At Age UK West Cumbria, 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.
- Who we are
- Why we collect information from you
- What type of information we collect from you
- How your information is used
- How long is your information kept for?
- Who has access to your information
- Lawful processing
- Fundraising and marketing communications
- Your choices
- Your rights
- Keeping your information safe
- Links to other websites
- Protecting the privacy of children aged 16 or under
- Transferring your information outside of Europe
- What to do if you want to make a complaint
- When this policy is reviewed
Who are we?
Age UK West Cumbria is an independent local charity (number 1122049) and company limited by guarantee (number 6047495) operating in Copeland and Allerdale since 1978. The registered address is Old Customs House, West Strand, Whitehaven, CA28 7LR.
How do we collect information from you?
Information you give to us
This could be when you :
- Register for, or use our services
- Register as a volunteer
- Undergo an assessment
- Tell us your story
- Provide us with feedback
- Complete a survey
- Participate in our training
- Support our work through a donation
- Fundraise on our behalf
- Submit an enquiry
- Make a complaint
- Register for an event
- Attend an event
- Enter into a competition
- Apply for a job
- Enter into a contract with us
- Are captured by CCTV recording
- Request communications which may be of interest to you. These may include information about campaigns, appeals, other fundraising
Information we collect when you visit our 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).
Information we collect when you interact with us on Social Media
When you interact with us on social media platforms such as Facebook and 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.
What type of information is collected from you?
The personal information we collect might include:
- your name and contact details (including postal address, email address and telephone number);
- your date of birth;
- Information about your next of kin
- 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; and
- any other personal information shared with us
Age UK West Cumbria must record service users’ explicit consent to storing certain information (known as ‘special categories of personal data’) on file.
This is because special category data is more sensitive, and so needs more protection. For example, information about an individual’s:
- ethnic origin;
- trade union membership;
- biometrics (where used for ID purposes);
- health and wellbeing
- sex life; or sexual orientation.
Special categories of personal information collected by Age UK West Cumbria will usually relate to service users’ physical and mental health. Data is also collected on ethnicity and held confidentially for statistical purposes.
Consent is not required to store information that is not classed as a special category of personal data as long as only accurate data that is necessary for a service to be provided is recorded.
As a general rule Age UK West Cumbria will always seek consent where special categories of personal information are to be held.
It should also be noted that where it is not reasonable to obtain consent at the time data is first recorded and the case remains open, retrospective consent should be sought at the earliest appropriate opportunity.
If personal and/or special categories of personal data need to be recorded for the purpose of service provision and the service user refuses consent, the case should be referred to the Compliance Officer for advice.
Consent may be obtained in a number of ways depending on the nature of the interview, and consent must be recorded on or maintained with the case records:
Specific consent for use of any photographs and/or videos taken should be obtained as written consent. Such media could be used for, but not limited to, publicity material, press releases, social media, and website. If the subject is less than 18 years of age then parental/guardian consent should be sought.
Individuals have a right to withdraw consent at any time. If this affects the provision of a service(s) by Age UK West Cumbria then the Services Manager should discuss with the Compliance Officer at the earliest opportunity.
How is your information used?
We may use your information to:
- Assess your needs and help you to prepare a Support Plan
- Provide a record of our contacts with you, (such as home visits), the services and support you have received and the outcomes
- Make a referral, agreed with you, to a partner or external agency to meet your wider needs
- Process a donation that you have made
- Process orders
- Carry out our obligations arising from any contracts entered into by you and us
- Deal with entries into a competition
- Seek your views or comments on the services we provide
- Notify you of changes to our services
- Send you communications which you have requested and that may be of interest to you. These may include information about campaigns, appeals, other fundraising activities, promotions of our associated companies goods and services
- Process a grant or job application.
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. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes).
We review our retention periods on a regular basis.
Who has access to your information?
We are committed to protecting the personal data we hold about you. Any details you give us will be held in accordance with the General Data Protection Regulation. Age UK West Cumbria is the sole owner any of the information collected.
We will not sell, share, or rent this information to third parties, unless we have your explicit permission 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. Where you have given us permission we may contact you about other services and products and/or pass your information to a 3rd party in order to process a service. We will only share the personal information necessary to deliver the service.
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 (eg partner agencies providing services to meet your support or care needs ). 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
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:
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.
Performance of a contract
Where we are entering into a contract with you or performing our obligations under it.
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.
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.
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 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;
- 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;
- monitor who we deal with to protect the charity against fraud, money laundering and other risks;
- enhance, modify, personalise or otherwise improve our services /communications for the benefit of our customers; and
- better understand how people interact with our website.
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).
Fundraising and Marketing
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.
We will only send you marketing and fundraising communications by email, text and telephone if you have explicitly provided your prior consent. You may opt out of our marketing communications at any time by clicking the unsubscribe link at the end of our marketing emails.
We may send you marketing and fundraising communications by post unless you have told us that you would prefer not to hear from us.
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 preferences (including to tell us that you don’t want to be contacted for marketing purposes) at any time using: email@example.com, or by telephone: 08443 843 843, or post: Audit and Governance Team, Age UK, Old Customs House, West Strand, Whitehaven, CA28 7LR.
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.
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, please send a description of the information you would like to see and proof of your identity by post to the address provided below.
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 08443 843 843.
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 firstname.lastname@example.org or write to Audit and Compliance Officer, Old Customs House, West Strand, Whitehaven, CA28 7LR. We may be required to ask you 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, we take steps to ensure that it’s treated securely.
Any sensitive information (such as credit or debit card details) are encrypted and protected by: 128 Bit encryption via SSL.
When you provide us with personal and/or sensitive information we take steps to ensure that it is treated securely and with respect. Information will be held on one or both of our two databases hosted by our partner organisations, Dizions Ltd and Compass, and we have satisfied ourselves that their practices are compliant with this privacy statement and current data protection legislation.
Age UK West Cumbria is accredited to ISO 27001 Information Security Management. This accreditation demonstrates our commitment to maintaining the highest security and compliance standards.
Any information collected or submitted via our website will be treated not only in accordance with the General Data Protection Regulation but also in accordance with the principles of our ISO 27001 accreditation.
Use of 'cookies'
It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit our full cookies policy. 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.
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.
Transferring your information outside of Europe
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.
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.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff and volunteers.
If you want to make a complaint or raise a concern, you can do so by emailing us at email@example.com or by writing to The Audit & Governance Team, Old Customs House, West Strand, Whitehaven, CA28 7LR.
Changes to this policy
Review of this Policy
This policy was last reviewed in July 2018. This is kept under regular review and updated where necessary.