Privacy Policy
We are committed to protecting your personal data and respecting your privacy.
This privacy policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and tell you about your privacy rights and how the law protects you.
It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy policy supplements the other notices and is not intended to override them.
We may update this privacy policy from time to time so please check back periodically. We will notify you of significant changes by placing a notice on our website.
Data Controller
This privacy policy is issued on behalf of the Cynthia Spencer Hospice Charity (registered charity in England & Wales 1174402, Company Number 10934348) and Cynthia Spencer Hospice Ventures Limited (company limited by guarantee 04089969) so when we mention "we", "us" or "our" in this privacy policy, we are referring to the relevant entity responsible for processing your personal data. We will let you know which entity will be the controller for your data when we collect your personal data, including where you purchase a product or service from us. Cynthia Spencer Hospice Charity is the data controller and responsible for this website.
Information we may collect from you
How do we collect personal data?
We may collect personal data about you when you interact with us (e.g. by phone or via our website or social media accounts), register with us, enquire about our activities, make a donation, participate in an event, buy from our shops, apply to work or volunteer with us, visit our website or otherwise provide us with your personal data.
You may give us information about you by filling in forms on our website http://www.cynthiaspencer.org.uk/ (our website) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website, subscribe to our service, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information and photograph.
What personal data do we collect?
Personal data means any information about an individual from which that person can be identified. Personal data does not include data where your identity has been removed or which not associated with or linked to your personal data (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender and photograph.
Contact Data includes address (home, postal or other physical address), email address and telephone numbers.
Financial Data includes bank account and payment card details, and whether you are a UK tax payer (so that we can claim Gift Aid).
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes, in relation to your website account, your username and password, personal description, purchases or orders made by you, your interests, preferences, feedback and survey responses.
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.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect “sensitive personal data” (now known as “special category personal data”) about our supporters unless there is a legitimate reason for this (e.g. if you participate in an event for which we may need to provide support). If we need to collect this data from you we will inform you at the point of collection including the purpose and legal basis of our processing of such data.
We also collect information about how our website is used and track which pages users visit when they follow links in Cynthia Spencer Hospice Charity emails. We use this information to monitor and improve our website, services and activities e.g. to personalise website presentation or to see which services or events are of most interest. Where possible we use anonymous or aggregated data that does not identify individuals and is not considered personal data in law. 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 privacy policy.
Please note that 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 (for example, to provide you with products or services that you request). In this case, we may have to cancel a product or service you have requested but we will notify you if this is the case at the time.
Information we receive from other sources. We may also receive information about you from third parties that we work with, for example JustGiving or eBay, where you have consented to them sending us your personal data. We will handle such personal data in accordance with this privacy policy.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy at https://www.cynthiaspencer.org.uk/cookie-policy.
Uses made of your personal data
We use the personal data collected from users for a number of purposes, as follows:
Registration – we will use your Identity and Contact Data to register you as a supporter of Cynthia Spencer Hospice Charity. This is necessary for our legitimate interest in the operation of our charity, maintaining records of our supporters and for the performance of our contracts with you;
Relationship management – we will use your Identity, Contact, Profile and Marketing and Communications Data for the purpose of managing our relationship with you including inviting you to participate in a survey, to provide you with further information about our work, services, activities or products. This is necessary for the performance of our contracts with you and for our legitimate interest in keeping our records updated to study how our supporters use our products and services;
Donations and payments - we will use your Identity, Contact and Financial Data to process donations or payments we have received from you and to ensure that you are thanked appropriately. This is necessary for the performance of our contracts with you and for our legitimate interest in the operation of our charity and receiving charitable donations and payments. Please note that when you use our secure online donation or payment pages you will be directed to a specialist supplier company, who will receive your Contact and Financial Data to process the transaction and we will not retain your Financial Data in such instances;
Provision of services/products/information – we will use your Identity, Contact, Financial and Transaction Data to provide you with services, products or information you have requested. This is necessary for the performance of our contracts with you;
Photographs – where you have provide us with photographs of yourself for use by us for the promotion of our charity and events, including sharing on social media, we will store an electronic copy of those photographs but they will not be linked to your supporter record;
Contacting us - If you make an enquiry or provide us with feedback, in order to reply to your message we will respond to you using the Identity and Contact Data that you provide to us. This information will be used to answer your enquiry as completely and thoroughly as possible and will not be used for any other purpose unless you have requested additional services from us such as to join our marketing list;
Advertising, marketing and public relations - we may use your Identity, Contact, Technical, Usage, and Marketing and Communications and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you and in doing so we will only send you information about our work, services, activities, events or products that are deemed relevant to you. This is necessary for our legitimate interest in furthering our charitable aims including for fundraising activities, studying how our supporters use our products and services and to inform our marketing strategy;
Orders – We will use your Identity, Contact, Financial, and Transaction Data to fulfill sales made online or through our shops and to manage payments, fees and/or charges in connection with such sales. This is necessary for the performance of a contract with you;
Surveys – We will use your Identity and Contact Data to invite voluntary participation in research or surveys that we conduct from time to time. If you choose to complete a survey that we use for research purposes we will retain the information you provide in response to that survey. This is necessary for our legitimate interest in studying how our supporters use our products/services and to obtain feedback about us, our charitable work and our products/services;
Competitions and Promotions – We will use your Identity and Contact Data to invite you to partake in a prize draw, completion or competitions and to enable your participation in the same. This is necessary for the performance of a contract with you, and for our legitimate interest in furthering our charitable aims and fundraising;
Online Accounts - to register, administer and personalise online accounts we will need your Identity and Contact Data so that we can identify you as an account holder. You will also be asked to create Profile Data, namely selecting a username and password and setting your preferences. Following creation your account will also hold details of previous purchase or orders made by you. This is necessary for the performance of our contracts with you and for our legitimate interest in maintaining records of our supporters;
Events - to register and administer your participation in events for which you have registered, and to contact you in relation to those events. This is necessary for the performance of our contracts with you and for our legitimate interest in furthering our charitable aims and fundraising activities;
Data Analytics – We use Identity, Contact, Technical, Usage and Marketing and Communications Data to analyse and improve our work, services, activities, products or information (including our website) or for our internal records. This is necessary for our legitimate interest in the running of our charity, to develop and improve our work, services, activities, products and information, to further our charitable aims and to inform our marketing strategy;
Website Administration – we use Technical and Usage Data to monitor website use, identify locations, block disruptive use, record website traffic or personalise the way information is presented to you. This is necessary for our legitimate interest in protecting our website and our charity, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, the provision of administration and IT services, network security and fraud prevention;
Fault Reporting – if you contact us to report a fault with our website, we will use the information provided for the purposes of rectifying that fault in accordance with our legitimate interests;
Recruitment – we will process personal data including your Identity and Contact Data to process and evaluate the merits of your application for a job or volunteer role with us in accordance with our legitimate interests.
We may also use personal data which you provide to us, where the law allows us to do so, as follows:
To deal with and/or respond to any enquiry or request made by you prior to entering into any contract or agreement with us or as a result of such contract or agreement;
Where we need to perform the contract we are about to enter into or have entered into with you;
Where we need to comply with a legal or regulatory obligation, including the prevention of crime and credit risk reduction; or
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.
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 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 data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Care and support services
If you, a relative, or a friend are cared for or supported by Cynthia Spencer Hospice, the personal data (including sensitive / special category personal data) you provide to the hospice will be handled by the NHS in accordance its own privacy policy.
Your updates and preferences
It is important that we keep your personal data up to date. You can contact us at any time if your circumstances change.
You can stop receiving emails or texts by clicking on the “unsubscribe” link in our marketing emails, sending us an “opt out” email or by otherwise contacting us at any time. We will not use your details for marketing purposes if you unsubscribe, however, if you agree we will retain your details on our supporters lists to help ensure that we do not contact you.
Please note that where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, experience or other transactions.
You can also update your contact preferences by calling us on 01604 973340 or contacting the Administration Team on fundraising@cynthiaspencer.co.uk.
Disclosure of your information to third parties
Your personal data will only be disclosed to relevant Cynthia Spencer Hospice Charity and Cynthia Spencer Hospice Ventures Ltd employees and volunteers that have a need for such access for the purpose for which it was collected. We will never sell your personal data to any third party. We will not share your details with other charities for marketing purposes.
However, we may need to share your personal data with third parties in the following circumstances:
Where we have your express permission to do so; or
Where we need to share your information with a small number of trusted partners (service providers, agents and affiliated companies) for the purposes outlined above (e.g. a supplier that produces promotional material or delivers goods for us or a supplier that processes payments securely, or a supplier that identifies and removes any data that is incorrect, incomplete or duplicated); or
Where you have provided us with personal data in order to participate in Your Hospice Lottery, in which case relevant personal data will need to be shared with Your Hospice Lottery in order to enable your participation; or
Where it is necessary for the performance of a contract that we have with you, including where we need to take steps to enforce any contracts which may be entered into between us; or
Where we are under a legal duty to do so in order to comply with any legal obligation; or
Where it is necessary to protect the rights, property or safety of Cynthia Spencer Hospice Charity, our staff, volunteers and others.
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.
International transfers
We use Microsoft Office 365, which is a multi-tenant cloud service, for our internal office use; this means that internal documents and information which are generated at Cynthia Spencer Hospice Charity and Cynthia Spencer Hospice Ventures Ltd are stored in cloud services which are hosted within the European Economic Area (“EEA”).
Exceptionally, we may use tools or services which process personal data outside the EEA; e.g. Microsoft may provide us with emergency support for Office 365 from outside the EEA in rare circumstances. In these cases we require our suppliers to ensure adequate protection for personal data, by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Security
We are committed to keeping your personal data safe and secure and 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 including the use of a firewall and appropriate security measures in our physical facilities. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our website; any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about supporters who purchase products and services from us (including Contact, Identity, Financial and Transaction Data). In general, we hold all personal data about our supporters, customers and suppliers for seven years from the date of your last transaction with us.
Personal data which is no longer required for our legitimate purposes will be regularly reviewed and, where necessary, deleted. A clear rationale will be supplied, upon request, where personal data is to be kept beyond the seven years referred to above.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your rights
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 personal 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 personal data unlawfully or where we are required to erase your personal data to comply with local law. Please 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 data 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 data 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 data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the personal data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 to perform 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can ask us or third parties to stop sending you marketing messages at any by following the “unsubscribe” (or similar) links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product/service experience or other transactions.
If you wish to exercise any of your above rights, please send a written request to us at the address listed at the end of this privacy policy.
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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
Website links
Our site may, from time to time, contain links to and from the websites, plug-ins and applications of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, plug-ins or applications, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to third parties or access their products or services.
Please also note that third party websites, plug-ins and applications are not investigated, monitored or checked for accuracy or completeness by us and the inclusion of any linked website, plug-in or application on or through this website does not imply approval or endorsement of the linked website by us.
About this privacy policy
We may update this privacy policy from time to time so please check back periodically. We will notify you of significant changes by placing a notice on our website.
Contact
Questions, comments and requests regarding this privacy policy, or requests to exercise your legal rights should be addressed to:
Charity Office, Cynthia Spencer Hospice Charity, Pondwood House, Pondwood Close, Moulton Park, Northampton, NN3 6RT
Telephone: 01604 973340
Email: fundraising@cynthiaspencer.co.uk
Name or title of data privacy manager: Alison Gee
Complaints
You 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 please contact us in the first instance.