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We have updated this policy to reflect changes in data protection law. This policy was last updated 20th June 2024.

At Age UK Bolton, we're committed to protecting and respecting your privacy.

This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.

Any questions regarding this policy and our privacy practices should be sent by email to enquiries@ageukbolton.org.uk or by writing to Corporate Services Manager, The Square, 53 – 55 Victoria Square, Bolton, BL1 1RZ. Alternatively, you can telephone 01204 382411.

Who it applies to

This policy applies to individuals whose personal data is processed by Age UK Bolton.

Who are we?

Age UK Bolton is a registered Charity (number 223240). The registered address is 53 – 55 Victoria Square, Bolton, BL1 1RZ

Usually, Age UK Bolton will be the 'controller' of your personal information. This means that we are responsible for deciding how your personal information is used and ensuring that it is used in compliance with applicable data protection law (in conjunction with other parties, where applicable).

How do we collect information from you?

We obtain information about you in the following ways:

Information you give us directly

This could be as a client, customer supplier, business contact, employee, volunteer or contractor of our service, when you donate, access a service or attend and event.

Mandatory information

In some circumstances, it may be mandatory to collect and process some of your personal details to deliver the service or provide the support you are looking for.

For example:

  • we need your contact details to respond to your enquiry or complaint.
  • if you kindly choose to make a one-off or regular donation to us and allow us to claim Gift Aid

 

Information you give us indirectly

Your information may be shared with us by third parties, for example where you have consented for them to do so or where there is an agreement/contract in place between us and the third party. These might include: 

  • Referrals made to us from another organisation or individual, such as your GP, if they think the service would be helpful to you.

You should check any privacy policy provided to you where you give your data to a third party.

When you visit this website

We, like many companies, automatically collect the following information:

  • technical information, including the type of device you're using, the IP address, browser and operating system being used to connect your computer to the internet. This information may be used to improve the services we offer.
  • information about your visit to this website, for example we collect information about pages you visit and how you navigate the website, i.e., length of visits to certain pages, products and services you viewed and searched for, referral sources (e.g., how you arrived at our website).

We collect and use your personal information by using cookies on our website. Some of these cookies can be enabled/disabled by selecting your preferences in the preference centre you are presented with when first interacting with this site. More information on cookies can be found under the 'Use of Cookies' section below.

When you use social media

When you interact with us on social media platforms such as Facebook, Instagram, LinkedIn and X (formally Twitter), we may obtain information about you (for example, when you publicly tag us in an event photo). The information we receive will depend on the privacy preferences you have set on those types of platforms. If you interact with us in this way, we encourage you to read the Privacy Policy of the social media platform(s) you use.

As mentioned above, we collect and use your personal information by using cookies, including social media cookies (i.e., third party cookies). We use social media cookies to enhance the functionality of this website and provide you with personalised content (see our Cookie Policy for more information).

Public Information

We supplement information on our supporters with information from publicly available sources such as annual reviews, corporate websites, public social media accounts, the electoral register, Mint UK, Google and Companies House in order to create a fuller understanding of someone’s interests and support. For more information, please see the section on ‘Building Profiles’ below.

What type of information is collected from you?

The information we collect, store and use from you may depend on the relationship you have with Age UK Bolton. This might include:

  • your name and contact details (including postal address, email address and telephone number)
  • your date of birth
  • your communications with us, such as call recordings and emails you send. These communications may relate to general enquiries, requests for support or guidance, and complaints or feedback about our activities, products and services.
  • your bank or credit card details. If you make a donation online or make a purchase, your card information is not held by us, it is collected by our third-party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions
  • information as to whether you are a UK taxpayer so we can claim gift aid
  • if you are a successful applicant to volunteer or work for us, we will ask for photographic ID to verify your identity. We may also collect your National Insurance number and information from the Disclosure and Barring Service (DBS) where appropriate.

Data protection laws recognise certain categories of personal information as sensitive and therefore requiring greater protection, for example information about your health, ethnicity and religion.

We do not usually collect sensitive data about you unless there is a clear and valid reason for doing so and data protection laws allow us to do so.

Where appropriate, we will make it clear why we are collecting this type of information and what it will be used for.

How and why is your information used?

The purposes for which we use your information may depend on the relationship you have with Age UK Bolton. We may use your information for a number of different purposes, which may include:

  • providing you with the services, products or information you asked for.
  • processing orders that you have submitted
  • carrying out our obligations under any contracts entered into between you and us
  • keeping a record of your relationship with us
  • administering your donation or support your fundraising, including processing Gift Aid
  • responding to or fulfil any requests, complaints or queries you make to us
  • conducting analysis and market research to better understand how we can improve our services, products or information
  • analysing the number and type of people who have used our services to demonstrate our impact and apply for funding
  • monitoring the interactions we have with our customers, donors and beneficiaries for quality control and compliance purposes to ensure we are delivering the service we and our regulators expect (See ‘Monitoring’ section below)
  • checking information we have collected about online and offline about you against third party sources so we can ensure that the information we hold about you is up to date and accurate
  • to monitor website-use to identify visitor location, guard against disruptive use, monitor website traffic, personalise information which is presented to you and/or to provide you with targeted advertisements
  • dealing with entries into a competition or draw
  • seeking your views or comments on the services we provide
  • notifying you of changes to our services
  • sending you communications which you have requested and that may be of interest to you. These may include information about campaigns, fundraising appeals and activities and promotions of goods and services
  • communicating with you about the fundraising events you have signed-up for to help us raise important funds for our charitable work.
  • administering a legacy, where the charity is potentially the beneficiary of a legacy, we will obtain the names and contact details of executors, a copy of the will, and a grant of probate
  • checking donations for the purposes of prevention of fraud or other crime
  • processing grant or job applications.

How and when will you hear from us

We respect your right to privacy, and we will only contact you about Age UK Bolton, our trading and charitable subsidiaries, if you are happy to hear from us or where appropriate to do so.

Fundraising and Marketing Communications

We may use your contact details to provide you with information about the vital work we do for older people, our fundraising appeals and opportunities to support us, as well as the products and services you can buy if we think it may be of interest to you.

Email, text and phone

We will only send you marketing and fundraising communications by email text and telephone if you have explicitly provided your prior consent. This does not apply to service communications (see below).

We’ll always ask for your permission to contact you about our products and services in this way, for example:

  • when you sign a petition
  • when you make a donation
  • when you fundraise for us
  • when you contact the Age UK Bolton Advice Line
  • when you enquire about, or purchase, one of our products or services.

If you have signed up for one of our fundraising events, then we may contact you by email to tell you important information about the event (such as location details and what to bring on the day), provide information about similar leisure activities or events we think you will be interested in, share stories from our community of fundraisers, and provide useful fundraising tips to help you raise important funds for Age UK Bolton.

You can opt out of our marketing communications at any time. Please see “Your Choices” for further information.

Post

We may send you marketing and fundraising communications by post that we think may be of interest to you, unless you have told us that you would prefer not to hear from us in this way.

If we contact you by post with marketing and fundraising information, we do so under the lawful basis of legitimate interest.

This means that we send postal communications to achieve our charitable and/or organisational aims and ideals, whilst ensuring that doing so does not impinge on your privacy rights.

We believe that we have a legitimate interest to do this to raise vital funds, including via our trading subsidiaries, to sustain our charitable work to be there for older people who need us most.

We ask you if you would prefer not to hear from us in this way the first time you contact us, and you can opt out of postal communications at any point going forward. Please see ‘Your Choices’ for more information.

Service communications

We may send you certain communications, without your consent, if we are under a legal obligation to do so; if we feel sending the communication is in both yours and our interests; and/or it would be a disadvantage to you if we didn’t send you the communication.

These communications may include:

  • ‘Thank you’ emails to confirm receipt of your kind donations made to us online
  • Registration confirmation, such as when you sign up to one of our events

 

Online advertising

We advertise on Facebook, Instagram, LinkedIn and X (formally Twitter).

We may use the following re-marketing processes on some or all of specific online platforms.

  1. 'Look-alike' / 'Similar' audiences: We send a list of 'hashed' email addresses to an online platform such as Facebook or Google (hashing is a security measure whereby the personal information is turned into a code).
  2. 'Custom audiences'/ 'Customer matches': We use a similar method as above to send information and support about our fundraising campaigns/ marketing campaigns to people who have already signed up for these.
  3. 'Saved' audiences to remember which supporters on Facebook are most likely to respond to our fundraising, campaigning, and marketing requests.
  4. Tracking people's interactions with our adverts so that we know when an individual has clicked on an advert. This allows us to measure the effectiveness of our campaigns.

In some of the above instances, this means that if you have already visited our website, we can direct you back to it through ads shown on sites you visit across the internet by third party vendors. These third-party vendors include Google and Facebook. All parties may use cookies to serve these ads based on your past visits to our website.

You can object to your information being used by withholding permission on our cookie preference centre when you visit our site.

Using your information to tailor our work

Philanthropy

We research, and profile potential or existing high-value donors, to allow us to identify and engage with appropriate high-value donors. This allows us to focus our fundraising resources, and to ensure that our requests for support are tailored to each individual, ultimately helping us to maximise the efficiency of our fundraising. If you would prefer that we do not carry out this type of analysis, please contact us at  enquiries@ageukbolton.org.uk   

Profiling and analysis

We may analyse your personal information to create a profile of your interests and preferences so that we can tailor and target our communications in a way that is timely and relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. This allows us to be more focused, efficient, and cost-effective with our resources and also reduces the risk of someone receiving information they may find inappropriate or irrelevant.

We're committed to putting you in control of your data so you’re free to opt out of your information being used in this way at any time by contacting enquiries@ageukbolton.org.uk   

We may also use your personal information to detect and reduce fraud and credit risk.

Website recording

Our website may also use technologies to monitor your use of our site. The types of information these technologies record may include IP address, mouse clicks, mouse movements, page scrolling and any text keyed into website forms. The information collected does not include bank details or any sensitive personal data and is stored and used for aggregated and statistical reporting. This information will be accessed by Age UK Bolton and trusted third-party agencies working on our behalf for the purpose of monitoring and improving the usability of the Age UK Bolton website.

Who has access to your information?

We do not sell or rent your information to third parties.

We do not share your information with third parties for marketing purposes.

However, we may disclose your information to third parties in order to achieve the other purposes set out in this policy. These third parties may include:

Third parties working on our behalf

We may pass your information to our third-party service providers, suppliers, agents, subcontractors, and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

Third-party product providers we work with

Our trusted third-party product providers provide a range of products and services designed to help people make the most of later life. When you enquire about or purchase one or more of these products, the relevant third-party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered with them. They will be acting as either a joint or independent controller of your information and therefore we advise you to read their Privacy Policy. These third-party product providers will share your information with us which we will use in accordance with this policy.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our staff, supporters, customers, users of the website or others. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

At the time of writing, we work with the following Third Parties:

  • NHS
  • Bolton Council
  • CAB Bolton
  • Dizions
  • Hands On computer Services
  • Bolton at Home
  • Home Instead
  • GP Federation
  • Age UK Blackburn
  • Bolton CVS
  • Bolton Cares
  • Bolton Carers Support Group
  • Bolton Dementia Support Group
  • Greater Sport
  • University of Manchester
  • Bolton Safeguarding Team
  • 1 Point
  • Halliwell Befriending Service
  • Reach Befriending
  • Senior Solutions

 

Lawful Processing

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

Specific Consent

Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing. Your specific consent is also used where you have agreed for us to use your personal information in case studies to promote our work. You can withdraw your consent at any time. Please see ‘Your Choices’ for more information.

Performance of a contract

Where we are entering into a contract with you or performing our obligations under it.

Legal obligation

Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like the Charity Commission or Fundraising Regulator.

Vital interests

Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual at one of our events) or a safeguarding issue which requires us to share your information with the emergency services.

Legitimate interests

Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).

We consider our legitimate interests to be running Age UK Bolton as a charitable organisation in pursuit of our aims and ideals. For example to:

  • send postal communications which we think will be of interest to you
  • send email communications about, and related to, fundraising events you have signed up for to help you raise important funds for our charitable work
  • conduct research to better understand our supporters and to improve the relevance of our fundraising
  • understand how people choose/use our services and products
  • determine the effectiveness of our services, promotional campaigns and advertising
  • Sharing personal data amongst relevant teams within Age UK to ensure we communicate with our supporters in the most effective way
  • Purchase marketing lists to promote our fundraising activity
  • monitor who we deal with to protect the charity against fraud, money laundering and other risks
  • record and monitor interactions for quality and training purposes
  • enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers; and
  • better understand how people interact with our website.
  • Retain records and call recordings as evidence in defence of a legal claim.

When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about the vital work we do for older people and the exciting products and services you can buy, then you can select your choices by ticking the relevant boxes situated on the form used to collect your information.

We’re committed to putting you in control of your data so you’re free to change your marketing communication preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time using:

  • enquiries@ageukbolton.org.uk, or
  • by telephone: 01204 382411, or
  • by post: Age UK Bolton, The Square, 53-55 Victoria Square, Bolton, BL1 1RZ.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like where we are processing a donation or thanking you for your participation in an event.

Your Rights

Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that we think apply:

Right of access

You have a right to request access to the personal data that we hold about you.

You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.

If you want to access your information, contact us using our details below. Please be aware that we will ask you for proof of identity or alternative proof of authority before sharing any information we may hold.

Right to have your inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we're working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post (see below). Alternatively, you can telephone 01204 382411.

Right to restrict use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we're not lawfully allowed to use it.

Right of erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to. In many cases, we will anonymise that information, rather than delete it.

Right for your personal information to be portable

If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.

Right to object

You have the right to object to processing where we using your personal information (1) based on legitimate interests, (2) for direct marketing or (3) for statistical/research purposes.

If you want to exercise any of the above rights, please email us at enquiries@ageukbolton.org.uk or write to Age UK Bolton, The Square, 53-55 Victoria Square, Bolton, BL1 1RZ. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.

Keeping your information safe

When you give us personal information, both offline and online, we take steps to ensure that appropriate technical and organisational controls are in place to protect it.

Any sensitive information (such as credit or debit card details) provided to us via our website is encrypted and protected with the following software: 128 Bit encryption on TLS. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Non-sensitive details (your email address etc.) are transmitted 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 website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Keeping your information up to date

We take reasonable steps to ensure your information is accurate and up to date.

Where possible we use publicly available sources to identify deceased records or whether you have changed address.

We really appreciate it if you let us know when your contact details change.

How long is your information kept for?

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information for is determined by operational and legal considerations, as well as best practice.

For example, we are legally required to hold some types of information to fulfill our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).

Further reasons we may retain personal information include:

  • For our auditing purposes
  • Evidence in defence of a legal claim
  • Ensuring you are suppressed from marketing if you prefer never to hear from us in the future.

We review our retention periods on a regular basis.

If you would like to know more about how long we hold your personal data for – please email us at enquiries@ageukbolton.co.uk  

Use of 'cookies'

Like many other websites, this website uses cookies. 'cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. For example, we use cookies to store your country preference. This helps us to deliver a more personalised service when you browse our website and improves our services.

Age UK Bolton has a Cookie Preference centre that allows you to control certain types of cookies that are used by Age UK. When anyone visits or is taken to our website, all Marketing/Targeting cookies are opted out by default, meaning that individuals will only receive targeted online advertisements if they opt-in to these types of cookies. Cookies for Performance allow us to anonymously assess how effectively our website is working which in turn, ensures that we are giving all of our users the best experience.

We use Google Consent Mode, a feature of Google Analytics 4, which interacts with our cookie preference centre.

If you choose to deny consent to targeting or performance cookies, instead of storing cookies on your device, tags send “cookieless” pings to Google. This allows us to track the effectiveness of our online campaigns while respecting your cookie preferences and privacy.

It is possible to switch off cookies by setting your browser preferences. Turning cookies off may result in a loss of functionality when using our website.

Links to other websites

Our website may contain links to other websites run by other organisations. This policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other websites even if you access those using links from our website.

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the privacy policy of that third-party site.

Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you're happy with any changes. If we make any significant changes we'll make this clear on this website.

16 or Under

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian's permission beforehand whenever you provide us with personal information.

Vulnerable circumstances

We are committed to protecting vulnerable supporters, customers and volunteers, and appreciate that additional care may be needed when we use their personal information. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.

Transferring your information outside of Europe

If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EEA. You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy.

We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff, volunteers and contractors.

 

Monitoring

Records of your personal information and interactions with us (including by email and telephone) may be monitored. This may include:

  • When you call or email us
  • When you speak to any of our services
  • When you call or email to update your details with us
  • When you call or email to make a complaint or provide feedback

We will only ask for the personal information that we need to provide you with the service you are looking for.

The purposes for which we monitor your communications with us are:

  • training and quality assurance to help us continuously provide the best possible service
  • to report, analyse and learn from the complaints and feedback that we receive.

Complaints

We welcome, and take seriously, all complaints and feedback about our work.

If you make a complaint to us, we will collect and use your information to respond to your concerns.

If your complaint relates to an area of our work where we employ a third-party processor or product provider, we may share your personal information with that third party to investigate your concerns.

We will keep a record of your complaint for 7 years from the date that we deem the complaint closed.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:


Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk

Changes to this policy

Any changes we may make to this policy in the future will be posted on this website so please check this page occasionally to ensure that you're happy with any changes. If we make any significant changes, we'll make this clear on this website.