Friends, Families and Travellers (FFT) Privacy and Data Protection Statement
Friends, Families and Travellers (FFT) is committed to protecting your privacy. This policy explains how we collect and use the personal information you provide to us whether online or via phone, mobile, e-mail, letter or other correspondence.
By using our website, any of our services, or providing us with any personal information we will assume you are agreeing to your information being used and disclosed in the ways described in this policy.
The EU General Data Protection Regulation (GDPR) effective from May 2018 gives all EU citizens more rights and protections for their personal data, to minimise the possibility of theft and fraud.
These regulations include provisions for the following areas:
- The right to be informed: Organisations must publish a privacy notice, in addition to explaining transparently how they use this personal data.
- The right of access: Individuals will have the right to demand details of any of their data that an organisation may hold. This information must be provided within one month of request at no charge to the individual.
- The right to rectification: If a person’s data is incorrect or incomplete, he or she has the right to have it corrected. If the organisation that holds the information has passed any of that information to third parties. The company must inform the third party of the correction and inform the person which third parties have their personal data.
- The right to be forgotten: A person may request the removal of his or her personal data in specific circumstances.
- The right to restrict processing: Under certain circumstances, an individual can block the processing of his or her personal data.
- The right to data portability: A person can access their data for their own use anywhere they prefer.
- The right to object: A person can object to the use of their personal data for most purposes.
We operate our Data protection in compliance with BS 10012:217: Specification for a personal information management system.
- Our core principles regarding user privacy and data protection
User privacy and data protection are inviolable human rights
- We have a duty of care to people contained within our data
- Data is a liability: it should only be collected and processed when absolutely necessary
- We despise spam in all its forms
- We will never sell, rent or otherwise distribute or make public any personal information
- Relevant legislation
Alongside our business and internal computer systems, the Friends, Families and Travellers website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
This site’s compliance with the above legislation, all elements of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (details of whom can be found in section 9.0 below) for clarification.
Data Protection Act
In carrying out our day to day activities we process and store personal information relating to our supporters and we are therefore required to adhere to the requirements of the Data Protection Act 1998. We take our responsibilities under this act very seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with that Act and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.
- This website collects and uses personal information for the following reasons:
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction.
We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to track their journey through the website.
Although GA records data such as your approximate geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 9.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
We use online forms to help you contact us, to allow you to subscribe to our newsletters, to allow you to purchase items from our online shop or to allow you to purchase licenses for our online Gypsy and Traveller cultural awareness training. The information collected by these forms is send to us via email and stored in the website’s database, long enough to enable us to manage our processes.
If the form includes a payment, some information will be passed onto out third party data processors, PayPal (see section 4 below). In these cases we will also store your computers IP address to help protect against fraud.
We delete any information when it is no longer needed.
Our website contains a shop built upon the Woocommerce platform. By making a purchase you are giving us consent to store information about you so that we can manage supply of your purchases.
Information will be passed onto out third party data processors, PayPal (see section 4 below). We will also store your computers IP address to help protect against fraud.
We need to keep records of sales information in order to comply with UK tax laws.
We monitor abandoned sales (where the person has not completed the transaction) and delete these from our website after a period of time.
3.7 Email newsletter
If you choose to join our newsletter mailings (which is sent via email), the email address that you submit to us will be stored in Mailchimp, which we use for our email marketing. We consider Mailchimp to be a third party data processor (see section 9.0 below). The email address that you submit will be stored within this website’s own database.
Your email address will remain within Mailchimp database on our website for as long as we continue to use this platform for email marketing or until you specifically request removal from the list.
You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
Credit, Debit card payment information
We use PayPal to process personal data on our behalf. The third parties we use are PayPal
Paypal process payments for any products purchase from our website. We do not retain any financial information you may submit as part of the purchasing process.
PayPal monitor every transaction, 24/7 to prevent fraud, email phishing and identity theft. Every transaction is heavily guarded behind PayPal’s advanced encryption. If something appears suspicious, their dedicated team of security specialists will identify suspicious activity and help protect you from fraudulent transactions.
Your data as mentioned below is encrypted before transmission to prevent misuse of the transmitted data by third parties. SSL (Secure Socket Layer) is a security technology which guarantees that your personal data, including credit card information, login data and payment method, are securely transferred via the Internet. The data is encrypted so that is only readable by the PayPal payment system.
Your data which is encrypted, is as follows:
- personal data (address data, telephone number, etc.)
- login data (username and password)
- all methods of payment selected, credit card and bank account
PayPal has been carefully chosen as it complies with the legislation set out in section 2.0.
Whilst we do not have any relationship or contract with Gravatar, we know some customers choose to use this service, hence their inclusion in this section.
Our e-learning module is managed by Me Learning who are a trusted data processor (see Section 9.0). If you purchase an online Gypsy and Traveller cultural awareness training license, your name, email address and organisation (if appropriate) is passed onto Me Learning in order to enrol users on the course. Me Learning may contact you in order to support your ability to access to modules.
6. FFT Services
You may give us your information in order to sign up for one of our events, make a donation, purchase our products, register as a volunteer, use our advocacy, advice or engagement services or otherwise communicate with us.
What personal information we collect
We collect, store and use the following kinds of personal information:
- your name;
- your contact details (including postal address, telephone number, e-mail address and/or social media identity);
- your date of birth;
- your gender;
- your bank or credit card details where you provide these to make a payment;
- if you volunteer for us or apply for a job with us, information necessary for us to process these applications and assess your suitability (which may include things like employment status, previous experience depending on the context, as well as any unspent criminal convictions or pending court cases you may have);
- information about events and activities which we consider to be of interest to you;
- information relating to your health (for example if you are taking part in or attending an event for health and safety purposes);
- where you have left us a legacy, any information regarding next of kin with which you may have provided us to administer this;
- age, nationality and ethnicity information for monitoring purposes; and
- any other personal information you provide to us.
Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this type of sensitive data would be information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality or genetic/biometric information.
We only collect this type of information to the extent that there is a clear reason for us to do so, for example asking for health information if you are taking part in an exercise activity, or where we ask for information for the purpose of providing appropriate facilities or support.
Wherever it is practical for us to do so, we will make why we are collecting this type of information clear and what it will be used for.
How we use your information
We will use your personal information to:
- provide you with the services, products or information you asked for;
- administer your donation;
- keep a record of your relationship with us;
- respond to or fulfil any requests, complaints or queries you make to us;
- understand how we can improve our services, or information by collecting feedback;
- manage our events;
- further our charitable objectives;
- register, administer and personalise online accounts when you sign up to products we have developed;
- send you correspondence and communicate with you;
- generate reports on our work, services and events;
- safeguard our staff and volunteers;
- conduct due diligence and ethical screening;
- process your application for a job or volunteering position;
- conduct training and quality control;
- audit and administer our accounts;
- meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
- carry out fraud prevention and money laundering checks; and/or
- establish, defend or enforce legal claims.
7. How we use your information to tell you about our work
Our marketing communications include information about the latest GRT news, campaigns and requests for support. We operate an ‘opt-in only’ communication policy. This means that, except as set out below, we will only send marketing communications to those that have explicitly stated that they are happy for us to do so. We may use information you have given us directly, for example the record of your previous donations to and/or relationship with us, to tailor our communications with you.
When you have asked for details of an FFT event, we will send you information including, where relevant, reminders on key information about the activity.
We make it easy for you to tell us how you want us to communicate, in a way that suits you. If you don’t want to hear from us, that’s fine, and you can change your preferences at any time. All marketing emails from Friends Families or Travellers will contain a link which will allow you to change your preferences of how we contact you. Alternatively, you can contact us on 01273 234777 or firstname.lastname@example.org to update your preferences.
If you’ve decided you don’t want to be contacted for marketing purposes, we may still need to contact you for administrative purposes. This may include where we are processing a donation you’ve made, thanking you for a donation or participation in an event, or keeping in touch with you about volunteering activities you are doing for us.
8. Legal basis for processing
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via post, phone, text or e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, Fundraising Regulator or Information Commissioner, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying something from us (for instance, a publication) or applying to work/volunteer with us.
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities FFT carries out with personal information. Some examples not mentioned under the other bases above where we are relying on legitimate interests are:
- analysis and profiling of our supporters using personal information we already hold;
- use of personal information when we are monitoring use of our website or apps for technical purposes;
- use of personal information to administer, review and keep an internal record of the people we work with, including supporters, volunteers and researchers;
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example, we need to process it for employment, your vital interests, or, in some cases, if it is in the public interest for us to do so).
Information sharing and disclosure
We will not sell or swap your information with any third party.
We may share your information with our data processors. These are trusted partner organisations that work with us in connection with our organisation’s purposes. All our trusted partners are required to comply with data protection laws and our high standards and are only allowed to process your information in strict compliance with our instructions. We will always make sure appropriate contracts and controls are in place and we regularly monitor all our partners to ensure their compliance.
We may disclose your personal information to third parties if we are required to do so through a legal obligation (for example to the police or a government body); to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for example, in the case of suspected fraud or defamation.
We do not share your information for any other purposes.
The accuracy of your information
We aim to ensure that all information we hold about you is accurate and, where necessary, kept up to date. If any of the information we hold about you is inaccurate and either you advise us or we become otherwise aware, we will ensure it is amended and updated as soon as possible.
Storing your information
We will keep your information for as long as required to enable us to operate our services but we will not keep your information for any longer than is necessary. We will take into consideration our legal obligations and tax and accounting rules when determining how long we should retain your information. When we no longer need to retain your information we will ensure it is securely disposed of, at the appropriate time.
For all areas of our website which collect personal information, we use a secure server. Although we cannot 100 per cent guarantee the security of any information you transmit to us, we enforce strict procedures and security features to protect your information and prevent unauthorised access.
What are cookies?
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work better, as well as to provide information to the owners of the site. A cookie often contains a unique number, which can be used to recognise your computer when a user of your computer returns to a website that it visited previously.
Changing your cookie preferences
The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. An online guide is available if you have difficulties trying to change your browser settings.
We have classified our cookies into two broad types – ‘first party cookies’ and ‘third party cookies’:
- We use Google Analytics cookies which help us monitor the site and improve it to make your experience better.
- We also use some social media cookies which allow you to interact with our website through various social media sites such as Facebook, Twitter and You Tube.
- Our content management system will also set cookies without which the site could not function.
In addition, cookies may be either ‘session cookies’ or ‘persistent cookies’. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached.
We do not use third party cookies that track your usage this and other websites to serve advertising.
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, we shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
Changes to the policy
This policy replaces all previous versions and is correct as of the date at the end of this web page. We will regularly review and update this Privacy and Data Protection Statement and will update, modify, add or remove sections at our discretion. Any changes will be notified to you through on this page. Your continued use of our website, any of our services and/or the continued provision of personal information after we have posted the changes to these terms will be taken to mean you are in agreement with those changes.
You have the right to:
- request a copy of the information we hold about you;
- update or amend the information we hold about you if it is wrong;
- change your communication preferences at any time;
- ask us to remove your personal information from our records;
- object to the processing of your information for marketing purposes; or
- raise a concern or complaint about the way in which your information is being used.
If you wish to find out more about these rights, or obtain a copy of the information we hold about you, please contact our Data Controller / us at:
Friends, Families and Travellers,
113 Queens Road,
Brighton, East Sussex, BN1 3XG
Tel: 01273 234 777
Fax: 01273 234 778
- Privacy queries
If you have any questions or queries about this Privacy and Data Protection Statement, please contact our Data Controller using the above address and contact details.
Date of publication: 25th May 2018