This notice explains how we will process your personal information when you engage with us, and provides you with additional information regarding your privacy rights. It is important that you read this Privacy Notice so that you are fully aware of how and why we use your personal data in the context of the services we provide.
For further information, please contact our Data Protection Officer by:
– Writing to Joe’s Buddy Line at Joe’s Buddy Line Charity, The Old Farmyard, Givons Grove, Leatherhead, Surrey, KT22 8LD.
– Emailing to firstname.lastname@example.org.
Who is primarily responsible for your personal information?
Joe’s Buddy Line (Charity number 1193127, registered in England) is primarily responsible for the personal information we collect about you when you engage with us. We are therefore termed the ‘controller’ under the UK version of the General Data Protection Regulation (UK GDPR).
Our registered office address is The Old Farmyard, Givons Grove, Leatherhead, Surrey, KT22 8LD.
What is Personal Information and which laws apply to us?
Joe’s Buddy Line is committed to protecting your personal information, ensuring it is processed in a fair, open and transparent manner.
Your ‘personal information’ is information that can be used to identify you. This can include your name, email address, postal address, telephone number, date of birth and credit/debit card details, as well as ‘sensitive personal information’ such as details about your ethnic origin, political opinions, religious beliefs, physical or mental health and details of criminal offences. Joe’s Buddy Line collects, stores and handles personal information for a variety of purposes, including to manage our volunteers, to process donations made to us, to engage with our supporters, and to provide our services to the public, including schools.
The following laws apply to Joe’s Buddy Line, as an organisation that collects, stores and handles personal information:
- the Data Protection Act 2018
- the General Data Protection Regulation (EU) 2016/679
- the Privacy and Electronic Communications (EC Directive) Regulations 2003
We will handle your information in accordance with these laws.
How do we collect information about you?
We want to make sure you receive the communications that are most relevant to you, be it through visiting our website or receiving emails, post or phone calls.
We collect information from you in a number of ways.
When you interact with us directly: This could be if you ask us about our activities, register with us for training or an event, make a donation to us, ask a question about mental health, purchase something, complete a survey providing feedback on our services, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This includes when you phone us, visit our website, make a purchase from our shops, or get in touch through the post, or in person.
When you interact with us through partners or suppliers working on our behalf: This could be if you access a service which is delivered through a trusted organisation working on our behalf and always under our instruction.
When you interact with us through third parties: This could be if you provide a donation through a third party such as Just Giving or one of the other third parties that we work with.
When you visit our website: We gather general information which might include which pages you visit most often and which services, events or information is of most interest to you. We may also track which pages you visit when you click on links in emails from us. We also use “cookies” to help our site run effectively. Please see our ‘cookies policy’ for more information on this.
We use this information to personalise the way our website is presented when you visit to make improvements and to ensure we provide the best service and experience for you. Wherever possible we use anonymous information which does not identify individual visitors to our website.
From other information that is available to the public: In order to tailor our communications with you to your background and interests we may collect information about you from publicly available sources or through third party subscription services or service providers.
What information do we collect and why?
Personal information we collect includes details such as your name, date of birth, email address, postal address, telephone number and credit/debit card details (if you are making a purchase or donation), as well as information you provide in any communications between us. It may also include photographs or video footage of your attending our events. You will have given us this information whilst making a donation, registering for an event, placing an order on our website or any of the other ways to interact with us.
We will only use this information:
- To process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions.
- To provide the services or goods that you have requested.
- To update you with important administrative messages about your donation, an event or services or goods you have requested.
- To comply with the Charities (Protection and Social Investment) Act 2016 and follow the recommendations of the official regulator of charities, the Charity Commission, which require us to identify and verify the identity of supporters who make major gifts so we can assess any risks associated with accepting their donations.
- To keep a record of your relationship with us.
- Where you volunteer with us, to administer the volunteering arrangement.
If you do not provide this information, we will not be able to process your donation, sign you up for a particular event or provide goods and services you have requested.
We may also use your personal information:
- To contact you about our work and how you can support Joe’s Buddy Line.
- To invite you to participate in surveys or research.
- To use photographs or video footage of those who attend our events to highlight the services we provide. We will always give you the option of opting out of any video footage or photographs we use for promotional purposes.
Sensitive Personal Information
You can of course decide if you want to remain anonymous, if you are happy to share your personal details with staff members or if you would like us to share your story with the media or other parties as part of our work telling people’s personal stories about mental health (for example, on our blog).
Data Protection Law recognises that some categories of personal information are more sensitive. Sensitive Personal Information can include information about a person’s health, race, ethnic origin, political opinions, sex life, sexual orientation or religious beliefs.
If you contact us through our Helplines or in other more general communications with us such as blogs or emails, you may choose to provide details of a sensitive nature.
We will only use this information:
- For the purposes of dealing with your enquiry, training, and quality monitoring or evaluating the services we provide.
- We will not pass on your details to anyone else without your explicit consent except in exceptional circumstances. Examples of this might include anyone reporting serious self-harm or posing a threat to others or children contacting us and sharing serious issues such as physical abuse or exploitation.
- Where you have given us your explicit consent or otherwise clearly indicated to us (for example, by submitting your story through our ‘Your Stories’ website page) that you are happy for us to share your story, then we may publish it on our blog or in other media.
Information about Children and Young People
We sometimes receive limited data about children if they decide to fundraise for us, and we will collect data about children for events we organise specifically for young people or where they agree to volunteer for us. Wherever possible, we will ask for consent from parents to collect information about children and young people under the age of 16.
There may be times where we need to contact you in emergencies. In these instances, we would use your name, email address and/or contact telephone number. It is in our legitimate interest to use this information to be able to contact you in an emergency.
We will only retain your personal data while it is necessary for the purpose we collected it for. Typically, this means we will delete your personal data once the purpose has closed. We may need to keep your personal data for longer than this where it is necessary (i) to establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement; or (ii) to preserve records to be able to deal with external or internal audits.
Confidentiality and Third Parties
Joe’s Buddy Line seeks to preserve the confidentiality of the people who use our service. No identifying information or discussion between you and Joe’s Buddy Line is disclosed to an external third party except in the exceptional circumstances outlined below. However, there are situations where we will pass on information without consent. This may be where there is a legal obligation to do so, or we need to protect your vital interests. We will only share information with people or entities when the law allows us to do so.
We will always think carefully about whether we need to break confidentiality, especially for a young person aged under 18. In the following circumstances, we may need to break confidentiality and engage with a third party:
- we believe your life is in imminent danger;
- we believe you or someone else is at risk of significant harm;
- you are a young person aged 17 or under who is being hurt, abused or neglected;
- you tell us, or we suspect you have committed or are about to commit a serious crime; and/or
- you tell us you are endangering the safety of another person.
Additionally, we are unable to provide confidentiality in the following circumstances:
- a message sent to or through Joe’s Buddy Line contains specific information about a terrorist suspect or terrorist activity that will take place or has taken place. This information must immediately be disclosed to the police; and
- Joe’s Buddy Line is forced through legal action to disclose specific confidential information; this can include legal action taken under the Data Protection Act 2018 or during criminal investigations.
Legal Basis for Using Your Personal Information
There are some lawful reasons that allow us to process your personal information and one of those is called ‘legitimate interests’. This means that the reason that we are processing information is because there is a legitimate interest for Joe’s Buddy Line to process your information.
Whenever we process your Personal Information under the ‘legitimate interest’ lawful basis we make sure that we take into account your rights and interests and will not process your personal information if we feel that there is an imbalance.
Some examples of where we have a legitimate interest to process your Personal Information are where we contact you about our work via post, use your personal information for data analytics, conducting research to better understand who our supporters are, improving our services, for our legal purposes (for example, dealing with complaints and claims), or for complying with guidance from the Charity Commission.
Change of purpose
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. However, we may process your personal data without your knowledge or consent where this is required or permitted by law.
Sharing your Information
Your personal data may be disclosed by us to the following third parties:
- third parties which assist us with providing our services to you;
- other service providers including IT suppliers, administration services providers;
- public bodies, including regulatory bodies, where we are obliged or permitted by law to do so (this may include the Information Commissioner’s Office); and
- our professional advisors including lawyers and auditors.
We may also disclose your personal data to third parties to whom we choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to obtain or merge with other organisations. If a change happens to our organisation, then our new owners may use your personal data in the same way as set out in this Privacy Notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
Keeping your Information Safe
We have put in place appropriate security measures to prevent your personal data from being lost, used, accessed, altered or disclosed in an accidental or unauthorised way. We are committed to ensuring that all reasonable and appropriate steps have been taken to protect your personal data which incudes, where appropriate, utilising encryption measures.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.
Under certain circumstances, you have a number of rights under data protection laws with regard to the personal data we use about you. These are described in the sections below. To exercise any of your rights in relation to Joe’s Buddy Line, please contact us by email at email@example.com.
Right of access to personal data – You have a right to request a copy of the personal data we hold about you.
Right to rectification – If you believe the personal data we hold about you is incorrect, you can contact us to request for any incomplete or inaccurate data that we hold about you to be corrected. However, we may need to verify the accuracy of the new information you provide to us.
Right to erasure – You have the right to request the deletion or removal of personal data we hold about you where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to us holding your information, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with the law. Although we will consider every request for erasure on its merits, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object to processing – You have a right to object to the processing of your personal data where we are using it for the purpose of our legitimate interests. If we agree that your objection is justified we will stop using your information for those purposes. Alternatively, we will explain why we still need to use your information.
Right to restrict processing of your personal data – You have a right to request us to suspend the processing of your personal data in the following situations:
- for the period it takes us to rectify any inaccurate data about you;
- where our use of the data is unlawful but you do not want us to erase it;
- where you want to prevent us from deleting your data at the end of the retention period in the event that you need it to establish, exercise or defend a legal claim;
- where you have objected to our use of your data, but we need to verify whether we (or a third party) have overriding legitimate grounds to use it.
Right to request the transfer of your personal data to you or to a third party – You have the right to ask us to transfer certain information we hold about you to a third party you have chosen, or directly to you. Where your request is valid, we will provide you with your personal data in a structured, commonly used, machine-readable format.
Right to lodge a complaint
If you have any complaints about how we handle your personal data, please contact us by email at firstname.lastname@example.org and we will do our best to assist.
You also have a right to make a complaint to the supervisory authority in your country of residence or employment or place of the alleged infringement. The Information Commissioner’s Office (“ICO”) is the UK supervisory authority for data protection issues. You can contact the ICO:
by Telephone: 0303 123 1113 or 01625 545 745
or in writing to: Information Commissioner’s Office (ICO)
or via their website: https://ico.org.uk/