Privacy Notice for Donors

Who are Centrepoint?

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 called Data Protection Law) and the information set out in this privacy notice.

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). 

What the law says Centrepoint must do

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

What information do we collect?

We may collect your:

• Name;
• Address and previous addresses;
• Email address;
• Telephone number (mobile);
• Contact preference; 
• Tax status;
• Bank account details; 
• Debit/credit card details;
• Date of birth;
• Biographical details; 
• Identification details, and;
• Survey responses.
• Copies of your will and your solicitor’s details, for legacy pledgers, and; 
• Identification details.

Why do we collect your information?

We collect your information in order to: 

• Acknowledge and process any donations made by you;
• Set up direct debits for recurring donations; 
• Acknowledge and process any sponsorship you have made; 
• Provide you with information about the activities of Centrepoint and its partners;
• Administer support that you provide to Centrepoint;
• Personalise our fundraising activity; 
• Adhere to statutory and regulatory compliance;
• Process any enquiries or complaints raised by you and responding to any communications from you;
• Undertake due diligence to protect Centrepoint and our supports from risk of harm; 
• Share your information to third parties with whom we have a relationship under which your Personal Data is protected;
• Transfer your Personal Data to HMRC in respect of any Gift Aid claims; and
• Send electronic communications to you keeping you informed about the activities and fundraising campaigns falling into any of the above categories.

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.

Processing your data

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
• That you have made a donation or sponsorship to the Charity and as a result have shown a willingness to support the work of Centrepoint;
• To set up a regular donation to Centrepoint; 
• The need to comply with regulatory requirements in relation to your donation, for example, the need to keep donation records for a minimum of seven years for accounting purposes;
• That the processing is reasonable in relation to the activities to which they relate;
• That the processing is such as you would reasonably expect to be undertaken by Centrepoint in respect of managing your donation; 
• That the processing is necessary in respect of the Charities activities and is in the interests of Centrepoint and the relevant third parties and does not limit your interests or fundamental freedoms guaranteed by Data Protection Law.

If you would like 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 undertake any further processing of your personal data other than that which is set out in this statement. However, if this changes Centrepoint will provide you with further information.

Where do we get your personal data from?

We get your personal data from:

• You directly. You are the source of all the personal data about you which we process. 

How do you share and/or transfer my personal data?

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

• HMRC
• Service providers to provide you with the services you have requested. For example, web hosting providers, telephone system providers, cloud storage providers, marketing companies and payment companies for the processing of donations and payments; 
• Third parties with whom we have a relationship including sub-contractors; 
• Data analysis companies and agents who undertake analysis and profiling activities to help us measure and improve our marketing, communications, and fundraising activities. 

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. 

How long do you keep my personal data?

We will store your personal data for the duration of our relationship with and for seven years after that relationship ends.  We will store personal data in accordance with our retention policy. 

What are my personal data rights?

• You have a right to ask Centrepoint to confirm whether or not your personal data is being processed by Centrepoint. To do this contact our Data Protection Team.
• 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(s). 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. To exercise this right contact our Data Protection Team.
• You have the right to data portability - that is to ask us to transfer your personal data electronically to another organisation in certain circumstances. To ask us this contact our Data Protection Team.

How do I complain? 

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 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. 

Cookies

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. 

Definitions

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

• 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.

Contact

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.