Our vision is a society where anyone with drug or alcohol addictions and complex needs can transform their life. Through our services, and by working with others, we aim to provide the UK’s most effective and compassionate recovery programme. In order to do this we need to have effective communications and fundraising activity. By understanding more about our supporters and potential supporters, we can improve how we communicate the most important messages that you need to hear.

SCT is committed to safeguarding and protecting all forms of personal information.

This policy complies with both the Privacy and Electronic Communications Regulations 2003 (PECR) and with the General Data Protection Regulation (“GDPR”), 2018.

The Spitalfields Crypt Trust is a company registered in England and limited by guarantee. Our company registration number is 3734793. Spitalfields Crypt Trust (SCT) is also a registered charity (charity number 1075947).

This Privacy Policy relates to information which is obtained by SCT and for which SCT is the Data Controller. This means that SCT decides how information about you is used and for what purposes.

SCT’s registered office is Acorn House, 116-118 Shoreditch High Street, London, E1 6JN.

We may collect information about you whenever you interact with us, for example when you:

• Sign up to receive our newsletter
• Donate to us
• Enquire about our activities or services
• Take part in one of our events or fundraise on our behalf
• Attend a meeting with us and provide us with information about you
• Post content to our social media sites (including Facebook, LinkedIn and Twitter)
• Volunteer for us
• Contact us or become involved with us in any other way than as stated above

The type and quantity of information we collect and how we use it depends on why you are providing it.

The information we may collect from the above interactions may include, but is not limited to any of the following:

• Your name, address, telephone number, mobile number, and email address, along with your preferences as to how we should contact you in the future
• Your date of birth
• Financial and credit card information which you give to us, including your gift aid status.
• Records of your donation history, correspondence and involvement in campaigns or events for us
• Your social media contact details (e.g. Twitter handle)
• We might also obtain personal information about individuals who may be interested in giving major gifts to organisations like ours. In these cases, in addition to information you give us directly, we may also collect information about you from publicly available sources, such as your work or interests.
• Any other details which you give to us, including your reasons for supporting us.

Sensitive Personal Information

We will only collect sensitive personal information about you – for example, your health status – when there is a clear reason for doing so. For example, if you were participating in an abseil or similar fundraising event, we might ask you for information relating to your health so that we can put appropriate support in place to enable you to participate in the event.

We will always make it clear when we are requesting this kind of information, why we are doing so, and how the information will be used and stored; we will make clear our legal basis for doing this and we will only process this information with your consent.

SCT may collect information in the following ways:

• When you give us information directly: You may provide your details to us when you sign up to receive our newsletter, make a donation, request specific information, fundraise on our behalf, participate in one of our events, or communicate with us.
• When you give us information indirectly: Your information may be shared with us when you use other fundraising sites and provide your consent to be contacted by SCT: for example, if you are fundraising for us via JustGiving. These organisations will have their own privacy policy and/or privacy statements, so please ensure you understand this when providing your data.
• When you have given other organisations permission to share it: The information we get from these services depends on your settings or the response choices you give, so you should regularly check what you have agreed to with third party organisations. When you give permission to other organisations to share your information, we will contact you to confirm that this is the case.
• Social media: Depending on your settings or the privacy policies for social media and messaging services like Facebook, LinkedIn and Twitter, you might give us permission to access information from those accounts or services.
• When we collect information when you are using our website: Upon visiting our website, information about your visit is recorded. Read our Cookies policy for more details.
• When we send you our digital newsletter: We will record information about each digital newsletter we send to you and your interaction with it, including whether you opened it or not, whether it was undeliverable, the number of times you opened it, and which sections you clicked on. We use this information to measure the effectiveness of our digital newsletters and to plan marketing campaigns.
• Desk Research:

In a limited number of cases, we may use desk research, profiling and screening techniques to analyse your personal information to create a profile of your interests and preferences. This is so that we can contact you with information relevant to you, be prepared when we meet you, or find others like you who might like to lend their support to SCT.

It also allows us to make appropriate and relevant approaches and target our resources more effectively. We may make use of additional information about you, including information related to your wealth. We may on occasion use third party suppliers to undertake these activities on our behalf and provide them with your information to the extent required.

Such information is compiled using publicly available data about you: for example, addresses, listed directorships, social media posts or newspaper articles. This helps us understand the background of the people who do or may support us. It therefore helps us to make appropriate requests for gifts to supporters who may be able and willing to give more than they already do and/or leave us a gift in their will.

Collating this publicly available information helps us better understand your motivations and preferences enabling us to deliver a more targeted and relevant donor experience. Additionally, it enables us to raise more funds, sooner, and more cost-effectively than we otherwise would.

All of our use of personal data is in accordance with the law. The law requires us to process data only where we have a valid legal basis for doing so. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you, such as participation in certain fundraising events.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation, (for example processing and retaining Gift Aid declarations, reporting to Companies House, and other regulatory bodies to satisfy our legal, regulatory and compliance obligations).
• Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending email direct marketing communications about fundraising and events (as detailed in section X).

You have the right to withdraw your consent to marketing at any time by contacting us or clicking the link at the bottom of the digital newsletter we send you: ‘Remove my name from all future email correspondence’.

SCT’s legitimate interests include administering the charity, sending you marketing materials by post, and understanding our supporters. A summary of each of these and some examples of how we may use your data in these ways, on the basis of it being within our legitimate interests to do so, are set out below:

1) Administration of the charity. As a charity our mission is to enable people with drug or alcohol addictions and complex needs to achieve lasting recovery and a more fulfilling life. In order to achieve our mission, we need to undertake certain processing activities. Some of these will be to govern our charity, and some will be for operational administration reasons.

Specific examples of processing activities under this legitimate interest include:

• Recording your communication and marketing preferences and maintaining suppression files so we don’t contact you when you have asked us not to
• Keeping a record of who our supporters are, your relationship with us, and your order and donation history
• Reviewing our database of supporters across the organisation for historical and statistical purposes
• Operational administration such as:
  • Health and Safety
  • Management and planning purposes
  • Thanking you for your support
• Keeping you up-to-date with the work you are supporting
• Administering your donation by sending your bank details to our bank
• Financial management and controls such as:
  • Taking steps to prevent fraud, knowing our donors, and taking steps to ensure there is no misuse of services or money laundering
  • Enforcing legal claims including debt collection and out of court expenses
  • Administering estates and gifts in Wills where SCT is named as beneficiary or executor

2) To contact you by post and phone. Contact with our supporters is vital to the way we operate. We want to keep in touch with you about how your support is helping and what we have achieved together. We also want to let you know about the ways you can get involved with SCT. We believe it is in our legitimate interest to send you such materials by post and to speak to you by phone, unless you have told us you prefer us not to. In order to achieve our mission we need people like you to support us, and to gather your support we need to be able to contact you.

Specific examples of processing activities under this legitimate interest include:-

• sending marketing materials as detailed below, including:
  • Asking for financial and non-financial support
  • Inviting you to events by post and phone

3) Understanding our supporters. It is important that we understand our supporters. If we don’t understand you, then we cannot communicate with you in a meaningful way, and in a way which will be engaging and interesting. If we understand you, then we are better able to direct communications to you which you will be interested in. This helps us safeguard your donations and ensure value for money across our communication activities. In order to understand our supporters better, we undertake a number of processing activities including analysis, research and profiling, as detailed in this policy.

Specific examples of processing activities under this legitimate interest include:

• Analysing our database and seeing what has worked and what hasn’t. This helps inform our marketing strategy so that we send you only information that we think will be of interest to you, and so that we understand the effectiveness of the marketing we send you.
• In limited circumstances, analysing the personal information we collect about you and using publicly available information to better understand your interests, preferences and level of potential donations so that we can contact you more effectively.

If you would like more information on our uses of legitimate interests or to change our use of your personal information in this manner, please contact us.

You have a specific right to ask us not to carry out these kinds of data processing, though we hope that by doing so we will ensure a better and more tailored experience for you. If you do not want your personal information to be processed in a specific way, please contact us using the details below:

Email: privacy@sct.org.uk
Call our Office Administrator on: 020 7613 5677
Or write to: Office Administrator, SCT, Acorn House, 116-118 Shoreditch High Street, London, E1 6JN

We will use your personal information in a number of ways, including for the following purposes:

• To provide you with the services or information you have requested
• To administer your donation, including Gift Aid processing
• To keep you up-to-date with information about  the work you are supporting
• To send you marketing communications, including news, fundraising, events, appeals and campaigns
• To manage your communication preferences, including marketing preferences
• To keep a record of your relationship with us
• To help us improve our services, campaigns or the information we provide
• To ask you for financial or non-financial support
• To support you in your fundraising efforts for SCT
• To maintain our organisational accounts and records
• To monitor the effectiveness of our email marketing
• To analyse our database for statistical purposes, and to communicate better with you about what we think would be of interest. Please note that this analysis is on a generic rather than an individual level
• To update you about any changes to our services
• To invite you to participate in voluntary surveys or research
• To invite you to take a tour of our projects and see our work first-hand
• To invite you to events
• To contact you where you have been identified as a contact person for an organisation, such as a trust or company. (If we obtain your contact details in this way, we will only use them to contact you in the ways in which you have agreed to be contacted.)

Direct marketing

In addition to news and updates on our work, we may also contact you about two other things (Please note: these detail examples of the types of communications we may send, and are not exhaustive):

1. Fundraising: your support is vital to our work and without you we would not be able to continue our work on homelessness and addiction recovery. We may ask you to make a donation, contribute to an appeal, upgrade your support or change its type. We may also ask you to renew or restart your support.

2. Events: we organise various events, from abseils to carol concerts, that we may invite you to participate in or attend. We’d also like to tell you about challenge events such as the Royal Parks Half Marathon or Tough Mudder, which we’d love you to get involved with. We’d also like to tell you about community fundraising opportunities and ways we can support you with your own events.

The law distinguishes between the channels you choose to receive this information, and so we give you different options when we ask to use your information in this way.

We will always ask for your consent if we want to contact you by email or text message. However, we do not normally ask for consent to make telephone calls to you or write to you about either of these things (provided you haven’t specifically told us you don’t want to receive them or if your telephone number is registered on the Telephone Preference Service). This is because, as a charity, each of these activities is fundamental to how we work, so we have a legitimate interest to contact you, as described in above.

When you give us your details, we will tell you what we are going to do with them. You will always be given the opportunity to opt out of receiving these materials by post if you prefer not to. You can unsubscribe at any time – see ‘How to change the way we contact you’ for further information.

Our forms have clear marketing preference questions and we include information on how to opt out when we send you marketing.

If you do not wish your data to be used in any of the ways listed above or have questions about this then please contact us at:

Email: privacy@sct.org.uk
Call our Office Administrator on: 020 7613 5677
Or write to: Office Administrator, SCT, Acorn House, 116-118 Shoreditch High Street, London, E1 6JN

We have appropriate physical, technical and managerial controls in place to protect your personal details; for example our online forms are always encrypted and our network is protected and routinely monitored.

Within our offices only those who have a business need to access your information will have access to your information. 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.

Whilst we hope it will never happen, we have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are required to do so.

When we use external companies to collect or process personal data on our behalf, we undertake due diligence on these companies before we work with them.

Despite all of our precautions, no data transmission over the internet can be guaranteed to be 100% secure. So, while we strive to protect your personal information, we cannot guarantee the security of any information you disclose to us online, and you must understand that you do so at your own risk.

However, any payment card details (such as credit or debit cards) we receive through our website are passed securely to our payment processing providers who meet the required Payment Card Industry (PCI) Security Standards.

We will only use your information within SCT for the purposes for which it was obtained.

Third parties for their marketing

We do not sell or share personal information with third parties for their own marketing purposes.

Service providers / suppliers

We will share information about you with some of our suppliers who process data on our behalf to help us to provide services to you. SCT uses external service providers to support our email communications, fundraising and marketing services. In these circumstances, the relationship between SCT and the external provider is governed by a contract and strict security requirements to protect personal information.

International transfers

We may need to transfer your personal data to suppliers based in the US or other countries outside of the European Economic Area (EEA) to allow them to perform services on our behalf. In doing so, your data may be stored or otherwise processed outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is in place:

• the country has been deemed to provide an adequate level of protection for personal data by the European Commission;
• Where we use service providers based in the USA, it is accredited under the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the USA.

If you would like to receive further information about our safeguards, please contact:

Email: privacy@sct.org.uk
Call our Office Administrator on: 020 7613 5677
Or write to: Office Administrator, SCT, Acorn House, 116-118 Shoreditch High Street, London, E1 6JN

Social media

Depending on your settings and the privacy policies for social media and messaging services like Facebook and Twitter, you might give us permission to access information from those accounts or services. For example, we occasionally participate in Facebook’s “Custom Audience” program which enables us to display adverts to our existing or potential supporters via Facebook. Our adverts may then appear when you access Facebook and on your Facebook feed. For more information please read the Facebook Business page about Custom Audiences and Facebook’s Data Policy.

Where required

We may legally be required to disclose your details if required to by the police or for regulatory reasons.

Where possible, we try to keep your records up-to-date, for example, using data cleaning companies who will check your contact details against publicly available records. However, we really appreciate it if you let us know if your contact details change.

We will only keep your personal information for as long as is necessary for the purpose for which it is collected, which may include the purpose of satisfying any legal, accounting or reporting requirements. If you request that we stop sending you marketing materials, we will keep a record of your contact details and the appropriate information to enable us to comply with your request not to be contacted by us.

In order to determine how long we keep your data we look at the category of data and the reason we collected and have processed it. We look at whether that reason is ongoing and whether you are an active supporter or not. We consider you to be an active supporter if you have opened our mailings and have interacted with us in some way: for example, if you have corresponded with us, signed up for an event and/or financially supported us any time within the preceding two years.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data and whether we can achieve these purposes through other means, and the applicable legal requirements.

Supporter Data

If at any time you cease to become an active supporter then we continue to send you communications for a limited period of time (no more than 3 years for email communications, and 5 years for post and phone call). We will keep your details for a further period of time for Gift Aid and other legitimate purposes such as legal and regulatory reasons (for example, for Gift Aided donations, the HMRC requirement that we keep financial information for 7 years after your last donation to us).

We will keep some data indefinitely (for example your name, address and donation history) as a large proportion of our legacy income comes from people we weren’t aware would leave us a gift in their Will, and knowing that you were a supporter in the past is important for us to know in case your Will is contested. This can be decades after the last interaction with SCT. In these cases, we will only retain data which is necessary for these purposes and will delete or anonymise other parts of your record.

Other data
As detailed above, we may hold personal data about individuals who interact with us in other ways (see ‘What information we collect’). We have a data retention policy which addresses each type of information we hold. Please get in contact if you would like to find out more about how long data is kept in these circumstances.

• Personalised marketing communications (including email contact and/or newsletters)

We will generally treat any marketing consent you give us as lasting for 24 months, but will apply the following exceptions (but only where we inform you of this at the time you give consent).

• Where you have committed to giving us a regular donation (usually monthly).
  In this situation, and unless you withdraw your consent, we will treat consent as enduring until you cancel your donation, at which point your consent will expire 24 months after the last donation. This is to enable us to keep you up to date with the impact of your gifts, and to ask whether alternative means of support would be of interest.

• Where you have notified us that you will be leaving a legacy to SCT.
  This is a lifetime commitment and although we will provide you with regular opportunities to shape and control your communication from SCT, we will treat your consent as ongoing.

You have the right to request a copy of the personal information that we hold about you, commonly known as a ‘subject access request’. If you would like a copy of some or all of your personal information, please email, phone or write to us using the following details:

Email: privacy@sct.org.uk
Call our Office Administrator on: 020 7613 5677
Or write to: Office Administrator, SCT, Acorn House, 116-118 Shoreditch High Street, London, E1 6JN

How to change the way we contact you

You can ask us to stop sending you marketing messages at any time by contacting us, or by following the opt-out links on any marketing message sent to you.

If at any time you’d like us to change how we contact you (via email, phone or post), please contact us at:

Email: privacy@sct.org.uk
Call our Office Administrator on: 020 7613 5677
Or write to: Office Administrator, SCT, Acorn House, 116-118 Shoreditch High Street, London, E1 6JN

You can also now register your details with the Fundraising Preference Service if you want to tell us through the Fundraising Regulator that you would prefer us not to contact you with information on our fundraising, campaigns and events. If you want to stop marketing via telephone then you can also register with the Telephone Preference Service (“TPS”).

We will only email you if we believe you have consented for us to do so. In every email we send there will be instructions on how to unsubscribe. During any phone conversation you have with us, please feel free to let us know how you prefer to be contacted.

Please note that if you request that we stop sending you marketing materials we will keep a record of your contact details and the appropriate information to enable us to comply with your request not to be contacted by us. See ‘How long we keep your data for’.

The right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our supporter insights and supporter demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we are continuing to process your personal information;

The right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it

Access to your information

You have the right to request a copy of the personal information that we hold about you, commonly known as a ‘subject access request’. If you would like a copy of some or all of your personal information, please see ‘How to find out what information we have about you’, above.

Request correction of your personal information

You can request that we correct the personal information we hold about you. This enables you to have any incomplete or inaccurate information that we hold about you corrected. Please note that we may need to verify the accuracy of the new information you provide to us.

Request deletion of your personal information

You have the right to ask us to erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally required or entitled to retain it.

What to do if you are not happy about how SCT manages your information

In the first instance, please talk to us directly so we can help resolve any problems or queries. You can contact us at:

Email: privacy@sct.org.uk
Call our Office Administrator on: 020 7613 5677
Or write to: Office Administrator, SCT, Acorn House, 116-118 Shoreditch High Street, London, E1 6JN

If you are not happy with how your complaint is dealt with, you should contact the Information Commissioner’s Office.  Alternatively, you are entitled to make a complaint to the Information Commissioner’s Office without first referring your complaint to us.

SCT has signed up to the Fundraising Regulator, the independent regulator of charitable fundraising, and works within their standards of fundraising practice.

For further information please see the Information Commissioner’s guidance.

This policy was last updated in May 2018. It was re-worded to give you further information about how we collect, use and store your personal data, and to reflect the changes in law as set out in the General Data Protection Regulation and to give you more clarity on how we use your data, and your rights in relation to it.

We may amend or update this policy at any time: for example, to take account of any changes to data protection law or other legislation.

When further updates to the policy are made they will be posted on this page, so please check back here regularly, particularly if you are sending personal information to us.

Any significant changes will be notified to you.

24 May 2018