Rotary Shoebox Scheme Privacy & Use of Cookies Policy
Rotary Shoebox Scheme (“we”) promise to respect the confidentiality of any personal data you share with us, or that we have access to through our distribution partners, to keep it safe, and we will always take every effort to protect your privacy.
We pride ourselves on our honesty and openness and will always be clear how, when and why we collect and process your information; we promise we will never do anything with your details that you wouldn’t reasonably expect.
Developing a better understanding of our members, supporters and donors is crucial, and your personal data allows us to do that.
We collect information in the following ways:
When you give it to us DIRECTLY
There are many ways you may give us your information. For example, when you complete an enquiry form, order boxes, request collection of filled, make a donation, or communicate with us either by phone, email or in person. We are responsible for your data at all times.
When you give it to us INDIRECTLY
Your information may be shared with us by independent organisations, for example sites like Just Giving or BT MyDonate or other such services. These independent third parties will only share your information when you have consented. You should check their Privacy Notice when you provide your information to understand fully how they will process your data.
Via Social Media
Depending on your settings or the privacy notices for social media and messaging services like Facebook, WhatsApp, LinkedIn or Twitter, etc., you might give us permission to access information from those accounts or services.
Via information available publicly
This may include information found in places such as websites, Companies House and information that has been published in articles/newspapers.
What personal information we collect and how we use it
We will only ever capture the minimum amount of information that we need to in relation to services we provide to you and we promise to keep your information secure. The personal data we may collect includes:
- Your name
- Your contact details (address, email and telephone number as appropriate)
- Details of the enquiry, service or product
Where it is appropriate, we may also ask for additional information, and this will be made clear to you at the time the personal information is requested.
How we will use your data
We will use your personal data for the legitimate interest of conducting core club or district activities, these will include:
- Administer your donation, including processing Gift Aid where applicable
- Provide you with the services, products or information you have requested.
- Providing services, products, guidance or information to supporters for their general activities.
- Communicating organisational messages and information
- To present our website and its contents to you and to allow you to participate in interactive features on our website
- Keep a record of your relationship with us
- Understand how we can improve our services, products or information
- In any other way we may describe when you provide the information
- For any other purposes with your consent
Sensitive information
We do not collect any personal information on members classified as ‘sensitive’ under GDPR. For example, information about an individual’s: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation.
Data Sharing
1) Our service/host providers
In the course of our legitimate Rotary Shoebox activities, there may be a need for us to share, or give access to, your personal data to third parties that provide us with services or host our applications/software that you may access, for instance:
- Banking organisations – those that provide our banking/payment services
- HMRC – for Gift Aid, tax and employment details
- Mailchimp – our newsletter communication mailing software service provider
- Jotform – Form processing provider
- Delivery & Collection companies we use to send boxes/leaflets to customers and collect filled boxes at the customers request
We will ensure that data processing agreements, compliant to GDPR, are in place before sharing with, or giving access to, your data with any of our service/host providers.
2) Sharing with third parties
We will never commercially sell your personal data to anyone else.
We will only ever share your personal data in other circumstances, not listed above, if we have your explicit and informed consent at the time of collection.
However, we may need to disclose your details if required to by the police, other agencies, for example HMRC, regulatory bodies or our legal advisors.
How we keep your information safe and who has access to it
We ensure that there are appropriate physical and technical controls in place to protect your personal details and we work within good practice, for example, confidential paper records are securely stored, or securely disposed of as appropriate. The Rotary Shoebox Scheme and its members ensure that PCs/devices holding personal information on behalf of them are protected with appropriate anti-virus and malware protection and this is routinely monitored by the us.
We undertake regular reviews of who has access to information that we hold to ensure that your personal information is only accessible by appropriate persons.
We have a duty to report certain types of personal data breaches to the relevant supervisory authority, and where feasible, we will do this within 72 hours of becoming aware of the breach. If a breach is detected and likely to result in a high risk of adversely affecting you, we will inform you without undue delay.
Where we store your information:
Your personal information will be hosted securely by ourselves and our service providers.
How long we retain your information and how we keep it up to date
We will only keep your information for as long as we need it to assist you with your enquiry, order, request etc. There are statutory timescales on how long we should keep your information, for example, gift aid transactions must be retained indefinitely, financial records must be kept for 7 years, information associated with Health & Safety can be retained for up to three years after an event etc.
We shall delete your information according to these statutory limits, or according to guidance issued by the Information Commissioner, or guidance issued at the time the personal information is collected.
Individual members are responsible for keeping their own personal data up to date. In addition, where necessary, we will keep your information accurate and up-to-date.
Your rights
The General Data Protection Regulations gives you certain rights and these are listed below for your convenience, further clarification of your rights is available on the Information Commissioners website (www.ico.org.uk):
- You have a right to be informed when your personal data is being collected, what is collected and how it will be used or shared.
- You have a right of access to your personal data: the right of access allows you to be aware of and verify the lawfulness of the processing of your personal data. You can also request a copy of the information which we hold on you. This information will be provided free of charge, unless the request is found to be manifestly unfounded or excessive then a reasonable fee will be charged. The application should be made in writing, by letter or email, and addressed to Rotary Shoebox Scheme, contact details shown below, enclosing two proofs of identification. Applicants should be aware that where requests are manifestly unfounded or excessive, in particular because they are repetitive, the Shoebox Scheme can:
– charge a reasonable fee taking into account the administrative costs of providing the information; or
– refuse to respond. - You have a right in certain circumstances to have inaccurate personal data rectified, blocked (restrict processing), erased (right to be forgotten), or destroyed.
- You have a right in certain circumstances to object to the processing of your personal data for such reasons as direct marketing, automated decision making, profiling; although we can confirm we make no decisions on you using an automated process.
- You have a right in certain circumstances to data portability.
We collect and process your personal data through legitimate interests or because you have provided it to us to enable us to deliver a service to you. We will only process your personal data as you would reasonably expect us to. You can opt out of general supporter mailings at any time.
Finally, if you are unhappy with how we have processed your information, you have the right to lodge a complaint with the Office of the Information Commissioner, contact details below.
Changes to this privacy notice
We may change this privacy Notice from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on our website or by notifying you directly.
Our contact details
These are available on our website www.rotaryshoebox.org
Or Email: feedback@rotaryshoebox.org.uk
Complaints
If you are unhappy with how we have processed your personal information, please firstly contact us details above. If you are still unhappy you may contact the following:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Helpline: 0303 123 1113 (local rate) or ++44 1625 545 745
Cookies:
Like most websites, we use “cookies” to help us make our site, and the way you use it, better. We do not store any personal data in the cookies that we use.
Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier.
In addition, the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
The type and quantity of information we collect and how we use it depends on why you are providing it. You should be able to control what cookies are placed on your device through your browser settings. Go to www.aboutcookies.org to find out more about cookies, including how to see what cookies have been set and how to manage and delete them.
We use Google Analytics to analyse the use of our websites by generating statistical and other information.
Details captured during your visit to our websites will include, but are not limited to, traffic data, location data, weblogs and other communication data and the resources you access. However, all data collected is anonymous and will not identify you as an individual.
Google, not the Rotary Shoebox, stores this activity information. You can view Google’s privacy notice here.
To opt out of being tracked by Google Analytics across all websites visit their website here.
Dated 25/05/2018