PRIVACY POLICY

Scholarships for Street Kids is committed to protecting your personal data.

Please read this policy carefully to understand how we collect, use and store your personal data.

WHO ARE WE? 

The processing of your personal data is carried out by or on behalf of Scholarships for Street Kids which is a registered charity in England and Wales (number 1131559)

HOW CAN YOU CONTACT US?

If you have any questions or concerns regarding our Privacy Policy or our processing of your personal information, please contact:

The Data Protection Officer
Scholarships for Street Kids
72-74 Sun Street, Haworth, Keighley BD22 8AH

Email: s4skfinance@gmail.com

HOW DO WE COLLECT YOUR INFORMATION?

We may collect information about you directly whenever you interact with us. For example, when you contact Scholarships for Street Kids regarding our activities, or receive information, engage with our social media or make a donation to us, you may provide us with your personal information.

We may collect aggregated or anonymous information when you visit our website or interact with our content.  For example, we may collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our website.

WHAT INFORMATION DO WE COLLECT?

The information we collect from you directly or from third parties with whom we work, may include:

• name
• address
• email address
• bank account details for setting up a regular direct debit
• taxpayer status for claiming Gift Aid

We may also collect and process information about your interactions with us, including details about our contacts with you through email, SMS, post, on the phone or in person (i.e., the date, time, and method of contact), details about donations you make to us.

HOW DO WE USE YOUR INFORMATION?

We may use your information in a number of ways, including:

• To provide you with information about our work or our activities;
• To process donations we may receive from you;
• To fundraise in accordance with our internal policies and procedures;
• For administrative purposes (for example, with a query regarding a donation you may have made to us);
• For internal record keeping relating to any donations, feedback, or complaints;
• To contact you where you have been identified as a contact person for an organisation such as a grant making trust (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organisation unless you have separately indicated that you are happy to be contacted as an individual supporter);
• To analyse and improve the content and operation of our website;
• To analyse and improve our internal business processes;
• Where we are required by law to disclose or otherwise use your information.

If you have provided us with your postal address or telephone number, we may send you information about our work or other communications of the kinds described above by direct mail or contact you by telephone unless you have told us that you would prefer not to hear from us in this way.  We provide information about how you can change your marketing preferences below.

HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?

You can opt out of your data being combined and analysed for marketing purposes by contacting our Data Protection Officer as described above.

HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?

We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect Scholarships for Street Kids, for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.

HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION? 

We will keep and delete your information according to our internal policies and will keep it no longer than reasonably necessary for the purposes for which we hold it, taking into account relevant legal and regulatory retention requirements (e.g. tax or health and safety requirements) and operational considerations.

HOW CAN YOU UPDATE THE INFORMATION WE HOLD ABOUT YOU?

If you have indicated that you do not wish to be contacted for fundraising purposes, we will maintain your details on a suppression list to help ensure that we do not continue to contact you for marketing purposes.  However, we may still need to contact you for administrative purposes, including (but not limited to):

• Processing a donation you have made and any related Gift Aid;
• Explaining and apologising where we have made a mistake.

Similarly, if your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us.

WHAT OTHER DATA PROTECTION RIGHTS DO YOU HAVE?

Under UK data protection law, you have certain rights over personal information that we hold about you. These rights are summarised below. Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances.

You can assert your rights, raise a concern, or make a complaint about how we process your personal data by contacting our Data Protection Officer.  It will assist us, if you explain your request or concern and describe the personal information you are referencing as specifically as possible. In order to action your request, we may need to request further information or request that you provide proof of identity.

Your rights in relation to our processing of your personal information, include:

Right to object to the processing of your data - you have the right to object to our processing of your personal data in certain circumstances.  If you object, please explain your objection and the reason for it.  If you are objecting to the processing of your data for direct marketing purposes, you can tell us in any of the ways described in the section ‘How can you change your marketing preferences or update the information we hold about you?’ above and we will stop processing your data for those purposes as soon as reasonably possible.

Right to have inaccurate or incomplete personal information corrected or completed - if you believe our records of your personal information are inaccurate or incomplete, you have the right to ask us to correct or complete those records.

Right to restrict processing – in certain circumstances, you have the right to ask us to stop making active use of the personal information that we retain in our records about you, if there is disagreement about its accuracy or legitimate usage.   

Right of erasure - in certain circumstances, you have the right to request that we delete your personal information from our records.

Right of access - you can write to us to ask for confirmation of what information we hold relating to you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exceptions that apply.

Right to receive your personal information in a portable format – in limited circumstances, where we are processing information you provided to us because you gave us your consent or because it is necessary for the performance of a contract and the processing is carried out by automated means, you may ask us to provide it to you in a portable format.

If you are not happy with how we have handled your request or complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in the UK.

Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first. 

WHY ARE WE ALLOWED TO PROCESS YOUR PERSONAL INFORMATION? 

Our Privacy Policy takes into account several laws, including:

• the Data Protection Act 2018
• the Privacy and Electronic Communications (EC Directive) Regulations 2003
• General Data Protection Regulation (EU) 2016/679

Generally, our processing of your personal information as described in this policy is allowed by these laws based on one or more lawful grounds, including:

• Where you have provided your consent to us using your personal information in a certain way. 
• Where the processing is reasonably necessary to comply with a legal obligation to which we are subject.  For example, we may rely on this basis where we are obliged to share your personal information with a regulator or HMRC.
• Where the processing is reasonably necessary for the purpose of a legitimate interest pursued by us or a third party and your privacy rights do not override the legitimate interest.  Our “legitimate interests” include pursuing the aims and ideals of Scholarships for Street Kids through advocating and campaigning for the welfare of children in Myanmar. However, "legitimate interests" can also include your interests, such as when you have requested information from us, and those of third parties, such as our beneficiaries.

For example, we rely on legitimate interests for activities such as sending marketing communications by post or telephone unless you have told us that you would prefer not to hear from us in this way, contacting you as a representative of an organisation about charity partnerships or in order to organise an event, and analysing your interaction with us to improve our internal business processes.

In any event, where we are relying on legitimate interests to process your personal information, we will consider any potential impact on you (positive or negative), your rights under data protection laws, and will not use your personal information for activities where the impact on you overrides the legitimate interests in the processing.

Where we process sensitive personal data (as mentioned above), we will make sure that we only do so in accordance with one of the additional lawful grounds for processing that type of data, such as where we have your explicit consent or you have made that information manifestly public.

May 2018