1.0 Introduction

This policy sets out how Charlie House uses and protects your personal information, including data from your use of our website.

Charlie House is the Data Controller for personal data about supporters, fundraisers, donors, event attendees, volunteers and subscribers. For the purpose of this document we will use the group term ‘supporters’ to describe any one of these groups.

This policy was updated in April 2018 to show that we are adhering to the new General Data Protection Regulation (GDPR), which comes into force in May 2018.

2.0 Why we need your data

Charlie House collect and process your personal data so that we can provide you with information to keep you updated with our charitable activities and events. We collect personal data from our supporters which may include name, address, email and phone number. How much of this information we collect, depends on the type of relationship we have with you and the information we build in the course of our relationship.

We will not collect any personal data from you that we do not need and we go to great lengths to keep your personal data secure.

3.0 What we do with your data

We do not trade personal data for commercial purposes and will only disclose it if required by law. All the personal data is processed within the UK, however, for the purposes of IT hosting and maintenance by certain systems and databases that we use, such as Salesforce, DropBox and Xero this information may be located on servers within the European Union.

On occasion, we are required by law to share your personal data. We will always contact you prior to sharing your personal data, so that you can understand the reasons why and give your consent, when required.

We have a Data Protection Procedure in place to oversee the effective and secure processing of your personal data. More information on this framework is available on request.

3.1 Subscribers

If you subscribe to our mailing lists from our website, you will automatically be subscribed to receive our quarterly ReCHarge Magazine.

We currently use Mailchimp to manage our subscription lists. Mailchimp store their data in the US although they comply with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework. They do share data with third parties. We are in the process of reviewing options for the future.

We transfer all contacts to our own database, Salesforce which is EU hosted. This system is kept updated with your preferences.

You can change your subscription preferences at any time, by contacting info@charliehouse.org.uk

3.2 Donors, fundraisers and event attendees

As we get to know you, we may collect the following types of information:

• Full Name, title/s
• Whether you are a UK tax payer, so that we can claim Gift Aid on your donation
• Contact details such as full postal address, email addresses and telephone numbers
• Information relating to events you may organise such as the event date, the donation collection method, records of the money raised
• How you heard about us
• What kind of connection you have with our charity
• Why you have decided to donate to us - we will never make this question mandatory, and fully understand if you are not comfortable telling us
• Your feedback from dealings with us
• Contact notes relating to your involvement with the charity or are considering having with our cause

We do not store sensitive personal information that you share with us unless you give your permission to do so.

We will use your information to:

• Thank you for your donation or support unless you have specified for us not to contact you
• Provide you with the services, products or information you asked for

• Administer your contact details and give you the opportunity to change your preferences as well as amend errors and update your data
• Manage donations (including processing Gift Aid)
• Support your fundraising activities
• Help with your fundraising activities online
• Keep a record of your relationship with us (including your feedback)
• Ensure we know how you prefer to be contacted
• Understand how we can improve our communication with you
• Flag your data record– for example if you request to be removed from certain mailing lists, opt out of any specific data processing, or if you have special requirements

As a valued supporter of our charitable activities we will contact you via your preferred method with:

• fundraising news
• events updates
• quarterly magazine
• charity news and up to date information on how your support enables us to continue our much-needed services

You can change your preferences at any time by contacting us.

We may also use your personal information to detect and reduce fraud, or for due diligence purposes. We need to keep the details of financial transactions for 7 years after the financial year of a donors last gift, in the event of a tax or banking enquiry. We will only contact you according to your preferences. You can change your preferences at any time.

As a charity we use various fundraising platforms e.g. JustGiving, Virgin Money Giving, Everyday Hero and My Donate. These platforms are available to you to choose how you raise funds for us. Each fundraising platform company will have its own Privacy Policy which you will be able to read when you register and is available on their websites. We will be informed in line with the fundraising platforms Privacy Notice.

3.3 Volunteers

If you would like to become a volunteer at Charlie House, we will ask you to complete a Volunteer Application Form. We may collect the following types of information to process your application:

• Full Name, title/s
• Contact details such as full postal address, email addresses and telephone numbers
• How you heard about us
• What kind of connection you have with our charity
• The volunteer role that you are interested in and why you would like to volunteer
• Your feedback from dealings with us
• Contact notes relating to your application and ongoing volunteering
• Preferred contact time and method

In processing your application, we may need to share information to someone outside Charlie House - for example, if we need a reference, or PVG from Disclosure Scotland - we will make sure we tell you beforehand, unless we are required to disclose this information by law.

3.4 Contact us

If you get in touch with us in any way e.g. by telephone or e: mail, we will save the details you share with us and your contact preferences in our database. This way, we can respond to your query and if you get in touch with us again in the future we can refer to our previous conversations with you. We will not contact you or share your details without asking for your consent. You can update your contact preferences at any time.

3.5 Website visitors

We use Google Analytics (GA) to track site user interaction. We have GA code installed on our site which creates one or more text files on your computer (called a “cookie”). The cookies contain an ID number which is used to uniquely identify your browser and track each site you visit that has GA enabled.

We use this data to determine the number of people using our site and to better understand how they find and use our web pages. With this information we can continually improve the information that we provide on our site and the processes for actions such as contacting us and donating. We can also use it to increase the number of new people finding our site.

Google analytics stores the following data:

• Time of visit, pages visited, and time spent on each page of the webpages
• Interactions with site-specific widgets
• Referring site details (such as the URL a user came through to arrive at this site)
• Type of web browser
• Type of operating system (OS)
• Flash version, JavaScript support, screen resolution, and screen color processing ability
• Network location and IP address
• Document downloads
• Clicks on links leading to external websites
• Errors when users fill out forms
• Clicks on videos
• Scroll depth

Google also collects information about you from its Doubleclick tracking and profiling service, from ad-supported apps on your Android or iOS device, from your YouTube and Gmail activity and from your Google account. This data is put together and used to make inferences about your age, gender, interests, hobbies, shopping habits and living circumstances.

Your rights

If you already have GA cookies, they will be updated with the latest information about your visit to the site.

As we cannot access any personal data about you ourselves, we are not the Data Controller for your Google Analytics or Doubleclick profile data. You would need to contact Google directly for this information.

You have the right to object to this tracking and to stop it happening.

If you would like more detail about the methods used however, please get in touch at info@charliehouse.org.uk.

How do I prevent being tracked by Google Analytics?

If you are uncomfortable with this tracking, you can take the following actions:

• Use a tracking-blocker, such as Privacy Badger
• Clear cookies after every browsing session
• Install the Google Analytics opt-out extension

3.6 Social Media

You may come across Charlie House naturally on various social media platforms e.g. Facebook, Twitter, Instagram, LinkedIn through your own networks, or you may be presented with an ad from us. We target ads at audiences that look like they have an interest in charitable organisations. We do this to inform, educate and engage new potential supporters.

All of our social media platforms are hugely valuable tools to us and for the community that we support, which is why we use them. However, these platforms are commercial companies. In these instances, we are not the Data Controller for your social media profiles. You would need to contact the relevant platform directly for how they manage the security of your personal data.

3.7 Job Applicants

If you apply to work at Charlie House, we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside Charlie House - for example, if we need a reference, or PVG from Disclosure Scotland - we will make sure we tell you beforehand, unless we are required to disclose this information by law.

If you are unsuccessful in your job application, we will hold your personal information for 1 month after we’ve finished recruiting the post you applied for. After this date we will destroy or delete your information. We keep de-personalised statistical information about applicants to develop our recruitment processes, but this does not contain any information that could be used to identify individual job applicants.

4.0 What are your rights

Data Protection Regulations and Laws ensure that Charlie House process your personal data robustly and appropriately.

You have the following rights:

• The right to be informed about the personal data that Charlie House processes on you
• The right of access to the personal data that Charlie House processes on you
• The right to rectify your personal data, if it is incorrect/inaccurate or changes
• The right to erasure of your personal data, in certain circumstances
• The right to restrict processing of your personal data
• The right to data portability, in certain circumstances
• The right to object to the processing of your personal data when it is based on public or legitimate interest
• The right not to be subjected to automated decision making and profiling
• The right to withdraw consent at any time

Where you have consented to Charlie House processing your personal data, you have the right to withdraw that consent, at any time, by contacting the Data Controller (see Section 5.0).

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Controller to have the matter investigated.

If you are not satisfied with our response or believe that we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office https://ico.org.uk/

5.0 Data Controller Contact Details

The Data Controller for Charlie House can be contacted as follows:

Email: info@charliehouse.org.uk