CARITAS DIOCESE OF SALFORD PRIVACY NOTICE
INTRODUCTION
At Caritas, we are committed to protecting personal information and we take our responsibilities regarding the security of staff, service user, supporter and volunteer information very seriously. This Privacy Notice explains what personal data we collect about you, how and why we use it, who we disclose it to and how we protect it. Caritas is the official charity of the Diocese of Salford. Caritas is a charity which provides social care services to improve the lives of people who use our services. Caritas enables individuals to enjoy and achieve in their lives and to contribute fully within their communities. Our mission is: ‘Inspired by the Gospel, Caritas helps people in need and provides opportunities for community service’.
WHO IS RESPONSIBLE FOR YOUR DATA
Our Privacy Notice applies to the personal data that Caritas collects and uses.
References in this Privacy Notice to “Caritas”, “we”, “us” or “our” means Caritas Diocese of Salford , a charity registered in England and Wales (Charity Registered Number 1125808) and a company limited by guarantee No. 6594417. Our registered office is Cathedral Centre, 3 Ford Street, Salford M3 6DP.
We control the ways your personal data is collected and the purposes for which your personal data are used by Caritas. We are the “data controller” for the purposes of the UK Data Protection Act 1998 and other applicable European data protection legislation.
We are registered with the Information Commissioner’s Office, registration number Z2245768.
Caritas has a designated Data Protection Lead who can be contacted via email at info@caritassalford.org.uk
PERSONAL DATA WE COLLECT ABOUT YOU
When using the term “personal data” in our Privacy Notice, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
We collect some personal data from you, for example, when you donate to us, use our website, use our services or contact us.
WHAT DATA WE COLLECT AND WHEN
We may collect and process the following categories of information about you:
Personal information, including contact details
• For example, your name, postal address, telephone number, email address and date of birth.
• We collect this when you contact us or donate by post, telephone or on our website.
Bank details
• We collect your name, sort code and account number, credit card details.
• We collect this when you set up a regular gift (e.g. standing order) with us or send us a cheque in the post.
Communications
• We collect the communications you exchange with us.
• We collect this when you email us, write a letter or call us.
Third party information
• We collect information indirectly from third parties such as event organisers (e.g. Eventbrite), marketing sites like Mailchimp, survey sites, like Survey Monkey or fundraising sites like JustGiving, where you have agreed to support Caritas and have given your consent. We collect this information when you use a third party site such as JustGiving whereby Caritas is the named beneficiary. You may wish to check their privacy statement to find out more about how they will process your data.
Non-personalised data
• We collect non-personal data such as IP addresses, details of web pages visited and files downloaded. Website usage information is collected using cookies. Please see the section on cookies below.
• We collect this when you use our website.
Social media
• We collect your posts and messages on social media directed at Caritas.
• We collect this when you interact with us on social media platforms such as Facebook, Twitter, Instagram or LinkedIn.
Website
• We collect Information about how our website is used, such as your searches for information.
• We collect this when you navigate on our websites.
Recruitment
• We collect personal data as part of our staff or volunteer recruitment processes.
• We collect this when you apply for a job or for volunteering opportunities with Caritas.
Legacy administration
• We collect personal data necessary for legacy administration.
• We collect this when a supporter has died, leaving a legacy to Caritas, and you are the executor or you have an interest in the estate.
Sensitive personal data
• We collect and use personal data you provide to us, as Caritas supporters, to contact you and inform you about Caritas’s activities. We recognise that many of our supporters (but not all) hold religious beliefs and, since this can be considered to be sensitive information, we put in place policies and procedures to ensure that your supporter data is kept secure.
• This information is only accessed on a need-to-know basis. Unless required by law or as otherwise described in this Privacy Notice, we do not disclose your personal data to any third party without your prior consent.
Sharing your personal data
• Caritas does not share your data with any other charity, public body or commercial organisation, unless we have to do so either for legal or compliance reasons, or where it is more cost effective and efficient for us to use a third party to deliver a product or service on our behalf.
Legal duty
• We may need to pass on personal information if required by law or by a regulatory body. For example, if requested as part of a Gift Aid audit or by a law enforcement agency.
Other service providers or third parties
• We sometimes work with other organisations to gather information to inform our strategies and work plans or when we do not have the capacity to do a specific task ourselves (for example, gather data on homelessness with other charities we work with on shared databases.) When we do this we ensure that data shared is anonymised to protect any individuals identity.
Coalitions
• We will let you know when we are working in partnership with other agencies on specific projects. Caritas is a member Caritas Social Action network of over 40 organisations and collaborates with other organisations on agreed projects. Supporter data will be held on a common database but will only be used for the purposes and duration of specific campaigns and only used by any member agency with the consent of the supporter concerned.
• Caritas is also part of the Diocese of Salford working together to promote social action in the Catholic community. We will only share individuals’ details with the specific member charities about whom they’ve requested more information. Data is stored securely and is not processed by Caritas unless individuals have shown interest in receiving updates from us. If you do not agree to all of these terms, please do not submit any material to Caritas.
HOW AND WHY WE USE YOUR PERSONAL DATA
We use your personal data for the following purposes:
To manage your engagement with us, donations, requests or calls to action
• When you interact with us, we use your information to perform our services in relation to your donation, to deal with your queries and requests and to process responses to our social action or advocacy work.
To fundraise and promote Caritas’s work, in both financial and non-financial ways
• We know how fundamental our volunteers, supporters and donors are to the work we do. In order to develop and foster your ongoing support, we want to keep in touch with you through feedback and further opportunities and invitations to support our work in both financial and non-financial ways.
To communicate with you and manage our relationship with you
• Occasionally we may need to contact you by mail, email and/or telephone for administrative or operational reasons – for example, to send you confirmation of your donation or your orders such as Christmas cards. Please be aware that these communications are not made for marketing purposes and as such, you will continue to receive them even if you opt out of receiving marketing communications from us.
• We will also record your personal data if we contact you after you have sent us a request, filled in a web form through our website or contacted us on social media.
• Your views and opinions are very important to us, so we may send you a survey to seek your feedback.
• We will use the communications you exchange with us and the feedback you may provide to manage our relationship with you as a volunteer, service user or supporter of Caritas and to improve our services and communications.
To personalise and improve your experience when engaging with Caritas
• We strive to continually improve the information and services we offer to our supporters so that we can be good stewards of the resources entrusted to us.
• We may use your personal data to tailor our communications to your needs and preferences and to provide you with a more relevant experience, for example, by sending you communications on topics you have shown an interest in.
• We may also collect information about how you use our website, which pages of our website you visit most and what you search for to understand your preferences. We may use this information to tailor content and, if you have agreed to receive marketing communications, to send you relevant messages that we think would be of interest to you.
To inform you about our news and ways you may be able to help Caritas
• We may send you marketing communications, if you have indicated that you are happy to receive these – for example, when you have donated or completed a social action and you haven’t opted out of receiving such communications. You can also ask us to send you communications by contacting our staff on 0161 817 2250 or via email at info@caritassalford.org.uk
• If you are happy to receive marketing and promotional communications, we will provide you with news, information about our activities, advocacy and campaigning work, together with opportunities and invitations to donate or support Caritas in other ways.
• Please note that we do not share your contact details and other personal data with any other charities or companies for marketing purposes.
If you do not want to receive marketing or promotional communications from us, you can simply tell us by ticking or clicking the relevant box on various materials, or by contacting our staff on 0161 817 2250 or via email at info@caritassalford.org.uk
• You can choose to opt out of receiving email marketing or promotional communications at any time by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us.
To manage our staff and volunteers
• We need to process and keep some personal information in order to recruit and manage people that volunteer for Caritas.
• For staff we need to keep all records of recruitment, contract, performance, disciplinary record, sickness record, pension details, salary and other benefits, appraisal’s and all other information arising in the performance of staff contracts of employment.
To maintain and improve our own accounts, records and organisational processes, to fulfil our administrative purposes and protect our charitable interests
• The purposes for which we will use your information include accounting, billing and audit, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, legacy administration, systems testing, maintenance and development.
• Our processing also includes the use of CCTV systems at our premises for the prevention of crime.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
The General Data Protection Regulation requires organisations to consider the legal basis on which they process personal data. Caritas will process personal data in line with the following principles:
• Where it is necessary for us to fulfil a contract with you: for example, when you make a donation or purchase.
• We will only send you emails, make telephone calls or send you SMS text messages with your explicit consent.
• When it is in our legitimate interests to do so: as part of our engagement and efforts to build long-term relationships with our supporters, we will send you communications and marketing material via post unless you have told us you do not wish to receive these communications. This need not be an “all or nothing” option.
We maintain a wide range of communication preferences and options, so you can choose both the type of material (whether that’s fundraising activities, our campaigns and advocacy work, volunteering or our work within schools and the education sector) and the most convenient channel(s) for you to receive information from us (such as email, post, telephone or SMS).
DATA ANALYSIS
We use Post Office address search, postcode lists and other sources to ensure the quality and accuracy of data you provide us – for example, where we cannot read information on a handwritten form. We do not attempt to complete any information you have chosen not to provide (for example, if you have left a telephone number blank).
We do not routinely use external sources to update our database; for example, a change of address. We will normally rely on you to tell us if your details have changed. However, if you are an active giver and we find items such as newsletters are returned to us, we may use external sources to update your address so that we can maintain contact with you.
Fundraising is a key part of Caritas’s work and enables us to reach poor and disadvantaged communities. For this purpose, we may use profiling techniques in order to send you communications we believe may be of interest to you. This means we conduct analysis of information held on our database, such as previous behaviour (previous donations or campaign actions) or information supplied by our supporters.
We sometimes include publicly available geographic and demographic data in our analysis using third party software. Often this information is aggregated at postcode level and so cannot be used to identify individuals directly. Where it might apply to an individual – for example, a date of birth – we check that you have consented to the third party sharing your data.
If you would rather your data was not used for the purposes of data analysis, you can contact our staff on 0161 817 2250 or via email at info@caritassalford.org.uk
WEALTH SCREENING
As Caritas is a charity that needs to raise funds, we are always grateful for any donation our supporters can give. Like the majority of other similar-sized UK charities we also build long-term relationships with individuals, private companies and family trusts and foundations that can support us with significant gifts, ensuring their donations make lasting positive change to the lives of the most vulnerable.
Our fundraising team organise regular events, can introduce individual donors to our programme and staff and (where possible) meet our partners and communities overseas, to see the difference their support is making.
As part of their work, our fundraising team may gather information about you from publicly available sources – for example, Companies House, the Electoral Register and the media – to help us to understand more about you as an individual and your ability to support Caritas.
We may use information gathered from public sources, from networking events or from your colleagues and peers. By doing this, we can focus our engagement with you as a supporter, donor or potential donor in the most effective way and ensure that we provide you with an experience that is appropriate for you.
For significant corporate financial donations, we also use publicly available sources to carry out due diligence on individuals who control companies and trusts and foundations, in line with Caritas’s Ethical Policy and Ethical Investment Policy to meet money laundering regulations.
We are committed to working in a transparent, ethical, responsible and honest way. To reflect this commitment, we are registered with the Fundraising Regulator and are committed to the Regulator’s Code of Practice.
If you would rather your personal data was not used for the purposes of wealth screening, you can contact our staff on 0161 817 2250 or via email at info@caritassalford.org.uk
CHILDREN AND ADULTS WHO ARE VULNERABLE
We are committed to protecting the privacy of the young people who engage with us through our work and services, our websites, at events and at schools. If you are under 18 and would like to get involved with Caritas’s work, please ensure you have consent from a parent or guardian before giving us your personal information.
Some of our young people’s and school events, our young leadership programmes such as Caritas Ambassadors we may request specific information about the age of participants and we may require explicit parental / legal guardian consent for this.
We will only ever collect or process any personal information for a child under 18 with explicit parental or legal guardian consent. When we collect information about a child or young person aged under 18 we will make clear the reasons for collecting this information, as well as how the information will be used. Children in care and adults that are vulnerable are a special category and Caritas operates a strict policy of consent from them, their parent or guardian, responsible adult or local authority.
SUPPORTERS IN VULNERABLE CIRCUMSTANCES
We are committed to protecting supporters who are vulnerable. We provide training to our staff who come into regular contact with supporters to be aware of, and to identify signs of, people in potentially vulnerable circumstances. We work in accordance with our safeguarding policies at all times.
HOW LONG DO WE KEEP PERSONAL DATA
We will keep your personal data only for as long as we consider it necessary to carry out each processing activity.
We maintain data retention criteria to help implement this. This takes account of our legal and accounting obligations, balancing this with what would be considered reasonable.
We are required to keep details of financial transactions, including donations, for seven years to meet accountancy and HMRC requirements. We will anonymise or delete personal data if, after a period of seven years, we have not had any contact or communication from you (this will be measured on a rolling seven-year period) – subject to special circumstances concerning legacies.
Many supporters kindly tell us that they have included a gift to Caritas in their will, or that they intend to do so. We retain their personal information indefinitely so that we can keep in touch during their lifetime and provide a caring and efficient legacy administration service.
YOUR RIGHTS
Caritas actively supports the principle of “fair and transparent” processing of your personal information. We support your rights in relation to your personal information under the General Data Protection Regulation, including the:
• right to be informed (chiefly via this policy)
• right of access
• right to rectification
• right to erasure
• right to restrict processing
• right to data portability
• right to object
• rights related to automated decision-making including profiling
If you wish to exercise any of these rights, please contact the Data Protection Lead in writing at Caritas Diocese of Salford, Cathedral Centre, 3 Ford Street, Salford M3 6DP or via email at info@caritassalford.org.uk
REQUESTING ACCESS TO YOUR PERSONAL DATA
You have a right to request access to the personal data that we hold about you. However, as a registered Adoption Support Agency and as a Fostering Agency, Caritas has certain specific legal obligations regards the sharing of sensitive information and complies with regulations concerning these areas of our work.
If you would like to request a copy of your personal data or have any questions in relation to your personal data, please contact us at info@caritassalford.org.uk
SECURITY OF YOUR PERSONAL DATA
We are committed to taking appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage. When you provide your personal data through our website, this information is transmitted across the internet securely using high-grade encryption.
Caritas takes particular care with online giving. The credit card form is secure, and your information is encrypted and stored on a secure database. Caritas does not retain any card payment information.
As described elsewhere in this Privacy Notice, we may in some instances disclose your personal data to third parties. Where Caritas discloses your personal data to a third party, we require that third party to have appropriate technical and organisational measures in place to protect your personal data.
The information that you provide to us will be held in our systems, which are located on our premises or those of an appointed third party, acting as our Data Processor. We may also allow access to your information by other third parties that act for us for the purposes described in this Privacy Notice or for other purposes approved by you.
UPLOADING INFORMATION TO THE CARITAS WEBSITE
All material uploaded to our website is subject to approval by Caritas before being used. By uploading material in the form of photographs, videos, stories or any other format onto our sites you are automatically agreeing to Caritas editing and using your material on the websites and in future promotional material or events. This agreement is lifelong and royalty free and non-exclusive to Caritas.
You must be 18 or over and if not you must have the express permission of your parent or guardian to upload the material. Material must not violate any copyright laws, the rights of any third party or any other laws. Photographs and videos must have been taken with the knowledge of the subjects, or where the subjects are under 18, with the permission of their parent or guardian. All subjects must have given permission for the material to be used by Caritas. Caritas operates a Media Policy.
By submitting material you agree that Caritas has the right to share the material with any third party involved in the submission and receipt of the material as well as any third parties which Caritas uses to act on their behalf.
Under certain laws and regulations Caritas might be asked to disclose information to government agencies or employees. By submitting material you authorise Caritas to do this without having to give you prior notice. However, Caritas will always operate under data protection laws. Caritas will use any material in accordance with our own Information Governance Policy and the Data Protection Act (1988).
COOKIES OR OTHER TRACKING TECHNOLOGIES
In order to improve our services, to provide you with more relevant content and to analyse how visitors use our websites, we may use technologies, such as cookies or other tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies, as this is based on your Internet Protocol (IP) address only.
The Caritas websites may use Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about aggregated use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States.
Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of our website.
In order for us to understand how our supporters interact with the emails that we send, the email tools we use let us know if the emails we send are opened or links are clicked on. We use this information to make the content that we send as relevant to you as possible.
UPDATES TO OUR PRIVACY NOTICE
We may make changes to this Privacy Notice from time to time, including as part of the new European data protection legislation. We will update the Privacy Notice as and when required and we will publish any new version.
CONTACT INFORMATION AND TELLING US WHEN THINGS HAVE CHANGED
Caritas will occasionally provide you with the opportunity to opt in to receiving certain types of communication. If you are already receiving such communication, you do not need to opt-in again as your existing preference will continue until you provide explicit instruction that you want to opt out.
You can change your preferences on what you receive from Caritas at any time, including fundraising and marketing materials or how we contact you. Let us know:
• By calling our staff on 0161 817 2250
• By emailing us at info@caritassalford.org.uk
• By writing to the Data Protection Lead at Caritas Diocese of Salford, Cathedral Centre, 3 Ford Street, Salford M3 6DP
We welcome any questions, comments and requests regarding this Privacy Notice.