Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. This privacy policy will tell you how we look after your personal data and tell you about your privacy rights and how the law protects you.

We collect your personal data in various ways, including:

  • when you visit our website at http://www.socappeal.com/(regardless of where you visit it from);
  • when we receive an e-mail or letter from you;
  • because you or your organisation are, or are interested in becoming, a supporter of the charity in some way, for example as a sponsor or by attending our events; or
  • because you or your organisation are seeking financial support from the charity.

There is more information in section 3.

Please use the glossary in section 11to understand the meaning of some of the terms used in this privacy policy.

If you volunteer your time to support our activities (for example, in the run-up to our main annual event and on the  night itself), please see our separate Supporter Privacy Policy.

1. Important information and who we are

This privacy policy aims to give you information on how The Story of Christmas (“we”, “us”, “our”, the “charity”) collects and processes your personal data.

Controller

The Story of Christmas (a company limited by guarantee and registered as a charity) is the controller and responsible for your personal data.

Data privacy manager

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 policy, including any requests to exercise your legal rights (as set out in section 10), please contact the data privacy manager using the details set out below.

Data privacy manager: Rory Graham (Company Secretary and Honorary Solicitor)
Email address:  rory.graham@cglaw.uk
Postal address: 54 Kingsway Place, Sans Walk, London  EC1R 0LU
Telephone number: 020 7099 7321

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 our privacy policy and changes to your details

This version was last updated on 25 May 2018, to ensure compliance with the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA 2018).

It is important that the personal data we hold about you is accurate and up to date.  Please keep us informed if your personal data changes during your relationship with us.

2. 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 Dataincludes first and middle names, family name, title and gender.
  • Contact Dataincludes work or home address, email address and telephone numbers.
  • Financial Dataincludes bank account and payment card details and HMRC references.
  • Marketing and Communications Data includes:
    • information about individuals who are involved in one of our Charitable Projects and who are identified in the publicity we produce about our charity’s work; and
    • your preferences in receiving marketing from us and your communication preferences.

3. 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 Identity and Contact Data by contacting us through our website, by corresponding with us by post, phone, email or otherwise or by attending one of our events. You may give us your Financial Information if you are making a donation, or bidding for or purchasing an auction item at an event.
  • Third parties. Wemay receive Identity and Contact detail from your organisation if it is a sponsor or other partner of the charity or seeking or receiving funding from us

4. How and why we use your personal data

We will only use your personal data when the law allows us to.  Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you (such as for sponsorship or other support of the charity);
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • where we need to comply with a legal or regulatory obligation.

To find out more about the types of lawful basis that we will rely on to process your personal data, please refer to the glossary in section 11.

Generally, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.  We have also identified what our legitimate interests are where appropriate.

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 usif you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing, basis of legitimate interest
To sign you or your organisation up as a supporter or sponsor Identity

Contact

Financial

Performance of a contract with you (eg to provide sponsorship benefits or sell you an auction item)

For our legitimate interests (we may be unable to set you up on our systems until we have the personal information we need to be able to perform our contract and to ensure tax efficient giving)

To work with you or your organisation as one of our Charitable Projects Identity

Contact

Financial

Marketing and Communications

Performance of a contract with you (to provide funds and support)

For our legitimate interests (i.e. in order to run our operations and comply with the charity’s objects and obligations to the Charity Commission and to keep our supporters and potential supporters informed about our projects)

To manage our relationship with you if you are a supplier of ours Identity

Contact

Financial Data

Performance of a contract with you

For our legitimate interests (e.g. to effectively manage our supplier relationships – and to pay our suppliers)

To deliver relevant marketing and other similar materials to you Identity

Contact

Marketing and Communications

Necessary for our legitimate interests (to provide our sponsors and supporters with useful and relevant information about our events and auctions and how we use the money we raise)

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. Marketing

We want to provide you with choices regarding certain personal data uses, particularly around marketing.  We may use your Identity and Contact Data to send you material as set out in the tablein section 4 if:

  • you have previously attended, or expressed an interest in attending, one of our events or have been a sponsor of the charity or purchased an item at one of our auctions; or
  • if you have opted-in to receiving that material

and, in both cases, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time  by contacting usat any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us in the context of our performing a contract.

Cookies

You can read our policy on cookies here.

6. Disclosures of your personal data

We may have to share your personal data with External Third Parties (as set out in the glossary in section 11) for the purposes set out in the tablein section 4.

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.

7. International transfers

We will not transfer your personal data outside the EEA.

8. 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.

9. Data retention

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.

Our policy is to retain personal data for six years after the last occasion the individual concerned communicated with us or attended an event

In some circumstances you can ask us to delete your data: see section 10for 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.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. To summarise, 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 fredoms. 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 susend 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; or
      • 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 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 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.

11. Glossary

Lawful bases for processing your personal data
Legitimate Interest the interest of our charity in conducting and managing our operations so as to comply with our charitable objects and raise and dispense funds in as efficient a manner as we can.  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 processing your data where it is necessary for the performance of a contract to which you are a party (for example the contract between us and you or your organisation for the provision of sponsorship or funding) or to take steps at your request before entering into such a contract;
Comply with a legal or regulatory obligation processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to (e.g. regulations relating to money laundering and to income tax relief (eg GiftAid));
Third parties we may pass your personal data to
External Third Parties

 

·       service providers acting as processors, including our providers of IT system management and information security and volunteersand others providing physical security at our events;

·       professional advisers acting as processors or joint controllers including lawyers, bankers, accountants, auditors, insurers, management consultants and other intermediaries and business partners; and

·       HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers.

Foundation Partners 2017