CARITAS DIOCESE OF SALFORD (‘Caritas’) PRIVACY NOTICE

INTRODUCTION

At Caritas, we are committed to protecting personal information and we take our responsibilities regarding the security of information about staff, supporter, volunteer and those that use our services 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 principal social action 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.  We enable 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 facing challenge and crisis 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.  Our mailing address is Caritas House, Nobby Stiles Drive, Collyhurst, Manchester M4 4FA.

We control the ways your personal data is collected and the purposes for which your personal data IS used by Caritas.  We are the “data controller” for the purposes of the UK Data Protection Act 2018 and other applicable data protection legislation depending upon where you may reside.

We are registered with the Information Commissioner’s Office, registration number Z2245768.

Caritas has a designated Data Protection Officer 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.
  • We collect this when you send us a cheque in the post.

*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.

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 platforms like JustGiving, where you have given your consent. We collect this information when you use a third-party site 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 may collect your posts and messages on social media directed at Caritas.
  • We may collect this when you interact with us on social media platforms such as Facebook, Twitter, Instagram or LinkedIn.

Website

  • We may collect Information about how our website is used, such as your searches for information.
  • We may 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 individual’s identity.

Coalitions

  • We will let you know when we are working in partnership with other agencies on specific projects. Caritas is a member of Caritas Social Action network (‘CSAN’) of over 40 organisations and collaborates with other organisations on agreed projects.  When we do this, we ensure that data shared is anonymised to protect any individual’s identity.  Supporter data would only be used by any member agency with the consent of the supporter concerned.
    • Caritas is a related party to the Roman Catholic Diocese of Salford (registered as the Salford Diocesan Trust) working together to promote social action in the Catholic community. If an individual requests more information about the principal social action charity of the diocese, data is stored securely and is not processed by Caritas, unless individuals have shown interest in receiving updates directly 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 an aspect of your note to us. 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 2285 or via email at comms@caritassalford.org.ukor by subscribing to our newsletter on the website.
  • 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 events, 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 2285 or via email at comms@caritassalford.org.uk

  • You can choose to opt out and withdraw your consent to receive 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, or by pressing ‘Unsubscribe’ on the home page of our website

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 UK General Data Protection Regulation (‘UK GDPR’) 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 purchase.
  • We will only send you emails, make telephone calls or send you SMS text messages with your 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).

Every effort is made to ensure the personal data we process about you is accurate. However, 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.  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 2285 or via email at fundraising@caritassalford.org.uk

WEALTH SCREENING

As Caritas is a charity that needs to raise funds in order to support the people we serve, 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 local people.

As a fundraising organisation, we undertake in-house research and from time to time engage specialist agencies to gather information about you from publicly available sources, for example, Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as Linkedin, political and property registers and news archives.

We may also carry out wealth screening to fast track the research using our trusted third party partners. You will always have the right to opt out of this processing. We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This may include people connected to our current major supporters, trustees or other lead volunteers. We also use publicly available sources to carry out due diligence on donors in line with the charity’s Gift Acceptance Policy and to meet money laundering regulations.

This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you. We shall be relying on legitimate interest to conduct this research.

If you would prefer us not to use your data in this way, please email us at fundraising@caritassalford.org.uk or call us on 0161 817 2250.

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, we will ensure we have the consent of a parent or guardian before we process your personal information.

For some of our young people 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 unless we have a legal obligation to do so.  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. Where there is no statutory retention period we have established clear guidance for each purpose data may be retained.

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 UK General Data Protection Regulation (‘UK GDPR’), 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 Officer in writing at Caritas Diocese of Salford, Caritas House, Nobby Stiles Drive, Collyhurst, Manchester M4 4FA or via email at dpo@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 previously 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 access to 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.  Access to the client relationship and contact management database is restricted, with two factor authentication in place.  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 allow access to your personal data to third parties for operational reasons, for example, if we upgrade the database.  Where Caritas discloses your personal data to a third party we will only do so where there is an agreement in place and where that third party has appropriate technical and organisational measures in place to protect your personal data for the period of time that they need access to it.

The information that you provide to us will be stored on secure servers, 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 acknowledge that Caritas may 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 2018.

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. Some cookies are essential and are required to ensure you can visit our website.

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) may 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. Some cookies such as those used for marketing will only be used with your consent. You can withdraw your consent at any time. Details about this are provided in the cookie banner which appears when you visit our website. If you have any concerns about our use of cookies and the processing of your personal data please email us here info@caritassalford.org.uk

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. This notice was last updated on 11 March 2024.

YOUR RIGHT TO COMPLAIN

You have the right to complain about the way we may process your personal data. If you are concerned, please write to us at info@caritassalford.org.uk

You may also complain to the regulator of information rights in the UK, the Information Commissioner’s Office (ICO). For further details about this please go here https://ico.org.uk/make-a-complaint/ If you reside outside of the UK, you may need to contact your local regulator.

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 dpo@caritassalford.org.uk
  • By writing to the Data Protection Officer at Caritas Diocese of Salford, Cathedral Centre, 3 Ford Street, Salford M3 6DP

We welcome any questions, comments and requests regarding this Privacy Notice.

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