This policy contains important information about your personal rights to privacy and how and why Clarke Foley uses your personal information. It sets out how we process your data and explains your rights and options around how we use your personal information.
What this policy covers
- Clarke Foley’s Charity and Company registrations
- Our commitment to your privacy
- Information we collect about you
- Information about online donations to Clarke Foley
- Technical information collected when you visit us online
- What counts as personal information
- What counts as sensitive personal information
- How we use your personal information
- Storing and keeping your personal data
- Our lawful grounds for processing your information
- How to contact us
Clarke Foley’s Charity and Company Registrations
For the purposes of this policy, “Clarke Foley” means The Clarke Foley Centre (registered charity in England & Wales (1109588) and company limited by guarantee (5389427). Our registered office is Clarke Foley, Cunliffe Road, Ilkley, LS29 9DZ.
Our Commitment To Your Privacy
We are committed to protecting your privacy. We promise to respect any personal information you share with us and to keep it safe.
However, there are times when we may need to share personal information, but these times will be limited.
For example, if you become ill whilst at Clarke Foley and we have to call for the emergency services, we may have to share your personal information or in the case of a potential safeguarding issue.
The only other time we would be required to share your information is if we were legally required to do so.
INFORMATION WE COLLECT ABOUT YOU
When we collect information directly from you
We collect information directly when you:
- Request to rent a room
- Make a donation - online or by other means
- Apply to work or volunteer
- Sign up for our monthly newsletter
- Take part in an event, including raffles
- Purchase food and drinks from our café
- Join a Clarke Foley Lunch club
- Attend a Clarke Foley organised class or activity
And we collect information when you give it to us indirectly
This is when your personal information is given to us by third parties. These might be:
- websites such as Charities Aid Foundation (CAF) who we use as an agent to collect online donations
- business partners
- sub-contractors in technical, payment and delivery services
- event organisers
You will always hear from them when this happens, and you will be told how and why we intend to use that information.
You might tell us through a third-party website (such as the Ilkley Half Marathon) that you would like to fundraise for Clarke Foley by taking part in an event. When this happens, we will contact you to check how you would like to hear from us in the future and to offer you support with your fundraising efforts.
And some information that is publicly available
Some information about you may be in the public domain, using public registers such as Companies House, the electoral roll and press reports. For example:
- whether you have charitable interests.
- to establish possible common connections between Clarke Foley’s network and yours.
- depending on your privacy settings for professional services such as LinkedIn.
Information about online donations to Clarke Foley
Our collection and processing agent
In order to receive online donation payments, Clarke Foley has appointed The Charities Aid Foundation (CAF) as its collection and processing agent.
The ‘donate’ button on the Clarke Foley website redirects donors to its online donation page with CAF. Online donations are made in pounds sterling and can be made by CAF payment, credit and debit cards and Paypal, as well as direct debit donations.
Clarke Foley claims the gift aid on donations made by UK taxpayers. This means that designated employees of Clarke Foley can access reports from our CAF account with personal information from donors which includes:
- amount donated
- gift aid status, and
- method of donation (e.g. via card or Paypal).
Your payment details
Clarke Foley at no time has access to any credit or debit card details used for online donations.
When making an online donation, as the Donor you are providing personal information that CAF will hold as a Data Processor. CAF does this as an agent for Clarke Foley and Clarke Foley remains the Data Controller.
CAF processes all payments made as donations, collects the funds and transfers these to a bank account nominated by Clarke Foley. CAF uses encryption technology and adopts security and anti-virus practices routinely used and adopted as a matter of good practice by financial services business in the United Kingdom.
CAF uses the BACS automated clearing system and complies with their standards.
Under the agreement with CAF, both CAF as the agent, and Clarke Foley as its customer shall comply with their obligations under applicable Data Protection legislation.
CAF and Clarke Foley shall only process Personal Information for the purpose of lawfully providing or receiving the donation service provided by CAF.
If you change your mind about an online donation
If you donate and then change your mind, you can request a refund from CAF and they will refund this within their own timescales and those imposed by third party providers, in a reasonable manner.
Clarke Foley does its best to ensure that our website and the donate button are kept fully operational and secure to ensure that software is virus free.
Clarke Foley uses a cookie file in order to operate the ‘donate’ button and by using this button you agree to the use of this cookie on your computer or device.
When making a donation online, you should take all reasonable precautions to protect your computer and websites from virus infection.
If, when making an online donation, you believe there is an issue or that something seems suspicious, please report this immediately to the Business Manager at Clarke Foley by calling 01943 607016 or email email@example.com.
TECHNICAL INFORMATION COLLECTED WHEN YOU VISIT US ONLINE
When you visit the Clarke Foley website
When you visit our website, the following personal information is collected automatically:
- technical information, including:
- the internet protocol (IP) address used to connect your computer to the internet
- your browser type and version
- your time zone setting
- browser plug-in types and versions
- your operating systems and platforms
- information about your visit to our website, including:
- the uniform resource locator (URL) clickstream to, through and from this site (including date and time)
- products/services you viewed and searched for
- page response times
- download errors
- length of visits to certain pages
- referral sources (how you arrived at the website)
- page interaction information (such as scrolling and clicks)
- methods used to browse away from the page.
WHAT COUNTS AS PERSONAL INFORMATION
We collect, store and use the following kinds of personal information:
- Your name and contact details, including postal address, telephone number, email address and, where applicable, social media profile URL
- Your date of birth
- Information about your computer/mobile device and your visits to and use of this website, including for example your IP address and geographical location
- Information about our services which you use/which we consider of interest to you
- Information as to whether you are a taxpayer so that we can claim Gift Aid.
WHAT COUNTS AS SENSITIVE PERSONAL INFORMATION
The General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (DPA18) recognises certain categories of personal information as sensitive and therefore requiring more protection.
For example, this includes information about your health, religious beliefs, ethnicity and political opinions.
If you inform us of sensitive health related information that we need to know in order to keep you safe at Clarke Foley, we may then record this.
Additionally, if you attend a regular lunch club or group or class with Clarke Foley, you may be asked for an emergency contact number which we will record.
The GDPR/DPA18 prohibits the processing of sensitive personal data (special category data) unless additional conditions are met.
How we use your personal information
We use your personal information to:
- To keep you safe whilst at Clarke Foley
- To contact you to provide further information about our work, services, activities or fundraising
- allow you to purchase goods or services
- process your donations
- further our charitable aims, including for fundraising activities
- register and administer your participation in events you’ve registered for
- report on the results and impact of our work, services and events
- use IP addresses and monitor website use to identify locations, block disruptive use, record website traffic or personalise the way information is presented to you
- to process your application for a job, fulfil your contract of employment or volunteer role with us
- training and/or quality control
- audit and/or administer our accounts
- satisfy legal obligations which are binding on us, for example arising from contracts entered into between you and us or in relation to regulatory, government and/or law enforcement bodies with whom we may work
- prevent fraud, misuse of services or money laundering and to perform due diligence in respect of larger donations
- communicate with you in any other way
Fundraising and Marketing
We use your details to give you information about our activities, events, services and/or products which we think might interest you, when you have given us consent to do so.
For example, we might contact you about rooms you have rented in the past or send you updates about our fundraising appeals, volunteering opportunities and latest campaigns.
We will not share your information for marketing purposes
We never share, sell or rent your information to third parties for marketing purposes.
However, in general we may disclose your personal information to selected third parties in order to achieve the other purposes set out in this policy.
In particular, we reserve the right to disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets
- if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets
- if we are under any legal or regulatory duty to do so; and/or
- to protect the rights, property or safety of Clarke Foley, its personnel, users, visitors or others.
storing and keeping your personal information
We promise to keep your personal information safe and secure.
We have appropriate and proportionate security procedures and organisational and technical measures in place to help us do this.
Only appropriately trained employees and volunteers (Trustees only) can access your information. It is stored on secure servers with features to prevent unauthorised access.
In general, the personal information that we collect from you will be stored at a destination within the UK.
However, we use agencies and suppliers to process personal information on our behalf.
Your personal information may therefore be transferred or stored outside, and/or otherwise processed by contractors operating outside, the UK who work for us or for one of our suppliers.
Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure.
How long we keep your personal information
In general, if we no longer need your information for the reasons you gave it to us, we remove your personal information from our records six years after the date it was collected.
But we will remove it sooner if:
- your personal information is no longer required for the purpose you shared it with us
- we are no longer lawfully entitled to process it
- you ask us to remove it.
You can ask to us to remove your data
If you ask to receive no further contact from us, we will keep some basic information about you to make sure we do not send you unwanted materials in the future. If you wish us to remove your data, please write to:
The Business Manager
Our lawful grounds for processing your information
The GDPR/DPA18 requires us to rely on one or more lawful grounds to process your personal information. These are the grounds we think are relevant.
- Where you have given your consent for us to use your personal information in a certain way.
- For example, we will ask for your consent to use your personal information to send you electronic direct marketing/fundraising
- Where necessary so that we can comply with a legal obligation (for example, where we need to share your personal information with regulatory bodies which govern our work and services).
- Where necessary for the performance of a contract which we have with you or to take steps before entering a contract (for example, if you hire a room or apply to work for/volunteer with us).
- Where there is a legitimate interest in us doing so (for example, writing to supporters to let them know about our work and ways of supporting us).
What do we mean by ‘legitimate interests’?
The GDPR/DPA18 allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests, as long as that processing is fair, balanced and does not unduly impact your rights.
In broad terms, our “legitimate interests” means running Clarke Foley as a charitable entity in pursuit of our aims and ideals. For example, by:
- processing donations
- administering events
- taking applications for employees and volunteers.
How do we balance these interests?
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 for activities 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).
Other than as stated above, we do not intend to collect sensitive personal data and there is therefore no need to process it.
These are your rights in relation to how we process your personal information:
Right to be informed
You have the right to be told how your personal information will be used. This policy and other policies and statements used on this website and in our communications provide you with a clear and transparent description of how your personal information may be used.
Right of access
You can write to us to ask for confirmation of what information we hold on you and to request a copy of that information.
Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will give you your personal information (subject to any exceptions that apply).
Right of erasure
You have the right to ask us to delete your personal information, and we will do this when you ask us to. In many cases, we will check to see if you are happy for us to make it anonymous first, rather than delete it completely.
Right of rectification
If you believe our records of your personal information are inaccurate, you have the right to ask us to update those records.
You can also ask us to check the personal information that we hold about you if you are unsure whether it is up to date.
Right to restrict processing
You have the right to ask us to restrict the processing of your personal information if there is disagreement about its accuracy or legitimate usage.
Right to object
You have the right to object to processing where we are:
- processing your personal information on the grounds of legitimate interest or
- using your personal information for direct marketing
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time.
This includes the right to ask us to stop using your personal information for marketing or fundraising by electronic means (for example to be unsubscribed from our email newsletter list).
How to exercise your rights
- To exercise any of these rights, please send a description of the personal information in question using the contact details below. We reserve the right to ask for:
- personal identification
- further information.
- Please note that you may only use/benefit from some of these rights in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) or please contact us.
- You have the right to make a complaint to the ICO about us or the way we have processed your personal information.
Information Commissioner's Office
Telephone: 0303 123 1113
Fax: 01625 524510
Changes to this Notice
We may update this Policy from time to time so please check back periodically. We will notify you of significant changes by placing a notice on our website. This Policy was last updated in July 2020.
Links and third parties
We link our website directly to other sites. This Policy does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.
How to contact us
Write to us at:
Attention of: The Business Manager
Telephone: 01943 607016