Privacy and Data Protection Policy
Sovereign House GH, a Registered Charity in England and Wales with Registered Number 1168568 and a Company Limited by Guarantee number 09551467.
We collect personal data about you:
• via our website – email and name, when you subscribe to our newsletter
• when you donate to the charity via our donation portals
• when you volunteer with us
• when you apply as a service user and
• when you correspond with us.
We are exempt from registering with the ICO.
Sovereign House GH respects your privacy and is committed to protecting your personal data. This privacy notice explains how we collect and use your personal data and tells you about your privacy rights and how the law protects you.
It is important that you read this privacy notice so that you are fully aware of how and why we are using your data.
You have the right to make a complaint about the way in which we handle your personal data to the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Our full contact details are:
Sovereign House GH, HQ Building, Clippers Quay, M50 3XP
Email: firstname.lastname@example.org | Tel: 0161 826 8747 /0331024495
Our Privacy Notice and your duty to inform us of changes to your information
This privacy notice was last updated on 31 May 2022. We may update this privacy notice from time to time. When we do so we will notify you of any significant changes by providing a notice on our website or by emailing you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third Party Links
Our website may include links to third-party websites, plug-ins and social media applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
What data do we collect about you?
You will be asked for personal data such as your name, address and email address when you register, join as a member/volunteer, or apply for our services.
Personal data, or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, last name, title or similar identifier.
• Contact Data includes residential address, email address and telephone numbers.
• Financial Data includes payment methods – via direct debit/standing order
*(we not have access to your credit or debit card details – these payments are made via secured and encrypted third party financial organisations).
• Transaction Data includes details about payments to and from you and other details of products and services we/you have engaged with from us.
• Usage Data includes information about how you use our services.
• Communications Data includes your preferences in receiving newsletter from us via your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing our services.
We may sometimes collect information relating to your health, where this is necessary to help us provide a service to you or give information to the healthcare authorities (for example if you need assistance). By submitting such data to us voluntarily, you will be consenting to us using that data for responding to and complying with your request.
What happens if you do not provide the requested information?
Where we need to collect data by law, or under the terms of an agreement we have with you or to use our services and you fail to provide that data when requested, we may not be able to engage with you (for example, to access our services, we need to have certain data about you, so we can identify you). In this case, we may have to cancel our engagement with you, but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• make a donation to us;
• subscribe to our services or publications;
• request information to be sent to you or submit feedback to us
• enter a competition, promotion or survey;
How do we use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to engage our services with you.
• Where we need to comply with a legal or regulatory obligation.
You have the right to withdraw consent to communication from us at any time by emailing us at contact@sovereignhousegh or simply unsubscribing when we send you newsletters.
How do we use your personal data?
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal obligations and legitimate interest we rely on to process your data.
|Purpose||Type of Data||Lawful Basis|
|To register you as a service user||Identity, Contact||To access our services|
|Donations and Grants received||Identity, Contact, Financial|| Necessary to comply with a legal obligation;
Legitimate interest (to keep our records updated)
|To manage our relationship with you||Contact, Communication||Progress update, activities|
|To protect the charity’s business||Identity, Contact, Transactions, Usage||Necessary to comply with a legal obligation – For running our business to prevent fraud, provision of admin, IT and security services|
|Data analytics||Contact, Identity, Usage||Legitimate interest: To grow our business, improve our services, develop relationships and experiences, measure our effectiveness and deliver relevant content|
We are committed to ensuring your privacy is protected and will only use the information that we collect about you lawfully under the Data Protection Act 1998. We may update this policy at any time, so you should check this page from time to time to ensure that you are happy with any changes. We will not sell, distribute or lease your personal information to third parties unless we are required by law to do so.
Cookies are small files stored on your computer or mobile device. They are used widely online and allow websites to work more efficiently as well as provide information about your visit to the website. Browsers usually accept most cookies automatically, but you can disable them in your browser settings. Please note however, that some of them are an essential part of online processes. Cookies are encrypted and do not give access to your computer or store any personal information of any kind. For more information on cookies visit www.allaboutcookies.org and www.aboutcookies.org
Online payment cookies
Sovereign House GH online payment system, uses authentication cookies, which allow customers to start the checkout process – or log in – by going to different parts of the website, which is encrypted securely. This is essential to the online payment process.
We use Google Analytics, a web analytics tool that helps us understand how visitors engage with our website, e.g. measures the number of visitors to our website, how they reach our website, how many pages they click on, etc., so we can improve the customer’s user-experience and performance of our website. They do not store any personal information.
Third party cookies
These cookies may be set by other companies whose functionality we utilise on our site, (for sharing events and information via Facebook, Instagram and Twitter), YouTube (where we have videos embedded on the event page). You can find out more about the cookies used by these services on their own websites:
Links to other websites
Our website contains links to other websites of interest. Once you leave our website, we are not responsible in any way for the protection and privacy of any information you provide whilst visiting such sites. This privacy statement does not apply to these other websites.
How do we share your personal data?
We do not share your data unless you have given us explicit instruction to do so. We may have to share your personal data with the parties set out below for the purposes set out in the table above.
• Internal Third Parties as set out in the Glossary (below)
• External Third Parties as set out in the Glossary (below)
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those parties who have a legal or legitimate need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
For how long do we keep your information?
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under the data protection laws in relation to your personal data including:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us. All the above is available to you by emailing us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
Legal basis for our use of your data:
• Legitimate Interest means the interest of our organisation in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
• Service User means processing your data where it is necessary for the performance of providing our services to you as a beneficiary.
• Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties means trustees/volunteers who are based in the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties means:
• Service providers based who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Your legal rights
You have the right to:
To your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing
Of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to deliver a service to you.
Withdraw consent at any time
Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.