1. INTRODUCTION
    1. Suzy Lamplugh Trust is committed to safeguarding the privacy of all our stakeholders, in this policy we explain how we will handle your personal data.

 

  1. HOW WE USE YOUR PERSONAL DATA
    1. In this Section 2 we have set out:
      1. the general categories of personal data that we may process;
      2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      3. the purposes for which we may process personal data; and
      4. the legal bases of the processing.
    2. When you engage with us by telephone, mail, in person, by email or online, we may collect information about you (referred to in this Privacy Notice as 'personal information'). This may include your name, email address, telephone number, job title, bank or credit/debit card details (if you are making a donation or purchase), why you are interested in Suzy Lamplugh Trust, and other information relating to you personally which you may choose to provide to us. If you are a service user of the National Stalking Helpline we may also collect special category data (such as your gender, ethnicity, religion, disability, D.O.B and sexual orientation), as well as information about your experience of stalking and information about your stalker. You will have given us this information or any of the other ways to interact with us.
    3. We may process data about your use of our website and email services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
    4. Data you provide us may be processed and stored in our online database. The account and profile data may include your name, work and personal email address, address, work and personal telephone number, gender, date of birth. The account data may be processed for the purposes of providing our services and communicating with you including through our newsletter. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    5. If you contact the National Stalking Helpline by telephone, we may process data about your use of this service ("telephone usage data"). The telephone usage data may include your (where available), and geographical location (where available), as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our call handling system. This usage data may be processed for the purposes of analysing the use of the telephone service. This data is not recorded in any way which is linked to your individual record without your consent, nor will we contact you using this information without your consent; unless we have reason to believe that this is essential for protecting a vital interest. The legal basis for this processing is our legitimate interests, namely monitoring and improving our telephone service.
    6. If you are a service user of the National Stalking Helpline, we may process anonymised data about your use of the service (“helpline usage data”). The helpline usage data may include collated statistics about the number, frequency, and method of contact with the service; geographical spread of service users, and collated data about service users’ experience of stalking. The legal bases for this processing are having obtained your consent to collect and process this data; our contractual obligations to our funders; and for our legitimate interests, namely in research and campaigning activities around stalking.
    7. If you are a service user of the National Stalking Helpline, we may process anonymised special category data (“special category data”) with your explicit consent. The special category data may include your gender, ethnicity, religion, disability, and sexual orientation. The legal bases for this processing are having obtained your explicit consent to collect and process this data, and for our legitimate interests, namely in research and campaigning activities around stalking. We will take the appropriate safeguards to ensure that this data cannot be connected to individual service users.
    8. If you are a service user of the National Stalking Helpline, you may provide us with your personal details including your name, email address, address, and telephone number (“contact data”). The legal bases for this are having obtained your consent to collect and process this data; our contractual obligations to our funders; and for our legitimate interests, namely in supporting you as a service user, in improving our service, and in research and campaigning activities around stalking with your agreement.
    9. If you are a service user of the National Stalking Helpline, we may be obliged to share your information with a statutory body – such as the police or safeguarding services – where we have a clear reason to believe that you or another individual (whether a child or adult) is at imminent risk of serious harm. The legal basis for this is our vital interest, namely that this processing is necessary to protect someone’s life.
    10. . This stalking data may include information about incidents, their impact upon you, and information about the person who is stalking you. If you do not provide your consent for us to process this data then we may not be able to offer you a service. The legal bases for this processing are having obtained your consent to collect and process this data; our vital interest in managing the risk to you, and our legitimate interest in providing a service which helps victims of stalking cope and recover from their experiences.
    11. We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    12. We may process and pass on information contained in a training agreement to external trainers who are subcontracted to carry out training on behalf of Suzy Lamplugh Trust. The purpose of this is that training can be provided that meets the need of the organisation. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    13. We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
    14. We may process information we obtain from you at conferences, exhibitions, training events and other events we host and attend where you provide us with either personal details of your profession including your name, work and personal email address, address, work and personal telephone number. We will only contact you for the purpose you have agreed to when giving your details to us. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
    15. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
    16. Please do not supply any other person's personal data to us, unless we prompt you to do so.

 

  1. HOW WE WILL USE YOUR INFORMATION IN PRACTICE
    1. We will mainly use your information:
      1. Donation processing or transactional purposes: to process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions. We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, training that we have delivered;
      2. Responding to a request: to provide the services or information that you have requested, for example, in response to a query or complaint;
      3. Administration: to update you with important administrative messages about your donation, a campaign or services, or to record and deal with a complaint, record a request not to receive further marking information, record what our volunteers have done for us, and for other essential internal record keeping purposes;
      4. Monitoring and evaluating our services: we may use your information in order to improve current and future delivery of our services;
      5. Processing an application to work with us: we may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and respond to you or, where you volunteer with us, to administer the volunteering arrangement;
      6. Employment: we need to ensure that we meet our obligations as an employer and manage people effectively in the organisation;
      7. Working with vulnerable adults: we collect essential information to enable us to safeguard vulnerable adults we work with, for example, in campaigns or events;
      8. Fundraising, direct marketing or campaigning: we will only send you marketing information by email, SMS, or telephone you if you have given us specific consent. If you withdraw your consent and then subsequently opt in to receive marketing information again, then your most recent preference will supersede your earlier one. You can opt out of at any time by contacting us by telephone: 020 7091 0014 or email: [email protected];
      9. Providing and developing our website: we may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further;
      10. Prevention of crime: if you visit our office, we may record your image on CCTV which we use to prevent crime and keep our staff, visitors and other users of our office safe;
      11. Protecting your vital interests: we may process your personal information where we reasonably think that there is a risk of serious harm or abuse to you or someone else;
      12. Market research and surveys: we may invite you to participate in surveys or market research to help us improve our website, fundraising, services and strategic development. Participation is always voluntary and no individuals will be identified as a result of this research, unless you consent to us publishing your feedback;
      13. Legal, regulatory and tax compliance: where we are subject to a legal obligation, we may process your personal information to fulfil that obligation;
      14. Profiling and analysis: we want to improve how we talk to you and the information we provide through our website, services, products and information. We may occasionally for the purposes of our legitimate interests use your personal information to conduct profiling of our supporters or potential supporters. To do this we sometimes use profiling and screening methods so that we can better understand our supporters, your preferences and needs to provide a better experience for you.
    2. In addition to this, if you are a service user of the National Stalking Helpline, we will use the information you give us for the following purposes:
      1. Risk management: to provide you will the best possible advice about your situation, including understanding risk and possible measures to reduce risk;
      2. Case management: so that if you contact the National Stalking Helpline again you do not need to repeat the history of your situation;
      3. Anonymised research and monitoring: the collated data produced may be shared, including with funders, but there will be no identifiable information within these reports;
      4. Contact you have consented to: we will ask for your explicit consent to contact you for evaluation, research, case study, or policy and campaign work. We will only contact you if you have given consent and this can be withdrawn at any time.
    3. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to such use of your personal information for profiling at any time by contacting us at the details set out at the end of this Privacy Notice.

 

  1. SENSITIVE PERSONAL INFORMATION
    1. Data protection law recognises that certain types of personal information are more sensitive. This is known as 'sensitive' or 'special category' personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person's sex life or sexual orientation.
    2. If you provide us with any sensitive personal information, we will treat that information with extra care and confidentiality and always in accordance with this Privacy Notice.
    3. With your explicit consent, we may also collect sensitive personal information if you choose to tell us about your experiences relating to our services for use in a case study, regarding stalking and lone working/personal safety.

 

  1. BUILDING SUPPORTER LISTS
    1. We do purchase lists from third sector organisations. We purchase these lists with the intention of acquiring and building relevant contacts for the purpose of offering, marketing and selling relevant products and/or services. The data processed from these lists are name, work email address, organisation and organisation role/position. The data collated and processed from these third-party lists is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. All data purchased is from GDPR-compliant organisations. This data will not be distributed to any third parties.

 

  1. RETAINING AND DELETING PERSONAL DATA
    1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
    3. We will retain and delete your personal data as follows:
      1. Account and profile, profile data, publication and enquiry data will be retained for 7 years following you providing or updating that data, at the end of which period it will be anonymised and deleted from our systems. This means deleting all personal information that could be used to identify any individual, replacing it with an anonymous record. Upon the end of contract with clients, this personal data will be anonymised and deleted from our systems in the same way;
      2. If you are a service user of the National Stalking Helpline, your personal information will be retained for 15 years following you providing or updating that data, at the end of which period it will be anonymised and deleted from our systems. This means deleting all personal information that could be used to identify any individual, replacing it with an anonymous record.

 

  1. AMENDMENTS
    1. We may update this policy from time to time by publishing a new version on our website. The date this policy was last updated was 25th May 2018 in line with the GDPR changes.
    2. You should check this page occasionally to ensure you are happy with any changes to this policy.
    3. We may notify you of changes to this policy by email.

 

  1. YOUR RIGHTS
    1. In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
    2. Your principle rights under data protection law are:
      1. the right to access;
      2. the right to rectification;
      3. the right to erasure;
      4. the right to restrict processing;
      5. the right to object to processing;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent.
    3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
    4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
    5. In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
    6. In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
    7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
    8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
    9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
    10. To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
    11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
    12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
    13. You may exercise any of your rights in relation to your personal data by written notice to us.

 

  1. THIRD PARTY WEBSITES
    1. Our website includes hyperlinks to, and details of, third party websites.
    2. This privacy policy only governs our websites and we are not responsible for the privacy policies that govern third party websites even where we have provided links to them. If you use any link on our website, we recommend you read the privacy policy of that website before sharing any personal or financial data
    3. We operate several social media pages (including Facebook, Twitter, YouTube and LinkedIn). Although this policy covers how we will use any data collected from those pages, it does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.
    4. When you interact with us on social media platforms such as Facebook, WhatsApp, Twitter or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform and the privacy policies of each platform. To change your settings on these platforms, please refer to their privacy notices.
    5. We may obtain information about your visit to our site, for example the pages you visit and how you navigate the site, by using cookies.

 

  1. UPDATING INFORMATION
    1. Please let us know if the personal information that we hold about you needs to be corrected or updated.

 

  1. COOKIES
    1. When you visit our website, we collect information to help us to understand how supporters use our site, and to make improvements. This information consists of your IP address, your browser (e.g. Internet Explorer), when you visited and which pages you visited or downloaded during your visit. We cannot use this information to find out further personal information about you and will not share any individual information unless required to do so by law.

 

  1. RIGHT TO COMPLAIN
    1. If you are not happy about the way in which we are processing your personal data, please contact us at [email protected]. You also have the right to make a complaint to the UK Information Commissioner’s Office.