Pass It On is committed to protecting the data that we hold and use about you and to respecting your privacy. We are confident that you will find the information that you need set out in this policy, but if you need to know more about the data that we hold or the way that we use it, you can contact us in one of the ways specified at section 6 below.
- Who we are
- The way that we use your personal data
- What personal data do we collect?
- How do we collect personal data and why we have it?
- How do we share your personal data?
- Security and retention of your personal data
- Security of your personal data
- Retention of your personal data
- Accuracy of your personal data
- Your rights and how to contact us
The “data controller” of your personal data (in other words, the organisation that determines how your data is used) is Pass It On, Unit C, Axis Park, Hurricane Way, Langley, Slough, SL3 8AG.
Who we are
Pass it on is a charitable initiative set up to support homeless & vulnerable people in the UK. Working in partnership with local organisations, corporate partners and our own network of volunteers, we deliver warm clothing, hot food and a friendly face to vulnerable people living on the streets.
Pass IT On is registered as a data controller with the Information Commissioner’s Office in the UK.
The way that we use your personal data
A. What personal data do we collect?
This policy gives you information about the way that we may use your “personal data”. Personal data is any information that could be used to identify you in some way (even if, in some scenarios such as online advertising, we don’t know your name). The personal data that we may collect from or about you will include the following:
- E-mail address;
- Technical information about the way that you use web services, including the internet protocol (IP) address used to connect your computer to the internet;
- Information collected from our websites and elsewhere across the internet through cookies, pixel tags, device identifiers and other technologies including information about your uses and preferences;
- Potential recordings of calls that you may make to us;
- Location information related to the device that you use to visit the site; and
- Other information provided by you in our contact form.
If you’re aged under 16, you must get your parent/guardian’s permission before you provide any personal information to us.
B. How do we collect personal data and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- When you register with our Charity website;
- When you populate the website form to enquire about how you can help us;
- When you make a donation to us;
- To register your consent to subscribe to our newsletter and receive information about forthcoming events.
We also receive personal information indirectly, from the following sources in the following scenarios:
- If you connect your social media accounts via our website or any of our apps, certain personal data from your social media account will be shared with us which may include personal data that is part of your profile or your friends’ profiles;
- Certain information is collected by most browsers or automatically through your device, and we also collect your IP address (this enables us to recognise your computer or device when you use the site) via our server log files.
We use the information that you have given for the following purposes:
- For purposes related to the provision of services that we may offer:
- to respond to your questions and comments;
- where you have volunteered to help, sort or distribute donations, and to organise your activity;
- to send you administrative information such as notification of changes to our terms, conditions and policies;
- We may use your information to deal with a complaint, record what our volunteers have done for us, and other essential record keeping purposes.
We use your data in this way as often necessary to fulfil your request or because it is in our legitimate interests to do so, but we will always ensure that your rights are protected.
- For advertising and marketing purposes, including to measure how effective our marketing is:
- We may contact you by email or text message for marketing purposes, including our newsletter and details of forthcoming events if you have agreed to be contacted in this way
- We may also use your postal address or telephone number to send you information by direct mail or contact you by telephone, unless you have told us that you would prefer not to hear from us
- To measure the effectiveness of our marketing campaigns and advertising (i.e. so that we can tell what interests our visitors and what doesn’t)
In order to contact you directly with marketing (particularly electronically), we will make sure that we have your consent (for corporate subscribers, or for postal or telephone contact we may also rely on legitimate interest). In other scenarios (for example, serving online adverts to you or measuring the effectiveness of our marketing), we will rely on our legitimate interests as a charity, always ensuring that your rights are protected.
- For security and legal and compliance purposes:
- As part of our efforts to keep our site safe and secure
- As we believe to be necessary or appropriate in each case in order to comply with laws or legal process;
- To detect or prevent fraud or other illegal activity
In some cases, we will need to use your personal data to fulfil a legal obligation (for example, if we receive a legitimate request from law enforcement agencies), and in other cases (such as the detection of fraud or ensuring the security of the site) we will rely on our legitimate interests as a charity to use your data in this way.
- Protecting your vital interests: We may process your personal information where we reasonably think that this is a risk of serious harm or abuse to you or to someone else
- For administrative and internal purposes
- To administer our site including troubleshooting, data analysis, testing, training, research, statistical and survey purposes;
- To ensure that content on our site is presented in the most effective and relevant manner for you and for your device and to tailor the site’s experience and content based on the way that you use the site;
- We may record calls and use this data for training and quality assurance purposes (where your call is to be recorded, you will be informed of this at the beginning of the call).
It is in our legitimate interests as a charity to use your data in this way. For example, we have a clear interest in ensuring that our site works properly and that our products and services are high quality and efficient. We will always ensure that your rights are protected.
C. How do we share your personal data
We will never sell, rent or swap your personal data or give it to anyone else for them to use for their own purposes without making that clear to you. There are, however, various ways in which we will share your data, as set out below:
Our IT Service Provider:
We work with our IT service provider Smiths News Trading Limited to deliver our website and related IT services and this will often mean that we need to share your personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities to provide these services ourselves and to ensure an orderly performance of any service to you). In this case, we will ensure that the IT provider is only allowed to use your personal data in order to provide the relevant services to us and you. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
Sharing data with online advertising related service providers:
We may from time to time work with online advertisers, social media platforms and advertising networks to deliver, tailor and measure marketing communications and advertising to you and others, both on the site and elsewhere on the internet (including on social media platforms such as Facebook and Twitter). We also use various Google tools to deliver, measure and tailor our online marketing communications and advertising.
The personal data that these third parties see would never include information such as your bank, credit / debit card or full address details – it relates only to online identifiers such as IP address, data from cookies or similar technologies, or other device related usage information.
Similarly, we may share certain online identifiers with analytics and search engine providers that assist us in the improvement and optimisation of our site.
You can choose not to allow your data to be used to deliver targeted advertising by changing your settings within social media platforms and via Google’s own Ads Settings. You can also contact us in one of the ways specified at section 5 below if you would prefer us not to use your data in this way.
Sharing data to comply with laws:
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.
International transfer of your data:
Our IT Service provider is UK based, and also operates a Shared Service Centre in India. Some of the processes involved in the support of our website and IT may involve the processing of personal data by the shared Service Centre.
We take steps to put in place suitable safeguards to protect your personal information. Whenever our provider sends your personal data outside of Europe, we will make sure that steps are taken to protect your data as required by applicable laws, including the use of appropriate safeguards, Standard Contractual Clauses and adherence to certain compliance programmes and relevant certifications.
Security and retention of your personal data
A. Security of your personal data:
We take the security of your data very seriously. We have implemented various strategies, controls and measures to keep your data secure and keep these measures under close review.
We undertake regular reviews of who has access to information that we hold to ensure that it is only accessible by appropriately trained and skilled volunteers, contractors and staff.
B. Retention of your personal data:
We have a Data Retention Policy that sets out the retention periods for your personal data. After a retention period has elapsed, the data is securely deleted.
Accuracy of your personal data:
You can help us keep our records up to date by telling us when your contact details and other personal information changes. If you tell us of any changes (either to your personal information or how you wish us to contact you from time to time) it may take a short while for such changes to take effect but rest assured that we respect your rights and will endeavour to process such changes as soon as possible.
Your rights and how to contact us
The law gives you a number of rights in relation to your personal data and our use of it. You have the right:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
A full summary of your legal rights over your data can be found on the Information Commissioner’s website here: https://ico.org.uk/
You also have the right to complain about our use of your personal data. You can contact the Information Commissioner’s Office via their website: https://ico.org.uk/concerns/ or by calling 0303 123 1113.
© v1.0 September 2020