Privacy

Centrepoint Soho, a company limited by guarantee (Company Number: 01929421) and a charity registered with the Charity Commission for England and Wales (Charity Number: 292411) which is also registered as a Housing Association (No. H1869) and its trading company CP Trading Limited, a company limited by shares, Company Number: 02951328 both of which have their registered office at Central House, 25 Camperdown Street, London, E1 8DZ (together Centrepoint) process your personal data in accordance with the UK Data Protection laws, specifically GDPR as defined below and the Data Protection Act 2018 (together the DPL) and the information set out in this privacy statement.

Centrepoint Soho (the Charity) is the UK's leading youth homelessness charity. We support young people aged 16–25 across 60 services in London, Yorkshire, Manchester, and the North East of England. We also do some trading activities through CP Trading Limited (CP Trading). 

GDPR means EU Regulation 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the General Data Protection Regulation - GDPR) which has been directly imported into the law of England and Wales, Scotland and Northern Ireland (UK Law) by virtue of section 3 of the European Union (Withdrawal) Act 2018 as amended by the Data Protection, Privacy and Electronic Communications (Amendment Etc.) (EU Exit) Regulations 2019.

The Information Commissioners Office (ICO). The ICO is the regulator with the responsibility for protecting the personal data rights of people within the UK, under the General Data Protection Regulation 2016/679 and Data Protection Act 2018 (DPA). Our Registration No. is ZA5455259. 

Centrepoint are registered as a “Data Controller” with the ICO. As a Data Controller we decide what information we collect, how we collect it, the purpose for which we collect it and what we do with it. This means we have specific responsibilities in relation to the personal data we collect. 

This privacy statement sets out how Centrepoint processes your personal data. Legally we must have different statements for the different data we collect - young people, donors, volunteers, supporters etc. These can be found at https://centrepoint.org.uk/privacy. 

We may collect your:

• Name;
• Address and previous three addresses;
• Email address;
• Telephone number (mobile);
• Contact preference; 
• Gender identify; 
• Racial or ethnic origin; 
• Religious or philosophical beliefs; 
• General health, physical and mental health information; 
• Sexual orientation; 
• Actual or alleged criminal offences; 
• Employment details;
• References and disciplinary history; 
• Work history; 
• Education history, including school, college etc. and qualifications;
• Unique learner reference number; 
• Outcome of initial assessments; 
• Current housing status and housing history; 
• Information in relation to your hobbies and interests; 
• Details of your next of kin; 
• Bank account details; 
• Debit/credit card details;
• Date of birth;
• Biographical details;
• National Insurance Number;
• Identification details, such as passport, driving licence etc. 
• NHS number; 
• Next of kin/emergency contact information; 
• Health care providers (GP, Dentist etc.)’ 
• Key worker information from external support agencies;
• Immigration status; 
• Language requirements; 
• Survey responses; 
• Vehicle information; 
• Trade union membership; 
• Political opinions;     
• Records of your engagement and communication with us; 
• Your photo and CCTV image; 
• Any content featuring you that has been produced for our website, publications, social media, articles, and blog posts;
• Donation information and Gift Aid details;
• Photographs and video recordings, and; 
• Information you have entered on to our website.   

We collect your information in order to: 

• provide and administer Centrepoint’s accommodation services;
• provide information, advice, and guidance services; 
• respond to enquiries; 
• further our charitable aims; 
• process personal details to administer training courses; 
• comply with all statutory and regulatory compliance;
• process any enquiries or complaints raised by you and responding to any communications from you;
• share your personal data to third parties with whom we have a relationship under which your personal data is protected; 
• process donations, grants received, sponsorship and administer Gift Aid; 
• administer Centrepoint’s bursary fund; 
• administer events; 
• communicate with you about our fundraising, campaigns, and the work that Centrepoint does; 
• manage your communication preferences; 
• process job applications, or volunteering opportunities and manage the recruitment process; 
• undertake research, conduct surveys and gather feedback;
• undertake research to find out more about the background and interests of our supporters and prospective  supporters; 
• ensure we comply with our contractual obligations to our funders, and; 
• undertake profiling of your information, for example by understanding where our donors come from, what you do and what you care about.  This informs our fundraising and marketing campaigns and helps us to effectively communicate with you. 

Please note that Centrepoint needs to process your personal data to provide our services to you and to make sure we meet our legal obligations, as set above. If you do not provide your personal data, we may not be able to provide you with some or all of the services you have requested.

You can object to your personal data being used by Centrepoint by contacting our Data Protection Team.

In order to process personal data the law says Centrepoint must have a legal basis to do so. The legal basis which allows Centrepoint to process your personal data are:

• legitimate interests for Centrepoint to provide you with a service(s)
• for the performance of a contract
• to comply with legal obligations
• to protect your vital interests or those of another person
• you are accessing our services; 
• you have made an application to become a volunteer, trustee, or employee at Centrepoint; 
• you have made a donation, or sponsorship; 
• we need to comply with regulatory requirements;
• reasonable in relation to the activities to which they relate;
• the processing of your personal data is reasonable for Centrepoint to operate its functions and
• is necessary for the activities that are undertaken;
• is in the interests of Centrepoint and the relevant third parties and does not limit your interests or fundamental freedoms guaranteed by the Data Protection Law.

If you want to withdraw your consent of us processing your personal data, we would still be required to retain your personal data for a time that is reasonable to fulfil the purpose in this notice, meaning that consent is not freely available.

When you made contact with Centrepoint you created a relationship between us. Where you did not opt out of receiving electronic communications from us, we have treated this as consent to send you communications electronically (commonly called “a soft opt in”). As the legal basis of the processing, Centrepoint undertakes in relation to electronic communications is your consent, please note that you may withdraw this consent at any time.

It is not intended that Centrepoint will undertaking any further processing of your personal data other than that which is set out in this statement. However, if this position does change Centrepoint will provide you with further information.

We get your personal data from:-  

• You directly, by completing paper forms, by contacting our helpline and web chat, by face to face or email conversations with a member of Centrepoint’s staff;
• Digital forms completed through our website and online surveys; 
• Our social media pages; 
• Local authorities as a referral; 
• Local agencies who have referred you to one of our services, and;
• Third party companies and websites.

We may share or transfer your personal data with the following organisations or types of organisations: 

• Service providers to provide you with the services you have requested. For example payment companies for the processing of donations and payments; 
• Third parties with whom we have a relationship providing services to Centrepoint and other charities combatting homelessness; 
• Regulatory and Quality Mark organisations to undertake inspection and audit activities, to ensure the quality of our work and to improve the services we provide; 
• Data analysis companies and agents who undertake profiling activities to help us measure and improve our marketing, communication, and fundraising activities; 
• Police and Social Care Services where we have a legal duty to share information for the prevention and detection of crime; 
• Local Authorities to report performance indicators on homelessness and outcomes for young people; 
• Department for Levelling-up, Housing and Communities to record details of lettings and sales in social housing and to provide statistical information on trends in social housing, characteristics of tenancies and types of tenancy agreements.

It is the intention of Centrepoint that your personal data will remain within the countries of the European Union (EU) and the European Economic Area (the EEA) and countries where the EU has decided that the country has adequate data protection laws in line with those in the EU.

Your personal data will only be transferred outside of the EEA or another country which has been declared as having adequate data protection laws, where:

• The transfer is necessary for the performance of any contract with you;
• You have entered your personal data into our website and the information has been transmitted from your server to our server using systems based outside of the EEA;
• We have entered into an appropriate contract protecting your rights and freedoms which is enforceable by you or the data protection authorities or
• We have obtained your explicit consent.

Generally, we do not expect that your personal data will be transferred outside of the EEA. 

We will store your personal data for the duration of our relationship with you unless a longer period is permitted by law. We will store your personal data in accordance with our retention policy. 

• You have a right to ask Centrepoint to confirm whether or not your personal data is being processed by Centrepoint.
• You have the right to access your personal data. To access your personal data please contact our Data Protection Team.

Please note - we will only provide personal data to you if we are satisfied you have established your identity. This may include a copy of your passport or other identification document. We will only provide information to you at an address which we have verified as belonging to you.

• You have a right to ask us to correct any inaccurate or incomplete personal data which we process about you. To do this, please contact us. Giving an explanation of why you believe the information is inaccurate will help us correct the information.
• You have the right to ask Centrepoint to delete certain personal data relating to you (as set out in Article 17(1) of the GDPR). Please email dataprotection@centrepoint.org setting out the reasons why you would like your personal data deleted.
• You have a right to ask Centrepoint to restrict the processing of your personal data. Please email dataprotection@centrepoint.org setting out the reason(s) you would like the personal data Centrepoint holds about you to be restricted.
• You have the right to object to your personal data being processed, for example, automated decision making, direct marketing and profiling activities. 
• You have the right to data portability - that is to ask us to transfer your personal data electronically to another organisation in certain circumstances.

Please contact the Head of Compliance who acts as our Data Protection Officer. 

In writing at Centrepoint, Central House, 25 Camperdown Street, London E1 8DZ;

By email at dataprotection@centrepoint.org; or

By telephone by calling 0800 587 5158.

You can email complaints@centrepoint.org. 

You also have the right to lodge a complaint about the processing of your personal data by Centrepoint by contacting the Information Commissioner’s Office (ICO). The ICO can be contacted at: Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone No. 0303 123 1113, or https://ICO.org.uk. 

In order to improve our website, we use ‘cookies’ and similar technologies. Cookies are small pieces of information sent by us to your computer or mobile device and stores on your device to allow us to recognise you when you next visit. 

We will ask you whether you give your consent for the use of cookies when you enter our website. 

For information, please see our Cookies Policy, which can be found - https://centrepoint.org.uk/cookie-policy. 

The following terms have the following meaning in this Privacy Statement:

• Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law. 
• Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
• Special Categories of personal data means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

The Data Protection Officer can be contacted:

In writing at Centrepoint, Central House, 25 Camperdown Street, London E1 8DZ;

By email at dataprotection@centrepoint.org; or

By telephone by calling 0800 587 5158.