SNAPS Privacy Statement
This privacy notice explains how SNAPS looks after personal information you give us or that we learn by having you as a client and the choices you make about marketing communications you agree we may send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
1. How we obtain your information
2. What information we collect about you
3. How information about you will be used
4. Payment information
7. How long your information will be kept for
8. Where your information is kept
9. Access to your information and correction
12. Other websites
13. Changes to our privacy statement
14. How to contact us
1. How we obtain your information
We collect information in the following ways:
• When you tell us directly
We collect information about you when you register with SNAPS, sign up to use one of our services, volunteer, take part in an event, make an enquiry or make a donation, whether contact is online, on paper, by email or over the phone.
• When you give it to us indirectly
This is when your personal information is given to us by third parties. These might include websites, such as JustGiving, Enthuse or event organisers e.g. the London Marathon; these independent third parties will only do so when you have indicated that you wish to support SNAPS. You should check their privacy policies when you provide your information to understand fully how they will process your information.
We may also obtain information about you from a family member or a friend or service provider who contacts us on your behalf or if a fundraiser passes on your details to us. For example, we have many kind individuals within our community who want to support SNAPS at their own events, for example weddings or anniversary parties and they may arrange for donations to be made and gift aid envelopes to be available during these events. We also have many supporters who take part in sponsored activities on our behalf. These supporters manage these processes and may then pass on the donations they receive and details of the persons kindly giving a donation to SNAPS for us to use to say thank you and record this donation. If you would rather we don’t receive this information, please let the event organiser know.
We may also receive information about you collected or processed by organisations working on our behalf e.g. our e-mail marketing provider. Those organisations are
required to notify you at the point they collect your data that they will be passing it to us and to give you the opportunity to object or consent.
• When your information is available publicly or from other external sources
We may combine information that we already have about you with information available publicly or information available from external sources to gain a better understanding of you, your charitable interests and connections and to improve our fundraising, marketing and communication methods and services. Such information could be, for example, socio-demographic and lifestyle information and information about previous donations you have made. Examples of public registers include Companies House, the electoral roll and media reports.
The information we get from other external sources may depend on your privacy settings or the responses you give, so you should regularly check them.
2. What Information We Collect About You
As standard we will collect your personal data. This is information that can be used to identify you such as your name, date of birth, email address, postal address, telephone numbers, social media profile, fax number, bank account details, credit/debit card details, IP addresses, the company you work for and whether you are a UK tax payer so that we can claim Gift Aid
Data protection law recognises that certain categories of personal information are more sensitive. This is known as special categories of personal information and covers health information, racial or ethnic origin, religious beliefs or other beliefs of a similar nature, political opinion, and trade union membership. We may need to collect “special categories of personal data” about you where there is a legitimate reason for this (e.g. to check your eligibility for SNAPS or if you participate in an event for which we may need health information, for us to provide tailored support to you and to ascertain what services are relevant to you). We may also need to record sensitive data if you choose to tell us.
We may also collect health or other sensitive information if you tell us about your experiences, (for example, if you act as a case study for us); however, we will make it clear to you when collecting this information as to what we are collecting and why.
We also collect information about how our website is used and track which pages users visit when they follow links in SNAPS’ emails. We use this information to monitor and improve our services and activities e.g. to make our website more visible to people who are looking to find our services or to see which services or events are of most interest. Where possible we use anonymous or aggregated data that does not identify individuals. See further information about our website below.
Details on children under the age of 16 are only kept/stored by SNAPS with the consent of a parent, carer or guardian.
3. How Information About You Will Be Used
We may process your personal information for a number of reasons, such as:
• To identify you
• To ensure we have the correct safeguards in place for children and young people
• To provide you with information on our services and activities
• To process a donation or payment we receive from you
• To register and administer your participation in events you have registered for
• To claim Gift Aid on your donations
• To further our charitable aims, including for fundraising activities
• To fulfil a sale or registration
• To register, administer and personalise your account with us
• To gain a full understanding of your situation so we can develop and offer you the best possible personalised communication and customer service
• To say thank you and provide you with information about how your support helps children living with additional needs and their families
• To send items that you have ordered
• To report on the results and impact of our work, services, and events
• To invite you to participate in surveys or research or share your experiences in other ways
• To keep a record of your relationship with us and for internal administrative purposes (such as our accounting and records), and to let you know about changes to our services or policies
• To look into, and respond to, feedback, complaints, legal claims or other issues.
• To carry out statistical analysis and research in order to help us to understand how we are performing and how we can improve our services
• To monitor website use, administer and keep our website safe and secure
• To improve our website by making sure that content is relevant to users and their interests and habits
• For training and or quality control
• For financial recording or reporting purposes
• Where required or authorised by law e.g. arising from contracts entered into between you and us or in relation to regulatory government and or law enforcement bodies
• To prevent fraud, misuse of services or money laundering and to perform due diligence in respect of larger donations, to communicate with you in other ways
We may also use your personal information for other purposes which we specifically notify you about and, where appropriate, obtain your consent.
We collect this information for legal and contractual reasons, because we have consent from the individual concerned or because the organisation has a legitimate interest to do so and so that it can raise awareness, engagement and funds needed to fulfil our mission. The lawful grounds we use will depend on the purpose for which your information is processed, and the type of data concerned, for example:
· When it is in our legitimate interest i.e., to apply for a grant, unless this is outweighed by your rights or interests
· When you consent to it: we will always ask for your consent to hold and use health and medical information.
· To fulfil a contract with you i.e., to provide the service you have requested and to communicate with you about details.
We have rigorous data protection and security policies in place with all our third party software. We will not share your information with any other third party without your consent except to help prevent fraud, or if required to do so by law.
4. Payment information
When you use the online donation or payment pages on our website you will be directed to a specialist supplier company, who will receive your credit card number and contact information to process the transaction. We do not retain your credit, debit
card or bank account details. We will only use third party payment providers who meet the Payment Card Industry Data Security Standard.
They may use, retain and disclose your personal information and credit card details for this purpose as set out in their privacy policies, including transferring your data outside of the European Economic Area (EEA). If you provide us with credit or debit card details on a hard copy form, over the telephone or in person we will ensure all card details are securely destroyed once the payment or donation has been processed. Only those staff authorised to process payments will be able to see your card details.
We would like to send you information about SNAPS and other relevant information which may be of interest to you. This is considered by law to be marketing activity. We will do this for two years from your last engagement with us. There may be exceptions to this approach for example where support may be ongoing, for example, people who support a building or service project, or are actively part of an identified group fundraising on our behalf or who notify us that they wish to leave us a gift in their will.
It is your choice whether you receive direct marketing communications from SNAPS and how you receive this information.
All our communication material has clear marketing communication preference questions and always contain information on how you can let us know you would like to change your communications preferences or tell us that you would like us to stop contacting you for marketing purposes.
As we are a small organisation, and individuals often support us in multiple ways, for example, they may take part in fundraising and attend services, much of our marketing activity features many areas of our work at once. But if you would like to only receive information about certain areas of our work then we encourage you to get in touch so we can try and better tailor our marketing to your specific interests.
You have the right at any time to stop us from contacting you for marketing purposes or giving your information to third party suppliers of products or services. If you no longer wish to be contacted for marketing purposes, please contact SNAPS.
We will not use your information for marketing purposes if you have told us not to and no service we provide is dependent on our ability to market to you. If you let us know that you would like us to stop contacting you for marketing purposes, we will fulfil this request within 28 days. It is also important to note, however, that we may need to retain your details on a suppression list beyond this point, if we are required to do so for either contractual or legal reasons such as if you have made a donation or a tax declaration.
You may also receive administrative communications via mail, e-mail, telephone, text or social posting, for example, if you have made a donation. This type of communication is considered separate to marketing communications and is necessary for us to fulfil the requests you make of us. For us to provide an effective service to you at the lowest cost to us, the primary tool we will use for administrative communication will be email. If you have a different preference, please do let us know and we will do our best to accommodate your request.
6. Employment / Volunteers / Trustees
The information we collect about employees (including contractors), volunteers and Trustees the purposes it is used for and who it will be shared with is set out in our employment contracts and employee handbook.
7. How Long Your Information Will Be Kept For
We will keep your information for as long as required to enable us to operate our services, but we will not keep your information for any longer than is necessary. We will take into consideration our legal obligations and tax and accounting rules when determining how long we should retain your information. When we no longer need to retain your information, we will ensure it is securely disposed of or anonymised to remove all personally identifiable information.
In general, unless you request otherwise, we will keep your information to for a maximum of 5 years from your last interaction with SNAPS. After 5 year we will delete all your personal information, except for financial transactions (which we are obliged to keep for 6 years). Information about unsuccessful job applicants will be deleted after four months. See our data retention policy for further information, including employee data.
8. Where Your Information Is Kept
We promise to keep your information safe and secure. We have appropriate and proportionate security policies and procedures in place to help us do this.
Your information is stored on secure servers provided by Tagabad, Paypal and MailChimp. Any payment transactions are encrypted and we will take all reasonable steps to make sure any suppliers implement appropriate safeguards to ensure adequate protection under UK law for personal data. However, unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure.
9. Access to Your Information and Correction
You have the right to request a copy of the personal information that we hold about you. This will normally be free, unless we consider the request to be unfounded or excessive, in which case we may charge a fee to cover our administration costs. If you would like a copy of some or all of your personal information, please contact SNAPS.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. You have the right to ask us to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it.
We email e-newsletters to inform you about events and services provided by SNAPS and other relevant information. You can unsubscribe from e-newsletters at any time. E-newsletters may contain subscriber tracking facilities within the actual email, for example, whether emails were opened or forwarded, which links were clicked on within the email content, the times, dates and frequency of activity. We use this information to refine future email campaigns and provide you with more relevant content based around your activity.
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org or www.allaboutcookies.org You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
12. Other Websites
Our website includes links to other websites. This privacy notice only applies to this website so when you link to other websites you should read their own privacy notices.
13. Changes to Our Privacy Notice
We keep our privacy notice under regular review and we will place any updates on this webpage. This privacy notice was last updated on 20th January 2022.
14. How To Contact Us
Please contact us if you have any questions about our privacy statement or information we hold about you.
You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern: www.ico.org.uk/concerns/handling