At Home-Start UK, we’re committed to protecting and respecting your privacy.

This policy explains when and why we collect personal information about you, how we use it, the conditions under which we may disclose it to others, how we keep it safe and secure and your rights and choices in relation to your information.

Any questions regarding this notice and our privacy practices should be sent by email to gdpr@home-start.org.uk or by writing to Home-Start UK, 4th floor, Arnhem House, 31 Waterloo Way, Leicester LE1 6LP. Alternatively, you can telephone 0116 464 5490.

Who are we?

Home-Start UK is committed to protecting your personal information and to being transparent about what information we hold. Home-Start UK understands its obligations to you to help you understand how and why we process your personal data. We will only do so in accordance with all applicable data protection legislation, including the General Data Protection Regulation. In this notice ‘Home-Start UK’, ‘we’, ‘us’ or ‘our’ means:

• Home-Start UK is a charitable company limited by guarantee. Company no. 5382181.
• Charity no. in England and Wales 1108837 and in Scotland SC039172.
• Registered office: 4th floor, Arnhem House, 31 Waterloo Way, Leicester LE1 6LP.
• Home-Start UK also works with around 180 local Home-Starts across the country.

The personal data we collect from you, how we collect and how we use it

• APPENDIX 1 – Human Resources (employees, trustees and job applicants)
• APPENDIX 2 – Website Visitors (cookies)
• APPENDIX 3 – Supporters (fundraising & communication)
• APPENDIX 4 – @home Intranet

Your Rights

Under UK data protection law, you have certain rights over the personal information that we hold about you. Here is a summary of the rights that are likely to apply to you when we are processing your personal information.

Right of access

You have a right to request access to the personal data that we hold about you.

You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.

If you want to access your information, please contact the address provided below. 

Right to have your inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected. The accuracy of your information is important to us so we’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or if you believe any of the other information we hold is inaccurate or out of date, please contact us via email or post (see below). Alternatively, you can telephone 0116 464 5490.

Right to restrict use

You have a right to ask us to restrict the processing of some or all of your personal information if there is a disagreement about its accuracy, or we’re not lawfully allowed to use it.

Right of erasure

You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions; we will do so as far as we are required to by law. In many cases, we will anonymise that information, rather than delete it.

Right for your personal information to be portable

If we are processing your personal information

(1) based on your consent, or in order to enter into or carry out a contract with you, and

(2) the processing is being done by automated means, for example when you interact with our website, you may ask us to provide it to you or another service provider in a machine-readable format.

Right to object

You have the right to object to processing where we are using your personal information based on legitimate interests or for statistical/research purposes. In these circumstances, we will consider your request against our legitimate reasons for continuing to process your information.

You have an absolute right to object to direct marketing.  If you wish to opt-out of receiving marketing materials from us at any time, please contact the address below.

If you want to exercise any of the above rights, please email us at info@home-start.org.uk or write to Home-Start UK, 4th floor, Arnhem House, 31 Waterloo Way, Leicester LE1 6LP. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however, if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office. 

Keeping your information safe

When you give us personal information, we take steps to ensure that appropriate technical and organisational controls are in place to protect it, such as Firewalls, anti-virus protection and encryption.  Home-Start UK has developed a set of security policies that include device security, authentication requirements, acceptable usage of resources, data storage requirements.  We undertake regular reviews of who has access to information that we hold to ensure that your info is only accessible by appropriately trained staff, volunteers and contractors.

Keeping your information up to date

We take reasonable steps to ensure your information is accurate and up to date. Where possible we use publicly available sources to identify deceased records or whether you have changed address. We really appreciate it if you let us know when your contact details change.

16 or Under

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

Vulnerable circumstances

We are committed to protecting vulnerable supporters, customers and volunteers, and appreciate that additional care may be needed when we use their personal information. In recognition of this, we observe good practise guidelines in our interactions with vulnerable people.

Transferring your information outside of Europe

In some situations, the information which you provide to us may be transferred to countries outside the European Economic Area (“EEA”). By way of example, this may happen if we work with third parties in a country outside of the EEA. You should be aware that these countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this notice. If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.

Changes to this notice

Any changes we may make to this notice in the future will be posted on this website so please check this page occasionally to ensure that you’re happy with any changes. If we make any significant changes we’ll make this clear on this website. We may notify you of changes to this notice by email.

Review of this notice

We keep this notice under regular review. This notice was last updated in June 2022.

How to complain

Please report any complaint to the details set out in ‘How to contact us’ below. We hope we can resolve any query or concern you raise about our use of your information. You also have the right to lodge a complaint with the ICO who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

How to contact us

Please contact us if you have any questions about this Privacy Notice or the information we hold about you at info@home-start.org.uk or by telephone 0116 464 5490. Our Data Protection Officer is provided by RGDP and is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data. RGDP can be contacted at info@rgdp.co.uk 

APPENDICES

1.Human Resources

1.A – Employees

How do we collect information about you?

The information we hold about you is primarily information you provided when applying for your job, supplemented by information generated in the course of your employment.

We may collect this information in several ways which include:

• Recruitment processes including information obtained from agencies
• Your identification documents you have given us
• Background checks conditional for your engagement with us
• PVG/Disclosure/DVLA/DBS checks relating to criminal convictions/offences
• Former employers or other individuals whom you have given us permission to contact to provide us with a reference. This data will include:
• Your work history with them, including your dates you were with them,

• • the work tasks you did,
  • your level of responsibility,
  • job title,
  • salary on leaving,
  • reason for leaving their workplace and
  • whether they would be happy to have you work for them again.
  • suitability to the post applied
  • strengths and weaknesses
• Medical professionals provide us with appropriate health information in order that we can manage any health-related situations that may have an impact on your ability to work with us.
• Membership with professional bodies that confirm membership
• Qualifications/training bodies that provide us information relating to you
• HMRC

What information do we collect?

Home-Start UK controls and processes a range of information about you.  In this privacy notice ‘your personal information’ means your personal data i.e. information about you from which you can be identified.  Your ‘personal information’ does not include data where your identity has been removed (anonymous data).  It is really important that your personal information that we hold and process is accurate and up to date.  Please keep us informed if your personal information changes during your engagement with us.

This includes:

• Your name, address, and contact details including email address and telephone number, date of birth and gender
• The terms and conditions of your employment or engagement with us
• Details of your qualifications, skills, experience and work history, including start and end dates with previous employers and workplaces
• Information about your remuneration, including entitlement to benefits such as, pay, expenses, pension and holidays
• Details of your bank account and national insurance number
• Information about your marital status, next of kin, dependants and emergency contacts
• Information about your nationality and entitlement to work in the UK
• Information about any criminal convictions if relevant for your job.
• Details of your work pattern (days of work and working hours) and attendance at work
• Details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals
• Details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence
• Assessments of your performance, including appraisals, performance reviews and ratings, performance improvement plans and related correspondence
• Details of any training received or planned
• Information about medical or health conditions, including if you have a disability for which the organisation needs to make reasonable adjustments
• Web browsing history and email exchanges will be routinely monitored for the purposes of maintaining the IT infrastructure

Sensitive personal data held by HSUK

We require to use some personal data that is considered under data protection law to be ‘special category data’ for example, in relation to your health or ethnicity.  We also use some other data which you may consider to be sensitive such as financial information. The information we hold is that which you provide to us (e.g. you may give us information when you applied for your role, or in response to staff surveys)

Records may contain:

• Individual demographic information in compliance with legal requirements (such as marital status, national identifier, passport/visa information, nationality, citizenship, military service, disability, work permit, gender)
• Health issues requiring adaptations to your working environment
• Leaves of absence such as maternity leave, sickness absence, etc
• Health and safety incidents, accidents at work and associated records.

How and why is your information used?

We are required to use your personal data for various legal and practical purposes for the administration of your contract of employment, without which we would be unable to employ you.  Holding your personal data enables us to meet various administrative and legal obligations, (eg, for tax purposes).

How long is your information kept for?

We will keep your personal data only as long as is necessary for the purpose(s) for which it was collected, and in accordance with our Data Retention Policy. Data will be securely destroyed when no longer required. Where you exercise your right to erasure, we will continue to maintain a core set of personal data (name, dates of employment at HSUK and date of birth) to ensure that we do not contact you or process your data again inadvertently in future and to maintain your record for employment record purposes.

We reserve the right to judge what information we must continue to hold to be able to fulfil our contract with you.

Who has access to your information?

Personal data, including sensitive personal data, may be shared with members of staff, including trustees, who legitimately need the information to carry out their normal duties to support your time with us.  We endeavour to ensure that special category personal data is only shared with colleagues with your explicit consent.  However, circumstances may arise where this data is shared with colleagues without obtaining your consent.  This will only occur in compliance with data protection law if it is necessary to protect your vital interests or the vital interests of another person, or for certain other reasons where it is not possible or appropriate to gain your consent such as disclosures to the police for prevention or detection of crime or to meet statutory obligations.  HSUK may disclose certain personal data to third parties.  These third parties and the purpose of sharing the information are set out below:

• Relevant data may be shared with your next of kin but only with your consent or in an emergency
• Relevant data may be shared with the Home Office, UK Visas and Immigration for the purpose of proving eligibility to work in the UK
• Data may be shared with reputable “data processors” for the purpose of supporting our business such as to provide our IT services, or for sending communications, e.g. staff surveys.  We have a contract with our data processors that obliges them to treat your personal data in compliance with data protection law
• With your permission, we may share information about you for publicity and marketing purposes online, in print and on social media

Otherwise, HSUK does not share data with any third party, except as allowed for in other privacy notices or required by law.  We do not sell your personal data to third parties under any circumstances or permit third parties to sell on the data we have shared with them.

Lawful Processing

The lawful basis for processing your personal data is necessary for the performance of your employment. There is a contractual requirement for you to provide much of the information detailed.  Without this, we are unable to fulfil our obligations which could result in termination of the contract.

Our lawful basis for processing special category information is for the purposes of carrying out our obligations in regard to our, and your, rights in relation to employment law.

1.B – Job Candidates 

How do we collect information about you?

As part of our candidate application and recruitment process HSUK collects, processes and stores personal information about you.  We process this information for a range of purposes relating to the recruitment process and this may include your application, assessment, pre-employment checks and your worker permissions.

What type of information is collected from you?

The following are some examples of the type of information we may process (there is a full list in the schedule at the end of this notice)

• Personal details such as name, address, date and place of birth
• Work history/job data, previous employers, positions, dates
• Compensation; salary, benefits, bonuses
• Education and work history including professional qualifications and skills
• Employer feedback/references, to include regulated references where necessary
• Nationality, visa, right to work information (eg, passport, National Insurance number)
• Results of pre-employment checks, such as DBS checks where permitted under local law
• Assessment results, such as results from any interview exercise, or video or telephone assessment

We will receive your personal data from former employers or other individuals whom you have given us permission to contact to provide us with a reference.  This will include:

• Your work history with them, including your dates you were with them,
• the work tasks you did,
• your level of responsibility,
• job title,
• salary on leaving,
• reason for leaving their workplace and
• whether they would be happy to have you work for them again
• suitability to the post applied
• strengths and weaknesses

During the process, we also capture some personal data that is considered under data protection law to be ‘special category data’ about you, e.g. disability information. We do this in order to make reasonable adjustments to enable all candidates to apply for jobs with us, to be able to take online/telephone assessments or interviews, to attend interview/assessment centres and to ensure that we comply with regulatory obligations with regard to hiring.

How and why is your information used?

In order to manage your application, we need to process certain personal information about you.  The purposes for this are set out below.  We only process your information as necessary for the purposes of progressing your application or as required by law or regulatory requirements, so not all of the purposes set out below will apply to you all of the time.

• Application: Application form or CV, name, address, employment history, academic and professional qualifications, age, diversity, (i.e. gender, ethnicity, disability, sexual orientation), nationality, previous disciplinary matters – for our legitimate interests in selecting the best candidate for the job.
• Assessment: CV, interview (face to face, telephone or video), exercise or test – for our legitimate interests in selecting the best candidate for the job.
• Pre-employment: Right to work in the UK, qualifications, references – for our legal obligations as an employer

How long is your information kept for?

For unsuccessful candidates, personal information will be retained for 12 months following the recruitment process.  For successful candidates, all personal information collected as part of the recruitment process will be transferred to an employee personnel file and will be retained for six years following termination of employment

Who has access to your information?

The recruitment process will involve:

• Assessing and progressing your application
• Assessing your suitability (skills, strengths and behaviours) for the role
• Activities needed to complete onboarding and screening processes should your application be successful

To enable these processes your personal information may be shared internally.  The information shared is limited to what is required by each individual to perform their role in the recruitment process. Your personal information may be shared with the following:-

• The hiring manager
• The line manager
• The interview panel
• The HR manager
• The IT Manager (if application successful)
• Finance (if application successful)

Our HR and recruitment systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of personal information does not occur. This is done in line with the Security of Personnel Files policy and the Computer Security Policy.

Pre-employment checks

As part of the recruitment and selection process, HSUK will carry out pre-employment checks.  These checks are only performed on candidates who have been selected for a role.  Your consent will be requested before pre-employment checks are carried out.

Lawful Processing

HSUK’s entitlement to process your personal information is governed under data protection law by a number of processing conditions.  This means we may rely on more than one of these conditions in order to process elements of your personal information throughout the recruitment process.

• HSUK will process your personal information where we are required to do so by law or regulation or it is in the legitimate interest of HSUK.

During the course of your application, it may also be necessary for HSUK to process special category information, such as about a disability you may have.  Our lawful basis for processing special category information is for the purposes of carrying out our obligations in regard to our, and your, rights in relation to employment law.

1.C – Referees 

How do we collect information about you?

Some of your personal details will have been provided to us by another person (applicant) who has indicated you as a referee, such as your name and contact details. We will only use your personal data in accordance with the terms of this privacy notice.

What type of information is collected from you?

• Name
• Name and address of company, position and relationship to applicant (when providing an employment reference)
• Personal address and relationship to applicant (when providing a personal or character reference)
• Telephone number and/or email address

How and why is your information used?

HSUK will collect your personal data and process your personal data for the purpose of obtaining references for our applicant.

How long is your information kept for?

HSUK will retain your personal data along with the applicant’s data for as long as is necessary.  Different laws require us to keep different data for different periods of time which are detailed in the Appendix below.

Where the applicant is unsuccessful

If the applicant is unsuccessful after you have provided a reference with the data will be kept for 12 months.  The electronic data will then be deleted and the paper data confidentially shredded.

Where the applicant is successful

If the applicant is successful the data will be transferred to their personnel file which will be kept for six years after the end of their employment with HSUK.  The electronic data will then be deleted and the paper data confidentially shredded.

Who has access to your information?

Where we need to share your personal data we require the recipients to treat your information as confidential and ensure the continued protection of your data whilst in their possession.  HSUK will process your personal data with the following recipients:-

1. The hiring manager
2. The line manager
3. The HR manager
4. Third-party, where necessary, to protect the applicant’s vital interest, eg, emergency services

Lawful Processing

The legal basis we rely upon when processing your personal data is: in our legitimate interests to fulfil our recruitment requirements which obtaining references is a vital part of.  This is in order to ensure we are recruiting the best and most reliable people for our organisation.

2. Website visitors

We are committed to safeguarding the privacy of our website visitors and service users; in this policy, we explain how we will handle your personal data. We will ask you to consent to our use of analytics or marketing cookies in accordance with the terms of this policy when you first visit our website. [See our Cookies notice below) 

Social Media

We operate a number of social media pages including Facebook, Twitter and YouTube. Although this policy covers how we will use any data collected from those pages it does not cover how the providers of social media websites will use your information.  Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

How do we collect information from you?

We collect your personal data when you enter your details into our website forms or comment on our social media pages.

If you consent to analytics cookies, we will collect data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data will be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interest in monitoring and improving our website and services. 

We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include name, address, email address, details of donations made or items ordered. The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

We may process information contained in any enquiry you submit to us on our website contact form (“enquiry data”). Your personal information will be processed for the purposes of dealing with your enquiry. The legal basis for this processing will depend on the nature of your enquiry.

We may process information relating to transactions, including donations or purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

Marketing Information

If you tick the opt-in box, we will process the information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters.  ~This data may be processed for the purposes of sending you relevant advertising and marketing information and/or newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you provide to us using the website contact forms (“correspondence data“). The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

Other processing

We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person’s personal data to us, unless we ask you to do so.

Who has access to your information?

We may disclose your personal data to any member of our group of charities in the Home-Start network insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

Financial transactions relating to our website and services are handled by our payment services providers, Stripe, GoCardless and PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at:

• Stripe (URL https://stripe.com/gb/privacy)
• GoCardless  (URL https://gocardless.com/legal/privacy/)
• Paypal (URL https://www.paypal.com/ie/webapps/mpp/ua/privacy-full)

Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity, the following will apply:

1. Your data will be made available to our website provider
2. The data that may be available to them include any of the data we collect as described above.
3. Our website provider will not transfer your data to any other third party or transfer your data outside of the EEA.
4. They will store your data for a maximum of 7 years.
5. This processing does not affect your rights

In addition to the specific disclosures of personal data, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

How long is your information kept for

This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain and delete your personal data as follows:

(a) All personal data will be retained for a maximum of seven years following the date it was submitted, at the end of which period it will be deleted from our systems unless requested by users.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Third-party websites

Our website includes hyperlinks to, and details of, third party websites. This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them.  If you use any link on our website we recommend you read the privacy policy of that website before sharing any personal or financial data

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

• Authentication – We use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: DisplayName);
• Status – We use cookies to help us to determine if you are logged into our website (cookies used for this purpose are: ASP.NET_SessionId, ARRAffinity, MemberLoggedIn);
• Personalisation – We use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: cc_cookie_accept)
• Security – We use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: __cfduid);
• Advertising – We use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: IDE,  DSID,_ct_rmm
• Analysis – We use cookies to help us to analyse the use and performance of our website and services, (cookies used for this purpose are a, __utmz, _ga and _gid, _gat_UA-8289996; ai_session and ai_user) 

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at https://www.google.com/policies/privacy/. The relevant cookies are: _ga, _gid, _gat, __utma, __utmt, __utmb, __utmc, __utmz and __utmv.

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:

• https://support.google.com/chrome/answer/95647?hl=en (Chrome);
• https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
• http://www.opera.com/help/tutorials/security/cookies/ (Opera);
• https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
• https://support.apple.com/kb/PH21411 (Safari); and
• https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

3. Our Supporters – Fundraising & Communications

How do we collect information from you?

We obtain information about you in the following ways:

Information you give us directly: For example, we may obtain information about you when you take part in our events, make a donation, purchase products or when you register to receive our newsletter.

Information you give us indirectly: Your information may be shared with us by third parties, which might include:

• Independent event organisers, for example, the London Marathon and fundraising sites like Just Giving
• professional fundraisers;
• charities with whom we are working in partnership for mutual fundraising campaigns; and
• subcontractors acting on our behalf who provide us with technical, payment or delivery services, our business partners, advertising networks analytics providers and search information providers
• You should check any privacy policy provided to you where you give your data to a third party.

What type of information is collected from you?

The personal information we collect, store and use might include:

• your name and contact details (including postal address, email address and telephone number);
• your date of birth
• information about your activities on our website and about the device used to access it, for instance, your IP address and geographical location;
• your bank or credit card details. If you make a donation online or make a purchase, your card information is not held by us, it is collected by our third-party payment processors, who specialise in the secure online capture and processing of credit/debit card transactions;
• information as to whether you are a UK taxpayer so we can claim gift aid; and
• any other personal information shared with us.

Data protection laws recognise certain categories of personal information as a special category and therefore requiring greater protection, for example, information about your health, ethnicity and religion.

We do not usually collect special category about you unless there is a clear and valid reason for doing so and data protection laws allow us to. Where appropriate, we will make it clear why we are collecting this type of information and what it will be used for.

Public Information

We supplement information on our supporters with information from publicly available sources such as annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support.

How and why is your information used?

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us then you can select your choices by ticking the relevant boxes situated on forms used to collect your information. We may use your contact details to provide you with information about the vital work we do for families, our fundraising appeals and opportunities to support us, as well as the products and services you can buy if we think it may be of interest to you. We may also send your data to agencies we work with to help us engage with you in the future.

Email/Text/Phone/Post

We will only send you marketing and fundraising communications by email, text and telephone if you have explicitly provided your prior consent. You may opt-out of our marketing communications at any time by clicking unsubscribe at the end of emails & website. We may send you marketing and fundraising communications by post unless you have told us that you would prefer not to hear from us.

How long is your information kept for?

We’re committed to putting you in control of your data so you’re free to change your marketing preferences (including telling us that you don’t want to be contacted for marketing purposes) at any time using fundraising@home-start.org.uk or by telephone: 0116 464 5490 or post: 4th floor, Arnhem House, 31 Waterloo Way, Leicester LE1 6LP.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted and will retain your details on a suppression list to help ensure that we do not continue to contact you. However, we may still need to contact you for administrative purposes like when we are processing a donation or thanking you for your participation in an event.

We keep your information for no longer than is necessary for the purposes it was collected for. The length of time we retain your personal information is determined by operational and legal considerations. For example, we are legally required to hold some types of information to fulfil our statutory and regulatory obligations (e.g. health/safety and tax/accounting purposes). We review our retention periods on a regular basis.

Who has access to your information?

We do not sell or rent your information to third parties.

We do not share your information with third parties for marketing purposes.

However, we may disclose your information to third parties in order to achieve the other purposes set out in this policy. These third parties may include:

Third parties working on our behalf

We may pass your information to our third-party service providers, suppliers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use these third parties, we disclose only the personal information that is necessary to deliver the services and we have a contract in place that requires them to keep your information secure and prevents them from using it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties unless we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.  We will not release your information to third parties for them to use for their own direct marketing purposes unless you have requested us to do so.

Third-Party Product Providers, we work with

Our trusted third party product providers provide a range of quality and reliable products and services designed to meet the needs of our clients. When you enquire about or purchase one or more of these products, the relevant third party product provider will use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them. They will be acting as a joint controller of your information and therefore we advise you to read their Privacy Policy. 

Lawful Processing

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

Specific Consent

Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.

Performance of a contract

Where we are entering into a contract with you or performing our obligations under it, like when you buy Home-Start named products and services.

Legal obligation

Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like the Charity Commission or Fundraising Regulator.

Legitimate interests

Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).

We consider our legitimate interests to be running Home-Start UK as a charitable organisation in pursuit of our aims and ideals. For example to:

• provide our services to support you and your family;.
• send postal communications which we think will be of interest to you;
• conduct research to better understand our supporters and to improve the relevance of our fundraising;
• understand how people choose/use our services and products;
• determine the effectiveness of our services, promotional campaigns and advertising;
• monitor who we deal with to protect the charity against fraud, money laundering and other risks;
• enhance, modify, personalise or otherwise improve our services /communications for the benefit of our customers; and
• better understand how people interact with our website.

When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

When we use sensitive personal information, we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law (for example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).

We may also use your personal information to detect and reduce fraud and credit risk.

4. @Home Intranet

@Home is the Home-Start intranet.  All Home-Start staff and trustees have the right to have an account with a username and password in order to access @Home.  An existing member of staff or trustee can request access for a colleague through the New Starter form that is located on @Home. New accounts are usually created once each week, a welcome email is then sent to the new starter containing access instructions and their login details.

In this section we have set out:

• How we collect information from you
• How and why is your information used
• Lawful Processing

Account Data

We may process your account data (“account data“). @Home account data will include your name, email address and local Home-Start. The source of the account data is usually the local Home-Start member of staff or trustee who requests an account for you. The account data may be processed for the purposes of creating an @Home account for you, operating @Home, providing our services, ensuring the security of @Home and services, communicating with you and enabling communication between you and other @Home account holders.  The legal basis for this processing is our legitimate interests, namely enabling and monitoring your use of our intranet as well as the proper administration of @Home and our services.

Profile Data

When we receive a request for an @Home account for you, we will process your profile information. This will be included in your @Home personal profile (“profile data“) which appears on your profile page and in the People Directory. These details are visible to all @Home account holders. The profile data will include your name, email address, job/role title, start date and local Home-Start.  It may also include a telephone number. The legal basis for this processing is a legitimate interest to enable @Home account holders to communicate with each other to share knowledge and expertise and work together to improve the services we offer to families.

The following information can be added and/or edited yourself through the ‘Edit profile’ option:  profile picture, expertise, interests and social media ids. The legal basis for this processing is consent. You can also edit your phone number(s) and start date yourself.

A change to your name, email address and/or local Home-Start can be requested by contacting intranet@home-start.org.uk

If a member of staff or trustee uses a personal (i.e. not provided by Home-Start) email address for their @Home access they may contact us at intranet@home-start.org.uk to ask for their email address not to be visible to other @Home users in the People Directory.

Usage Data

We may process data about your use of @Home (“usage data“). The usage data may include your local Home-Start, geographical location, device, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing and frequency of your @Home use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of @Home. The legal basis for this processing is our legitimate interests, namely monitoring and improving @Home and services.

Engagement Data

We may process data about your engagement on @Home (“engagement data”). Engagement may include comments on pages and discussion forums, likes, shares, and reports submitted about pages and documents downloaded. The legal basis for this processing is our legitimate interests, namely monitoring and improving @Home and services.

Form Data

We may process your personal data that are provided in forms (“form data“). Forms are used to collect new starter details, leaver details, changes to local Home-Start contact details, Chair, Treasurer or Most senior staff changes, webinar bookings, funding applications etc. The form data may include name, email address, local Home-Start and other information requested. The source of the form data is you or a colleague completing the form on your behalf. The form data may be processed for the purposes of operating @Home, providing our services, ensuring the security of @Home and services and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of @Home and our services.

Publication Data

We may process information that you post for publication on @Home (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering @Home and services. The legal basis for this processing is consent.

Publication Notification Data

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

Correspondence Data

We may process information contained in any correspondence between us and you (“correspondence data”). Correspondence data may be processed to provide support and/or the proper administration of @Home and services. The legal basis for this processing is consent.

Pulse Survey Data Data

Pulse is the survey function within @Home (“survey data”). We may process the information you submit to a Pulse survey.  Pulse automatically collects which local Home-Start you are from.  The legal basis for the processing of survey data is consent. 

Other

We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. Please do not supply any other person’s personal data to us, unless we prompt you to do so.

APPENDIX – Retention Periods

Part1: Statutory Retention Periods

The main UK legislation regulating statutory retention periods is summarised below.  If there is any doubt, it is recommended that records are kept for at least 6 years (5 in Scotland), to cover the time limit for bringing any civil legal action

Part 2: Non-Statutory Retention Periods

When the recommended retention period given is 6 years, this is based on the 6-year time limit within which legal proceedings must be commenced as laid down under the Limitation Act 1980. Thus where documents may be relevant to a contractual claim, it is recommended that these be retained for at least the corresponding 6-year limitation period.

When retaining any information Home-Start UK is aware that under the General Data Protection Regulations data must not be kept longer than is necessary for a particular purpose.