1. IMPORTANT INFORMATION AND WHO WE ARE
Recycling Lives Charity is committed to protecting your personal information and being transparent about what information we hold, whether you are a donor, volunteer, service beneficiary, or campaigner.
Developing a better understanding of our supporters through their personal information allows us to fundraise more efficiently, which ultimately helps in our charitable aims. We have made improvements to this Policy so that transparency is at the core of what we do.
We ensure that we use your personal information in accordance with the law.
The Policy may change from time to time. For example, we have recently updated it to reflect new legal requirements of the UK General Data Protection Regulation (also known as the ‘GDPR’) and Data Protection Act 2018. Please visit this website section periodically to keep up to date with any changes in our Policy.
Recycling Lives Charity is registered in the UK with the Information Commissioner’s Office as a Data Controller under reference ZB010983.
Full name of legal entity: Alex Mercer
Email address: [email protected]
Postal address: The Recycling Lives Centre, 1a Essex Street, Preston PR1 1QE
Telephone number: 01772 654321
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.
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.
Third party links
2. THE DATA WE COLLECT ABOUT YOU
We collect information about you in the following ways:
Information you give us. For example, when you post information on our social media or message boards, make a donation to us, register for an event or otherwise provide us with personal information. When you register, we may ask for personal information, like your name, email address, telephone number, date of birth, bank account details for setting up a regular direct debit gift and contact preferences.
Information from known third parties. We may also receive information about you from our third-party partners with whom you choose to interact, for example such as Gift Aid when making a donation. This can include information such as your name, postal or email address, phone number, your geographic location, credit/debit card details and whether you are a taxpayer so that we can claim Gift Aid. To the extent that we have not done so already, we (or they) will notify you when we receive information about you from them and tell you how and why we intend to use that information.
Information available publicly. We may include information found in places such as Companies House, LinkedIn and information that has been published in articles/newspapers.
Wherever possible we use aggregated or anonymous information which does not identify individuals by name. See below How we use your personal data to understand our purposes for processing your personal information.
We collect, store, and use the following kinds of personal information:
- Your name and contact details, including postal address, telephone number, email address and, where applicable, your social media profile.
- Your date of birth.
- Financial information you provide where you make a payment, such as bank details or credit/debit card details, although we do not store credit or debit card details (see below).
- Information about your computer/mobile device and your visits to and use of this website, including for example your IP address and geographical location.
- Information about our services which you use/which we consider of interest to you.
- Information as to whether you are a taxpayer so that we can claim Gift Aid.
- Any other personal information you share with us as described above.
- Your debit and credit card information.
If you use your credit or debit card to donate to us, buy something or pay for a registration online we will use a specialist payment processor. We will also ensure that card details are handled securely under Payment Card Industry (PCI) Data Security Standards. For more information about these Standards see here – https://www.pcisecuritystandards.org/security_standards/index.php.
We never store your credit or debit card details following the completion of your transaction. All card details and validation codes are securely destroyed once the payment or donation has been processed.
Please do not send an email containing any credit or debit card details.
All purchases or donations should be completed through the donation page.
3. DO WE COLLECT SPECIAL CATEGORY DATA?
Certain categories of personal information are regarded by the law as more sensitive than others.
This is known as ‘special category’ or ‘sensitive personal data’ and covers things like information about your health, ethnic origin, religious beliefs, political opinions or any genetic or biometric data that is used to identify you.
We do not usually collect ‘sensitive personal data’ about our supporters unless there is a clear reason for doing so, such as participation in a marathon or similar fundraising event or where we need this information to ensure that we provide appropriate facilities or medical support to enable you to safely participate, or attend any of our sites, and/or events.
We will always make it clear when we collect this information from you and what sensitive personal data we are collecting and why.
Cookies are small text files that can be used by websites to make a user’s experience more efficient.
The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies, we need your permission.
This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
You can at any time change or withdraw your consent from the Cookie Declaration on our website.
Please state your consent ID and date when you contact us regarding your consent.
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
4. HOW WE USE YOUR PERSONAL DATA
We use your personal information for a number of purposes including the following:
- To provide you with the services, products or information you have requested:
- To provide information about our work, activities, volunteering or events although this will only be where you have consented to being contacted for those purposes unless Recycling Lives is in a position to rely on the Legitimate Interest basis for contacting you (see further information below under Legal Basis for Processing).
- To process donations, we may receive from you.
- To fundraise in a manner referred to in this Policy or that you would reasonably expect.
- To create an account for you if you register with us.
- To deliver products or services to you.
- For administration purposes (for example we may contact you regarding a donation you have made, including in relation to Gift Aid or the event you have registered for).
- For internal management, such as record keeping of enquiries, feedback, or complaints.
- To invite you to participate in surveys or research (although this is voluntary).
- To use IP addresses to identify your approximate location, to block disruptive use, to record website traffic or to personalise the way our information is presented to you.
- To analyse and improve the online services we offer, to make them as user-friendly as possible.
Where collecting and holding your information is required or authorised by law:
- We may use your personal information for the purposes of credit risk reduction or fraud prevention (using external specialist agencies to help us); and
- Other specific purposes that you may agree to from time to time.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Legal basis for processing
The law requires us to set out the lawful grounds on which we collect and process your personal information as described in this Policy. Depending on the purposes for which we use your data, one or more of the grounds listed below may be relevant:
We rely on the “legitimate interest’ ground for processing where we believe it is in the legitimate interests of you, as the data subject, or of Recycling Lives, to process your data. When we process your personal information in this way, we also 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 information for activities where our interests are overridden by the impact on you, for example where collection and use of your information would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law). We will only use your information in accordance with the purposes described in this Policy.
Examples of processing based on the legitimate interest ground are:
- Conducting research to better understand who our supporters are and better target our fundraising activity:
- Measure and understand how our audiences respond to a variety of marketing activities so we can ensure our activity is well targeted, relevant, and effective:
- Taking and using photos and/or films of event participants and attendees:
- Administering events:
- Sending relevant communications to your work email address:
- Staff recruitment and taking applications for volunteers and contacting volunteers about their role; and, the use of CCTV recording equipment in and around our premises for monitoring and security purposes.
- Promoting Recycling Lives Charity on social media, Google, YouTube, and other online platforms.
In some instances, we will rely on obtaining your consent to our use of your personal information in a certain way (for example, asking for your consent to use your personal information to send you direct marketing information, and we may ask for your explicit consent to share sensitive personal information with us).
We may need to collect, process, and disclose personal information to comply with a legal obligation. For example, where we are ordered by a court or regulatory authority or we are legally required to hold donor transaction details for Gift Aid or accounting/tax purposes. We may also use personal information to cross check and prevent known malicious activities on other operated services.
Performance of a contract:
For example if you purchase something from us, or agree to work for us, we need to be able to process your information for the purpose of meeting our contractual obligations.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 to you (we call this marketing).
Third party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
You may opt-out of our marketing communications at any time by clicking the ‘unsubscribe’ link in our marketing emails or by sending us an “opt-out” text message, following the instructions we provide you in our initial text.
If you have indicated that you do not wish to be contacted by us for marketing purposes, we will retain your details on a ‘do not contact’ list to help ensure that we do not contact you accidentally. However, we may still need to contact you if you carry on dealing with us, including (but not limited to):
Processing a donation that you make, or any continuing direct debit:
Providing you with information you need to participate in an activity or event for which you have registered:
Explaining and apologising where we have made a mistake; and
Dealing with future legal claims in connection with a contract we have with you.
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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
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.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
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 confidentiality.
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.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting, or other requirements.
By law we must keep certain basic information about our customers and service beneficiaries (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will 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.
Keeping your personal information
We keep your personal information only for as long as we need to use it for the purposes set out in this Policy.
We have adopted a data retention policy that sets out the different periods we retain personal information for in respect of these relevant purposes. The criteria we use for determining these retention periods is based on various legal requirements; the purpose for which we hold data and whether there is a legitimate reason for continuing to store it (such as to deal with any future legal disputes); and guidance issued by relevant regulatory authorities including, but not limited to, the Information Commissioner’s Office (ICO).
Personal information that we no longer need is securely disposed of and/or anonymised, or put beyond use, so you can no longer be identified from it. Some personal information may be retained by us in archives for statistical or historical research purposes although we will do this in a manner that complies with applicable data protection law.
We continually review what personal information and records that we hold and delete what is no longer required. We never store payment card data after the transaction has been completed.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
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 could 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 could 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.
YOUR LEGAL RIGHTS
You have the right to:
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.
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.
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. The erasure of your personal data is managed in conjunction with the Data Retention Policy.
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.
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:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful, but you do not want us to erase it.
- 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.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
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.
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.
Legitimate Interest means the interest of our Charity and/or business in conducting and managing our business, and/or Charity, 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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
INTERNAL THIRD PARTIES
Other entities in the Recycling Lives Charity, such as our wholly owned subsidiary company Recycling Lives (Social Enterprises) Limited, acting as joint controllers or processors including those who provide IT and system administration services.
EXTERNAL THIRD PARTIES
Professional advisers 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 based in the United Kingdom who require reporting of processing activities in certain circumstances.
Facebook connect and Facebook custom audience.