This page contains our Privacy and Data Policy.
GLADE Privacy and Data Policy
Introduction and general terms
GLADE promises to take great care with your personal data, and we commit to protecting any personal information we obtain about you, whether you are a financial supporter, shopper, volunteer or campaigner.
This Privacy & Data Policy sets out how and why we obtain, use and protect personal information if you interact with us in one of these roles.
1. Who we are
The GLADE Centre is a registered charity in England and Wales (charity number 1104504). We are also a company limited by guarantee (company number 5148165).
THE GLADE CENTRE’s registered address is THE GLADE CENTRE, Resources for Learning, Parkway, Bridgwater, Somerset TA6 4RL.
2. Why we hold and process supporters’ personal data
We hold and process personal data for a number of reasons:
- For our own internal records
- To improve the products and services we provide
- To contact you in response to a specific enquiry
- To customise the website for you
- To send you promotional emails about products, services, offers and other things we think might be relevant to you.
- To send you promotional mailings or to call you about products, services, offers and other things we think might be relevant to you.
- To contact you via email, telephone or mail for market research reasons.
These reasons are underpinned by a “legal basis” under GDPR. We outline in the next section what these are for our main activities.
3. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for organisations to collect and process your personal data: When collecting your personal data, we will always make clear to you which data is necessary for a particular purpose.
THE GLADE CENTRE relies on the following legal bases in our marketing activities:
Wherever possible, we will ask for your consent to send you marketing information. We will do this through a clear statement of what you will receive and allow you to select only those channels that you wish to hear from us by.
In specific situations, we process your data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests. THE GLADE CENTRE’s use of legitimate interest includes the following:
Sending direct marketing information by post, to keep our supporters updated on THE GLADE CENTRE’s projects and activities. We will only do this where we have reason to believe that this information will be of interest. We make it easy for you to opt out, see ‘6. How to control what we send you or request we update your personal information’
If you have been a customer of our services the we will email you to tell you about other services which we feel would be of interest. All such emails will include a simple opt out mechanism.
We analyse your previous support of THE GLADE CENTRE in order to offer relevant ways of supporting THE GLADE CENTRE in the future.
To help identify businesses who may wish to support THE GLADE CENTRE, we send emails to individuals where relevant to their job, for instance people working in Corporate Social Responsibility.
For activities other than marketing, we may rely on different legal bases:
If the law requires us to, we may need to collect and process your data.
We may ask for your consent for data – for instance where you engage with our service provision in the UK and can give you a clear choice about what information you need to provide.
In many situations we need data in order to carry out a task, such as enrol you on a program, run an event, administer our organisation, plan or run campaigning activities etc.
In limited situations we may use data in the public interest. It is likely to be in the public interest to collect data to prevent crime or dishonesty, ensure that we are fair in our practices by carrying out equality and diversity monitoring, or safeguard the wellbeing of people with whom we work.
4. When and why we will send you personalised marketing communications
THE GLADE CENTRE will only contact you for marketing purposes – for example keep you up to date on our work, or let you know of ways in which you can support that work – where we have your consent or we are otherwise allowed to do so (see ‘5. Other circumstances in which you may receive marketing information from THE GLADE CENTRE’).
We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information (post, email, SMS and phone). We will not send you marketing material if you tell us that you do not wish to receive it. There are a variety of ways you can do this, see ’12. How to control what we send you or request we update your personal information’.
Where you give us your consent to send marketing information, we will wherever possible let you know how long this consent will last. Unless we have grounds for believing that a longer period is reasonable and have explained this to you, we will understand your consent to last for 24 months. After this time, in order for us to continue to update you, we will need your refreshed consent. You can update or withdraw your consent at any time, for individual channels of communication, or for all channels. See ’12. How to control what we send you or request we update your personal information’ for details on how to do this.
Consent lasting more than 24 months
We will generally treat any marketing consent you give us as lasting for 24 months, but will apply the following exceptions (but only where we inform you of this at the time you give consent):
- Where you have committed to giving us a regular donation (usually monthly). In this situation, and unless you withdraw your consent, we will treat consent as enduring until you cancel your donation, at which point your consent will expire 24 months after the last donation. This is to enable us to keep you up to date with the impact of your gifts, and to ask whether alternative means of support would be of interest.
- Where you have notified us that you will be leaving a legacy to THE GLADE CENTRE. This is a lifetime commitment and although we will provide you with regular opportunities to shape and control your communication from THE GLADE CENTRE we will treat your consent as ongoing.
5. Other circumstances in which you may receive marketing information from THE GLADE CENTRE
We may send you marketing communications by direct mail where you are a regular supporter and we have evidence that you do not object to receiving marketing material through the post.
We will not use “legitimate interest” if you have opted out of direct mail whether direct to THE GLADE CENTRE or by registering with the Mailing Preference Service (MPS) or the Fundraising Preference Service (FPS).
“Soft opt in”
This allows organisations to send marketing communications by email and SMS to individuals who have previously purchased similar goods and services, provided they were given the opportunity to opt out at the time of purchase. In THE GLADE CENTRE’s case, this allows us to send marketing emails and SMS to previous customers of THE GLADE CENTRE services. We apply a 24-month time limit, and only communicate on this basis where you have used our services within this period. We will not use the “soft opt in” option if you have opted out of receiving email and/or SMS, whether direct to THE GLADE CENTRE or via the Fundraising Preference Service.
6. How and when we collect information about you
THE GLADE CENTRE may collect your personal data in the following circumstances:
a. When you give it to us DIRECTLY
You may give us your personal data directly when you make a donation, sign up for one of our events or workshops, volunteer with us, purchase services from us, or when you communicate with us.
b. When you give it to us INDIRECTLY
You may give us your information indirectly when you contribute to THE GLADE CENTRE via fundraising sites like JustGiving or Virgin Money Giving, or participate in a campaigning action with a partner. These independent third parties will pass your data to THE GLADE CENTRE where you have indicated that you wish to support THE GLADE CENTRE and have given your consent or it is a necessary part of completing a contract with you.
Sometimes your personal data is collected by an organisation working on our behalf (for example a professional fundraising agency) but as they are acting on our behalf we are the “data controller” and responsible for the security and proper processing of that data.
c. When you access THE GLADE CENTRE’s Social Media
We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
d. When the information is publicly available
We might also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like THE GLADE CENTRE. In this scenario, THE GLADE CENTRE may seek to find out more about these individuals, their interests and motivations for giving through publicly available information. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies House. THE GLADE CENTRE will not retain publicly available data relating to major donors without their consent, which will be sought at the earliest practical opportunity. Where we decide not to make contact, we will delete all personal data obtained, other than basic contact details, to which we will apply a suppression flag to ensure we do not make contact in the future.
We may also gather information if your activities relate to our work – for instance, if you are a public figure such as a Member of Parliament or you represent an organisation which we work with or which is related to one of our campaigns we may gather information about you in order to inform our campaigning and make decisions – for instance, whether we engage with you to seek your support for our work, ask your constituents to write to you, or choose to work you in another way.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), THE GLADE CENTRE may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device).
7. What information might THE GLADE CENTRE collect about you?
We only collect personal data relevant to the type of transactions or interaction you have with THE GLADE CENTRE.
Whatever your interaction with us this information will be minimal and linked to the purpose for which we need it.
For example, when you contact THE GLADE CENTRE to make a donation, purchase a service, or sign up to any of THE GLADE CENTRE’s activities or online content (such as newsletters, competitions, or message boards) or you telephone, email, write to or text THE GLADE CENTRE, or engage with THE GLADE CENTRE via social media channels, we may receive and retain personal information.
In these cases we are likely to process details such as your name, email address, postal address, telephone or mobile number, bank account details to process donations and whether or not you are a tax payer so that we can claim Gift Aid.
If you participate in an event we may (with your permission) take your photograph or video, or interview you.
If you participate in market research, we may ask you questions regarding your experience with us, or other survey questions relating to your experience.
If you are a campaigner or work with our campaigns team, we may collect information such as correspondence with you regarding campaigning, details of your background and activities with us or relating to the issue, the events you attend, or how we would like to work with you.
Where we gather information about you which is publicly available – for instance as a major donor or your views on our campaigning activity – this may include your name, contact details, views and positions you have expressed, and details regarding your circumstances- for instance which political roles you hold or what your background is.
Sensitive Personal Data
We only collect “sensitive personal data” about our supporters, e.g. health status, where there is a clear and specific reason for doing so, such as participation in a marathon or volunteering with us.
We collect this data where we need it to ensure that we provide appropriate facilities or support to enable you to participate in the event or carry out your role. Clear notices will be provided on application forms so that it is clear what information we need and why we need it. In certain circumstances, such as when we recruit volunteers, we need to obtain information about criminal convictions (where these are unspent) in order to check that it is appropriate for you to undertake the role.
Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this we will do it carefully and in accordance with applicable laws.
Should you support THE GLADE CENTRE in a substantial way, we may provide an account manager to help you tailor your relationship to suit your interests. If this is the case we may collect sensitive personal data where relevant to our relationship, such as your political or religious views. Should you disclose information to us about your health or your family, this may also be recorded, so that we can communicate with you in a considerate and appropriate manner.
All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
8. How will THE GLADE CENTRE use your personal data?
THE GLADE CENTRE will use your personal information for the following purposes:
a. For administrative reasons, including:
- “service administration”, which means that THE GLADE CENTRE may contact you for reasons related to administering any donations you have made, your tax status with regard to Gift Aid if claimed, the completion of commercial or other transactions you have entered into with THE GLADE CENTRE or the activity or online content you have signed up for;
- to confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used. for example if you donate via text you will receive a “bounce back” text message;
- in relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide;
- for internal record keeping so as to keep a record of your relationship with us;
- to provide logistical and fundraising information to people who are taking part in a fundraising event in aid of THE GLADE CENTRE, such as the London Marathon;
- to communicate with THE GLADE CENTRE volunteers – to support you in your designated role or administer that role and our organisation;
- to keep your data up to date – for instance we use the Royal Mail’s data on postal address changes to ensure that we can maintain contact with you where we believe you are happy to be contacted by post, we also use services which notify us of the recently deceased to avoid any distress that continued communications would cause;
- to implement any instructions you give us to with regard to withdrawing consent to send marketing information or informing us through the Fundraising Preference Service that you do not wish to receive any marketing information;
- to use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries;
- to protect our staff and those with whom we work, or to prevent crime and dishonesty.
b. For marketing and fundraising reasons (see ‘5. When and why we will send you personalised marketing communications’).
c. For market research
- to invite you to participate in surveys or research about THE GLADE CENTRE or our work (participation is always voluntary);
- to analyse and improve the activities and content offered by THE GLADE CENTRE website to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
9. Will THE GLADE CENTRE share your personal information with anyone else?
We will only use your information within THE GLADE CENTRE for the purposes for which it was obtained. THE GLADE CENTRE will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
THE GLADE CENTRE’s suppliers
We may need to share your information with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These “data processors” will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
Where legally required
We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies, statutory bodies, or law enforcement agencies for tax purposes, where it is in the public interest, or the prevention and detection of crime, subject to appropriate protection in law).
THE GLADE CENTRE may transfer your personal data outside the EEA. If it does so, this may occur under the protections of the European Commission’s standard contractual clauses, but will otherwise only take place where appropriate standards and safeguards are in place.
10. How long will THE GLADE CENTRE keep your personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules.
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.
Legacy income is vital to the running of the charity. We may keep data you provide to us indefinitely, to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyse the source of legacy income we receive.
Where you contribute material to us, e.g. user generated content or in response to a particular campaign, we will 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.
11. How to control what we send you or request we update your personal information?
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 contact us:
- email us at email@example.com
- write to us at: The GLADE Centre, Resources for Learning, Parkway, Bridgwater, Somerset TA6 4RL
- call us on: 01278 439 347
Additionally you can opt out of email and SMS separately:
- Email – You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from THE GLADE CENTRE.
How long will it take for these changes to be effective?
We endeavour to meet the following service levels where supporters request we do not send them marketing information:
- Email – 24 hours from receipt of email
- Telephone – within 7 working days
- Mail – 28 days from receipt of ‘do not mail’ request. This period is longer than for other channels due to the production times for mailing campaigns, and in most cases we would expect the change to be effective much more quickly.
12. How THE GLADE CENTRE keeps your data safe
We ensure that there are appropriate technical controls in place to protect your personal details. For example our online forms are always encrypted and our network is protected and routinely monitored.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.
We use external companies to collect or process personal data on our behalf.
These organisations – referred to as “Data Processors” also have legal liability for the way in which your data is used, providing you with additional protection.
14. Your rights over your personal data
You have a variety of rights in respect of your data, including the rights to see, update, restrict, object to the use of or withdraw use of your data. In particular, depending upon why we hold your data, you may have the right to request:
- Access to the personal data we hold about you, including how we first obtained your details, free of charge in most cases (this is known as a ‘Subject Access Request’).
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we delete your personal data from our systems (this is known as the “Right to be Forgotten”).
- That we no longer process your data automatically to decide whether particular marketing activities are likely to be of interest, or suggest an appropriate donation level based on your previous donation history. This is known as profiling, and helps us to ensure that our marketing is relevant and appropriate.
You can contact us to request to exercise these rights at any time, see ’11. How to control what we send you or request we update your personal information’ for details of how to get in touch.
Opting out of Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request.
Where we are sending you direct marketing on the basis of our legitimate interest, you can also ask us to stop. In the case of postal marketing sent on this basis, we will always comply with your request to opt out. Similarly, where we send email marketing on a soft opt in basis (see ‘6. How and when we collect information about you’), we will also comply with all requests to opt out.
Right to be Forgotten
Upon request we will delete your personal data from our systems, to the extent that we are permitted to by law or regulatory guidelines. For instance under HMRC rules we are required to retain financial data for 7 years for audit purposes, and so will not be able to delete donation details until this time period has elapsed.
Opting out of profiling
Upon request we will cease using your personal data to decide whether you would be interested in particular updates and other marketing. Such requests may lead to you not hearing from us in future.
Subject Access Requests
You have the right to request a copy of the personal information we hold about you. We will provide this as soon as possible, and within a month unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
15. How to find out more, or make a complaint about THE GLADE CENTRE’s approach to data protection
If you would like more information, to update your details or have any questions about this policy, please contact our supporter relations team by email at firstname.lastname@example.org or write to us at: THE GLADE CENTRE, Resources for Learning, Parkway, Bridgwater, Somerset TA6 4RL, or call us on 01278 439 347.
To make a formal complaint about THE GLADE CENTRE’s approach to data protection or raise privacy concerns directly with our data protection team, please contact:
The Data Protection Officer
THE GLADE CENTRE,
Resources for Learning,
Somerset TA6 4RL
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites).
18. Privacy FAQs
Q. Does THE GLADE CENTRE obtain data from other organisations?
A. THE GLADE CENTRE receives data from a limited number of Third Parties, including:
Publicly available sources such as Twitter, Facebook, LinkedIn, parliamentary records, or statements which you make publicly, depending upon our relationship with you – in particular we are likely to collect these in connection with our campaigning activities
Cookies and how we use them
What is a cookie?
A cookie is a small file placed on your computer’s hard drive. It enables our website to identify your computer as you view different pages on our website.
Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
- Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.
- Identify whether you are signed in to our website. A cookie allows us to check whether you are signed in to the site.
- Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.
- Store information about your preferences. The website can then present you with information you will find more relevant and interesting.
- To recognise when you return to our website. We may show your relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.