How to contact us
Postal address: Orchard House, Holcombe Hill, Holcombe, Radstock, BA3 5DJ.
Complaints about how we handle your information
You have the right to make a complaint at any time to the Information Commissioner’s Office (the “ICO“), the UK supervisory authority for data protection issues (www.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. If you wish to contact us to make a complaint about how we handle your personal data, you can do so using the contact details above.
This policy was last updated on the date shown at the bottom of this page.
We will only use your personal data for the purposes for which we collected it, or for reasons which we believe are compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we will not process your personal data without your knowledge or consent unless this is required or permitted by law. In such cases, we will do so only in compliance with the law. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The data we collect about you.
Personal data, or personal information, means any information which can be used to identify an individual.
We may collect, use, store and transfer different kinds of personal data grouped together and categorised as follows:
- Identity data: Forename, surname, date of birth and age. Please see the section “Our lawful bases and purposes for processing your data” for more information.
- Contact data: Billing address, home address, email address, telephone and/or mobile number if you have provided this when donating.
- Financial data: We use PayPal as our payment provider and no credit card data is stored on The Old Talbot House Foundation’s servers or systems. We also share information with HMRC as legally required, where donations are made, and we receive a completed gift aid form. Please do see the PayPal and HMRC’s privacy notices below:
- Transaction data: Details of donations you have made and where appropriate, products or tickets you have purchased or fundraising events you have been involved in.
- Technical data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use when you access our website.
If you do not provide personal data: Some of the data we collect is necessary for the performance of a contract we have entered or are trying to enter into with you. For example, we can’t take payment from you unless you share your billing address with us and we might need your email address or telephone number in order to send you important administrative information, such as changes to the timings for an event.
Other data may be required by law, for example we need to verify your age when you access any online services.
If you do not provide data when requested, we may not be able to provide our services effectively or perform the contract we have or are trying to enter into with you.
How is your personal data collected?
We use different methods to collect data from and about you as outlined below.
- Direct interactions: You may give us your personal data by filling in paper-based or online forms or by corresponding with us by post, phone, email, face to face or via social media. We may also collect your personal data when you attend events for The Old Talbot House Foundation.
- Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may use these technologies to customise content and advertising, including delivering advertisements about the charity, its news, and events, on third party websites or services not owned or operated by The Old Talbot House Foundation to provide social media features and to analyse traffic to our website site. We also share information about your use of our site with trusted social media, advertising and analytics partners.
Our social media, advertising and analytics partners are:
- Facebook – you can find out more about how to manage your Facebook ads preferences here.
- Twitter – you can find more information about how to control your Twitter ad and privacy settings here.
- Third party sources: We also collect your data from third party sources such as providers of online fundraising platforms e.g., PayPal.
- Publicly available sources: Some of the personal data we collect about you may not have been provided to us by you directly but may instead have been gathered from publicly available sources. Sources of your personal information include but are not limited to internet search engine results and social media sites; Companies House, the Electoral Register, company websites, wealth reports and listings, social networks such as Facebook and Linkedin, political and property registers and news archives.
We will never use information that has been entered into the public domain unlawfully or, in our judgement, against your expressed wishes. For more information about how we use this information and our lawful bases, see “Our lawful bases and purposes for processing your data”.
Our lawful bases and purposes for processing your data:
We will only use your data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
- Necessary for the performance of a contractwe are about to enter into or have entered into with you.
- Necessary for compliance with a legal obligation that we are subject to. We rely on this legal basis in the following circumstances:
- to undertake due diligence, if you make a large donation to the charity, in accordance with charity law for the purposes of the prevention of financial crime.
- to comply with record retention obligations e.g., the requirement to retain Gift Aid declarations for six years as required by Her Majesty’s Revenue and Customs (HMRC).
- for information security monitoring.
- where we identify a crime and have a duty to report it to the relevant authorities.
- where we are obliged to share data with regulators such as the ICO for audit and breach reporting purposes.
- if we investigate, record and report incidents or accidents that may involve you.
- to handle any requests you make when you exercise your legal rightsas outlined in this policy.
- to conduct audits to assess regulatory compliance including in relation to the Code of Fundraising Practice and General Data Protection Regulation.
- 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.
We collect your data for this reason in a number of circumstances including:
- to process your donation including sending you an administrative “thank you” letter or email.
- to manage our relationship with you and respond to your queries or complaints.
- to sign you up to one of our newsletters or mailing lists.
We rely on your consent to process your personal data in limited circumstances and where required by law as follows:
- to send you marketing communications by telephone, email or text promoting the work of the charity and our fundraising campaigns.
- to capture a photo image or video footage of you for future marketing purposes.
- to use images of you and/or information about you in any marketing materials and publicity campaigns or in local or national press.
- to record special categories of data in relation to you, for example details of your religious or political beliefs for relationship management purposes, where this data has not already been made public by you.
In addition to the lawful bases set out above, when we process Special Categories of personal data, we must identify an additional lawful basis for processing.
At The Old Talbot House Foundation and in relation to data processing we carry out linked to our Supporters, we rely on the following legal bases:
- the data subject has given explicit consent to the processing of those personal data.
- the processing relates to personal data which are manifestly made public by the data subject.
Disclosures of your personal data
There are a number of third parties with whom we share your personal data in order to provide and monitor our services and to comply with our contractual and legal obligations.
Where we regularly share data with processors and other controllers, we have data sharing agreements in place and do not allow processors to use your personal data for their own purposes. We only permit processors to use your data for specified purposes and in accordance with our instructions.
The list below sets out the possible third-party recipients of your data:
- HMRC in relation to Gift Aid declarations
- Other IT services and data hosting providers
- Regulatory bodies and supervisory authorities who may audit our data processing activities.
- Talbot House in Poperinge, Belgium
For details about international transfers of personal data and the safeguards in place, please see International Transfers.
Third party links
We may share your personal data with Talbot House in Poperinge, Belgium and therefore this involves transferring your data outside the UK. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
How long will you keep my personal data?
We will only retain your personal data for as long as reasonably necessary to fulfil the relevant purposes set out in this privacy notice and in order to satisfy our legal, statutory, accounting, or reporting requirements.
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 requirements.
How we protect your personal data
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.
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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Click to find out more:
- Requestaccess 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.
- Requestcorrection 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.
- Requesterasure 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
- 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request thetransfer 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 withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Object to automated decision making or profiling. This enables you to ask us not to subject your personal data to automated decision-making or profiling with legal or similarly significant effects.
If you wish to exercise any of your rights above, please contact us on firstname.lastname@example.org
What we may need from you
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.
Time limit to respond
We shall respond to all legitimate requests within one month unless your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated and may take longer to respond.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We hope that you will be happy for us to send you news about the work of the charity but you are free to change your mind at any time.
The Old Talbot House Foundation will never share your data with third parties for their direct marketing purposes without your consent.
You can withdraw your consent (if given) or ask us to stop sending you marketing messages at any time by contacting us at email@example.com
01 July 2021