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Privacy Notice

1. Introduction

Your Place (“we”) is a registered charity with registered charity number 1147794 and registered address at Anchor House, 81 Barking Rd, London E16 4HB.

We rely on the generosity of individuals such as yourself to continue our outstanding work in rebuilding the lives of people experiencing homelessness who come to us for help.

We promise to respect any personal data you share with us and keep it safe. We aim to be clear when we collect your data about how it will be used, and not do anything you wouldn’t reasonably expect.

Please read this Privacy Notice carefully to understand our practices regarding your personal data and how we will collect, use and store your personal data. We may update this notice from time to time so please check it regularly. If there are any significant updates, we will contact you.

If you have any queries, or would like to change your communication preferences, please do email us at communications@your-place.org.uk, call us on 020 7476 6062, or send a freepost letter to: “Freepost: YOUR PLACE” (no other details are required).

Our Privacy Notice covers the following:

  1. Introduction
  2. What personal data we collect and how we use it
  3. When we collect personal data about you
  4. What lawful bases do we rely on to use your personal data
  5. Direct Marketing and Communications
  6. Data sharing
  7. Children’s data
  8. How we keep your personal data safe and who has access to it
  9. Keeping your personal data up to date
  10. Your rights
  11. Complaints
  12. Data retention
  13. Contact

2. What personal data we collect and how we use it

This section aims to set out the types of personal data which we collect and hold about you, as well as explaining to you how we will use this personal data.

o What personal data do we collect?

The type and quantity of personal data we collect and how we use it depends on why you are providing it.

Supporters

If you support us, for example you make a donation, volunteer, register to fundraise or sign up for an event, we will usually collect:

  • Your full name
  • Your contact details, including postal address, telephone number(s), email addresses
  • Details of the transaction/payment method, such as your bank or debit/credit card details (card details are destroyed once the transaction has been processed, except the last four digits of the card number so that we are able to identify payments)
  • Whether you are eligible for Gift Aid
  • Records of your correspondence with us

We may also ask why you have decided to donate to us, and ask for details of how you would like to be involved and support us. We will never make these questions mandatory, and only want to know the answers if you are happy to tell us.

We will only process sensitive personal data, also known as special categories of data (e.g. in relation to your health), with your explicit consent, for reasons of substantial public interest or where necessary for establishment, exercise or defence of legal claims.

o How will we use this personal data?

We will use your personal data in different ways, to allow you to interact with us and to improve how we communicate with you.

We will use your personal data to:

  • Provide you with the services or information you asked for
  • Administer your donation or support your fundraising, including processing Gift Aid
  • Ensure we know how you prefer to be contacted, and provide you with information we think you will be interested in (when we can legally do so)
  • Understand how we can improve our services, products or information
  • Notify you about changes to our service
  • Comply with applicable laws and regulations and requests from statutory agencies.

We may contact you about administrative issues if needed. We may also collect and retain your personal data if you send feedback about our services or make a complaint. We will never use screening techniques with any of our supporters or their personal data that would lead to assessing your potential propensity or ability to give.

Photographs

Photographs and film comprise personal data when a depicted individual is identifiable – meaning that the individual can be identified from the information in the image or from a caption or text surrounding the image. Where individuals or small groups are photographed or filmed for promotional purposes, it is Your Place’s policy that consent must be obtained from children and vulnerable adults (adults at risk), or those acting on their behalf. With un-posed, event or group photographs and film where there is no reasonable expectation of privacy, Your Place may take and use photos and film without obtaining consent, unless specifically requested not to do so. Where possible, Your Place will display information in the area where the photographs and film are being shot, informing individuals that they can request that their photograph is not used.

Your Place takes and uses photographs and film of people, as we have legitimate interest in promoting and marketing our charitable work in this way.

Sharing your story

Some people choose to tell us about their experiences of homelessness to help further our work. This may include sharing sensitive information related to their personal circumstances in addition to their biographical and contact information. Others may also choose to provide stories of why they work with or support Your Place.

If we have the explicit and informed consent of the individuals, or their parent or guardian where appropriate, this information may be made public by us at events, in materials promoting our work, or in documents such as our annual report.

Support for individuals with experience of homelessness

We run services to provide support to individuals with experience of homelessness and collect personal data in order to provide those services as part of a contract. This information is managed separately from other personal data provided to the charity. We have robust policies in place to ensure this data is managed responsibly.

3. When we collect personal data about you

We collect information in the following ways:

o When you give it to us directly:
You may give us your personal data in order to sign up for one of our events, make a donation, offer to volunteer or communicate with us, or otherwise interact with us or use our website.

o When you give it to us indirectly:
Sometimes your information may be shared with us by fundraising sites like Just Giving, or independent event organisers like the London Marathon. These independent third parties will only do so when you have indicated that you wish to support Your Place and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your personal data.

o When you give permission to other organisations to share personal data, or it is available publicly:

The information we get from other organisations may depend on your privacy settings or the responses you give, so you should regularly check them.  We use these types of personal data to gain a better understanding of you and to improve our communications and fundraising. This personal data comes from the following sources:

Social Media

Depending on your settings or the privacy policies for social media and messaging services like Facebook or Twitter, you might give us permission to access personal data from those accounts or services when you interact with us via these channels.

Information available publicly
This may include information that has been published in places such as Companies House.

o When we collect data from our website:

The Your Place website does not collect personally identifiable data such as name or email address when someone visits it.

However, it does collect anonymised data and uses “cookies” to enable us to understand our website users and to enhance our website and experience for users. Please refer to the Cookies Settings (see in footer of website)@ for details on how and why we use this data.

We also use share tools on our website pages from social networks, such as Twitter and Facebook, whereby an individual can share information from our website via social media. Any information shared via these tools is not shown to us, and we do not store any information from them. Please refer to each social network site’s own privacy policies for more information.

We may also link to other sites from our website. This privacy notice does not cover other websites, and we would encourage you to read the privacy policies of any external websites you visit.

4. What lawful bases do we rely on to use your personal data?

The legal bases that we rely on for processing your personal data are:

o You have provided your consent to us using your personal data for a specific purpose:

We will ask for your consent to use your personal data to send you electronic communications such as e-newsletters and emails. You always have the right to withdraw your consent at any time.

o It is necessary in connection with the performance of a contract with you:

Sometimes it is necessary to process your personal data so that we can enter into contractual relationships with you.  For example, if you apply for employment with us or for a volunteer role, we will require your personal data to enable us to perform our agreement.

o It is necessary for compliance with a legal obligation to which we are subject:

This would include where we have to retain certain records, for example, because we are under a direct legal obligation.

o It is within our legitimate interests.

We can collect and use personal data if it is reasonably necessary for our legitimate interests or a third party’s legitimate interests (as long as the processing is fair, balanced and does not unduly impact individuals’ rights).  We will rely on this ground to process your personal data when it is not practical or appropriate to ask for your consent, and where we are confident that this will not impact your rights.

Our legitimate interests include achieving our purpose of carrying out our charitable objects and working with those affected by homelessness.  We also have a legitimate interest in publicity and income generation and have legitimate interests to campaign and fundraise in order to support our objectives.

We will also rely on our legitimate interests for the proper administration of Your Place, and to manage our operations (for example, maintaining appropriate records and databases).

When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws.  We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

5. Direct Marketing and Communications

Our marketing communications include information about our latest successes, campaigns and life-changing work, and how you can donate and otherwise participate in our fundraising activities.

As long as you are happy for us to do so, we will contact you from time to time in relation to the above. We will only email you, call you or text you if you have explicitly consented to receiving this form of communication from us, in accordance with applicable law and regulation. For our postal mailings, we provide each and every one of our supporters with the option to opt out of receiving post and will continue to contact you by post unless you let us know you’d rather not hear from us in this way.

We make it easy for you to tell us how you want us to communicate with you, in a way that suits you. We include information on how to change your communication preferences or opt out of communications whenever we send you marketing. If you don’t want to hear from us, that’s fine. Just let us know when you provide your personal data or contact us on communications@your-place.org.uk or 020 7476 6062.

You can decide if you would rather hear from us by post or email, or not at all. You can also choose what you would like to hear about (including newsletters, invitations to events, information about our services, appeals and fundraising) or decide if you would like us to send you information that we feel is relevant.

6. Data sharing

We will never sell or share personal details to third parties for marketing purposes.

We will share your details with HMRC where we are able to process gift aid.

If we run an event in partnership with another named organisation your details may need to be shared. In such circumstances, we will be very clear what will happen to your personal data when you register for that event.

We may allow our staff, consultants and/or external service providers acting on our behalf to access and process your personal data for the activities we have described above (for example IT support, to process payments and an account management system).

We will only permit them to use it to deliver the relevant service and if they apply an appropriate level of security protection.

We may need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies or legal advisors. We may also partner with other organisations and in doing so, acquire or transfer personal data, but your personal data would continue to be used for the purposes set out above.

7. Children’s data

Occasionally, we collect and manage personal data about children, and aim to manage it in a way which is responsible and appropriate to the age of the child. Information is usually collected when children get in touch to fundraise for us through schools or youth groups. Where consent is required to process children’s personal data and the child is under 13 years old, we will seek consent from a parent or guardian. We will only hold personal data about children where this is absolutely necessary for the purpose of the activity they are participating in.

8. How we keep your personal data safe and who has access to it

We are committed to maintaining confidentiality at all times, and we aim to ensure your personal data is held securely in accordance with the Data Protection Act and General Data Protection Regulation and any subsequent legislation. We ensure that there are appropriate technical controls in place to protect your personal data. For example, our network is protected and routinely monitored.

We undertake regular reviews, at least annually, of who has access to personal data that we hold to ensure that your personal data is only accessible by appropriately trained staff.

9. Keeping your personal data up to date

We really appreciate it if you let us know if your contact details change. You can do this by contacting us on communications@your-place.org.uk or 020 7476 6062.

10. Your rights

You have a range of rights in relation to your data. These are:

o Right to restrict processing

You have a right to request that we stop processing your personal data, and if it’s not necessary for the purpose you provided it to us for (e.g., processing your donation or registering you for an event) we will do so. Contact us on communications@your-place.org.uk or 020 7476 6062 if you have any concerns.

o Right of access

You have a right to ask for a copy of the personal data we hold about you, which we will provide promptly and in any event within 28 calendar days of receiving the request. We will not charge you for these requests. If there are any discrepancies in the personal data we provide, please let us know and we will consider correcting it.

If you want to access your personal data, send a description of the personal data you want to see and proof of your identity (including a passport, driving license or utility bill) by post to Communications Team, Your Place at Anchor House, 81 Barking Road, London E16 4HB. We do not accept these requests by email so we can ensure that we only provide personal data to the right person.

o Right to erasure

You have the right to request that your personal data is erased from our database in certain circumstances.

o Right to rectification

We also want to make sure that your personal data is accurate and up to date. Please let us know if your details change. You may also ask us to correct or remove personal data which is inaccurate.

o Right to object

You can also opt-out of receiving all or some of our marketing/fundraising communications or request that we stop processing personal data about you for certain purposes at any time by contacting us using the details below.

o Right to data portability

In certain circumstances you have a right to data portability which means we will provide you (or a third party you nominate) with your personal data in a structured, commonly-used and machine-readable format.
To exercise these rights or if you have any questions, please contact us.

Please note that you may only use/benefit from some of these rights in limited circumstances.  For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ – or please contact us using the details below.

11. Complaints

If you are unhappy with the way in which we have handled your personal data or our fundraising and marketing practices, please contact us using the details below.

Please let us know if you have any queries or concerns. You can find out more about how to make a complaint to Your Place here.

You are also entitled to make a complaint to the Information Commissioner’s Office https://ico.org.uk/for-the-public/personal-information or the Fundraising Regulator https://www.fundraisingregulator.org.uk/ about our fundraising practises, but would encourage you to raise the issue with us directly first.

12. Data retention

We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected and subject to any legal obligation we are required to comply with or in order to protect or defend our legal rights.

In the event that you ask us to stop sending you marketing communications we will retain certain details, such as your name, to help us ensure that you are not contacted again. If you have any questions about our data retention policy, please contact us using the details in section 13 below.

13. Contact

If you have any questions, comments or suggestions, please let us know by emailing communications@your-place.org.uk, calling 020 7476 6062 or writing to the Communications Team, Your Place at Anchor House, 81 Barking Road, London E16 4HB.

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