, 3 Waterfront Business Park, Brierley Hill, West Midlands, DY5 1LX.
Other websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
Complaints
If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Information Commissioner’s Office. We would appreciate the chance to deal with any concerns in the first instance before the Information Commissioner is approached. If you do have any concerns, please send them to privacy@captaintom.org or write to us at The Data Controller, The Captain Tom Foundation, C/o Higgs & Sons Solicitors, 3 Waterfront Business Park, Brierley Hill, West Midlands, DY5 1LX
Changes to our Privacy Policy
We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 30 April 2020 and the Version number is 1 in line with the new GDPR guidelines.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you:
By email: privacy@captaintom.org
Or write to us at The Data Controller, The Captain Tom Foundation, C/o Higgs & Sons Solicitors, 3 Waterfront Business Park, Brierley Hill, West Midlands, DY5 1LX