This Policy is provided in a layered format so you can easily click through to the specific topic areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.
- IMPORTANT INFORMATION AND WHO WE ARE
- THE PERSONAL DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Policy
This Policy gives you information on how we collect and process your personal data: (i) through your use of this website (“Website User”); (ii) when you sign up to receive information from us, or otherwise contact/interact with us on or off-line (“Enquirer”); (iii) if you apply for a job, a temporary role or to become a volunteer (“Applicant”) ; or (iv) where you represent one of our existing or potential future service providers or organisations to whom we provide services (“Partner”) all together collectively (“Data Subjects”).
Our website is not intended for anyone under thirteen (13) years of age. We do not knowingly collect personal data via any medium relating to children.
Thrive at Five, registered charity number 1195059, is the controller responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy and our other privacy policies and fair processing notices. If you have any questions about this Policy or our others, including any requests to exercise your legal rights, please contact our DPO using the details set out below.
Full name of charitable entity: Thrive at Five
Email address: firstname.lastname@example.org
Postal address: 18 Buckingham Palace Road, London, SW1W 0QP
Telephone number: 07901 516149
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator 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.
Our changes to this Policy and your duty to inform us of changes
We keep this Policy and our others under regular review. This version was last updated in September 2023. Historic versions can be obtained by contacting our DPO.
If you submit personal data to us via any medium, including this website it is important you keep us informed if your personal data changes so that we may update our copy of it.
2. THE PERSONAL 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 as you interact with us, including via this website and other on and off-line media which we have grouped together as 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 physical address, email address and telephone numbers.
- Financial Data includes bank account and payment card details from you and/or any Partner you represent.
- Transaction Data includes details about payments to and from you and/or any Partner you represent.
- 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] or conduct your relationship with us.
- Profile Data includes your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website.
- Marketing and Communications Data includes your opt-in preferences in receiving marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 Policy.
We do not collect any Special Category Personal Data about you, 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 or provide the service you have requested (e.g., to provide you with the information you are seeking).
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect personal data from and about you including through:
• Direct interactions. You may give us your Identity, Contact, Financial and Transaction Data by filling in forms or by corresponding with us by post, phone, email,web or otherwise. This includes personal data you provide when you:
- Ask to learn more about or volunteer for our services;
- Contract with us for the supply of goods or services;
- Fill in forms on the website
- Subscribe to our services and/or publications;
- Request direct marketing to be sent to you;
- Enter a competition, promotion or survey; or
- Give us feedback or contact us.
- Third Parties or publicly available sources. We will receive personal data about you from various Third Parties and public sources as set out below:
- Technical Data from the following parties: (i) analytics providers such as Google Analytics based outside the UK (ii) marketing networks such as Mailchimp outside the UK.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. 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 it 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 Obligation.
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 1 below:
|Purposes for which we will use your personal data||Type of personal data||Lawful basis for processing including basis of Legitimate Interest|
|To register you as an Applicant, Enquirer or Partner, including as a subscriber to our communications||(a) Identity|
(e) Marketing and Communications
(b) Performance of a Contract with you
|To manage our relationship with Data Subjects which will include:|
(a) Notifying you about changes to this Policy or our other policies and fair processing notices
(b) Asking you to leave a review or take a survey
(c) Assessing how Website Users use our website or services
(e) Marketing and Communications
(b) Performance of a Contract with you
(c) Necessary to Comply with a Legal Obligati(d) Necessary for our Legitimate Interests (to keep our records updated and to study how you and people like you use our website and services so that we may develop them to better achieve our goals)
|We use Data Subjects’ personal data to administer and protect our charity and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
(b) Performance of a Contract with you
(c) Necessary for our Legitimate Interests (for running our charity, provision of administration and IT services, network security, to prevent fraud and in the context of a reorganisation or amalgamation of our charity)
(d) Necessary to Comply with a Legal Obligation
|To (a) deliver relevant website content to Data Subjects;|
(b) measure or understand the effectiveness of the content] we serve
(c) use data analytics to improve this website, our services, marketing and our relationships with our Data Subjects and their experiences with us
(f) Marketing and Communications
(b) Necessary for our Legitimate Interests (to study how Data Subjects and people like them use our website and services, in order to develop them, to grow our charity, achieve our goals, increase our efficiency and to inform our marketing strategy)
We may use your Identity, Contact, Technical, Profile and Usage 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 services and information is most relevant to send to you by email, SMS.
We provide you with choices regarding certain personal data uses, particularly around direct marketing. We will only send direct marketing communications with your prior Consent. You can opt-out at any time by clicking the unsubscribe button in every email we send AND/OR by contacting our DPO.
Where you opt-out of receiving direct marketing messages, this will not apply to our processing of your personal data based on any of the other legal bases detailed in Table 1.
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 legally permissible by being 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 our DPO.
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. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in Table 1 Purposes for which we will use your personal data above.
- Third Parties as set out in the Glossary.
- Third Parties to whom we may choose to sell, transfer or merge parts of our charity or its assets. Alternatively, we may seek to amalgamate with other charities or public or third sector organisations. If a change happens to our charity, then the new amalgamated entity may use your personal data in the same way as set out in this Policy.
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.
6. INTERNATIONAL TRANSFERS
Under certain circumstances we will transfer your information outside of the UK and European Economic Area. We will only do this with your informed consent, when it is necessary to perform a contract we have with you or where receiving organisation has adequate safeguards in place.
7. PERSONAL 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 and 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.
8. DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for (as set out in Table 1), including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with our Data Subjects.
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 it and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, reporting or other similar requirements.
Sometimes the law dictates minimum retention periods for different categories of information. Where we have discretion in how long we keep personal data for we keep the following types of personal data for the time periods set out below in Table 2 before it is permanently deleted. In some circumstances we will anonymise your personal data (so that it can no longer reasonably be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.
|Type of personal data||Retention period|
|Identity||6 years after last use|
|Contact||6 years after last use|
|Financial||6 years after last use|
|Transaction||6 years after last use|
|Technical||6 years after last use|
|Profile||6 years after last use|
|Usage||6 years after last use|
|Marketing and Communications||6 years after last use|
In some circumstances you can ask us to delete your personal data sooner than set out in Table 2: see YOUR LEGAL RIGHTS section below for further information.
9. 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:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw Consent.
If you wish to exercise any of the rights set out above, please contact our DPO using the contact details above.
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 to satisfy a clearly unfounded, repetitive or excessive request. Alternatively, we could 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 could 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 as to our progress. We have a maximum of three months to comply in these circumstances.
Consent means a specific, informed, freely given unambiguous indication of your agreement to our processing of your personal data.
Legitimate Interest means our interest in conducting and managing our charity to enable us to give you and others like you the best service 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 to process your personal data). 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 our DPO.
Performance of Contract means processing your personal 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 Obligation means processing your personal data where it is necessary for us to comply with a legal obligation.
Third Parties means our:
- Service providers (Google Analytics and Mail Chimp) acting as processors based in the US who provide analytics and marketing services.
- HM Revenue & Customs, regulators and other authorities acting as controllers based in the United Kingdom who require reporting of personal data processing activities in certain circumstances.
YOUR LEGAL RIGHTS
Subject to certain restrictions set down in data protection law, 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 personal 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 applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will will notify you of, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on oura Legitimate Interest (or that 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 continuing processing 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:
- If you want us to establish the personal data’s accuracy.
- Where our use of the personal data is unlawful, but you do not want us to erase it.
- Where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your personal 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 for the Performance of 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 services to you. We will advise you if this is the case at the time you withdraw your Consent.