Privacy & Cookies policy

Our commitment to your data

At Shaftesbury, we value the support and engagement people have with our charity. From donors, the people that use our services, staff, volunteers or campaigners – each person is a valued part of our charity community.

In the delivery of our care services, engaging with supporters, fundraising and raising the profile for our cause; Shaftesbury gathers personal data. We collect data to enhance our service quality; help us tailor our services; for training and resources; understand our supporters better and also help us to fundraise more efficiently. We also collect data in relation to the contract or relationship we have with an individual, or because it’s necessary to their vital interests.

We want every interaction people have with our charity to be positive. In all areas of our work, we are committed to protecting your personal information, being open about what information we hold and also ensuring that we only gather information that is necessary.

This policy outlines how we go about this – in line with the requirements and stipulation of the GDPR which came in to effect from 25th May 2018.

The policy applies to how Shaftesbury – and all our subsidiaries – collects and uses personal information you provide to us and that we collect, whether online, via phone, email, in letters or in any other correspondence or from third parties.

More information for students in our education centres and for parents, carers and governors is available in our Schools Privacy Notices.

We ensure that we use your information in accordance with all applicable laws concerning the protection of personal information.

This policy explains:

Understanding your rights
The information we collect
When we collect information about you
Use of cookies and website usage
Why we collect and use your personal data
Sensitive personal data
Our legal basis for processing your data
How we work with third parties in processing your personal data
How long we keep your information for
How we keep your information secure
Keeping your information up to date
Your right to access personal information
How to control the marketing that we send you
Breach notifications
Privacy assessments
Complaints

If you have any queries about this privacy and cookies policy please contact the Data Protection Officer at Shaftesbury’s Head Office or email: dataprotection@shaftesburygroup.org

Please select below to read more:

Who we are

Shaftesbury is the disability charity that connects people with their communities.

We tackle social isolation and the barriers that can cause this in the lives of disabled and vulnerable people.

Through a wide range of disability, education, training and community services, we promote inclusion and wellbeing for all.

Together, we work to see people take part, contribute and be valued. We put the elements in place that all add up to connected lives and communities.

Charity legal details

Shaftesbury is a charity registered with the Charities Commission under charity number 1116530, and a company limited by guarantee and registered in England and Wales under company number 5967087.

Shaftesbury was established in 2007 as a merger of The Shaftesbury Society and John Grooms. In May 2016 Prospects for People with Learning Disabilities and its subsidiary At Home in the Community became members of the Shaftesbury Group.

Shaftesbury is the parent charity of a group of charities and operating companies.

Our registered charity numbers are 1116530 in England and Wales.

Shaftesbury is a Data Controller, registered with the Information Commissioner’s Office (Registration Number Z974176X).

Within the context of this policy ‘we’ means both the charity and its subsidiaries. Each of these organisations are data controllers under the data protection rules.

Understanding your rights

It is important that you understand your legal rights around your personal data and how we may use it. If you would like to discuss or exercise any of these rights, please contact our Data Protection Officer at Shaftesbury Head Office or email: dataprotection@shaftesburygroup.org

You have the right to be informed

This Privacy Policy ensures that you are informed about how we will process your personal data. You might also see messages on some of our forms (or otherwise when we collect personal data from you) that explain why we ask for specific pieces of information from you.

You have rights of access

You have the right to access a copy of your personal data and receive certain information about what the data is and how and why we are processing it.

Please note that we will require you to prove your identity before we disclose any information.

You have the right to rectify information

If you feel that any of the information that we hold about you is incorrect, do let us know so that we can look into it for you and amend it.

You have the right to object

You have the right to object to the processing of your data that we have outlined in this policy in certain cases. You can object in instances whereby we are processing your personal data on the basis that it is within our ‘legitimate interests’ to do so. Please see further information on this in the Our legal basis for processing your data section below.

You have the right to be forgotten

You have the right to request that we delete your information and you can discuss this with us at any time.

You should know that there are some circumstances where we may need to keep your details, for example, if it is necessary for us to comply with a legal obligation. If this situation occurs, then we will explain and discuss these circumstances with you.

You have the right to restrict processing of your data

You can request that we restrict the processing of your data, as an alternative to deleting it – this means that we will keep the data but stop processing it for most purposes. You may want to exercise this right if you feel that the data is inaccurate, there is disagreement over its legitimate use, or you feel that we have no further use of your data.

You have the right to object to automated decision making

You have rights to avoid being subjected to decisions based solely on automated processing (e.g. using computerised models and algorithms) which may have legal or other significant effects on a person.

You have the right to data portability

You have the right to request a copy of certain personal data to have it transferred to another organisation in certain circumstances.

You should know that there are some circumstances where these rights may not apply, but where this is the case we will always explain this to you. Please do contact us if you have any questions or concerns on how we collect and use your personal data, or on your rights, as we are always happy to speak to you.

You also have the right to make a complaint direct to the UK’s data protection authority, the Information Commissioner’s Office (ICO). The ICO can be contacted at their website.

The information that we collect

The personal data that we collect about you will be based on how you interact with us, but we collect the following information from many of our supporters and volunteers:

Your name
Your postal and email addresses
Your telephone number or numbers
Details of any correspondence that we have had with you. For example, if you call our Supporter Services team, they will make a note of the conversation, in case you need anything else on that matter.
How you would like to hear from us, and when you told us this
Details of any donations that you have made to us
Whether or not you have signed up to the Gift Aid Scheme, and when you did so
Your date of birth
Any fundraising appeals that you may have responded to
Events that you have taken part in or enquired about

There is also other information that we may collect and hold in specific circumstances. For example:

Your bank account details if you set up a direct debit with us
Health information that you give us if you are participating in an event, to help us ensure your safety
Details of your connection to our charity or one of the many services we support, should you wish to provide this link. Please see further information on this in the Sensitive personal data section below.
Our telephone system lists the numbers that have recently called or been dialled, but we do not link these to any supporter records
Information to support our work with high net worth individuals, to understand their philanthropic interests, and complete any necessary due diligence

When we collect information about you

Shaftesbury collects information in the following ways:

When you give it to us DIRECTLY

You may give us your information in order to sign up for one of our events, tell us your story, sign up to our e-newsletter, fundraise on our behalf, make a donation, pledge a legacy, purchase Christmas Cards and other merchandise or to simply communicate with us. Sometimes when you support us, your information is collected by an organisation working for us (e.g. a professional fundraising agency), but we are responsible for your data at all times.

When you give it to us INDIRECTLY

Your information may be shared with us by independent event organisers, for example the London Marathon or fundraising sites like Just Giving. These independent third parties will only do so when you have indicated that you wish to support Shaftesbury and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

When you give permission to OTHER ORGANISATIONS to share your information or it is AVAILABLE PUBLICLY

We may combine information you provide to us with information available from external sources in order to gain a better understanding of our supporters and to improve our fundraising methods, products and services.

The information we get from other organisations may depend on your privacy settings or the responses you give, so you should regularly check them. This information comes from the following sources:

Third party organisations

You may have provided permission for a company or other organisation to share your data with third parties, including charities. This could be when you buy a product or service, register for an online competition or sign up with a comparison site. The data we receive depends on your agreement with the third party organisation. We, like all charities and companies, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer. We do not sell or swap data with third parties or other charities.

Social Media

Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those accounts or services.

When we collect it as you use our WEBSITE & DIGITAL SERVICES

We collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our websites or view and interact with our ads and content. This helps us to understand your interests in our cause and information and to tailor our resources to be more focused on what supporters or service users need.

We assign web browser cookies to enhance each visitor’s use of our website. Cookies are used for saving small amounts of information such as user settings.

We may also work with third parties to help us measure visits to our website in order to improve its usability. The data we measure may contain personal information (an IP address and/or cookies).

Use of cookies and website usage

Our website uses cookies to help provide you with the best online user experience we can. Cookies are small text files that are placed on your computer or electronic device when you browse a website. We use this information to provide you with a good experience when browsing our website and to improve the functionality of our site.

Our cookies help us:

Make our website work as you would expect
Remember your settings during and between visits
Improve the speed and security of the site
Personalise our site to you to help you get what you need fast
Continuously improve our website for you

Examples of cookies we use include (but are not limited to):

Google Analytics: This allows us to collect anonymous information about how visitors use the website. For example, information which pages on the site have been visited and the length of time spent on each page. This information enables us to improve our website for future visitors.

Session: Session cookies enable us to keep track of your movement from page to page so you do not get asked for the same information you have already given to the site. This allows you to proceed through many pages of our website quickly and easily without having to authenticate or reprocess each new are you visit.

CQC Widget: This cookie forms part of a widget provided by the Care Quality Commission, which is the independent regulator of all health and social care services in England. The widget displays the result of our service’s most recent CQC inspection and provides a link through to the record of the inspection on the regulator’s website.

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our website

Website users

All Shaftesbury websites use cookies to help our websites work well and to track information about how people are using them.

All Shaftesbury websites collect personal information which may include:

Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblog statistics and other communication data.
Information that you provide by filling in forms on our website, such as when you make an enquiry about one of our services, or make a donation to
Email addresses, postal and telephone information if you opt in to receive emails or other resources from us.
Information provided to us when you communicate with us for any reason.

Third party links

You may find links to third party websites on our website. These websites will have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Offensive behaviour on our website

If you post or send any content on Shaftesbury digital channels that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content on our social media pages, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

Tracking

We use multiple first and third party technologies such as pixel tags and web beacons to track and improve the user experience on our sites, quality of service and to monitor the effectiveness of campaigns and digital marketing

We may use them to:

See what website content is popular and how people are using the site as they allow us to track users’ movement through our website. This type of information is amalgamated so that we can build up a picture of how the site is performing.
Make sure we offer you a consistent service. For example, if we are testing new website content or we want to run a survey, we use tracking to remember what content you have seen or if you have already been asked to join the survey.
In addition, when we email you, we may place a tag (also known as ‘tracking pixel’) on the email we send you. These let us monitor performance of our email marketing activity.
Form the basis of advertisement profile and retargeting as we seek to ensure any adverts displayed on our behalf are as relevant and interesting as possible to the people those adverts are displayed to.

International transfer of data

We may transfer data that we collect from you to locations outside of the European Economic Area for processing and storing. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this Privacy Policy.

Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted.

Why we collect and use your personal data

We collect personal data to help us to process your requests, keep in touch with you and to help us to interact with you in the most effective way.

We will use your personal information:

To provide you with the services, products or information you have asked for
To process your donation, and where applicable, including the processing of gift aid
To support your fundraising efforts
To ask you to help us raise money or to donate through our appeals
To provide you with information about our work and activities or to send you materials that you have requested
To invite you to participate in market research
To invite you to events
To manage and administer any legacies that have been pledged or left to us
To keep a record of our relationship with us
To ensure we know how you prefer to be contacted
For internal record keeping, such as the management of feedback or complaints
Where it is required or authorised by law

Direct Marketing

From time to time, we will contact you to let you know about the progress we are making and to ask for donations or other support. We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions and we include information on how to opt out when we send you marketing. If you don’t want to hear from us, that’s fine. Just let us know when you provide your data or contact our Supporter Services team on 020 7452 2121 or at supporterservices@shaftesburygroup.org

Building profiles of supporters and targeting communications

As part of our major donor fundraising activities we undertake research and profiling of supporters and prospective supporters who may have an interest in, and financial ability to, support Shaftesbury and particular aspects of our work. This research helps us to target our communications in a more focused, personalised and cost effective way by giving us greater insight into what donors and prospective donors may find interesting and the level of support they may be able to provide.

When undertaking research or gathering information in order to build a picture about a supporter or prospective supporter, we consider geographic, demographic and other publicly available information such as location, listed Directorships or trusteeships, donations to other organisations and measures of affluence such as typical earnings in a given profession and house values.

Our profiling methods and analysis activities can be categorised in the following four ways:

Data Matching

We may use the personal information an individual has given us in conjunction with data that has been obtained from external sources in order to obtain a greater understanding of their likely social, demographic and financial characteristics. This allows us to tailor communications with a greater degree of relevancy to better meet the expectations and desires of the individual and other individuals in similar circumstances. We will not use this data in any way that might intrude upon an individual’s rights or be considered inappropriate.

Segmenting

We analyse supporters by group, post code or geodemographic area where supporters may be located. This enables us to better tailor relevant campaigns and mailings for those most likely to be interested and get involved. This is not designed to identify any specific individuals, but rather many individuals who may lie in a particular segment of supporters.

Event Planning

We sometimes create short biographies of individuals who are attending our events or meetings for the purpose of understanding more about the people we are engaging with. This includes reviewing publicly available sources such as public registers, broadcast media and online publications and stories.

Major Donor Analysis

We analyse our database and use information on how supporters have engaged with us in the past to see if we believe that they would be interested in building a relationship with our fundraisers. We then use publicly available sources of information to understand their philanthropic interests and capacity to give greater support (which includes estimated levels of wealth where available). We may also identify other potential new supporters this way. We may from time to time engage a specialist third party prospect research company to analyse our database against their demographic database for this purpose.

These external data sources are gathered entirely from publicly accessible sources and include examples such as:

Public Registers: Companies House (directorships, shareholdings and company accounts), The Electoral Commission (Political Donations), The Electoral Roll (Open Register), The FCA (Financial Services Register), The Law Society, The Land Registry
UK Reference Volumes: Who’s Who, Debrett’s People of Today, Debrett’s Peerage and Baronetage, City of London Livery Company information, Trustfunding.org.uk, Sunday Times Rich List
Reliable print and broadcast media: newspapers (The Telegraph, Financial Times, The Times and Sunday Times, City AM), magazines
Trade and Industry References, Professional directories, Charity Commission
Information that individuals put into the public domain such as on company websites or biographies on professional networking sites
Geographic and demographic information based on postcode

The information that we then review from these sources includes things such as whether a person is a company director or trustee of a charity, their business profession, and estimated property values.

Using this information means that we can tailor communications to areas of our work that we believe will be of interest to you, as we know that donors want information relevant to their motivation for giving. It enables us to spend less money than we otherwise would to raise more funds. It also allows us to ensure that we do not contact people inappropriately.

If you would like any further information on our profiling and major donor analysis, or do not wish us to use your details in any of the ways described above, please contact our Supporter Services team on 020 7452 2121 or at supporterservices@shaftesburygroup.org

Ethical screening and minimizing risks

As part of our Ethical Fundraising Policy and being an open and ethical fundraising charity, we will from time to time need to carry out due diligence on funders and companies. This is our legitimate interest to ensure the company or funder acts in accordance with our ethical policy and whether we would choose to accept or refuse a donation.

There may also be times where we need to carry out due diligence when a large gift or shares are donated to Shaftesbury and we may want to assure ourselves that the money for the gift has been obtained legally by the supporter and that it had been done in a way that does not conflict with our charity values.

It will therefore be necessary screen supporters to minimise the risk of associating ourselves with an individual or organisation that conflicts with the high standards we have set ourselves in our ethical policy.

Sensitive personal data

Data Protection law and the GDPR recognises that certain categories of personal information are more sensitive. This is known as sensitive personal data and covers health information, race, religious beliefs and political opinions.

We do not always collect ‘sensitive personal data’ about our supporters or the people that use our services, unless there is a clear reason for doing so. For example, with supporters participating in a fundraising event or initiative, we would need this information to ensure that we provide appropriate facilities or support to enable individuals to participate in the event.

We are a charity with an inclusive Christian ethos, working with people of all faiths and none. From time to time, we may seek to understand our audiences better by collecting information about religious affiliation.

Sharing your story

Some of our supporters may choose to tell us about their health and care experiences relating to disability (for example, if you use our disability care services, call our charity, act as a case study for us, or volunteer to share your story).

Should supporters choose to share this information with us, we will always make it clear to you when we collect this information from you, what sensitive personal data we are collecting and what purposes we may use it for.

If we have the explicit and informed consent of the individuals, or their parent or guardian if they are under 18, this information may be made public by us at events, in materials promoting our campaigning and fundraising work, or in documents such as our annual report.

Children and young people under the age of 13

We are committed to protecting the privacy of the young people that engage with us through our disability care and education services.

Our fundraising events also request specific information about the age of participants.

If you are under 13 and would like to get involved, please ensure that you have consent from a parent or guardian before giving us your personal information. When we collect information about a child or young person aged under 13, we will make it very clear as to the reasons for collecting this information and how it will be used.

Please note that more information for students in our education centres and for parents, carers and governors is available in our Schools Privacy Notice.

Web site users

All Shaftesbury websites use cookies to help our websites work well and to track information about how people are using them.

All Shaftesbury websites collect personal information which may include:

Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblog statistics and other communication data.
Information that you provide by filling in forms on our website, such as when you make an enquiry about one of our services, or make a donation to us.
Email addresses, postal and telephone information if you opt in to receive emails or other resources from us.
Information provided to us when you communicate with us for any reason.

Third party links

You may find links to third party websites on our website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Use of cookies

Our cookies help us:

Make our website work as you would expect
Remember your settings during and between visits
Improve the speed/security of the site
Personalise our site to you to help you get what you need faster
Continuously improve our website for you

Non-exhaustive list of cookies

Google Analytics: This allows us to collect anonymous information about how visitors use the website. For example, information on which pages on the site have been visited, and the length of time spent on each page. This information enables us to improve the website for future visitors.

Session: Session cookies enable us to keep track of your movement from page to page so you do not get asked for the same information you have already given to the site. This allows you to proceed through many pages of a site quickly and easily without having to authenticate or reprocess each new area you visit.

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our website.

Transfer of data internationally

Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted.

Tracking

We may use them to:

See what website content is popular and how people are using the site as they allow us to track users movement through our websites. This type of information is amalgamated so that we can build up a picture of how the site is performing.
Make sure we offer you a consistent service. For example, if we are testing new website content or we want to run a survey, we use tracking to remember what content you have seen or if you have already been asked to join the survey.
In addition, when we email you, we may place a tag (also known as ‘tracking pixel’) on the email we send out. These let us monitor performance of our emails marketing activity.
Form the basis of advertisement profile and retargeting as we seek to ensure any adverts displayed on our behalf are as relevant and interesting as possible to the people those adverts are displayed to.

Use of credit and debit card information

If you use your credit or debit card to donate to us, buy something or pay for a registration online or over the phone, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard.