- what information Aylesham Hub may collect about you;
- how Aylesham Hub will use information we collect about you;
- when Aylesham Hub may use your details to contact you;
- whether Aylesham Hub will disclose your details to anyone else;
- your choices regarding the personal information you provide to us;
Aylesham Hub is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the General Data Protection Regulations (EU 2016/279), Data Protection Act 1998 and the Privacy & Electronic Communications (EC Directive) Regulations 2003.
Who we are
Aylesham Hub Limited is a charitable community benefit society, registered with the Financial Conduct Authority (number 7816).
Reasons for collecting your personal data
You might contact Aylesham Hub to:
- enquire about volunteering with us
- support our campaigns
- register for one of our events
- access online content
- sign up to our e-newsletter
- take part in our survey
- get in touch by email or post
- engage with us via social media channels
This list is not exhaustive but does represent the list of circumstances under which we believe you will be providing information to us.
Types of personal data we collect
Depending on your interaction with Aylesham Hub, we might collect the following types of information about you:
- your contact details, such as name, postal address and email address
- your date of birth
- a record of our communications with you
- your communication preferences
- your interests, and reasons for your support
- your experiences or views on survey topics
- photography and videography, such as images at events, case studies and other marketing materials
We do not currently collect “sensitive personal data” e.g. health status.
If you are simply browsing our website as an anonymous visitor, Aylesham Hub may still collect certain information from you, such as your IP addresses (an IP address is a number that can uniquely identify a specific computer or another network device on the internet).
Personal information from people aged under 18
We are committed to protecting the privacy of the young people that engage with us, for example to complete our survey. We recognise that children need protection when collecting and processing their personal information because they may be less aware of the risks involved.
Where processing a child’s personal information is related to communications activities, we will only do so:
- (where the child is under 13 years old) with the consent of an adult with parental responsibilities
- (where the child is over 13 years old) with their informed consent
If a person is under 18, we will always notify them that they need to obtain consent from a parent or guardian before providing any personal information. When we collect information from a person aged under 18 we make it very clear as to the reasons for collecting this information and how it will be used.
Where does this information come from?
The personal data we process is given to us directly by supports, volunteers or survey participants in the course of their interactions with us.
Using your personal information
In simple terms, your personal data may be used to help us effectively deliver our aims to create a new social facility for Aylesham. If you participate in our survey, your personal data may be used for statistical purposes or archiving purposes in the public interest.
We have summarised below the different reasons why we do this (these are often referred to as ‘purposes’). How we use your data for these purposes will depend on the nature of our relationship with you.
Examples of purposes for which we collect, store and process your data:
- To enable us to recruit volunteers
- To support and train volunteers and ensure their safety
- To enable us to communicate with volunteers regarding their volunteering work, the wider work of Aylesham Hub and how they might support in other ways
Marketing and PR
Examples of purposes for which we collect, store and process your data:
- To send you marketing including behind the scenes news, updates about our work, general information about assistance, volunteering and various ways you can support Aylesham Hub
- To collect and store images and videography with the purposes to promote our work and events
- To archive and store images and videography for historical purposes
- Contacting you about case studies to promote our work
Examples of purposes for which we collect, store and process your data:
- To send you surveys
- To carry out research in relation to our supporters and services
Analysing your personal information
It’s important for us to know why you choose to support Aylesham Hub, as this helps us to give you the information that is most relevant for you. We’ll analyse your data in order to better understand your preferences, to improve our services, and to tailor our marketing communications to you.
Aylesham Hub also carries out click-through email tracking, which allows us to analyse when an email has been interacted with (e.g. opened or when links within it are clicked). This helps us to better understand the impact of our communications and success of our campaigns.
Sharing your personal information
We will only use your information within Aylesham Hub for the purposes for which it was obtained. Aylesham Hub will not, under any circumstances, share or sell your personal data with any third party for marketing purposes and you will not receive offers from other companies or organisations as a result of giving your details to us.
We will comply with legal requests where disclosure is required or permitted by law (for example to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime), subject to such bodies providing us with a relevant request in writing.
We may need to share your information with “data processors” such as our service providers, associated organisations and agents, or suppliers, who help us to prepare and send the materials relating to our work such as our email service providers.
In these situations, the relationship between Aylesham Hub and the third-party data processor will be governed by a contract and strict security requirements will be in place to protect your personal information. They will only act under our instruction and will not be allowed to use your data for their own purposes.
How the law applies to Aylesham Hub’s use of personal information
We are required under law to make sure that we have a valid ground for processing your data. The law sets out six different grounds for when personal data can be processed (plus additional ones where sensitive data is used) The three legal grounds that are most relevant to Aylesham Hub’s use of your personal information are:
- Legitimate Interest
Aylesham Hub will only process your personal information if any of the following apply:
- We have asked you for your express consent and have a record of this (for example, we will ask for your consent to send you marketing communications by email)
- We have a legitimate interest to do so. Our use will be fair and balanced and never unduly have an impact on your rights (for example, it is in our legitimate interests to analyse the data you provide so that we can improve our services and tailor our communications to you)
- We have a contract with you which we can only fulfil by using your personal information (for example, paying for a service we have purchased a service from you)
In some cases we will rely on consent, for example, to send you or make marketing emails, phone calls and text messages. You can withdraw consent for these channels and activities by contacting us.
This legal ground for processing means that we can process your personal information if we have a genuine and legitimate reason for doing so, and that reason is not overridden by your rights and interests as an individual.
Examples of the legitimate interests processing activities we undertake are:
- For administration purposes
- To conduct research
- To analyse data to better understand our supporters and tailor our communications to them
- To recruit and manage volunteers
We have considered and balanced our legitimate interests against individuals’ privacy rights in these scenarios and we do not believe that any adversely affect the rights or interests of our supporters. If you would like to find out more or ask us to stop processing your data in these ways, you can do this at any time by contacting us.
In some cases, we will be in a contractual arrangement with you which means that we have to process your data in order to fulfil those obligations. Some examples of this include if you are providing a service to us for which payment is required.
How we store your personal information
Aylesham Hub operations are based in the UK and we store your information on secure systems that are maintained and controlled by Aylesham Hub within the European Economic Area (EEA), or by approved third-party suppliers whose security credentials and data security processes have been vetted by us.
Access to information provided is restricted to only those who need access to it. This means your information is treated confidentially within Aylesham Hub.
We may share information collected as part of our survey which has been anonymised (for example, we might provide your age but we would not provide them with identifiable information without seeking your consent first).
Retaining your personal information
We will hold your personal information on our systems for as long as is necessary for the relevant activity.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Where you contribute material to us, e.g. user-generated content or in response to a particular campaign we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
If you decide you no longer wish to hear from us, we’ll need to keep a note of that on our suppression list indefinitely so we don’t inadvertently contact you.
Your data protection rights
The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest. If you wish to change how we communicate with you, or update the information we hold, then please email us: email@example.com
When Aylesham Hub is using your personal information on the basis of your consent, you have the right to withdraw that consent at any time. You also have the right to ask us to stop using your personal information for direct marketing purposes. Simply contact us and we will amend your contact preferences.
Presuming that these rights are not overridden by our legal obligations or where our legitimate interests are not overridden by your rights and interests as an individual, you have the following data protection rights:
- Right to be Informed
You have the right to be told how your personal information will be used. This policy document, and shorter summary statements used on our communications, are intended to be a clear and transparent description of how your data may be used.
- Right of access
You can contact us asking what information we hold on you and to request a copy of that information. From May 2018 we will have 30 days to comply once we are satisfied you have rights to see the requested records and we have successfully confirmed your identity.
- Right of erasure
From May 2018, you have the right to be forgotten (i.e. to have your personally identifiable data deleted). We’ll be required to keep an appropriate record (such as a suppression list) so that we can make sure you don’t receive future communications.
- Right of rectification
If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated.
- Right to restrict processing
In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
- Right to data portability
Where we are processing your personal data under your consent the law allows you to request data portability from one service provider to another. This right is largely seen as a way for people to transfer their personal data from one service provider to a competitor.
- Right to object
You have an absolute right to stop the processing of your personal data for direct marketing purposes.
- Right to object to automated decision making
In a situation where a data controller is using your personal data in a computerised model or algorithm to make decisions that have a legal effect on you, you have the right to object. This right is more applicable to mortgage or finance situations; Aylesham Hub does not undertake complex computerised decision-making that produces legal effects.
If you want to exercise any of these rights, please contact email us: firstname.lastname@example.org
Filming and photography
Please note that Aylesham Hub (or our authorised service providers) or our commercial partners may film or photograph participants, volunteers and spectators and use such footage or photographs. This may include attending or taking part in events hosted by us or by a third-party.
We do this in order to publicise the event for awareness and/or fundraising purposes including, but not limited to: television broadcasts, advertising, publications, marketing material, social media, personalised direct mail and other media that may be made available to the public. Secondly, to enable our partners to publicise their involvement and/or association with the event.
No personal details (including names) of any under 16-year-old participants will be used in any publicity materials without the written consent of their parent or legal guardian, but we may use images where children are incidentally included (for example, images of mass participation in a community event).
Notification of changes to this policy
If you have any questions about this Policy, or about how Aylesham Hub manages your data please contact us. If you are unhappy with the content of this Policy, please talk to us directly so we can help resolve any problem or query. You can email us: email@example.com
You also have the right to contact the Information Commissioners Office (ICO) if you have any concerns about Data Protection using their helpline 0303 123 1113 or at www.ico.org.uk
Policy last updated: 1 November 2018.