Privacy Policy

Policy Owner: Lucy van Amerongen (lucy@sionmullanefoundation.com)

SMF Privacy Policy

The Sion Mullane Foundation is the controller and responsible for your personal data (collectively referred to as the SMF, Foundation, "we", "us" or "our" in this privacy notice).

The purpose of this Privacy Policy is to inform you of the types of personal information which we collect from you and how we use your personal information.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 7th February 2021 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Our policy

GDPR provides the legal framework that defines how personal information can be used. The SMF is fully committed to complying with the principles set out in GDPR and has a legal duty to protect any information we collect from you. Please read this privacy policy to understand how we use your data. In summary:

·         Only information that we need is collected.

·         Your personal information is only used for the purpose for which we collect it.

·         Your personal information is only seen by those who need it to do their jobs.

·         We will only disclose data when we have your consent, or where we are obliged to disclose personal data by law, or as expressly permitted under the GDPR (through contract; legal obligation, vital interests; public task; or legitimate interests).

·         We will keep your information up to date. Inaccurate or misleading data will be corrected as soon as possible.

·         Personal information is retained only for as long as it is required for the purpose collected; normally, this will be for a maximum of 7 years if we do not hear from you during this time.  Unless there is a legal requirement to do otherwise, at the six-year point, we will take steps to remove your information from our records.

·         Your information will be protected from unauthorised or accidental disclosure and processed in an appropriate manner to maintain its integrity and confidentiality.

·         We will provide you with a copy of your personal information on request (please see below for information on access rights and requests).

These principles apply whether we hold your information on paper or in electronic form.

How do we collect information?

We obtain personal information from you when you enquire about our activities – including fundraising and trading – register with us, send or receive an email, make a donation to us, ask a question or otherwise provide us with personal information. We may also receive information about you from third parties, for example from mailing list brokers.

We may collect technical information relating to your use of our website, including your browser type or the Internet Protocol (IP) address used to connect your computer to the internet.

We also gather general information about the use of our website, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in emails.

If you provide services to the SMF, we will collect information in line with your contract for services.

We will only ever collect the information that we need, including data that will be useful to help improve our services. The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You do not have to disclose any of this information to browse our sites.

What information do we collect?

The personal information we collect might include name, date of birth, email address, postal address, telephone number and credit/debit card details.

We may also collect special categories of personal data such as information about your health if this is required for the purpose you have contacted the SMF. We collect special categories of personal data only if we are permitted to do so by data protection law, and we have additional measures in place to protect this data.

Why do we collect this information?

We collect this information for the purpose of promoting the aims of the Charity and communicating effectively and appropriately with our supporters and, in particular, providing support to our beneficiaries. The lawful basis for which we process your information is:

·         Your consent;

·         processing is necessary for the performance of a contract to which you are a party. If you fail to provide this information, we may be unable to perform the contract;

·         processing is necessary for compliance with our legal obligations, for example to comply with our obligations as an employer to disclose employee salary details to HMRC;

·         processing is necessary to protect your interests or that of another person;

·         processing is necessary for the performance of a task carried out in the public interest;

·         processing is necessary for the purpose of the legitimate interest pursued by us or a third party, except where your rights as a data subject override our legitimate interest. The legitimate interest we rely upon is subject to a assessment based on the specific context and circumstances.

How do we use this information?

We will use the information you provide in the ways set out below:

·         promote the aims of the SMF;

·         to provide and personalise our services to beneficiaries;

·         to communicate with our supporters, dealing with your enquiries and requests, recording any contact with you;

·         to provide you with information that you have indicated an interest in, for example information about our campaigns, volunteering, fundraising and trading activities and how you can donate to us;

·         we may use this information to personalise the way our website is presented when users visit it, to make improvements to our website and to ensure we provide the best service for users;

·         to claim Gift Aid on your donations;

·         to conduct market research;

·         segmentation, so that we can offer supporters information relevant to them;

·         for administrative purposes.

If you enter your contact details in one of our online event registration forms, we may use this information to contact you even if you do not “send” or “submit” the form. We will only do this to see if we can help with any problems you might be experiencing with the form or with our websites.

Do we share your information with anybody else?

We share your personal information with our suppliers, who we engage to process data on our behalf. In such cases information is only shared for the purpose of providing services on our behalf relating to communications, or agreements between yourself and the SMF. Such processing is conducted under relevant Data Processing Agreements.

We also may need to disclose your information if required to do so by law or as expressly permitted under applicable data protection legislation.

We do not sell personal details to other charities or other third parties.

Our websites may include links to websites run by other organisations. The SMF is not responsible for the privacy practices of these other websites so you should read their privacy policies carefully before sharing any personal or financial data.

Storing and protecting your information

We recognise the concerns that many people have about giving personal information online.

We place great importance on the security of all personally identifiable information associated with our beneficiaries, supporters, and volunteers. We have security measures in place to protect against the loss, misuse and alteration or destruction of personal data under our control. Information is stored by us on computers located in the UK. We may also store information on paper files. All our online forms are protected by encryption. We also use a secure server when you make a donation or payment via our website.

However, no data transmission over the internet is 100% secure. As a result, whilst we cannot absolutely guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to prevent this and protect your personal information.

We will keep your information only for as long as we need it to provide you with the goods, services or information you have required, to administer your relationship with us, to inform our research or the preferences of our supporters, to comply with the law and tax accounting rules, or to ensure that we do not communicate with people who have asked us not to. When your information is no longer required, we will always dispose of it securely.

Your rights

You have a right to object to the SMF processing your personal information (‘right to object’) at any time where we rely on our legitimate interests for doing so.  Such a request must be sent to the Data Protection Officer at the above address.

You also have a right to object to our processing your data for the purposes of marketing. The SMF always acts upon your choices around what type of communications you want to receive and how you want to receive them. You have a choice about whether you want to receive information about the Charity’s work and fundraising and trading activities. We make it easy for you to tell us how you want us to communicate, in a way that suits you. We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted.

You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’).

You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records. If your personal details change, please help us to keep your information up to date by notifying us.

You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’). This right does not apply where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest.

You have a right to ask us to restrict our processing of your information (‘right to restriction’) if:

·         You contest its accuracy and we need to verify whether it is accurate;

·         the processing is unlawful and you ask us to restrict use of it instead of erasing it;

·         we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims;

·         you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests;

·         you exercise your right to restrict processing, we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons.

If you would like to exercise any of your rights above, please contact the us at our address below or by email. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.

Lucy van Amerongen
The Sion Mullane Foundation
77-79 Blythe Road
London
W14 0HP

Email: lucy@thesionmullanefoundation.com

You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113.

Cookie usage

The SMF website uses cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device. Our site uses cookies dropped by us or third parties for a variety of purposes including to operate and personalise the website and to ensure you see content that is relevant to you. Cookies help us to provide you with a better experience by allowing us to understand what areas of the website are of interest to our visitors (e.g. via Google analytics).

Most browsers will allow you to turn off cookies. Please note however that turning off cookies will restrict your use of our website. To learn more about cookies and how to manage them, visit AboutCookies.org.

When you first visit our site, you are given the option to opt-out of cookies but please be aware that this may negatively impact on your ability to view and use content on our website.

Trademarks and copyright

The SMF website contains material which is protected by copyright and/or other intellectual property rights. All copyright and intellectual property rights including the names, images and logos are owned by the SMF unless otherwise stated. All rights are reserved.

You are responsible for complying with all applicable copyright laws. We permit you to make copies of information on the SMF website as necessary incidental acts during your viewing and you may take a print for your personal use of so much of the site as is reasonable for private purposes. All other uses are prohibited. Nothing in these terms shall be construed as conferring any right to use any trademark, logo, patent right or copyright of the SMF.

Changes

We may change the terms of this privacy statement on occasion but will not reduce your rights under this Privacy Policy without your explicit consent. If we do so, we will post the changes here, so please check from time to time. We will also keep prior versions of this Privacy Policy in an archive. By continuing to use our websites you will be deemed to have accepted such changes.

Data protection regulator

Further information and advice about data protection is available from:

The Office of the Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: +44 (0) 01625 545 745

Website: www.ico.org.uk

Fundraising Preference Service

ABF The Soldiers’ Charity is committed to empowering our supporters to manage their information. The Fundraising Preference Service (FPS) enables donors to take control of their charitable giving and conversations; and we want to help you use the service effectively.

The SMF supports the Fundraising Regulator and its efforts to develop the Fundraising Preference Service as a means of rebuilding trust between charities and the public. The Charity is committed to upholding fundraising best practice and being as transparent as possible with our donors.