Introduction

Welcome to the Housing Justice's privacy notice.

Housing Justice 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. You do not have to take any action with regard this policy.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

Purpose of this privacy notice

This privacy notice aims to give you information on how Housing Justice collects and processes your personal data through your use of our website, including any data you may provide through this website when you sign up to our newsletter or make a donation.

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

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Housing Justice is the controller and responsible for your personal data (collectively referred to as Housing Justice "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise [your legal rights], please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Housing Justice

Kathy Mohan, Chief Executive Officer

Email address:[email protected]

Postal address: 258 Bermondsey Street, London SE1 3UJ

0203 544 8094

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 24/05/2018 and historic versions can be obtained by contacting us.

The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.

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.

  1. 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 billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from 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, purchases or orders 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.

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 which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (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). Nor do we collect any information about criminal convictions and offences.

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 we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. 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, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you;
  • apply for our products or services;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a survey; or
  • give us some feedback.
  • 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, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below
  • Technical Data from analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Go Cardless, based inside the EU.
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  1. How 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.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

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.

Purposes for which we will use your personal data

We have set out below, in a table format, 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 us if 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 including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 from us or if you provided us with your details when you or registered for a promotion and in each case, you have not opted out of 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 Housing Justice group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

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 see our cookie policy.

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.

  1. 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 the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.

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.

  1. International transfers

 We share your personal data within the “Mail Chimp” Group. This will involve transferring your data outside the European Economic Area (EEA).

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

  • 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may only transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. 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.

  1. 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.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

By law we have to keep basic information about our donors including Contact, Identity, Financial and Transaction Data for six years after they cease being customers 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.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about your rights under the section “your legal rights”

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.

  1. 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 USA and in the EEA 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 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 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.

Housing Justice and Legitimate Interests

This sections documents Housing Justice’s position on using Legitimate Interests as lawful grounds for processing the personal data of our donors/ supporters , through postal or telephone communication, in accordance with the General Data Protection Regulation ( GDPR).

Our position has been taken based on the “Guidance of Legitimate Interests under the EU General Data Protection Regulation “created by the Data Protection Network.

We will be using Legitimate Interests as lawful grounds with a refresh period of 2 years. If there has been no contact or further donation after 2 years we will no longer contact the donor based on the premise of Legitimate Interest.

When taking our position on Legitimate Interest we have been mindful of the specific wording in Article 6 (1) (f):

“ Processing will be lawful if it is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by  the interests of fundamental right and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”

We have also been mindful of the GDPR guidance on Legitimate Interests and direct marketing:

“ The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest. An organisation may wish to rely upon Legitimate Interests where consent is not viable or not preferred and the balance of interests condition can be met”.

This report establishes the necessity for processing personal data and demonstrates how we have balanced the needs of Housing Justice with the interests of those receiving our direct marketing communications ( ie our donors/supporters).

Legitimate Interests and the donor/ supporter experience

When making a donation our supporters are indicating that they want to support the work that we do and we believe that they want to open up communication with us and hear about how that money is spent and what our future needs and aims are.

The Legitimate Interests Assessment (LIA)

We followed the 3 stages of a LIA

  • Identification of a legitimate interest
  • Carrying out a necessity test
  • Carrying out a balancing test.

 

Identification of a legitimate interest

(a) What is the purpose of the processing operation?

The purpose of Housing Justice (and by extension the processing of donor data) is to support church and community groups in taking action to alleviate homelessness and poor housing by taking practical action and/or pressing for change.

We can only achieve these aims with the engagement of individuals and organisations who support our aims. We depend upon direct marketing to keep donors and supporters up to date with what we are doing and how they are making a difference and to invite them to offer further support.

(b) Is the processing necessary to meet one or more specific organizational objective?

We cannot carry on in our work without raising funds from individuals, churches and other organisation’s and so are of the view that processing personal data for direct marketing is necessary.

(c) Does the GDPR, ePrivacy regulation or other national legislation specifically identify the processing activity as being a legitimate activity , subject to the completion of a balancing test and positive outcome?

Our processing activity is a traditional direct marketing activity through post . We have noted the GDPR guidance on Legitimate interests and direct marketing:

“The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest. An organization may wish to rely upon Legitimate interests where consent is not viable or not preferred and the Balance of Interests condition can be met”.

Our Balancing Test below explains why we believe that the processing activity is of legitimate interest to Housing Justice and also achieves a benefit for society by enabling us to continue our work addressing rough sleeping, homelessness and housing need.

There is no impact within the current draft of the ePrivacy regulation that will impact on postal communication.

Necessity Test

1- Why is the processing activity important to the controller?

It is essential for us to engage supporters in donating to continue our work. We rely on voluntary contributions for a significant part of our income, in particular for core funds.

2- Is there another way of achieving the objective?

It is the view of housing Justice that without the use of Legitimate Interests as the basis for our supporter communications Housing Justice would be unable to reach the number of supporters we need to in order to achieve our aims.

Balancing Test

1- Would the individual expect the processing activity to take place?

The person has given us their data freely at the point of donation or making contact. It is our opinion that the individual would reasonably expect to receive updates and communications about supporting our work in the future.

2- Does the processing act add value to a product or service that the individual uses?

It does add value in that it keeps the individual up to date with the work of the charity and gives them the opportunity to support the charity again.

3- Is the processing likely to negatively impact the individual’s rights?

We can see no occasion whereby the processing by Housing Justice would have a harmful effect on the rights of the individual.

We have taken steps to ensure that supporters are aware of their rights  and aware of how they can control / enforce their rights according to their personal circumstances:

  • Our privacy policy reflects our stance on Legitimate Interests and explain the purpose of the data processing
  • We have clear signposts across our channels as to how supporters can contact us regarding treatment of their data
  • Supporters are sent consent forms with our direct communications and so it is clear to them how they can opt out of future communication
  • Supporters can register their preferences for contact (including opting out of all future contact) via our website.

4- Is the processing likely to result in unwarranted harm or distress to the individual?

We can see nor circumstances where our contact would lead to harm or distress as every time we contact we will offer the opportunity for them to opt out of any future contact.

5- Would there be a prejudice to the Data Controller if processing does not happen?

Yes as we rely on raising funds from our donors to carry out our work.

6- Would there be a prejudice to the third party if processing does not happen?

N/A

7- Is the processing in the interests of the individual whose personal data it relates to?

We are confident that our supporters donate or contact us because they share our vision and mission. If they have made a donation we believe that means they want to understand how we are spending that money,what our future plans are and how they can donate again.

8- Are the legitimate interests of the individual aligned with the party looking to rely on their legitimate interests for the processing?

According to the criteria set by the ICO the legitimate interests of Housing Justice and the individual do not strictly align in this context as the benefit is of a wider societal nature rather than the individual in question.

It is our belief that at least on an aspirational level the motivations of both the individual ( our supporters) and the data controller ( Housing Justice) are aligned in that we both want to alleviate homelessness and housing need. We consider that this is sufficient justification to continue the processing.

9- What is the connection between the individual and the organization?

We consider all who financially support us as “partners” in our partnership scheme. As such we aim to keep them up to date with our work and give them the opportunity to consider carrying on in their capacity as partners or to withdraw.

10- What is the nature of the data to be processed? Does data of this nature have any special protections under GDPR?

The nature of the data to be processed is

  • Name and salutation
  • Postal address
  • Telephone Number
  • E mail address

We do not process any data ( for direct marketing purposes) as defined by the Special Categories of Personal Data, and are therefore not required to meet the Article 9 condition for lawful basis of processing in this context.

11- Is there a 2 way relationship between the organization and the individual whose personal information is going to be processed? If so, how close is that relationship?

In most cases this is a typical scenario of direct marketing whereby the supporter responds by choosing to donate or not. However, we do have a newsletter that we offer to all supporters and some donors receive that and respond to it.

Some significant donors have a more personal relationship and will make contact or receive contact by way of update on spending on specific areas of interest.

Because we are a Christian organization supported largely by active Christians there can be contact made around times of prayer also eg Homeless Sunday or the annual Commemoration Service for homeless people who have died during the year.

12- Would the processing limit or undermine the rights of the individual?

We do not believe that the processing of this data in any way undermines or frustrates the ability to exercise the rights of the individual, either now or in the future.

We make it easy to disengage every time we make contact.

13- Has the personal information been obtained directly from the individual , or obtained indirectly.

All of the personal information we hold has been obtained directly from the individual; we do not work with third parties.

14- Is there any imbalance in who holds the power between the organization and the individual?

We do not consider there to be an imbalance of power. As stated previously, we offer opportunities to opt out of contact with every communication and people can register their contact preferences at any time via our website or by telephone.

15- Is it likely that the individual may expect their information to be used for this purpose?

Individuals who have donated or made contact and registered their details with us will be likely to expect us to write to them to appeal for donations. Appeals and updates are standard communications for all charities.

16- Could the processing be considered intrusive or inappropriate? In particular could it be perceived as such by the individual or in the context of the relationship?

We do not think that our direct marketing would be considered intrusive or inappropriate. We currently only contact people who have donated before or registered their details with us. As such we consider they would expect to hear from us.

17- Is a fair processing notice provided to the individual? If so, how? Are they sufficiently clear and up front regarding the purposes of the processing?

Our privacy policy will be the subject of continual review, reflecting and communicating any necessary changes to our data processing.

18- Can the individual, whose data is processed, control the processing or object to it easily?

The individual can easily access our complaints process if they are unhappy with how their data is being processed. They can also easily opt out of any further communication.

19- Can the scope of the processing be modified to reduce/ mitigate any underlying privacy risks or harm? 

The processing is very simple as we do not work with any third parties. We consider that the risk is already minimal with clear channels of communication if there are any concerns.