Privacy Policy

Privacy Policy

Introduction
The Big C Appeal Ltd respects your privacy and is committed to protecting your personal data. This privacy notice 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.

Important information and who we are

Purpose of this privacy notice
This privacy notice aims to give you information on how The Big C Appeal Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, volunteer or donate.

This website is not intended for children and we do not knowingly collect data relating to children.

We are a large regional charity with relationships with hundreds of fundraisers, volunteers, supporters and researchers, so we use personal data on a day to day basis in order to operate.  We ask that you take time to read this privacy policy so that you are fully aware of how and why we are using your data.

Who we are
In this privacy policy, “The Big C Appeal”, “Big C”, “we” or “our” means The Big C Appeal (registered charity in England and Wales (281730) and registered company in England and Wales (1521441)).

Controller
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details
Our full details are:-
Full name of legal entity – The Big C Appeal Limited
Name or title of data privacy manager – Dr Chris Bushby, CEO
Email address - Chris.Bushby@big-c.co.uk
Postal address - Big C, Centrum, Norwich Research Park, NR4 7UG

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.
 
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on Thursday 24 May 2018 and historic versions can be obtained by contacting us.
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
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data 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 Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes postal address, email address [social media profile] 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 have made to us.
Technical Data includes internet protocol (IP) address, your login data, 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.
Profile Data includes your username and password, donations made by you, your interests, preferences, feedback and survey responses. 
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 personal information which falls into the 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, for example, asking for health information for the purpose of providing appropriate facilities or support.  We also collect this type of information if you make it public or volunteer it to us – for instance if you tell us you have cancer when applying for a voluntary role.  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 one of our events, make a donation, purchase our products, register as a volunteer, apply for funding, use our support services 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 on the cookies and tracking methods we use in our Cookie Policy.

Third parties or publicly available sources. We may receive your personal data through third parties, for example:
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.
Specific Consent
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.
Legal Obligation
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 on of our regulations 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.
Vital Interests
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.
Legitimate Interests
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 Big C 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, including supporters, volunteers and researchers;
·       Where you have signed up with us for a charity place for a third party event (for example a sponsored event not organised by Big C), 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 “the data we collect about you” section above), 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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us or donated to Big C and, in each case, you have opted in to receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Big C for marketing purposes.

Unsubscribe
You can ask us or third parties to stop sending you marketing messages at any time by contacting us or them.  
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, warranty registration, product/service experience or other transactions.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please click here. 

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 in in clause 4 above.
  • External Third Parties as set out in the Glossary.
  • Specific third parties such as Active Campaign [email marketing], Just Giving [donations],
  • 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.

International transfers
We transfer some personal data outside the European Economic Area (EEA) for storage purposes.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  3. Where we use providers based in the US, we may transfer data to them if they are certified as being part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contract us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
 
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.

Data retention

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 legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
 
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.

Glossary

LAWFUL BASIS
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.

THIRD PARTIES
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.

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.

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: (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 wehave 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.