INTRODUCTION
Spear Brighton Trust is a charity registered in the UK (no. 1179174).
Our work is focused on social transformation by means of the Spear programme, helping young people from disadvantaged backgrounds to find work.
Spear Brighton Trust follows industry best practice regarding how we collect, store and use your personal data. We have applied for registration with the Fundraising Regulator and the Information Commissioner’s Office.
This policy explains how we collect personal data, how we use and store it, and how to contact us regarding your data.
If you have any questions about this privacy policy please do not hesitate to contact us on hello@spearbrighton.org.
WHO WE ARE
Spear Brighton Trust is a registered UK charity number 1179174. For the purposes of this Policy, ‘Spear Brighton ‘us’, ‘we’ and ‘our’ refers to Spear Brighton Trust.
WHAT INFORMATION DO WE COLLECT?
We collect certain personal information each time you interact with us. For example when you make a donation, request information, apply for a programme or sign up for an event, such as Spear Celebration, or submit a request to volunteer. We do so to ensure we can complete any request you make of us, or to provide you with the most relevant information.
• From interaction on our website
We collect non-personal data such as IP addresses, details of pages visited and files downloaded. Website usage information is collected using cookies, see the section on Cookies below.
• Indirectly from Third parties
We collect information from third parties, such as fundraising sites including Virgin Money Giving, Just Giving and Facebook Giving, where you have agreed to support Spear Brighton and our work and have given your consent.
We may collect information that you make publicly available, for example on social media platforms such as, Twitter, LinkedIn etc.
As with all third parties, you may wish to check how they collect, store and process your personal data.
• From publicly available data
We may collect information from Companies House, the Charity Commission and information published online or in printed news media, to help us tailor our communication to you.
• Sensitive data
Certain pieces of personal data are classed as ‘sensitive’, including religious beliefs, health or financial information. If you provide this information to us, we may store it to ensure we communicate with you in the most relevant way. For example, if you tell us you go to a local church we may invite you to a relevant local event.
Spear Programme – Young People
When you sign up to the Spear programme and share personal data with us, we will retain this information for analysis and monitoring purposes.
Some information you share with us may be classed as ‘sensitive personal data’, including, but not limited to, information about your mental and physical health, ethnic background, criminal record, educational history and exam results and data regarding your socio-economic background, such as the type of housing you live in. This information is stored securely on our Salesforce database, and is only accessible by staff who have a legitimate reason to access the information. We collect this data to ensure that we can provide the best service possible to young people, and to ensure that we are working with young people who most need our help.
When analysing data on the effectiveness of the Spear programme this is anonymised, and no individual data is shared.
Spear Brighton may share your information listed above, and any employment outcomes, with The Department for Work and Pensions. Your place on the Spear programme may be funded by the Job Centre, which means sharing your name, NI number, date of birth, gender, post code, programme start/finish dates and employment outcomes with them. The data will be used to measure whether the success of the scheme.
WHAT DO WE DO WITH YOUR DATA?
Processing of requests and donations
We may use the personal data we collect to:
• Keep you up to date on news and stories about our work;
• Ask for financial and non-financial support, such as volunteering;
• Process donations you give us, or to support your fundraising for us, including gift aid;
• Provide information you have requested;
• Provide a personalised service, such as personalised emails;
• Record your interaction with us, such as any volunteering you engage in or events you attend;
• Analyse the personal information we collect about you and use publicly available information to aid our understanding of our supporters, understand the level of potential donations, profile supporters into categories to help provide the right information at the right time to the right supporters; and
• Ask for your feedback on our work and our communication with you.
Basis of processing your data
Consent: From 1st March 2019, we will process your personal data on the basis of the consent you provided us with. In practice, this means that we will contact you by email and phone only if you have given us permission to do so. You are free to change your preferences at any time by contacting us by telephone, post or email, using the details shown below.
Legitimate interest: Contacting the right supporters at the right time. We may write to our supporters occasionally by post to inform them of our work or of opportunities to get involved. When you make a donation, a series of donations, express an interest in our work, or show a potential to give to our work, we will rely on our legitimate interest in order to collect additional information as noted above. This helps us to identify those supporters who would benefit from an initial discussion with a us.
Applying for a job or volunteering with us
Where you provide personal data and sensitive personal data when applying for a job or volunteering opportunity, such as the information on your CV, we will process, store and disclose this personal data to support the recruitment process. With your consent we will use this information to contact third parties, such as referees, or to check DBS records. CVs and application forms will be stored for a period of six months before being deleted. We will store anonymised data regarding applicants to monitor compliance with our equal opportunities policy.
HOW AND WHERE WE STORE YOUR INFORMATION
How long do we keep your data?
We will keep your personal information only for as long as we consider it necessary to carry out each activity.
We have a data retention policy to implement this. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned.
For example, we will retain details of donations for eight years to meet tax, accounting and auditing requirements. Where someone leaves us a legacy, we will retain this data indefinitely to carry out the administration of legacies and to communicate with families and executors of those who’ve left us a legacy.
If you have any questions about our Data Retention Policy please contact us in writing at:
Data Protection Officer
Spear Brighton
Rostrum Lodge, Ditchling Road
Brighton
BN1 4SB
Or emailing: hello@spearbrighton.org
We ensure that access to personal data is restricted only to those staff members or volunteers whose job roles require such access and that regular training is provided for these individuals.
Where we store your personal information
We use an online database called Salesforce to store and process personal data. Salesforce ensures personal data is held in compliance with European data protection regulations, and Spear Brighton takes steps to ensure that your data is stored and processed securely. When you share your data with us, you agree to it being stored and processed in this way.
WHEN WE SHARE YOUR INFORMATION
Spear Brighton does not share or sell any personal data with other organisations. In order to do our work, we use third party suppliers, such as Mailchimp and Ninjaforms to collect and record data. Resurgo (with whom we contract for Spear programme intellectual property and support) has completed due diligence with these firms to ensure that they are compliant with data protection regulations, and we delete information from these suppliers as soon as possible when it’s no longer needed. If you have any questions please contact us.
Legal duty
We may need to pass on information if required by law or by a regulatory body. For example, a Gift Aid audit by the HMRC, or if asked for details by a law enforcement agency.
COOKIES
What are Cookies?
We collect data using cookies. A cookie is a text file that is sent from our website as soon as you visit the site. It is stored on your computer’s hard drive and helps us to identify your computer (not you) and collects information in an aggregate, anonymous way.
Cookies may be used to collect information about your visit to our website, for example, traffic data, location data, device information, the date and time of your visit and the pages that you visit.
The use of cookies is an industry standard for most major websites.
The cookie data that we collect we may use to:
• Customise the content on our website and to help us understand visitor’s current and future needs
• Process any requests, applications or transactions you may make
• Aid internal administration and analysis
Managing cookies
• Most browsers allow you to turn off the cookie function. To do this you can look at the help function on your browser.
Third party cookies
Spear Brighton occasionally works with a number of third party suppliers who set cookies on our website to enable them to provide us with services. These are mainly used for reporting and advertising purposes so we can improve the way we communicate.
We use websites such as Youtube and Vimeo to embed videos and you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third party website for more information about their cookies and how to manage them.
Spear Brighton also uses third party suppliers such as Facebook, HotJar and Google Analytics and these providers may use cookies. They may also use tracking pixels, which are commonly found in advertising, to track the effectiveness of adverts.
As some of these services may be based outside of the UK and the European Union, they may not fall under the jurisdiction of UK courts. If you are concerned about this you can change your cookie settings (see above).
CHANGING OR UPDATING YOUR PREFERENCES
Preferences
We want to ensure that we communicate with you in the way that best suits you. You can change your preferences on what you receive from us, including marketing and fundraising materials, or how we contact you, by mail, phone or email, at any time. You can also let us know if your contact details change.
You can do so by:
Emailing us: hello@spearbrighton.org
Writing to us:
Rostrum Lodge, Ditchling Road
Brighton
BN1 4SB
Telling us to stop processing
You have the right to ask us to erase your personal data, to ask us to restrict our processing or to object to our processing of your personal data. You can do so at any time by writing to us at:
Data Protection Officer
Spear Brighton
Rostrum Lodge, Ditchling Road
Brighton
BN1 4SB
ACCESS TO YOUR INFORMATION
You have the right to request details of the information we hold about you. To do so, please write to our Data Protection Officer at the address below. In line with regulations, we will respond within 30 days.
CHANGES TO SPEAR BRIGHTON’S PRIVACY & SECURITY POLICY
Changes to this Policy
This policy was last updated in March 2019. We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other legislation. If we make any significant changes to this policy we will show this clearly on our website. By continuing to use our website you will be deemed to have accepted these changes.
Feedback
We welcome feedback or questions on this policy or on any of our actions by
Emailing us on: hello@spearbrighton.org
Writing to us:
Spear Brighton
Rostrum Lodge, Ditchling Road
Brighton
BN1 4SB