Retail Gift Aid Privacy Statement

This Policy explains when and why we collect your personal information in the course of running our retail Gift Aid scheme, how we use it, the conditions under which we may disclose it to others and how we keep it secure.

We may change this Policy from time to time so please check this website page occasionally to ensure that you’re happy with any changes.  The date upon which the Policy was last updated is displayed at the end of the Policy.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Any questions regarding this Policy and our privacy practices should be sent to our Data Protection Officer.

You can do this:

By email to: dataprotectionofficer@norwood.org.uk

By telephone: 020 8809 8809

By writing to: Data Protection Officer, Broadway House, 80-82 The Broadway, Stanmore, HA7 4HB

We are Norwood and refer to ourselves in this policy as “Norwood”, “we”, and “us” or “our”.  We are made up of two entities: Norwood Schools Limited, a private company limited by guarantee registered under company number 00516901 and a registered charity (registered charity number 307992) and Norwood Ravenswood, a private company limited by guarantee registered under company number 03263519 and a registered charity (registered charity number 1059050).  For the purposes of data protection law, we are the data controller.

We are the largest Jewish charity in the UK supporting vulnerable children and their families, children with special educational needs, and people with learning disabilities. We help children and adults to maximise their potential at home, at school and throughout their lives, through personalised services designed to enable choice.

Organisations are required by law to have a lawful basis for all processing of personal information that they carry out.  When we process your personal information in the course of running our retail Gift Aid scheme we rely on the following lawful bases:

  • You have given us your consent to the processing; and/or
  • We need to carry out the processing to perform a contract we are about to enter into, or have entered into, with you; and/or
  • We need to carry out the processing to comply with a legal obligation; and/or
  • The processing is necessary for our legitimate interests (or those of a third party) and we have undertaken a balancing exercise (and, where appropriate, put appropriate checks and safeguards in place) to ensure that your rights and interests do not override those interests.

You can read more about when we rely on each of the above lawful bases for processing your personal information in the section headed How do we use your information?

We will collect personal information that you provide to us when you participate in our retail Gift Aid scheme.  You may share you information with us when:

  • you complete a Gift Aid declaration when you make your first donation of clothes or other goods to one of our charity shops
  • you make any subsequent donations of clothes or other goods
  • you contact us with a comment, query, request or complaint regarding your donation or other retail Gift Aid scheme
  • you notify us of a change to your personal information

We will collect the following types of information about you when you participate in our retail Gift Aid Scheme:

  • Your name and title
  • Your address
  • Your email address (if you chose to share this with us)
  • Your telephone number (if you provide this when corresponding with us)
  • The fact you are a UK taxpayer
  • Details of the items you donate to us and the shop you donate to, whether we are able to sell your items and, if so, the individual and aggregated amount paid for your items
  • Any opinions or views you express in correspondence with us
  • Any marketing preferences indicated on your Gift Aid declaration
  • Your unique donor ID number (which we allocate to you when you register to participate in our retail Gift Aid scheme)

We do not collect any special categories of personal data about you for Gift Aid purposes (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 us with the personal information marked with an * on the Gift Aid declaration form we will be unable to claim Gift Aid on your donation.

We have set out below, in a table format, a description of all the ways we plan to use your personal information and which of the lawful 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 information for more than one lawful ground depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

The information in this Policy only concerns how we use your personal information in relation to your participation in our retail Gift Aid scheme.  If you also support or engage with us in other ways, please see the additional privacy policies on our website.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To conclude the Retail Gift Aid Agency Agreement with youYour name and title

Your address

 

Performance of a contract with you
To issue you with a donor ID number and track your donationsYour name and title

Your address

Your email address (if you chose to share this with us)

Details of the items you donate to us and the shop you donate to, whether we are able to sell your items and, if so, the individual and aggregated amount paid for your items

Your unique donor ID number

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to track and manage donations)

(c) Necessary to comply with a legal obligation

To claim Gift Aid on your donationsYour name and title

Your address

The fact you are a UK taxpayer

Details of the items you donate to us and the shop you donate to, whether we are able to sell your items and, if so, the individual and aggregated amount paid for your items

Your unique donor ID number

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to receive the maximum financial benefit possible from your donation)

(c) Necessary to comply with a legal obligation

To send you mandatory correspondence required for compliance with the Gift Aid scheme e.g. your annual statementYour name and title

Your address

Your email address (if you chose to share this with us)

Details of the items you donate to us and the shop you donate to, whether we are able to sell your items and, if so, the individual and aggregated amount paid for your items

Your unique donor ID number

(a) Necessary to comply with a legal obligation
To manage our Gift Aid relationship with you which will include:

(a) Notifying you about changes to our agency agreement or this Policy

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

(c) Responding to your queries, requests and complaints

 

Your name and title

Your address

Your email address (if you chose to share this with us)

Details of the items you donate to us and the shop you donate to, whether we are able to sell your items and, if so, the individual and aggregated amount paid for your items

Your unique donor ID number

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to maintain our relationship with you, to keep our records updated and to study how our supporters engage with our retail Gift Aid scheme)

Developing a profile of you to help us understand and categorise your characteristics as a participant in our retail Gift Aid scheme

*If you also support or engage with us in other ways please see our Privacy Policy for Donors and Supporters to understand how we may develop and use a general supporter profile for you

Your name and title

Your address

Your email address (if you chose to share this with us)

Your telephone number (if you provide this when corresponding with us)

The fact you are a UK taxpayer

Details of the items you donate to us and the shop you donate to, whether we are able to sell your items and, if so, the individual and aggregated amount paid for your items

Any opinions or views you express in correspondence with us

Any marketing preferences indicated on your Gift Aid declaration

Your unique donor ID number (which we allocate to you when you register to participate in our retail Gift Aid scheme)

 

Necessary for our legitimate interests (to better understand those who participate in our retail Gift Aid scheme with a view to increasing participation in the future)
To update your marketing preferences

*if you have consented  to marketing and would like to see details of how your personal information will be used for marketing purposes please see our Privacy Policy for Donors And Supporters

Your name and title

Your address

Your email address (if you chose to share this with us)

Your telephone number (if you provide this when corresponding with us)

Any marketing preferences indicated on your Gift Aid declaration

(a) Your consent

(b) Our legitimate interests (in maintaining an up to date marketing database)

We may also create, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate marketing consents to calculate the percentage of participants in our retail Gift Aid scheme who consent to receiving marketing communications from us or use aggregated postcode data to understand the demographic spread of participants. However, if we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Policy.

We will only use your personal information 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 information 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 rules set out in this Policy and where this is required or permitted by law.

We keep the paper copy of your Gift Aid declaration for 2 years from the date of the declaration.

We will keep an electronic copy of your Gift Aid declaration, a record of your donation history and copies of any correspondence with you regarding your participation in our retail Gift Aid scheme for 8 years from the date of your last donation.

We create a record of each supporter on our supporter database.  If your relationship is limited to participation in our retail Gift Aid scheme, we will retain your record on our supporter database for 8 years from the date of your last donation.  However, if you have supported us in other ways (for example, by requesting to receive our fundraising communications, taking part in events we arrange or making cash or legacy donations to us) we will maintain your record on our supporter database for longer.  Please refer to the additional privacy policies on our website to understand how long we will retain your information when you support us in different ways.

When you give us personal information, we take steps to ensure that there are appropriate technical measures in place to protect it. For example, access is restricted only to those who are entitled to see the personal information and our network is protected and routinely monitored.

We do not collect of process any special category personal data, such as health information, for Gift Aid purposes.

We will only store and process your personal information within the European Economic Area.

Who has access to your information?

Your personal information may be accessed and shared as described below.

Within Norwood:

Your personal information is accessible by our trained staff and volunteers who need to use it in order to perform their roles.

Within the wider Norwood group:

We will share your personal information with Ravenswood Trustees Limited, a private company limited by guarantee registered under company number 03007790.  Ravenswood Trustees Limited provides services to Norwood under the terms of a data processing agreement to assist us in achieving the purposes set out in the section headed How do we use your information.

Outside of Norwood:

We will share your personal information with our third party service providers where this is necessary for us to achieve the purposes set out in the section headed How do we use your information?  This includes our database provider, Raiser’s Edge, as well as suppliers of IT services, file storage services and secure data deletion/destruction services.

Your personal information will be shared with HMRC where necessary to enable us to claim Gift Aid on your donation.

We may, if necessary and on a case-by-case basis, share your personal information with our professional advisors such as lawyers, accountants and auditors in order that they are able to advise us properly.

If required to do so, we will share your personal information with the police and other regulatory bodies.  It may be disclosed to a court or tribunal if necessary in connection with any legal proceedings including if required under a court order.

If we choose to sell, transfer or merge any part of our organisation or assets we will share your personal information with the new owner.  The new owner will use your personal information as set out in this Policy.  Should this happen, you will be notified of the sale, transfer or merger and, if appropriate, provided with an updated copy of 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.

Under certain circumstances, you have rights under data protection laws in relation to your personal information.  A list of the rights you have is set out below – you can:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information 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 information 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 information 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 information 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 information. This enables you to ask us to suspend the processing of your personal information in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the information is unlawful but you do not want us to erase it.
  • Where you need us to hold the information 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 information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide you, or a third party you have chosen, your personal information 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 information. 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.

You also 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 would ask that you please contact us in the first instance.

If you would like to access the information we hold about you or exercise any of your other rights, please:

You will not usually have to pay a fee to access your personal information (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 could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 or to ask you to to complete a form in order to help us locate information that you would like access to.

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.

If you have any questions regarding this Policy, our privacy practices or data protection, please contact our Data Protection Officer. You can do this:

  • By email, to: dataprotectionofficer@norwood.org.uk
  • By telephone: 020 8809 8809
  • By writing to: Data Protection Officer, Broadway House, 80-82 The Broadway, Stanmore, HA7 4HB

We keep this Policy under regular review. This Policy was last updated on 3 April 2019.  If you would like to request historical copies of our privacy notices please contract us.