Priscilla Bacon Norfolk Hospice Care Ltd. respects your privacy and is committed to protecting your personal data. This policy will inform you as to how we look after your personal data when you visit our website, (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.
This website is not intended for children and we do not knowingly collect data relating to children.
Who we are
Priscilla Bacon Norfolk Hospice Care Limited. is a registered charity (no. 1166579) and a company limited by guarantee (no. 09832765) and it has a subsidiary company called Priscilla Bacon Retail Limited (no. 11695945) – together “Priscilla Bacon Hospice”. We are the data controller of personal information that this policy applies to under the Data Protection Act 2018.
Full name of legal entity – Priscilla Bacon Norfolk Hospice Care Limited and/or Priscilla Bacon Retail Limited (as appropriate)
Email address – email@example.com
Postal address – 9-11 Drayton High Road, Norwich NR8 6AH
Telephone number – 0330 233 4274
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
This version was last updated in February 2019. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
What information do we collect about you?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
Identity & Contact Data includes name, postal address, email address and telephone numbers.
Financial Data includes bank account, payment card details and information as to whether you are a taxpayer to enable us to claim Gift Aid.
Transaction Data includes details about payments to and from you and other details of donations you have made to us.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
If you volunteer for us or apply for a job with us, information necessary for us to process these applications and assess your suitability, (which may include information such as employment status, previous experience, criminal convictions), may be collected.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data.
We may collect some Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We only collect this type of information to the extent that there is a clear reason for us to do so. We may also collect this type of information if you make it public or volunteer it to us. Wherever it is practical for us to do so, we will make why we are collecting this type of information clear and communicate to you what it will be used for.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract or service we have or are trying to enter into with you. In this case, we may have to cancel the contract or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your personal information in order to sign up for our newsletter, ask a question via out contact form, register for one of our events, make a donation, register as a volunteer, or otherwise correspond with us.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. There are more details in relation to cookies in the section below headed “Cookies”.
Third parties or publicly available sources.
We may receive your personal data through third parties, for example:
o Online giving websites (e.g. Total Giving, Just Giving);
o Professional fundraising agencies;
o Independent event organisers; and
o If you sign up as a volunteer via an external volunteering website.
We may also receive your personal information from subcontractors acting on our behalf who provide us with technical, payment or delivery services, and from business partners, advertising networks and search/analytic providers.
How we use your personal data
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via post). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with one of our regulators, such as the Charity Commission, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a Contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract, for example applying to work/volunteer with us.
We have a basis to use your personal information where it is necessary for us to protect life or health. For example, if there was emergency impacting individuals at one of our events requiring us to share personal data with the emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights). We consider our legitimate interests include all of the day-to-day activities Priscilla Bacon Hospice carries out with personal information.
We process personal data for reasons not mentioned above which we rely upon legitimate interests, examples of which include:
• Analysis and profiling of our supporters using personal information we already hold;
• Updating your address using third party sources if you have moved house;
• Use of personal information when we are monitoring use of our website for technical purposes;
• Use of personal information to administer, review and keep an internal record of the people we work with;
• Where you have signed up with us for a charity place for a third party event, (for example a sponsored event not organised by Priscilla Bacon Hospice), sharing personal information with the third party event organiser so they can administer the event.
Note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
When we use sensitive personal information (please see the section above headed “What information do we collect about you?”), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or donated to Priscilla Bacon Hospice and, in each case, you have opted in to receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Priscilla Bacon Hospice for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by contacting us or them.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out above.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to transfer, merge or sell parts of our charity organisation or our assets. Alternatively, we may seek to acquire other charities or merge with them. If a change happens to our charity, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidence.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our supporters (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being supporters for tax purposes.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your rights in relation to personal data
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest, (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
“EXTERNAL THIRD PARTIES”
• Service providers acting as processors based in the UK who provide IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.