Privacy policy

(a) When you give it to us directly

For example, personal information that you submit through our website by making a donation, signing up for our email newsletter or filling in a form to apply for help, or personal information that you give to us when you communicate with us by email, phone or letter.

(b) When we obtain it indirectly

For example, your personal information may be shared with us by third parties including, for example, our business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; and family or friends who have suggested that you might require our services. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.

(c) When it is available publicly

Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us through platforms such as Facebook, Instagram, Youtube, Linkedin or Twitter).

(d) When you visit our website

When you visit our website, we automatically collect the following types of personal information:

(i) Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.

(ii) Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page. We also collect and use your personal information by using cookies on our website – please see our Cookie Policy We may also augment the personal information you provide with personal information obtained elsewhere, for the purpose of managing our supporters’ database efficiently and effectively. Please see section 5 for more details. In general, we may combine your personal information from these different sources for the purposes set out in this Policy.

We may collect, store and otherwise process the following kinds of personal information:

(a) your name and contact details (including emergency contacts), including postal address, telephone number, email address and, where applicable, social media identity;

(b) your date of birth and gender;

(c) your financial information, such as bank details and/ or credit/ debit card details, account holder name, sort code and account number;

(d) information about your computer/ mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;

(e) personal descriptions and photographs;

(f) details of your qualifications/ experience;

(g) immigration/ emigration information;

(h) your support of the Society, including donations and support given to related organisations;

(i) any other personal information which you choose to share with us as per section 1. Do we process special categories of data? The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and political opinions. In certain situations, the Society may collect and/or use these special categories of data (for example, to provide you with emotional support as part of our services, we will need to know your health information). We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so. For instance, we will usually seek your explicit consent to use such data.

Your personal information, however provided to us, will be used for the purposes specified in this Policy. In particular, we may use your personal information:

(a) to provide you with support or information you have requested;

(b) to provide services to our beneficiaries;

(c) to provide further information about our work, services, activities or products (where necessary, and only where you have provided your consent to receive such information);

(d) to process your donations;

(e) to answer your questions/ requests and communicate with you in general;

(f) to manage relationships with our supporters and beneficiaries;

(g) to further our charitable aims in general, including for fundraising activities;

(h) to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;

(i) to report on the impact and effectiveness of our work;

(j) to run/ administer our website, keep them safe and secure and ensure that content is presented in the most effective manner for you and for your device;

(k) to register and administer your participation in events;

(l) to process your application for a job or volunteer role with us when you apply through our “Support Us” page;

(m) to provide financial aid;

(n) to audit and/ or administer our accounts;

(o) to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);

(p) for the prevention of fraud or misuse of services; and/or

(q) for the establishment, defence and/ or enforcement of legal claims.

The GDPR requires us to rely on one or more lawful bases to use your personal information that we have outlined above. We consider the grounds listed below to be relevant:

(a) Consent Where you have provided your consent for our use of your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you fundraising material by email, or to send you our newsletter).

(b) Legal obligation Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject, for example where we have a legal obligation to share your personal information with a doctor.

(c) Contractual obligation Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps prior to you entering a contract), for example where you volunteer with us.

(d) Vital interests Where it is in your (or someone else’s) vital interests (for example, in the case of a medical emergency suffered by a beneficiary).

(e) Legitimate interests Where applicable law allows us to collect and use personal information on the condition that to do so is reasonably necessary for our legitimate interests (and the use of your personal information is fair, balanced, and does not unduly impact your rights). In broad terms, our “legitimate interests” means the interests of running the Society as a charitable entity, and pursuing our aims and ideals; for example providing financial and emotional support to our beneficiaries, taking donations, administering events and taking applications for volunteers.

We may also analyse your personal information to create a record of your interests and preferences. This allows us to ensure communications are relevant and timely, to contact you in the most appropriate and relevant way and in general to provide you with an improved user experience. It also helps us to understand the background of our supporters so that we can make appropriate requests to those who may be willing and able to give more than they already do, enabling us to raise funds and help beneficiaries sooner and more cost-effectively. If you would prefer us not to use your personal information for supporter research please let us know by using the contact details below.

We may use your contact details to provide you with information about our work, events, services and/ or products which we consider may be of interest to you (for example, about services you previously used, or updates about fundraising appeals and/or volunteering opportunities via our newsletter). Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law). Where you have provided us with your consent previously but do not wish to be contacted by us about our projects and/or services in the future, please let us know by using the contact details at section 17. You can opt out of receiving emails from the Society at any time by clicking the “unsubscribe” link at the bottom of our emails.

When you use our secure online donation function you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.

When we process children’s personal information, where required we will not do so without their consent or, where required, the consent of a parent/ guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care.

In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected.

However, if before that date

(i) your personal information is no longer required in connection with such purpose(s),

(ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see Section 13 below), we will remove it from our records at the relevant time. If you request to receive no further contact from us (in accordance with Section 13), we will maintain a skeleton record about you on our suppression list, comprising your name and contact details in order to comply with your request and avoid sending you unwanted materials in the future.

We do not share, sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Policy. Non-exhaustively, those parties may include:

(a) healthcare professionals and organisations involved in the provision of care, facilities and/ or supplies;

(b) suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers;

(c) insurers;

(d) financial companies such as CAF that collect or process donations on our behalf;

(e) professional service providers such as accountants and lawyers;

(f) parties assisting us with research to monitor the impact/ effectiveness of our services;

(g) external fundraising entities/ platforms; and

(h) regulatory authorities, such as tax authorities.

In particular, we reserve the right to disclose your personal information to third parties:

(a) in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets;

(b) if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;

(c) if we are under any legal or regulatory duty to do so; and/or

(d) to protect the rights, property or safety of the Society, its personnel, users, visitors or others.

The Society is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers with features enacted to prevent unauthorised access.

Given that we sometimes use agencies and/or suppliers to process personal information on our behalf, it is possible that personal information we collect from you will be transferred to and stored in a location outside the European Economic Area (“EEA”). Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy. If you have any questions about the transfer of your personal information, please contact us using the details below.

Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.

The Society may contact you by post unless you request otherwise, and by telephone, email, text, social media or other electronic means depending on the communication preferences you have previously indicated. Where we rely on your consent to use your personal information, you have the right to withdraw your consent. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time.

When we use your personal information you have the right to:

(a) Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we are able to confirm your identity, we will provide you with this personal information.

(b) Request that we delete the personal information we hold about you, as far as we are legally required to do so.

(c) Ask that we correct any personal information that we hold about you which you believe to be inaccurate.

(d) Object to the processing of your personal information where we:

(i) process on the basis of the legitimate interests ground;

(ii) use the personal information for direct marketing; or

(iii) use the personal information for statistical purposes.

(e) Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us:

(i) in reliance on your consent; or

(ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means.

(f) Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage. If you decide you do not want to receive any further emails from us please tell us and we will remove you from the mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed at section 17.

Please note that where you ask us to delete your personal information we will maintain a skeleton record comprising your name and contact details to ensure that we do not inadvertently contact you in the future. We may also need to retain some financial records for statutory purposes, for example Gift Aid. Please note that you also have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns.

We may update this Policy from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an updated Policy on our website. This Policy was last updated on 23rd May 2018.

Our Information Governance Officer (“IGO”) can be contacted directly at Robert.ball@absnet.org.uk.

Alternately, please use the details in Section 17 below and mark the email/ letter for the attention of the IGO or ask for the IGO.

We link our website directly to other sites. This Policy does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.

The Society’s Information Governance Officer is responsible for monitoring compliance with relevant legislation in relation to personal information. You can also contact that person if you have any questions about this privacy notice or our treatment of your personal information:

Email: Robert.ball@absnet.org.uk

Telephone: 020 7580 2823

Post: FAO Information Governance Officer, Architects Benevolent Society, 43 Portland Place, London W1B 1QH.

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