Feed The Hungry UK Privacy Notice

Version 2.0 - Last Updated: 22nd May 2018
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1. Privacy

Feed The Hungry UK has privacy processes to help maintain your trust in us and to protect the personal information you provide to us. The following information describes how we handle the information provided to us by donors, supporters, partners, volunteers and others who express interest in our work.

These processes have been prepared using guidance from the Information Commissioner's Office in readiness for compliance with the General Data Protection Regulation (GDPR) which is due for enactment on 25th May 2018.

This notice is applicable for all individuals of whom we hold personal information.

2. Who We Are

Feed The Hungry UK is a registered charity (Charity No. 1112955) and a company limited by guarantee (Company No. 5537293). We work from offices and in a warehouse in Hinckley, Leicestershire. By engaging with a wide range of supporters and donors in the UK, we are able to ship donated food, clothing and resources via trusted partners to schools and communities overseas. Our registered office address is in Leicester. Full details are available at www.feedthehungry.org.uk

3. Collecting Personal Information From You

The information that we may collect from you will include specific personal information, including your name, address, city, county, postcode, telephone number(s), e-mail address, mailing preferences, Gift Aid information and date of birth. Credit card details may be stored temporarily for single donations, or longer for a recurring gift.

Photographs, video clips and CCTV images may be captured and used. See Sections 11, 16 and 17 for more details.

All information is held in a suitably secure manor.

With your personal information, we are also required to keep (1) details of when and how contact was established with you and (2) what information has been given to you by us to explain our obligations with your personal information (this Privacy Notice).

4. Lawful Basis for Holding and Processing Personal Data

All personal data is held by Feed The Hungry under the lawful basis of 'Legitimate Interest', 'Consent' or 'Contract'. We do not buy, rent or acquire personal data from other sources other than the individual, or those who have the legal right to act on behalf of an individual. In some cases, we may receive your personal data indirectly through a third-party provider, for example, from 'JustGiving' or 'CAF', but only on the understanding that you have donated to Feed The Hungry through these channels, and that you have agreed that your personal details can be passed on to us.

Legitimate Interest is used as a basis for processing personal data for anyone who actively submits their personal details to us; we assume that if you give us your personal information, then you have an interest in the work of Feed The Hungry UK and are happy for us to hold and process your data. It is the basis for processing and holding the data of anyone who has financially donated to Feed The Hungry.

Where 'Legitimate Interest' is not the legal basis, 'Consent' will usually be the basis. This is the case for anyone who has supplied their personal details to us, but not given financially.

For Employees, Volunteers and anyone who has entered into a contract with Feed The Hungry, the lawful basis for holding and processing data will be under 'Contract'.

If data is held on the basis on 'Legitimate Interest', it will be held for up to 7 years from the point of last inbound contact. If data is held on the basis of 'Consent', it will be held for 5 years from the point of last inbound contact. Data held on the basis of 'Contract' will be held indefinitely. You may enquire as to the basis under which your data is held at any time and we will try to respond to your request within 10 working days.

If a donation has been made by a supporter, the details of the supporter and transaction will be held for 7 years in accordance with our legal obligations in terms of accounting and tax.

5. Communication

Where people wish to stay in contact with Feed The Hungry, we offer the opportunity to receive regular communications from us. These describe how donations are applied to significantly reduce the poverty and deprivation that we encounter in the places where we work in the UK and overseas.

In accordance with the Privacy and Electronic Communications Regulations (PECR), we will only contact supporters for whom we have received an active and positive opt-in to receive electronic communication (e-mail, phone and SMS). We may contact supporters via postal mail by assumed or explicit consent, but on the understanding that anyone can opt-out of any method of contact at any time. Donors will be removed from mailing lists as soon as is feasible. There is a 28 day settlement period from the point of opting-out, where systems will be updated and any communications which have already been issued will be delivered. We recognise that you can exercise choice in how and how often we communicate with you. Hence, the information you provide to us enables us to tailor our communications and make best use of charitable resources with which we have been entrusted.

6. Opting-out of Communication

You always have the option to re-state your preferences or to have your details removed from our mailing lists.

The simplest way to change your preferences or have your details removed from our mailing list, is by using the “contact us” page on our website. Just confirm your name and address and indicate your desired outcome in the comments section.

Other ways to make these requests are: We adhere to the Fundraising Preferences Service (FPS).

7. Individual Rights

You have rights as individual whose data is held by another party:

7.1. The right to erasure

You are entitled to have your details removed from our records. This can be done by getting in touch with our office using the details in Section 6. However, we may be legally required to continue to hold your personal details, even if requested by yourself, or someone acting on your behalf, to have them removed. If this is the case, we will explain as far as possible what personal information we must continue to hold.

7.2. The Right to Complain

If you would like to complain to Feed The Hungry, please write to our Office at: Feed The Hungry UK, Suite 1, 1 Castle Street, Hinckley, LE10 1DA

8. Donor Support

We are very grateful for the support we receive through our donors. When donors choose to make an online donation or give by phone to sustain our work, Feed The Hungry UK has a third party provider to collect payment card information on our behalf. This provision will only be used to process donations. We do not store payment card details electronically ourselves, but the third-party providers may do so temporarily for one off gifts, and longer for recurring Credit Card or Debit Card donations.

For donations made by Credit Card or Debit Card by a donation given by post, the card details will be destroyed as soon as the gift has been processed. Sensitive information will not be held any longer than necessary after a donation has been processed.

All third-party service providers process card payment information in accordance with the Payment Card Industry (PCI) Standard.

We may use information you give us to process and account for donations and, where you have indicated that we may, to collect Gift Aid against your donation from HMRC.

9. Security of Personal Information

We maintain up-to-date software to protect our computer systems from unauthorised access, and regularly test our IT network for vulnerabilities. We do store personal information records within cloud-based data resources operating within UK & EU requirements. However, due to the nature of the cloud-based systems, we can not guarantee that the data is held and processed within the EU, but we adhere to the EU's Data Protection Regulations. We take all reasonable steps to ensure that your data is stored and processed securely in accordance with this policy. By submitting your personal data you agree to this transfer, storing and processing of your information.

We operate an industry recognised data management system which has restricted users directly accountable to Feed The Hungry UK. All our electronic files containing personal information are encrypted and secured with password protection, with the exception of photographs and video clips, which may be stored securely but unencrypted. All paper-based personal information is held in a secure manor.

Where third-party service providers hold personal data on our behalf, we ensure that our relationship with the third-party provider is outlined in a Data Handling Agreement, which is upheld by both parties.

10. Accuracy of Information

We want your personal information that is stored by us to be up-to-date and to be accurate. Should any of your details change, please let us know so that your records can be updated. If we have inaccurate information, we are keen to correct this. In most instances, you will be aware of these inaccuracies before we are.

Please contact us with any corrections and the details we hold will be changed. We may have reasonable grounds to check the identity of the person requesting alterations and for this we will usually request confirmation by referring to information we have obtained from you before.

We may use Royal Mail's Postcode Address File or other available sources to confirm data that you provide us with, where, for example, we are unsure of what you have completed on a form.

At any time, you may request to check the personal information about you that we hold on our records. We have only a small team of staff at our offices, so we may opt to contact you when the appropriate member of staff is next at work. We aim to fulfil this task within ten working days of receipt of your request. Please allow an extra two to three days if our response is to be sent to you by post within the UK. A charge may be made for this request.

For more information about your rights please visit the website of the Information Commissioner's Office (ico.org.uk).

11. Sharing of Personal Information

Feed The Hungry does not share your personal information with other organisations external organisations, or with other Feed The Hungry International Offices or partners, with the exception of photographs and videos for advertising or social media purposes. We maintain secure systems to ensure that your details will be kept confidential. Unless we are required to do so for legal reasons, we will never intentionally give out your details to anyone else. Your personal information is important to us and will never be rented, sold, shared, or otherwise exchanged by Feed The Hungry.

12. Security of online payments

For the processing of donations, Feed The Hungry only uses third party providers which use Secure Socket Layer (SSL) Protocol when collecting or transferring sensitive data such as payment card information. With the current SSL technology, the card information you enter while making a donation or purchase will be encrypted before traveling over the internet. However, we emphasise that despite all our efforts for your information to be transferred and stored securely, the internet cannot be guaranteed to be 100% secure, and that you submit data at your own risk.

13. Donations given by telephone

We use a dedicated secure means for donors to give towards our work by telephone. Once a transaction has been authorised by the donors' bank, no account details are retained by our service provider2. Only the contact details of the donor, the details of the gift and any contact preferences collected are passed to Feed The Hungry for retention in line with these processes. The service provider may retain a copy of the information provided by the donor, but will not be shared with any other party in accordance with this Privacy Notice.

14. Use of third party mailing services

Feed The Hungry uses a third-party UK-based mailing company3 to despatch by post our regular newsletters and selected communications. For this service, we have to supply the names and addresses of the recipients. In line with our commitment to you, this is achieved through encrypted and password-protected files and no personal information is stored by the mailing company beyond a reason timeframe for each mailing. The mailing list is refreshed by us each time a mail-out is prepared.

15. Website visitors

Feed The Hungry has an online presence through its websites (feedthehungry.org.uk, fth.org.uk and somethingamazing.org.uk) which details much of our work. The sites are maintained and regularly reviewed. The websites also uses cookies which gather information that is unique to each online visitor. This information is held for up to 5 years.

15.1. Cookies

Cookies are small text files on your device. They are made by the web browser on your computer or mobile device whenever you visit a website. If you go back to that website, your browser will send the cookie file back to the website's server. Cookie files improve your experience of using a website, for example, by remembering your preference settings and your use of our website.

Cookies are useful because they allow a website to recognise a user's device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu. For a video about cookies visit https://www.google.co.uk/goodtoknow/data-on-the-web/cookies

15.2. Why does Feed The Hungry use cookies?

Like many websites, Feed The Hungry uses cookies in order to provide you with a more personalised web service.

Cookies help us identify which parts of our website people are using most frequently. This helps us to work on those sections of the website and improve our virtual visitors' experience. We also use cookies to help show content on our site which is relevant to you and your interests, for example, if on a previous visit you went to our pages about emergencies, campaigns or events, we might find this out from your cookie and direct you to view other information on our website related to emergencies, campaigns or events on subsequent visits.

Information supplied in cookies also allows us to measure the effectiveness of our online marketing campaigns. This enables us to ensure any money we spend on digital marketing gives us a good return on investment.

15.3. Managing cookies

Most browsers allow you to turn off the cookie function. To do this you can look at the help function on your browser.

15.4. Third party cookies

We use websites such as YouTube to embed videos and you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third party website for more information about their cookies and how to manage them. Feed The Hungry UK also uses third party suppliers such as Facebook and Google Analytics and these providers may use cookies. They may also use tracking pixels, which are commonly found in advertising to track the effectiveness of adverts. As some of these services may be based outside of the UK and the European Union, they may not fall under the jurisdiction of UK courts. If you are concerned about this you can change your cookie settings (see above).

6. CCTV

Feed The Hungry UK uses CCTV to capture video for the safety of staff and volunteers, and as a deterrent for crime in and around the premises used by Feed The Hungry. The video captured by the CCTV system is held securely for up to 12 months. For queries and requests related to CCTV, please contact the Feed The Hungry UK Office on 01455 618 455.

17. Photographs & Video

Feed The Hungry UK stores photographs and video. These may have been taken by Feed The Hungry UK staff at events or while visiting projects overseas. These photographs or videos may be shared with other Feed The Hungry International Offices and partners for social media or advertising purposes.

Where an individual or a small group of individuals are the focus of the photograph or video clip, consent will be gained for the use of the photograph. Consent may be implicit, for example, it may be announced at an event that photographs or videos are being taken for advertising purposes and if you would not like to be included, to make yourself known. In this case, the individual would need to act in order not to be included in the photographs or videos. For food packing events, it is the organisers responsibility to arrange consent for photographs and videos. Every effort will be made prior to and during an event to make participants aware that photographs and videos are being captured, and to give the option not to be captured.

Photographs and videos may be stored indefinitely. You can request that a photograph or video clip of yourself ceases to be used. However, where the picture has already been used, no action will be taken to try to retract the existing publications of the material; only future use of the material.

18. Children and young people below the age of 18 years

We maintain links with schools and colleges across the UK to engage support for many aspects of our work. We aim to ensure that within these organisations, our designated points of contact are adults only, e.g. teaching staff. Where any child or young person requests to be included on our records, we would request an adult (parent or carer) to give to us their own details and then undertake to pass on any mailings or items intended for the child or young person.

Where we do have to hold records of someone under the age of 18, we will not contact them without consent from a parent or guardian, and only in reference to a specific activity or field of our work, for example, 'volunteering'.

Learning resources are available from the Feed The Hungry website and presently, no registration, subscription or age-verification is required or requested in order to download or access these.

19. Data breaches & Data Protection Lead

We have designated to Gwyn Williams the role of Data Protection Officer for Feed The Hungry UK. If you require details of our information access arrangements, please clearly mark any correspondence for his attention. Any apparent breaches of personal data security will be investigated by our Data Protection Officer. If necessary, any actual breaches will be reported to the Trustees of Feed The Hungry and to the Information Commissioner's Office in accordance with the requirements of the GDPR. If a breach occurs which would affect the freedoms of individuals as set out by the GDPR, we will inform those individuals affected as soon as reasonably possible.

20. International Context

For the purposes of information security and data protection, Feed The Hungry UK will adhere to all UK based legal requirements in its application of the processes required to maintain integrity.

21. Changes to this Privacy Notice

This notice may be updated from time to time, so you may wish to check them each time you submit personal information to us. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to submit personal information to us. If material changes are made to the Privacy Notice, we will notify you by placing a prominent notice on our website.

Data Protection Officer: Gwyn Williams, Operations Director