Privacy Policy
Service Users and Supporters
Service Users and Supporters Privacy
Policy
2020 - 2021
1.1.
We respect your privacy
and are committed to protecting your personal information.
1.2.
We comply with the General Data Protection
Regulation and Data Protection Act 2018 and invite you to read about our
personal data processing practises in case you fundraise for us, donate to us,
offer grants to us, participate in our programmes, subscribe to our
newsletters, visit our website, follow us on social media, attend our events,
or supply products and services to us (all data subjects are referred
collectively as ‘service users and supporters’).
2. Who are we?
2.1.
Smart Choices is a charity with a mission to break the cycle of youth
violence. We implement that in a variety of intervention programmes. Smart
Choices is based in London, United Kingdom at 40 Cambridge Drive, Lee, SE12
8AJ.
2.2.
Smart Choices is responsible for deciding how to hold and use personal
information about you during and after your working relationship with us.
Therefore, for the purpose of data protection legislation, we are the data
controllers and serve you the information contained in this Privacy Policy.
2.3.
This policy has been designed in accordance to the General Data
Protection Regulation (EU) 2016/679 of the European Parliament and of the
Council of 27 April 2016 on the protection of natural persons with regard to
the processing of personal data and on the free movement of such data, and
repealing Directive 95/46/EC and Data Protection Act 2018.
2.4.
The policy applies to those individuals who fundraise for us, donate to
us, offer grants to us, participate in our programmes, subscribe to our
newsletters, visit our website, follow us on social media, attend our events,
or supply products and services to us (all data subjects referred collectively
as ‘service users and supporters’).
2.5.
If you are our service user and supporter, it is important that you read
this policy, together with any other policy or notice we may provide on
specific occasions when we are processing personal data about you, so that you
are aware of how and why we are using your personal information.
2.6.
If you have any questions or requests, you can directly contact our
representative at robert.rankine@smartchoices.org.uk or by writing to us at our office.
3.
Why are you being given this policy?
3.1.
We want to make you aware of how
and why your personal information will be used by Smart Choices. It also gives you
certain information that relevant data protection laws require us to provide to
you.
3.2.
Smart
Choices aims to comply with data protection laws. The personal information we
hold about you will be:
3.2.1.
Used
lawfully, fairly and in a transparent way.
3.2.2.
Collected
only for valid purposes that we have clearly explained to you and not used in
any way that is incompatible with those purposes.
3.2.3.
Relevant
to the purposes we have told you about and limited only to those purposes.
3.2.4.
Accurate
and kept up to date.
3.2.5.
Kept
only as long as necessary for the purposes we have told you about.
3.2.6.
Kept
securely.
4.
How we collect and process
information about you?
4.1.
We will collect, store, and use certain categories of personal
information and special categories of personal information, about you for
specific reasons. The information that we will process will be either provided
by you to us or it may be gathered from publicly available sources.
4.2.
We will process your information for a range of purposes, but only when
the law allows us to. Most commonly, we will use your personal information in
the following circumstances:
4.2.1.
Where we need to perform the contract we have
entered into with you.
4.2.2.
Where we have your consent to process your data.
4.2.3.
Where it is necessary for our legitimate interests and your interests
and your fundamental rights do not override these interests.
4.3.
Smart Choices holds certain personal data, including special categories
of personal data, about diverse service users and supporters.
4.4.
Personal data is any information about an individual from which that
person can be identified; it does not include data where the identity has been
removed. Special categories of personal data relate to racial or ethnic origin,
religious or philosophical beliefs, health and other specific attributes
defined by data protection legislation.
4.5.
We will only use your personal data when the law allows us to for
specific purposes and based on relevant legal grounds. Your information will be
used for the purposes for which we collected it, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with
the original purpose. If we need to use your personal information for a new
purpose, we will notify you and we will explain the legal ground which allows
us to do so.
4.6.
If you do not provide certain information when you are requested, we may
not be able to perform the contract we have entered into with you.
4.7.
We do not use any automated decision-making processes when we process
your personal information.
4.8.
We collect, store, and use
different kinds of personal data from a range of our service users and
supporters. Depending on who you are, please see a relevant section below to
understand how we collect and process data about you.
4.8.1.
If you make donations to us, Smart Choices may collect your name, email
address, address, bank account details, credit/debit card details, information
describing where you work, what is your education, interests and hobbies, and
which other charities or organisations you support. We will collect this
information when you send us inquiries, complete either a donation form on our
website or our sponsorship form, or when we network at events. Some of this
information can be disclosed to us by the Charities Aid Foundation when you
make a donation. We will use information about you to fulfil our legitimate
interests in order to process your donations and to store relevant records for
accounting purposes. We may also ask whether you would like to receive any news
from us in relation to our campaigns and actions you can take part in.
4.8.2.
If you take part in our
fundraising campaigns, Smart Choices may collect your name, email address, phone number, date
of birth, information about your gender, age, and contact details of any
organisation that you represent. We may also take your photos and ask for your
quotes. If you take part in events where we are fundraising, we may ask you to
provide us with the information about your health condition and emergency
contact details. We will collect this information through our online sign-up
forms, your enquiries and when you take part and follow up on events. Based on
our contract with you, and our necessity to protect your vital interests or our
legitimate interest, we will use information about you to ensure your
possibility to participate in events and/or to fundraise for us in other ways,
to grow the knowledge about our activities, throughout your testimonials, and
we will retain some of this information to comply with legal requirements.
4.8.3.
If you participate in any of
our programmes dedicated to children and young people, Smart Choices may use your name, contact
details, information about your school, age, gender and ethnicity. We may also
use information about your learning and development outcomes, diagnosed or
statemented learning or developmental needs and disabilities. You may share
some of your personal information with us when you complete written exercises
in which you express your journey of learning, feelings and safety concerns. We
may also ask you to use your photos and quotes. This information may be
collected when the school refers you to us, through your enquiries and when you
take part in our programmes and activities. We may also ask whether you would
like to receive any news from us in relation to our campaigns and actions you
can take part in. Based on your or your parents’ or legal guardians’ consent,
we will use information about you to facilitate your participation in our
programmes and, throughout your testimonials, to grow the knowledge about our
activities. We will retain some of this information for a reasonable time to
trace your development journey through your participation in our programmes.
4.8.4.
If you help us to facilitate
participation in our programmes at your school, Smart Choices will process your name, job
title, contact details and information about the school that you represent. We
will collect this information from publicly available sources or through your
enquiries. It is within our legitimate interest to process such information
about you in order to establish a collaboration with your school and to facilitate
the accessibility of our programmes to pupils.
4.8.5.
If you provide a funding
opportunity to us, we may collect your
name and contact details from publicly available sources or through our
enquiries. Based on our legitimate interest, we will use information about you
to consult about available grants and to apply for them.
4.8.6.
If you subscribe to our
newsletters, Smart Choices will collect your name and contact details
that you may provide though the online subscription form on our website. If you
provide this information directly to us, we will seek your consent. However, if
we are already in contact with you for another purpose
we will verify whether we can deliver our newsletter to you based on our
legitimate interest, where you would expect to be contacted by us. We will use
your personal data only to inform you about our campaigns and activities and to
grow the knowledge about us. You will be given an option to withdraw your
consent or to opt-out from our mailing list at any time.
4.8.7.
If you visit our website online
or follow us on social media, we may collect your IP address, browsing time and
date, device details, as well as your name, photos and your messages to us. We
will collect this information through cookies if you allow them, as well as you
will provide this information directly to us when you start following us on
social media or send a message. Based on our legitimate interest, we will use
information about you to improve content and accessibility of our website,
increase knowledge about our activities on social media and respond to your
enquiries.
5.
When will we share your personal information?
5.1.
Your information may be shared with
third parties only when it is required by law or where it is necessary to
administer our relationship with you.
5.2.
We will not sell your information to any other charities or
organisations.
5.3.
If you sign up to participate in an event which is hosted or organised
by a third-party, we may need to share some of your personal information with them
which is necessary to help ensure your safe participation.
5.4.
We may also need to share information with government agencies or law
enforcement authorities where we have a legal obligation to do so, e.g. with
HMRC in relation to donations or with police for prevention or detection of a
crime.
5.5.
Additionally, we use third-party service providers to help us to provide
services to you and support the functioning of our back office. For example, we
use service providers for the storage of your personal data, delivery of
newsletters, registration to events, and facilitation of donations. We have
undertaken due diligence on all these organisations and have entered into
contracts requiring them to only process your information for the purposes we
instruct them to and in a safe manner.
5.6.
Some of our service providers are located in the US, for this reason we
may need to transfer your personal information beyond the EU and EEA. In any
such instance we will make sure that your personal information receives an
adequate level of protection. We will take steps to ensure your privacy rights
are protected and your personal information is treated in a way that is
consistent with and which respects EU data protection laws, by putting in place
appropriate measures, including requiring appropriate security measures.
6.
How will we protect your personal information?
6.1.
We have put in place appropriate
security measures to prevent your personal information from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed.
6.2.
In addition, we limit access to your personal information to those staff
members and other third parties who have a business need to know. They will
only process your personal information on our instructions
and they are subject to a duty of confidentiality.
7.
How long do we retain your personal information for?
7.1.
We will only retain your personal
information for as long as necessary to fulfil the purposes we collected it
for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
7.2.
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
requirements. We have put an appropriate retention process in place to make
sure that the data is retained for a reasonable time. Please contact us, if you
wish to get more details.
7.3.
In some circumstances we may anonymise your personal information so that
it can no longer be associated with you, in which case we may use such
information without further notice to you.
8. What are your rights in relation to your personal
information?
8.1.
Under certain circumstances, you have
the right to access, verify, correct, complete or request erasure of your
personal information, object to the processing of your personal data, restrict
the processing of your personal data or request that we transfer a copy of your
personal information to another party. If you wish to submit your request,
please contact us at robert.rankine@smartchoices.org.uk or write to
us at our office.
8.2.
Under certain circumstances, you have
the right to:
8.2.1.
Request access to your personal
information (known as a
“data subject access request”). This
enables you to check whether we process any of your personal data and to
receive a copy of it.
8.2.2.
Request correction or
completion of the personal information that we hold about you. This enables
you to have any incomplete or inaccurate information we hold about you
corrected or completed.
8.2.3.
Request erasure of your
personal information. This enables
you to ask us to delete or remove personal information 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 information where you have exercised your right
to object to processing (see below).
8.2.4.
Object to processing of your
personal information where we are
relying on a legitimate interest and there is something about your particular
situation which makes you want to object to processing on this ground. You also
have the right to object if you wish to opt-out form our mailing list.
8.2.5.
Request the restriction of
processing of your personal information. This enables you
to ask us to suspend the processing of personal information about you, for
example if you want us to establish its accuracy or the reason for processing
it.
8.2.6.
Request the transfer of your
personal information to another party. You will not have
to pay any fee to exercise any of your rights. However, we may charge a
reasonable fee if your request is clearly unfounded or excessive or,
alternatively, we may refuse to comply with the request.
8.3.
We may also refuse to comply with your
request to access personal data if the information you ask us to provide relates
to our business management forecasting or planning and the disclosure of such
information would likely affect our business, or where the information consists
of records of our intentions in relation to any negotiations with you and such
disclosure would be likely to prejudice those negotiations, or the requested
information consists of a reference given (or to be given) regarding your
prospective or current education, training, employment, appointment to any
office or your provision of any service. If we refuse your access to personal
data, we will explain the reasons in our response to you.
8.4.
Additionally, you have the right to
make a complaint at any time to the Information Commissioner’s Office if you
believe that we process your personal data inappropriately.
9.
Changes to the privacy policy
9.1. This policy does not form part of any contract. We may update it at any time, and make the new privacy policy available directly to you when we make any substantial updates.