Privacy Notice

Sailors’ Society is committed to doing the right thing in how we collect, use, and protect your personal data and being transparent about what we do with it no matter how you interact with us. That is whether you work, volunteer, advocate for us, donate, use our services and training, need information or want to learn more about what we do.

Sailors’ Society is the ‘Data Controller’ referred to in this Privacy Notice as ‘SS’, ‘we’ or ‘us’. This Privacy Notice:

• Sets out what personal data we may collect from you.
• Explains why and how we use your personal data.
• Explains who your personal data might be shared with.
• Explains how long we might keep your data for.
• Explains how we keep your data safe.
• Explains your rights and choices in relation to your personal data.

Definitions

‘Personal Data’: information capable of and used in identifying an individual;
‘Data Processing’: any activity carried out using personal data (including storage);
‘Data Subject’: the individual to whom the personal data pertains;
‘Data Controller’: the organisation (or individual) who collects and processes your personal data;
‘Data Processor’: a third party individual or organisation that may carry out processing activities on behalf of the Data Controller.

Most of the personal information we process is provided to us directly by you, when you directly give us information.

We may collect and process your data in a number of situations. Whenever we process your personal data, we will do so in accordance with this Privacy Notice. This Privacy Notice will apply to you when you:

• Use our website or social media sites.
• Contact us via email, telephone, post or in person.
• Support us by making a donation.
• Participate in a fundraising or other Society event or fundraise on our behalf.
• Access our services including our Helpline, online chat service, Wellness at Sea or Crisis Response Network.
• Participate in our Peer-to-Peer Support Groups.
• Participate in our Cadet Conferences.
• Participate in our Wellness E-learning or facilitated training and coaching.
• Apply for employment or to volunteer.
• Apply for a grant.
• Visit Seafarer House and grounds.
• Enter into a contract with us in order to provide us with your services.

For a copy of our Privacy Notice for residents of Lagarie Children’s Home please email: [email protected] or call the Lagarie line: 07565 903377.

WE DO NOT USE AUTOMATED PROFILING OR DECISION MAKING IN RESPECT OF ANY PERSONAL DATA THAT WE PROCESS

What Data we might Process:                          

• Information about your online browsing behaviour on our website.
• Information about any devices you may have used to access our website or Social Media sites, including the make, model, operating systems, IP address, geographical location, browser type and mobile device identifiers.
• Information on your activities and what links you have clicked on within the website, social media or e-newsletter.

 Why we Process it:

When you use our website, we may need to process your personal data in order to be able to:

• Administer and maintain our website and improve functionality and accessibility.
• Detect potential online security threats that may be posed to our systems and those who access them.
• Gather information about activity on our website for statistical purposes.
• Prevent inappropriate behaviour and protect our staff and other users of our social media applications and sites.

When you visit our website either to browse or to access our services, you do so in accordance with our Terms and Conditions and we will process personal data that we collect from your use of our website according to this Privacy Notice. This is limited to the processing that we carry out once we have received your personal data, and not during or as a result of your transmission of that data from your own devices or software.

Our website contains links to other websites. This Privacy Notice only applies to our own website, so when you link to other websites you should read their own Privacy Policies. We cannot guarantee the security of your personal data when you navigate away from our website to those of third parties.

When you interact with us via our social media applications and sites, you may be subject to the rules of usage operated by the service or application provider. If you transmit or provide personal data via social media applications or sites, we cannot guarantee the security of that data nor the compliance with Data Protection legislation by the service or application providers. You should check the Privacy Policy of each provider according to the software or social media that you choose to utilise. Please remember that anything that you ‘post’ on social media is essentially publicly available and we cannot control the access to those platforms that you may choose to use. How we process the data we receive via social media will be governed to an extent by this Privacy Notice, but only insofar as we process it for our own purposes. If third parties access your personal data via any of our social media, then we are not responsible in law nor otherwise for their processing of your personal data.

We really value our followers’ engagement and very much welcome considerate discussion on our social platforms and posts. However, please note that we will not tolerate offensive or abusive language on our social pages or groups. If a post or comment contains unacceptable language or if a user behaves in an inappropriate way then we will request that the post is rephrased and/or possibly remove or hide the comment. If a user continues to behave in an unacceptable way and/or repeatedly posts offensive or abusive comments, we will take steps to remove the user from our platforms and/or page.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Please read our Cookies Policy to find out more.

What Data we might Process:

• Your basic identifying and contact information.

Why we Process it:

• Communicate with you and deal with your enquiry.
• Grant you access to our facilities and services.
• Provide you with information about events, products, services or support that you may have indicated you are interested in.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, date of birth, gender, and title.
• Location information such as postcode, preferences, and interests.
• Information relating to bank or credit card details.
• Donation arrangement information (for example regularity).

Why we Process it:

When you contact us via email, telephone, post or in person, or when you use our website (www.sailors-society.org) we may need to process your personal data in order to be able to:

• Communicate with you and deal with your enquiry.
• Manage the administration/processing of the donation or Gift Aid.
• Provide you with information about events, products or services that you may have indicated you are interested in.
• Maintain our own accounts and records.

Third party platforms:

Please note that when you make a donation online you may be donating through a third party platform (for example reCAPTCHA or Stewardship). We encourage you to review the Privacy Policy of the donation platform to understand how they may collect, use, and disclose your personal information.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, date of birth, gender and title.
• Location information such as postcode. 
• Information relating to bank or credit card details.
• Employment details.
• Emergency contact information (next of kin or designated contact) including name, phone number and email address.
• Body type/size.
• Photographic/video images.

Some or all of this may be Special Category Data, which is subject to additional regulation, which we process in order to personalise support or facilitate emergency assistance.

Why we Process it:

• To communicate with you and deal with your enquiry.
• To send you marketing information that you have given us specific consent for.
• To support you with your participation in the event.
• To maintain our own accounts and records.
• Where you have provided your consent to allow us to use your information in a certain way – for example using your image to publicise an event or our services.

Third party platforms:

Please note that our fundraising platforms may utilise services provided by third-party platforms (including, but not limited to, Enthuse and JustGiving). We encourage you to review the Privacy Policy of the fundraising platform to understand how they collect, use, and disclose your personal information.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, gender and title.
• Employment details including job title, department, rank on board ship, current vessel assignment, and employment history within the company.
• Education information, which includes academic records, professional qualifications, certificates obtained, and ongoing training records.
• Emergency contact information (next of kin or designated contact) including name, phone number and email address.
• Sensitive personal data (special category data) including diagnosed mental health conditions, stress factors, medical fitness and physical and mental health conditions, treatments, specific medical needs or medications.

Some or all of this may be Special Category Data, which is subject to additional regulation, which we process in order to personalise support or facilitate emergency assistance.

Why we Process it:

• To personalise support, enabling tailored advice and support to your individual circumstances and needs, fostering a better mental state and coping strategies.
• To provide early intervention, enabling access to early intervention services in the case of mental health issues, preventing these issues escalating.
• To enhance career longevity, by providing resources and tools tailored to your individual needs by equipping you with the skills to manage stress, fatigue, and other occupational hazards.
• To provide emergency assistance in critical situations, the personal data shared can facilitate swift emergency response, ensuring you receive immediate care or assistance when needed.
• To protect your vital interests where we reasonably think that there is a risk of serious harm or abuse to you or someone else.
• There are certain circumstances where we cannot guarantee confidentiality, for example where we are made aware of a vulnerable adult or child being at risk. In these circumstances we may be required to share the information we hold with other services including the police/emergency services/shipping company.
• To provide statistical evaluation. We will use anonymised data collected to measure and report on the general wellbeing of seafarers to industry.

Based on your location, some or all of your personal data may be shared with our staff or volunteers in another international location. This is necessary for the service provision that you have requested from us.

Third party platforms:

Please note that for the Chat facility we use a third-party platform ‘Fresh Chat’, and we encourage you to review their Privacy Policy. When calling using this facility you are assigned a username and will remain anonymous. However, during your interaction with us, you may choose not to be anonymous and to give personal information.

What Data we might Process:

This Privacy Notice explains how we process your data when you join and participate in our Peer-to-Peer Support Groups on WhatsApp or Telegram or WhatsApp Community. Participation in these groups is voluntary, and any personal information you share will be processed in accordance with this Privacy Notice.  

We may process the following types of data, as provided by you: 

• Personal identifying details, including your name, postal address, email addresses, phone number, gender, title, profile picture (as displayed on WhatsApp or Telegram) and nationality. 
• Location information such as postcode, country.  
• Employment details including job title, department, rank on board ship, current vessel assignment, and employment history within the company. 
• Education information, which includes academic records, professional qualifications, certificates obtained, and ongoing training records. 
• Emergency contact information (next of kin or designated contact) including name, phone number and email address, used only where necessary to safeguard your wellbeing. 
• Communication data you may give us, which may include sensitive personal data (special category data) relating to physical and mental health. 
• Communications and shared content including messages, images, videos, or other content you choose to post or share within the group. These may include sensitive personal data (special category data) such as information relating to your physical and mental health.

Some or this information may constitute Special Category Data under data protection law and is subject to additional regulation. Such data will only be processed where necessary to personalise support, provide welfare services, or respond to emergencies-either with your explicit consent or to protect your vital interests.  

Your personal data, such as name, profile picture, and any messages or media you share in the group, may be visible to other participants in the WhatsApp Group or Community or Telegram group. Please be mindful of the information you post and respect the privacy of others and refer to our terms of usage given in the group guidelines.  

Why we Process it:

The personal data you provide to us or through these groups will be processed for the purpose of facilitating communication, connection, collaboration and peer support among participants. 

• To provide welfare and emergency assistance to protect your vital interests where we reasonably think that there is a risk of serious harm or abuse to you or someone else. 
• To provide statistical evaluation. We will use anonymised data collected to measure and report on the general wellbeing of seafarers to industry. 

As you may expect and depending on your location when you provide us with your personal information, we may need to transfer it from one global location to another which is necessary to provide the services and support that you have requested from us. 

Third Party Platforms:

When you interact with us via a WhatsApp Group or Community or Telegram group, you will be subject to the rules of usage and privacy notice of those platforms. If you transmit or provide personal data in the WhatsApp Group or Community or Telegram group, you should review their respective privacy notice to understand how they process your data.  

Please remember that anything that you ‘post’ (for example, screenshots, photographs, etc) on WhatsApp or Telegram is essentially publicly available within the group and as such, we are not responsible for, or have control over, how others in the group use this information.  

How we process the data we receive through these platforms is governed to an extent by this Privacy Notice, but only insofar as we process it for our own organisational purposes. If third parties access your personal data because of your use of these platforms, the Society will not bear the responsibility for their processing of your personal data. 

We make use of third-party software to facilitate Wellness e-learning. 

What Data we might Process:

• Personal identifying details, including your name, , email addresses, phone number, gender, title and nationality. 
• Location information such as postcode, country. 
• Employment details including job title, department, rank on board ship, current vessel assignment. 
• Anonymised Survey data; answers to the survey questions. 
• If online, information about any devices you may have used to access our sites, including IP address, geographical location, browser type and mobile device identifiers. 

Some or all of this may be Special Category Data, such as any information you may communicate to us about your physical or mental health, which is subject to additional regulation, which we process in order to personalise support or facilitate emergency assistance.

Why we Process it:

• To provide you with our training services, to deliver our Mobile App training to you, including course enrolment, progress tracking and certificate issuance.
• To personalise your learning experience by content and learning paths. 
• To provide customer support and monitor technical performance.
• To communicate updates, and information on our support services.
• To analyse usage data to develop, improve and enhance our courses. 
• To provide statistical evaluation. We will use anonymised data collected to measure and report on the general wellbeing of seafarers to industry.

As you may expect, and depending on your location when you provide us with your personal information, we may need to transfer it from one global location to another which is necessary for the service provision that you have requested from us.

Third Party Platforms:

We do not sell your information. We may share your details with the Service providers who assist in operating the Mobile App ‘My WAS’, to enable them to monitor the performance of the app and provide updates to software. 

When you register with My Was, we encourage you to review their Privacy Notice & Policy to understand how they may collect, use, and disclose your personal information. Any data shared between third party and the Society will always be processed in line with Data Protection law and, where relevant, we will ensure that the appropriate contractual clauses are in place to protect your data.

We make use of third-party software to facilitate our Wellness e-learning. 

What Data we might Process:

• Personal identifying details, including your name, , email addresses, phone number, gender, title and nationality. 
• Location information such as postcode, country. 
• Employment details including job title, department, rank on board ship, current vessel assignment. 
• Anonymised Survey data; answers to the survey questions. 
• If online, information about any devices you may have used to access our sites, including IP address, geographical location, browser type and mobile device identifiers. 

Some or all of this may be Special Category Data, such as any information you may communicate to us about your physical or mental health, which is subject to additional regulation, which we process in order to personalise support or facilitate emergency assistance.

Why we Process it:

• To provide you with our training services, to deliver our online training to you, including course enrolment, progress tracking and certificate issuance.
• To personalise your learning experience by content and learning paths. 
• To provide customer support.
• To communicate updates, and information on our support services.
• To analyse usage data to develop, improve and enhance our courses. 
• To provide statistical evaluation. We will use anonymised data collected to measure and report on the general wellbeing of seafarers to industry.

As you may expect, and depending on your location when you provide us with your personal information, we may need to transfer it from one global location to another which is necessary for the service provision that you have requested from us.

Third Party Platforms:

We do not sell your information. We may share your details with the Service providers who assist in operating the Web platform, in order to monitor the performance of the platform. 

When you register on the Wellness e-learning platform, we encourage you to review any third-party Privacy Notices & Policy to understand how they may collect, use, and disclose your personal information. Any data shared between third party and the Society will always be processed in line with Data Protection law and, where relevant, we will ensure that the appropriate contractual clauses are in place to protect your data.

You may participate in one or more of our facilitated training or coaching, these are delivered by us directly in person via one of our facilitated training programmes.

If you are participating in our Wellness e-learning training online via our web platform or by using the ‘My WAS’ Mobile App please refer to relevant Privacy Notice section covering this. 

What Data we might Process:

• Personal identifying details, including your name, , email addresses, phone number, gender, title and nationality. 
• Location information such as postcode, country. 
• Employment details including job title, department, rank on board ship, current vessel assignment. 
• Anonymised Survey data; answers to the survey questions. 
• If online, information about any devices you may have used to access our sites, including IP address, geographical location, browser type and mobile device identifiers. 

Some or all of this may be Special Category Data, such as any information you may communicate to us about your physical or mental health, which is subject to additional regulation, which we process in order to personalise support or facilitate emergency assistance.

Why we Process it:

• To provide you with our training services, to deliver our facilitated training to you, including course enrolment, progress tracking and certificate issuance.
• To personalise your learning experience by content and learning paths.
• To communicate updates, and information on our support services.
• To analyse usage data to develop, improve and enhance our courses. 
• To provide statistical evaluation. We will use anonymised data collected to measure and report on the general wellbeing of seafarers to industry.

As you may expect, and depending on your location when you provide us with your personal information, we may need to transfer it from one global location to another which is necessary for the service provision that you have requested from us.

Third Party Platforms:

We do not sell your information. During our Wellness training you may be asked to participate in a survey on the third-party platform SurveyMonkey and we encourage you to review their Privacy Policy to understand how they may collect, use, and disclose your personal information.

Please note that for the Wellness e-learning training we use a third-party developers and platforms. If you are participating in our Wellness e-learning training online via our web platform or by using the ‘My WAS’ Mobile App, please refer to relevant Privacy Notice section covering this. 

Please note that this covers applicants for employment or volunteer posts only. If you are subsequently engaged under a contract of employment or a volunteer agreement, you will be provided with a separate Privacy Notice specific to your circumstances.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, gender, title and nationality.
• Location information such as postcode, country.
• Education information, which includes qualifications, professional qualifications, certificates obtained.
• Employment history details including job title, skills and experience relevant to the delivery of its services.
• Information about how much you may be paid and any expenses you may incur relevant to the delivery of services.
• Information relevant to protecting your health and safety (including information about your health or any medical conditions) whilst you deliver the services.
• Information about any criminal records or pending court cases that may impact the delivery of services.
• Information about how you deliver the services and any training you receive.

Why do we Process it:

• To process your application.
• To determine your eligibility for the role for which you have applied.
• To conduct background checks as part of your application.
• To communicate with you about future job opportunities.
• To comply with the law and our obligations.
• To communicate with you and with SS employees and third parties.
• To comply with our financial and regulatory obligations.

If you are not offered employment or if you are not engaged as a volunteer, we will usually only retain your personal data for a restricted period of time before disposing of it. We do not retain information about individual applicants for longer than 12 months where the application has not been successful.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, date and place of birth, nationality, gender and title, passport details/photo ID, discharge book and proof of address.
• Location information such as postcode, country of origin. 
• Marital status and family details, details of dependents such as name, age, living at home, relationship to applicant and if at school/university.
• Information relating to bank details for grant payment.
• Employment history and education history, referee details.
• Financial – income and expenditure and debts/loan obligations, proof of costs/bills such as medical bills, treatment bills, course outline and fees.

Some or all of this may be Special Category Data, which is subject to additional regulation, which we process for the purpose of administering your application.

Why we Process it:

• To communicate with you and deal with your enquiry.
• For the administration of the grant.
• To maintain our own accounts and records.
• To provide statistical evaluation. We will use anonymised data collected to measure and report on the general wellbeing of seafarers to industry.

As you may expect, and depending on your location when you provide us with your personal information, we may need to transfer it from one global location to another which is necessary for the service provision that you have requested from us.

Please note that Seafarer House is a shared work location, and your personal data may need to be shared with the other organisation which is based in the offices for the purposes of security and health and safety.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, title, vehicle registration,
• Location information such as postcode, 
• Employment and education details,
• CCTV footage captured of you when you visit Seafarers House and Grounds.

Why we Process it:

When you visit Seafarer House as a guest, visitor, or contractor (whether attending for work or a visit), we may need to process your personal data in order to be able to:

• Maintain security at Seafarer House.
• Grant you access to the site.
• Meet our obligations to safeguard your health and safety whilst on site.
• Maintain security at Seafarers House.

CCTV cameras operate at Seafarers House, and grounds. We do this to monitor the safety and security of our site, detect crime and anti-social behaviour. This means that when you visit Seafarers House we may capture live images of you. The images are monitored and may be reviewed after being recorded. These images may be shared with the police or other law enforcement agencies where we are required to do so or to protect you and other visitors to our site.

Please note that this will not cover contracts for services when you are carrying out work on our behalf or in our name as a charitable organisation – this will be covered by a separate written notice which may be contained within your contract with us.

What Data we might Process:

• Personal identifying details, including your name, postal address, email addresses, phone number, title, vehicle registration.
• Location information such as postcode. 
• Information relating to bank or credit card details.

Why we Process it:

• To enable us to carry out or obligations arising from any contracts entered into between you and us for goods or services.
• To maintain our own accounts and records.
• To grant you access to our premises for health and safety and security reasons.

Under UK Data Protection Legislation as a Data Subject, you have a number of rights. We have listed an overview of your rights below:

The right to be informed.

You have the right to be informed about the collection and use of your personal information. We aim to satisfy this right through the provision of this Privacy Notice. If you have any questions about how we collect and use your personal information, please write to Sailors’ Society, Seafarer House, 74 St. Annes Road, Southampton. SO19 9FF.  or email: [email protected] Marked – FAO Compliance Lead

Access to your personal data.

You have the right to request a copy of the information that we hold about you. You are entitled to be given a description of what information we hold about you; what we use it for and who we might pass it on to. We are required to answer your request within one month of its receipt at the latest, and occasionally may then need to ask for an extension. We may need to carry out additional identity checks before we release your personal data to you. In most circumstances we will not charge a fee when you wish to access your information. If you would like a copy of the personal data we hold about you, please write to the contact details as above or email: [email protected] Marked – FAO Compliance Lead

Accuracy.

We want to make sure that the personal information we process about you is accurate and up to date. You may ask us to correct or remove information that you think is inaccurate and, in most circumstances, we will correct inaccuracies within one month of you informing us. To help us in this, we would ask you please to keep us informed when your details change by writing to us at the address or email address given above.

Deleting personal data, restricting processing activity or objecting to the processing activity.

You may ask us to delete the personal data that we hold about you in part or in full. This is sometimes called an ‘erasure request’ or your ‘right to be forgotten’. There are some circumstances in which we cannot delete all personal data (for example where we have a legal obligation to retain it or because we may need it to defend legal claims), but we will always consider such requests on a case-by-case basis and, where we can comply, in most cases complete the deletion within one month of your request.

In addition, you may ask us to restrict or stop some types of processing activities.

With some or all of your personal data, or you may object to a particular processing activity. For example, if you are a donor, you may wish us to stop sending you appeal letters. You can do this by changing your communication preferences by emailing us, calling us or by writing to us to outline what types of processing you wish us to restrict. Again, please use the address or email address given above.

Ask us to transfer or ‘port’ a copy of your data.

This is your right to obtain and reuse your personal data that you have provided to us for your own purposes across different services. There are rules regarding data portability that may restrict us from complying with any request that we receive under this right. If you have any questions about how we can help you achieve data portability, please contact our Compliance Lead using the address or email address below.

Complain to the Information Commissioner.

We would like an opportunity to resolve any complaints that you may have about data processing by Sailors’ Society, which you may do by contacting our Compliance Lead using the address or email address given. However, you also have the right to complain to the UK Data Protection Regulator (currently the Information Commissioner or ‘ICO’) about how we have used your personal data. The ICO website is the best way of finding out how to do this: www.ico.org.uk

Who has access to it?

Sailors’ Society is a Data Controller registered with the Information Commissioner’s Office (ICO) registration number Z5775919.

Our policy is to limit who has access to your personal data as much as we can and to only use your information for the purpose for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities, or other organisations as a result of giving your details to us.

Our Service providers can be third party Data Processors or other Data Controllers.
We sometimes need to share the personal information we process with the individual themselves and also with third-party organisations who will process it on our behalf – ‘Data Processors’ (for example our website administrator, printing supplier, data hosting providers). In this case we only provide the personal data to our Data Processors necessary to carry out this function. We select these organisations carefully and put in place data processing agreements which require that they comply with data protection legislation. And where this is necessary, we are required to comply with all aspects of the UK General Data Protection Regulations (UK GDPR).

Sometimes we may share your data with organisations or individuals who may be acting as ‘Data Controllers’ in their own right. In this case, you may have provided your personal data to us or to the other Data Controller, and any data that is shared between us is limited to that which is necessary to carry out the respective functions of the associated Data Controllers. (for example, your cadet college, your fundraising page administrators).

We may also share your information with our bank to process a payment; our professional advisors (such as our legal advisors), regulators or authorities where it is necessary to; and our IT service providers and data storage providers.

Where required, we will process personal information to comply with our legal obligations. In this respect we may share your personal data to comply with Subject Access Requests; tax legislation; for the prevention and detection of crime; and to assist the police and other competent authorities with investigations including criminal and safeguarding investigations.

Sharing or transferring your data across borders or internationally

As you may expect, and depending on your location when you provide us with your personal information, we may need to transfer it from one global location to another. This may occur in any of the processing examples we have given in this Notice above. We may need to transfer your personal information internationally for a number of different reasons. For example, when you contact us to access our services, you may speak to one of our representatives in another global location, and even that first point of contact may mean you are providing your personal information across borders. Other examples may be because the data processor, service providers or data controllers that we use are based overseas or use data storage facilities (such as digital servers) overseas or it is necessary for the service provision that you have requested from us.

Where we share your data with our data processors or with other organisations that may involve an international transfer of your personal data, we will restrict the information that we transfer only to that which is necessary to the purpose, we will regularly review the adequacy of the legislation and security of the territories in which our service providers and partners are operating, we will put appropriate safeguards in place where necessary or we may decide not to transfer. Please note that we may have a limited control over international transfer of data where we keep an open channel of communication with you over a period of time and where you remain mobile, particularly if you are a seafarer accessing our services whilst you work. We will do our best to keep you informed where we know that an international transfer is likely to happen or is necessary for the service provision that you have requested from us.

We hold your personal data only for as long as is necessary. We will not retain your personal information if it is no longer required. In some cases, we may legally be required to retain your personal information, for example for finance, or audit purposes.

If you need to know how long we keep your data for, please contact us and we will provide you with this information separately. You can contact us by writing to the contact details as below or email: [email protected] Marked FAO – Compliance Lead  

We use computer safeguards such as firewalls and data encryption, and we have access controls to our building to keep your personal data safe.

Electronic data and databases are stored on secure computer systems, and we control who has access to information using both physical and electronic means, we only authorise access to employees who need it to carry out their job responsibilities. Our staff and volunteers receive data protection training and guidance that they are required to follow when handling personal information.

Where necessary we issue guidance and rules to our Data Processors and other controllers with whom we share your data in order to govern their processing of your data in compliance with our security requirements.

We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We may occasionally ask for proof of identity before we share your personal data with you, and we may refuse to share your data with third parties who approach us on your behalf until we have satisfied ourselves that there is a lawful purpose for doing so (including having your consent to do so).

Please note that whilst we take appropriate technical and organisational measures to safeguard your personal data, we cannot guarantee the security of any personal data that you transfer over the internet to us using your own equipment and software.

In accordance with the UK Data Use and Access Act 2025 (DUA Act), UK GDPR and Data Protection Act 2018, as a controller of personal data we maintain and operate a complaints process that individuals can use to raise data protection complaints/concerns directly with us. 

If you have a data protection complaint/concern about the way in which we are handling your data, please contact our Compliance Lead (contact details below) so that we can take appropriate steps to respond, make appropriate enquiries, and inform you of the outcome of your complaint. 

Our Compliance Lead can be contacted by:

• Emailing  [email protected] Marked – FAO Compliance Lead.
• Alternatively, you can call us on 023 8051 5950 and ask to speak to the Compliance Lead.  

You may also make a complaint to the Information Commissioner, who is an independent regulator, (who will normally ask you to raise the complaint with us first). The Independent Commissioner’s Office (ICO) can be contacted either by: 

• Website:  ico.org.uk/make-a-complaint/  

• Phone: 0303 123 1113 or  

• Writing to them at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, UK.  

As the services we provide change, we keep our Privacy Notice under regular review, and we will place any updates on the Company website. This Privacy Notice was last updated in April 2026.