GDPR – Privacy Notice
1.What the Law says about Protection of Personal Information.
The Law on Data Protection is derived from various pieces of legislation including the Data Protection Act and the General Data Protection Regulation (the ‘GDPR’) which came into force as of 25/05/18. The GDPR states that personal data (information relating to a person who can therefore be identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information, wo0uld fall into the GDPR’s definition of processing.
The GDPR provides legal grounds under which personal information can be processed in a way that is lawful. For processing information, one of the lawful grounds must apply:
- Legitimate Interest
- Legal Obligation
- Vital Interest
- Public Interest
Round Table Children’s Wish (RTCW) is a registered charitable company dedicated to granting ‘handcrafted’ wishes to children with life threatening illnesses. Wishes are developed and delivered to meet the needs of the child and the wider family circumstances. Every wish is bespoke and made to create magical memories for children and those most dear to them.
To grant wishes, RTCW works with other organisations, companies and agencies to ensure that the wish always meets the needs of the child, as well as ensuring it is safe and appropriate.
3.What information we collect?
RTCW collects information in relation to the following work:
RTCW collects personal and sensitive information about children (0-17years) and adults (wish child and wish family members), but only those involved directly with the wish itself. To ensure it delivers a wish that is safe, the charity collects medical information about the child and family to avoid any risk of the wish being detrimental to the illness, condition or wider family circumstances.
Information is provided by families, hospitals, hospices, volunteers, members of the public, consultants and any other person involved with the wish, including the child.
The type of information RTCW usually collects and holds includes, names. addresses, telephone numbers, email addresses, dates of birth, medical records, hobbies and interests of the child.
On occasion we may need to collect bank account details, should we need to make any payment directly to the parent/carer for part of the wish, for example – taxi fees, spending monies for trips. However, this occurrence is rare. We do not ask for any financial details as part of the main application for a wish, as it is not relevant to the Wish application process.
3.2 Fundraising and Events
RTCW collect a range of information from those who fundraise and support the charity. For each event or fundraising activity there will be a need to collect basic contact information so that we can ensure, we are able to communicate with you and support you. For activity where there is a physical run or challenge, we may need to collect information about your medical history or current illness or conditions. More often, this sensitive information is logged and stored directly by the individual with the organisers and RTCW only collects and stores when they are running their own events.
Information is provided by the individual fundraiser or supporter, or maybe received by a legacy.
The type of information collected and stored includes, names, addresses, telephone numbers, email addresses, dates of birth (if applicable).
On occasion we may need to collect bank details. For example, should we need to reimburse a fundraiser for their running place registration fee, should they pull out of an event.
We also collect ‘shirt sizes’ from individuals taking part in runs and challenges, so that we can send them the most appropriate kit for training and taking part.
We collect and store the amount of monies raised, and information relating to gift aid claims.
3.3 Websites, Subscriptions and Social Media
The only personal information we collect and store for marketing purposes, is an email address from individuals who have given explicit consent, to receive mailouts from RTCW.
RTCW may collect information from ‘messenger’ via Facebook, for example, when a member of the public asks us to send information or wants to make a referral for a wish.
3.4 Personnel, Internal & People
RTCW collects and stores, both personal and sensitive information, for internal employment, support and communication purposes. This includes names, addresses, illnesses and conditions, prescribed medication, NI Number and bank details, to pay salaries and expenses. RTCW also collects sufficient information to carry out DBS checks.
RTCW collects and stores ‘personal’ information on Volunteers. This includes name, address, email and telephone numbers. Any sensitive information on volunteers would be collected and stored on a ‘need to know’ basis such as if a volunteer Ambassador is running an event under the name of RTCW. In these circumstances we may seek to collect emergency contact details and any medical information we should be aware of. This would only be collected and stored with consent from the Data Subject.
4.How do we use personal information?
RTCW will never unduly prioritise its interest as a charity, over the interests of the data subject’s rights.
4.1 RTCW use information to keep a record of the relationship involved with us; Wishes, Fundraising and Events, Marketing, Governance. This allows us to make a profile of the activities and history of your involvement with RTCW. This profile may also help us to identify specific events and fundraising opportunities of interest to you.
4.2 It also uses your personal information to carry out the functions and activities of RTCW including to process information, wishes and products you have requested, or donations made, to comply with our legal obligations and to help us manage and provide quality services.
4.3 The Wish Application form asks applicants to provide contact, personal and medical information that we vitally need to be able to fulfil a child’s wish. RTCW will need to share this information, as appropriate, with other organisations, for example when we make travel arrangements for wishes. This is to ensure arrangements meet the needs of the child and family. RTCW will never share your information unnecessarily and we always treat it as confidential and store it securely.
4.4 For each wish application, we liaise and share information with other Wish charities to ensure that each child has not had a previous wish. We do this to ensure we have services in the future to support as many children as possible who are or become poorly. (See Appendix 1 – Wish Application Privacy Notice)
4.5 RTCW on occasion will use wish information to form case studies. Information will be used either on a consensual basis or where the charity anonymises the wish omitting any information that identifies who the child/family is.
4.6 Photos, videos and images of wish children and their wish, will not be used without prior consent. Wish families are given a range of options to consent to, or not consent to as to how we can use information for marketing and fundraising purposes. These can be found in the Wish Application Form.
4.7 Where other organisations are involved with the direct delivery of a Wish, information about the child and family will need to be shared. This is to ensure the wish is fit for purpose and meets the individual needs of the child and family. On these occasions, a Partnership Agreement outlining the arrangements for sharing, storing and the destroying of information, is signed between RTCW and the relevant organisations, is signed.
4.8 For administrative purposes to let you know of any changes, information, reporting of news and granting of wishes.
4.9 We use your information to claim gift aid on your donations.
4.10 We use information, should we need to investigate a complaint, or dispute.
4.11 We will use supporter’s and fundraiser’s profiles when selecting recipients of the RTCW Recognition and Awards Scheme. We undertake this scheme as a method of recognising and valuing the ongoing support of volunteers, to the charity.
4.12 We use information for safeguarding matters such as performing a DBS check or where there is need to refer children and families onto other agencies.
4.13 We use internal information stored, to support the ongoing professional development, service and performance of employees and volunteers (including Trustees). Information may also be used when approached by a future employee to give a Professional Reference.
4.14 RTCW engages with and has its own Facebook, Twitter & LinkedIn pages. RTCW collects data from these pages such as, number of page likes, number of comments and other data-based insights. We never collect or store, any personal information, such as names, email addresses or telephone numbers from these pages. The public have complete ownership over whether they choose to engage with RTCW through social media. The only exception would be as and when RTCW receive messages, from the public via ‘Messenger’ to request items or enquiring about wishes. This would then, be classed as ‘Legitimate Interest’ to store information.
4.15 RTCW collects and stores information on its Trustees, employees and volunteers for legal, communication and safeguarding reasons; Annual Returns, Companies House, Charity Commission, Auditors, HMRC, Payroll and Pensions, are all examples of some of the Agencies and Authorities whom require this information from the charity for legal reasons.
4.16 The charity undergoes DBS checks for all its Trustees and Employees. It occasionally also undertakes DBS checks on those Volunteers, who will be spending time representing RTCW in Hospices and Hospitals or where there is regular contact with children. Information collected is stored with a third-party company who RTCW commissions, to undertake checks on its behalf.
4.17 Irrelevant of involvement with RTCW, we will always seek consent to store your information for marketing purposes. These purposes are for mailouts via email on the work of RTCW and any events and opportunities you might like to get involved with.
5. Who has access to your information?
5.1 We do not share information about children, families, supporters and employees with anyone, without consent to do so, or where the law requires it.
5.2 We NEVER SELL data or information to third parties.
5.3 Where other organisations are involved with the direct delivery of a Wish, information about the child and family may need to be shared. This is to ensure the wish is fit for purpose and meets the individual needs of the child and family. On these occasions, a Partnership Agreement outlining the arrangements for sharing, storing and the destroying of information, is signed between RTCW and the relevant organisations.
5.4 As a registered charity, RTCW is required to undertake a legal audit of its accounts and processes, on a yearly basis. The Appointed Auditor will occasionally need access to the information we hold. This is used as evidence to demonstrate that the charity is acting in accordance with the law and its Charity Commission registered Objectives.
5.5 For each wish application, we liaise and share information with other Wish charities to ensure that each child has not had a previous wish. We do this to ensure we have services in the future to support as many children as possible who are or become poorly.
NB: We recommend that data subjects read Privacy Policies of companies and other organisations they come into or, are in contact with.
6. Transfer of data outside of the UK
6.1 RTCW currently has no need to share information outside of the European Union.
7. Legal Basis for Processing Information
7.1 RTCW will only process information if we have:
- asked you and have a record of your express and consent for us to do so
- a Legitimate Interest to do so, to support our charitable purposes. The need for this will be balanced and never unduly have an impact on your rights
- a contract that we can only fulfil by using personal information e.g. to send you an item you have requested
- a legal obligation to use or disclose information about you, such as Gift Aid claim, Insurances and Audits, part of the wish delivery
- extreme circumstances to do so, such as disclosing to emergency services where there is risk to ‘life and limb’. This falls into the ‘Vital Interest’ ground for using personal information.
8.1 Where RTCW have asked for your consent for processing data, this can be withdrawn at any time by:
Calling: 01202 514515
Writing to: Round Table Children’s Wish, 857 Wimborne Road, Bournemouth, Dorset. BH9 2BG
8.2 At times when we do not need to obtain explicit consent, RTCW will only process personal information when it meets another legal ground, such as ‘legitimate interest’.
8.3 RTCW seek consent for use of photos and videos for marketing and fundraising purposes. Only where consent has been obtained, will RTCW use for such purposes.
8.4 RTCW only sends out ‘general information’ about the charity for marketing purposes, where consent has been received. This is in addition to any other involvement with the charity.
9. Breach of Data
Whilst we make every effort to ensure that breaches of data disclosure do not occur, RTCW has a robust procedure to look into and resolve, any potential reports of data breach. (Please refer to the Breach of Data Procedure).
Review Date: May/June 2019
Round Table Children’s Wish, 857 Wimborne Road, Bournemouth. BH9 2BG
Registered Charity Number: 1060225