We collect, use and are responsible for certain personal information about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
1. Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our
World’s Big Sleep Out Trust with charity number SC049124 and registered address c/o Lindsays, Caledonian Exchange, 19A Canning Street, Edinburgh, EH3 8HE.
Any information relating to an identified or identifiable individual.
Special category personal information
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership,
Genetic and biometric data,
Data concerning health, sex life or sexual orientation.
2. Personal information we collect about you
We may collect and use the following personal information about you:
- your name and contact information, including email address, postal address, and telephone number and company details;
- your date of birth;
- your gender information;
- confirmation that you are a member of the PVG scheme;
- secondary contact details for you including this person’s name, phone number and email, and confirmation that they are also a member of the PVG scheme;
- information about the services we provide to you;
- details of any feedback you give us by phone, email, post or via social media; and
- information about how you use our website, IT, communication and other systems.
3. How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website, such as when you make a donation or fill in one of our online forms. However, we may also collect information:
- from publicly accessible sources, eg Companies House, social media websites or Office of the Scottish Charity Register;
- directly from a third party, eg:
- fundraising platform providers (Virgin Money Giving); and
- our events registration portal (Primo Events Ltd).
- via our IT systems, eg:
- automated monitoring of our websites and email and instant messaging systems.
4. How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so. In order to use your personal information, we rely on the following legal bases:
- to comply with our legal and regulatory obligations;
- for the performance of a contract we have with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party (in particular, in making sure we can keep in touch with you regarding the Big Sleep Out programme); or
- where you have given us clear consent for us to process your personal information for a specific purpose.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
We will only process special category personal information with your explicit consent.
If consent is the basis for our processing of your personal information, you have the right to withdraw your consent at any time. If you wish to do so, please contact us using the details listed at set out below – see 'How to contact us'.
We collect and process your personal information in order to:
- provide services to you;
- create and manage your Virgin Money Giving account for Big Sleep Out;
- verify your identity;
- customise our website and its content to your particular preferences;
- notify you of any changes to our website or to our services that may affect you;
- improve our services;
- respond to communications from you;
- provide you with information about events or fundraising activities you may be interested - in or are registered with; and
- process donations.
5. Who we share your personal information with
We routinely share personal information with:
- Our fundraising platform providers, Virgin Money Giving; and
- Other third parties we use to help us run our business, eg marketing agencies, mail fulfilment services or website hosts.
- The City Event Organisers so they can manage the event (ticketing, welfare etc) and contact you with information relating to the event
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
6. How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- for after-care services including feedback, distribution of participation certificates and to notify you of the Big Sleep Out programme running again in the future, unless you ask us not to;
- to show that we treated you fairly; or
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Further details on how long we retain your personal data are available on request using the contact details set out below – see “How to contact us’.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
7. Where your personal information is held
Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.
8. Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
- with our service providers located outside the EEA; or
- if you are based outside the EEA.
These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you would like further information regarding the mechanisms used to comply with data protection law, please contact us (see ‘How to contact us’ below).
9. Cookies and similar technologies
For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.
10. Promotional communications
We would like to send you information about future events and projects, fundraising activities and ways you can get involved, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone or text message (SMS).
We would also like to do this so that we may send you promotional material, depending on what you agree with us.
We will only ask whether you would like us and other organisations to send you marketing messages when you tick the relevant boxes when you make an account, or sign up to an event.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:
—contacting us at [email protected]; or
—using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
For more information on your rights in relation to marketing, see 'Your rights’ below.
11. Your rights
You have the following rights, which you can exercise free of charge:
The right to be provided with a copy of your personal information (the right of access)
The right to require us to correct any mistakes in your personal information
To be forgotten
The right to require us to delete your personal information—in certain situations
Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the data
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email or write to us —see below: ‘How to contact us’;
- let us have enough information to identify you (eg. your full name, address and email address);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
13. Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We have put in place suitable physical, electronic and managerial procedures to safeguard and secure your personal information. Steps we take to secure and protect your personal information include:
- keeping a data processing activities log, which we review every six months to ensure security measures for data processing are sufficient and adhered to;
- securing all personal information in an online cloud based system with restricted access; and
- ensuring we use password protection on files if we ever exchange personal information via emails.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
14. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 08th May 2019 and last updated on 14th October 2019
We may change this privacy notice as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our website www.bigsleepout.com
16. How to contact us
Our contact details are shown below:
Our contact details
The World’s Big Sleep Out Trust
1 Leith walk