1 About this policy
Helping Hands Community project helps people who are struggling with difficult situations including homelessness, addictions, unemployment, mental ill-health through our advice and support.
When doing this, we process personal data about people who receive advice and support services from us – or provide us with support through campaigns, donations (in kind or financial), or volunteering. We are committed to protecting your privacy and take this responsibility very seriously. We therefore take care to safeguard it. This notice outlines what data we collect, how we may use it, how we protect your data and your rights, and how you can exercise those rights.
References to ‘we’ or ‘us’ are to Helping Hands Community Project, registered charity no: 277354 (England) of 12 Gloucester Street, Leamington Spa CV31 1EE.
From time to time we check this notice to ensure we provide you with up-to-date information regarding our data processing activities. We strongly advise you to read this policy from time to time to ensure you are happy with any changes that might be made.
If you have any questions about this policy, please contact us using the details in the ‘Contact us, section.
2 Why we collect your data
We collect personal data for many reasons, including to provide you with services, communicate with you and send you information you have requested, and administer campaigns and donations. Depending on how you interact with us, we may process data for the following reasons:
a) to provide you with advice, support or legal services that you have requested or been referred to
b) to record personal details shared during conversations with our trustees, staff and volunteers
c) to process staff’s personal details required for the administration of staff personnel issues such as payroll or supervision and appraisal
d) to process volunteers personal details required for the administration of rotas for activities such as soup kitchen, House2Home, the Sleepout and fundraising events
e) to process personal details required for the administration of your booking on our events or to process a purchase from Helping Hands Community Project
f) to record and contact you regarding payments you make to Helping Hands Community Project
g) to administer services Helping Hands Community Project is providing to you
h) to communicate with you regarding Helping Hands Community Project’s work, fundraising, and campaigning activities
i) to process donations and administer Gift Aid information for any donation you make to Helping Hands Community Project
j) to process a purchase or donation via our charity shop, online shop or café
k) to provide you with information about and to administer events
l) to administer and send you information about leaving a legacy to the Helping Hands Community Project
m) for our own internal administrative purposes, and to keep a record of your relationship with us
n) to manage your communication preferences
o) to process job applications or volunteer placements
p) to conduct surveys, research and gather feedback
q) to obtain information to improve Helping Hands Community Project’s services and user experiences
r) to comply with applicable laws and regulations, and requests from statutory agencies
3 Information we collect
We collect the following personal information:
(a) your name
(b) contact details – including your postal address, telephone number(s), and email address
(c) date of birth
(d) details of your case when providing you with advice, support and services (including referrals)
(e) your bank details
(f) records of your correspondence and engagement with us
(g) donation history and Gift Aid details
(h) information you may enter on the Helping Hands Community Project website
(i) photographs, video or audio recordings
(k) Personnel information for staff and volunteers
(l) biographical information
(m) other information you share with us
This information may be collected via:
(a) any paper or digital forms you complete
(b) telephone conversations or face-to-face interactions
(c) digital forms completed via our website, or online surveys
(d) third-party companies and websites such as Just Giving and MyDonate
(e) third-party organisations that we refer our clients to or have referrals from to enable us to provide you with advice, support and services (e.g. client details from the local authority to allow us to know the clients that are due to stay overnight under the Severe Winter Emergency Provision (SWEP))
(f) publicly available sources
(g) communication via social media
We sometimes also collect sensitive, personal data about individuals. This includes information about health, religion, sexuality, ethnicity and criminal records. We will normally only record this data where we have your explicit consent, unless we are permitted to do so in other circumstances under data protection law. For example, we may make a record that a person is in a vulnerable circumstance or other information to enable a referral, such as for drug rehabilitation or to comply with requirements under law.
4 Using your personal data
People supported by Helping Hands Community Project
If you are receiving advice, guidance or support from us, we will need to process your data because of your specific relationship with us.
We will keep all your case information – including notes, letters and information given to us about you – in a confidential record that is specific to you. We use this information to support our advice, guidance and support. This means that we can keep the information you provide us, so we are able to see the history and relevant details of your case(s). This ensures that we provide appropriate and accurate advice or support. We take information security very seriously. No one is allowed access to our system or files unless they need this to provide the service to you, or one of the other purpose discussed in this notice.
To ensure that our services meet a high standard of quality, client files are sometimes checked by our quality assurance staff. Files may also be checked by external auditors if the work we do is funded by another organisation, such as a local authority. All auditors are bound by confidentiality policies.
We may use your data for statistical reports. These statistics will not include any information that could be used to identify any individual unless that individual has given specific consent, for example for a case study.
We would love to keep you up to date with our fundraising, marketing and campaign activity.
We use a range of marketing activities and channels to contact our supporters – including our website, social media, face-to-face fundraising and email.
We will obtain your consent to contact you by email to let you know about our activities, events, fundraising and relevant information about the vulnerable in our community.
We send the following marketing materials:
(a) updates about Helping Hands Community Project’s work – including newsletters and other publications informing you about our work
(b) appeals and fundraising activities – including requests for donations, information about how you can leave us a gift in your will, how you can raise money on our behalf, attend or take part in a fundraising event and updates on the impact that your fundraising activities have had on our work
(c) events – including details of our sleepout, as well as other events such as concerts in aid of Helping Hands Community Project. Please note that if you sign up to a Helping Hands Community Project event, we will also send you administrative communications about how you can take part. On occasion we will also send you a reminder about the same event in future years, in case you want to participate in it again
(d) shop products – including information about products offered by our online shop or charity shops
(e) volunteering – information about how you can help support Helping Hands Community Project by giving up your time or using your influence to progress our aims, along with updates on the impact of your work
We will never share or sell your personal data to a third-party organisation for its marketing, fundraising or campaigning purposes.
You can withdraw your consent, unsubscribe from or update your marketing preferences at any point using the details in the ‘Contact us’ section below.
Any electronic communications, such as emails, will have a link to unsubscribe from future electronic communications, so you can manage your own communication preferences.
If you make any changes to your consent, we will update your record as soon as we possibly can. It may take up to 60 days for our systems to update and stop any postal communications from being sent to you. Where you have followed a link to unsubscribe from email communications this will, however, be stopped immediately. If you tell us you do not wish to receive marketing, fundraising or campaign communications, you may still receive transactional and service-based communications confirming and servicing other relationships you have with us (as described below). We are looking into registration with the Fundraising Preference Service so that you would also be able to opt out of receiving marketing communications from us by signing up to the Fundraising Preference Service.
Administrative communications to supporters
In addition to the fundraising and marketing communications that you receive from Helping Hands Community Project, we will also communicate with you by post, telephone, and email in relation to administrative and transactional matters. For example, we may call you after you have set up a Direct Debit to confirm your details, and upon cancellation. There may also be other occasions where we need to contact you about your donation – for example, if there is a problem with a payment or in relation to your gift aid declaration.
On occasion, we will also contact you about an event that you have signed up to participate in, to – for example – check that fundraising pages have been set up and to provide any other necessary information.
As mentioned above, we may still need to communicate with you for administrative purposes even where you have opted out of marketing communications from us.
5 Supporter research and analysis
We may create a profile of your interests and preferences, such as an interest to join a cycling fundraising team. This allows us to ensure communications are relevant and timely, to provide an improved experience for our supporters.
We are also legally required to carry out checks on individuals who give us large donations, to comply with our duties in respect of anti-money laundering legislation and the prevention of fraud.
6 Helping Hands Community Project charity shop and Gateway Café
When you donate or purchase an item from one of our charity shops, our online shop or the Gateway Café, we may collect certain information from you – including your name, address, phone number, email address, Gift Aid status, marketing preferences, and payment details – so that we can process your purchase or donation or contact you if we have any queries regarding your purchase or donation.
Depending upon the communication preferences you select when registering your details, we may then also contact you for fundraising and marketing purposes, about the activities listed in the fundraising and marketing communications section of this policy.
7 Social media/digital
Our website uses web beacons or pixels through third-party service providers that allow us to understand the activity on our website.
If you receive an email, open it, don’t open it, select a link and/or browse our website, we collect this information to ensure that the information we send to people is received and relevant.
8 Applying for a Helping Hands Community Project job or volunteer position
When you apply for a job or volunteer position with us, your personal data will be collated to monitor the progression of your application, and the effectiveness of the recruitment process through the statistics collected. Where we need to share your data – such as for gathering references, obtaining a Disclosure and Barring Services (depends on the role) – you will be informed beforehand, unless the disclosure is required by law. These checks are only done after a position has been offered only to the successful candidate. On the application form, you are asked to complete the referees details, and can let us know whether you have provided permission to contact referees.
Personal data about unsuccessful applicants are held for 12 months after the recruitment exercise is complete for that vacancy. You, as an applicant, can ask us to remove your data before this time if you do not want us to hold it. If we feel there is another suitable vacancy available, we will contact the applicant prior to sharing your application details with the relevant manager.
Once you have taken up employment or a volunteer post with Helping Hands Community Project, we will compile a file relating to your employment or volunteer post. The information contained in this will be kept secure and will only be used for purposes directly relevant to your employment or volunteer post. Once your employment or volunteer post with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it from our files.
9 Professional contacts
We may collect data about professional contacts and partners with whom we work. Personal data collected in this way will be processed in accordance with data protection legislation and this policy.
We may send our professional partners information and updates about our work (primarily by email). Such contacts can opt out of receiving this information at any time.
10 Our legal basis for processing personal data
We need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Four of these are relevant to the types of processing that we carry out. This includes information that is processed on the basis of:
(a) a person’s consent (for example, to send you a newsletter by email)
(b) a contractual relationship (for example, to provide you with goods or services that you have purchased from us)
(c) processing that is necessary for compliance with a legal obligation (for example to process a Gift Aid declaration, and carrying out due diligence on large donations)
(d) Helping Hands Community Project’s legitimate interests (please see below for more information)
(e) Vital interests such as providing medical information if appropriate (for example if an emergency medic is called to site to treat a client and that information is relevant).
Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned.
When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair. Our legitimate interests include:
Charity Governance: including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes.
Administration and operational management: including responding to solicited enquiries, providing information and services, research, events management, the administration of volunteers and employment, and recruitment requirements
Fundraising and Campaigning: including administering campaigns and donations, sending thank you letters, analysis, targeting and segmentation to develop communication strategies, and maintaining communication suppressions.
If you would like more information on our uses of legitimate interests, or to change our use of your personal data in this manner, please get in touch with us using the details in the ‘Contact us’ section below.
11 Disclosure of your personal data
We will not share any of your personal data to any third party – except where:
(a) the transfer is to a secure data processor, which carries out data processing operations on our behalf (please see section 13 for more information)
(b) we are required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
(c) it is necessary to protect the vital interests of an individual
(d) we have obtained your consent
We will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.
12 Security of your personal data
We use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of your personal data.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website. Once we have received your information, we will use our procedures and security features to try to prevent unauthorised access.
We encourage you to review the privacy statements of websites you choose to link to from the Helping Hands Community Project website, so that you can understand how those sites collect, use and share your information. We are not responsible for the privacy statements, security, or other content on sites outside of the website.
13 Use of data processors
We may use a third-party supplier to manage mailings for fundraising appeals, campaigns, conduct research surveys or storage of your personal information on our behalf. You can find out more about the suppliers that we use by getting in touch with us using the details in the ‘Contact us’ section below.
14 Transfers of data outside of the European Economic Area
We may use Microsoft Office 365 and other applications, which are a cloud services, for our internal office use. This means that internal documents and information generated by us are stored in cloud services hosted within the European Economic Area (EEA).
15 Retention of your data
Whatever your relationship with us, we will only store your information for a specified amount of time, as set out in our internal data retention policy.
The length of time that data will be kept may depend on the reasons for which we are processing the data and on the law or regulations that the information falls under, such as financial regulations, Limitations Act, Health and Safety regulation etc., or any contractual obligation we might have – such as with government contracts or if we have a business case, such as with research data. For business case data, we will anonymise the data so no individual is identifiable.
Subject to the above, we will typically store data relating to donors and people who have taken campaign actions for approximately three years after their last donation or interaction, and people to whom we provide services to for approximately three years after completion of those services. Personal data about unsuccessful applicants are held for 12 months after the recruitment exercise is complete for that vacancy.
Once the retention period has expired, the information will be confidentially disposed or permanently deleted.
If you request to receive no further contact from us, we may keep some basic information about you on a suppression list to avoid sending you unwanted materials in the future.
16 Your rights
You have many rights under data protection legislation. These include:
(a) Right of Access
You have the right know what information we hold about you and to ask, in writing, to see your records.
We will supply any information you ask for that we hold about you as soon as possible, but this may take up to 30 days. We will not charge you for this other than in exceptional circumstances. You will be asked for proof of identity as the person dealing with your request may not be the staff member you have met before. We need to be sure we are only releasing your personal data to you.
This is called a data subject access, and can be done by:
i) e-mail firstname.lastname@example.org
ii) writing to Helping Hands Community Project, 12 Gloucester Street, Leamington Spa CV31 1EE
(b) Right to be informed
You have the right to be informed how your personal data will be used. This policy, as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.
(c) Right to withdraw consent
Where we process your data based on your consent (for example, to send you newsletter e-mails), you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.
(d) Right to object
You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.
(e) Right to restrict processing
In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
(f) Right of erasure
In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials, we will need to keep some limited information to ensure that you are not contacted in the future.
(g) Right of rectification
If you believe our records are inaccurate, you have the right to ask for those records concerning you to be updated. To update your records, please get in touch with us using the details in the ‘Contact us’ section below.
(h) Right to data portability
Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.
If you have any complaints about the way in which we have used your data, please get in touch with us using the details in the ‘Contact us’ section below. We would be happy to help and discuss your concerns. In addition, you are also entitled to make a complaint to the Information Commissioner’s Office and the Fundraising Regulator.
18 Contact Us
If you have any questions about this policy, would like more information, or want to exercise any of the rights set out in section 15 above, you can get in touch with us in the following ways:
(a) email us at email@example.com
(b) Helping Hands Community Project, 12 Gloucester Street, Leamington Spa CV31 1EE
Version 1.0 Policy updated: 14 October 2018