Sensory Trust is committed to safeguarding the privacy of your personal data. Please read the following policy to understand how your personal data will be treated as you make full use of our services.
1. Who are ‘We’?
In this policy, the words ‘We’, ‘Us’ or ‘Our’ refer to Sensory Trust and its subsidiary and affiliated companies, including Orange Spiral Limited and any other companies that may be incorporated as part of the Sensory Trust Group of companies. Either of these may be the data controller, data processor or both data controller and data processor of your personal data that We collect from you from time to time.
It's really important to Us that you trust Us with your personal data so We want to make sure that you understand what personal data We hold about you and how We collect, store and process it. We comply with the Data Protection Act 1998 and any other relevant statutory and self-regulation such as the Charities (Protection & Social Investment Act) 2006.
We will use your personal data in the way(s) set out in this policy. If you are not happy with the way that We are using your personal data, please do not provide us with your personal data (We have set out more information on how We collect your personal data below). If you have any questions about this policy, or what We do with your personal data, please contact Us using the contact details below.
You can contact Us about this policy at [email protected] or write to the Information Manager, Sensory Trust, Fig Leaf Building, Eden Project, Bodelva, Cornwall PL24 2SG.
2. What is personal data?
Personal data is information about you that can help Us identify you, such as your name, address, phone number or email address, or more discrete data such as the device type and IP address of any smartphones, tablets or similar mobile devices you own.
There are also special categories of personal data that are treated by law as being particularly sensitive. This may include your racial or ethnic origin, your religious beliefs or information related to your health. We will only ever collect special categories of data where We have your explicit consent to do so, where it is in your vital interests that We do so, or to enable Us to make decisions regarding the services that We provide to you.
3. What personal data do We collect about you?
The nature and the type of personal data We collect will depend on why you are giving it to Us. Developing a fuller understanding of our supporters and service users through your personal data allows Us to make better decisions, fundraise more efficiently and to ensure We provide support to more people with disabilities and long-term health conditions.
We collect personal data about you when you:
- purchase items from Our online shop. We collect information such as your name, contact details, delivery address (if applicable) and your anonymised bank/credit card details;
- interact with Us on Our social media pages (such as Twitter, Facebook, and Instagram). We collect information about you from Twitter and Facebook's sites if the settings on your accounts or the privacy policies of those sites give Us permission to do so. This would include your name, and any direct or private messages sent to Us);
- participate in events hosted by Us or if you make a donation to us. We collect information such as your name, contact details and delivery address (if applicable). In some circumstances (e.g. if you were taking part in a project activity) We may also ask you for information related to your health;
- voluntarily provide Us with your personal data whilst completing surveys, signing up for events, or providing feedback. We collect information such as your name, email address, postal address and any additional comments or information you give to Us.
4. What do We use your personal data for?
When processing your personal data, We will only do so in relation to specific purposes and only after giving careful consideration to ensure that your privacy rights are not seriously impacted.
We will process the personal data that you provide to us in the following ways for the purpose of (and on the basis of) our performance of our contractual obligations to you:
- To provide you with the services that you have requested or purchased from Us, such as fulfilling your purchase of a product through Our website;
- To administer Our events that you wish to attend, such as if you attend a dementia-friendly activity club We will need to process your information to deliver the activity, including your medical information to ensure that you are protected on the day;
- To process donations or other payments, to verify financial transactions and to claim Gift Aid on your donation;
- To record any contact with you and provide you with information that is tailored and relevant to you;
- We may occasionally use external information to check the accuracy of the contact details We hold. For example, the Royal Mail Postcode Finder is used if We have an incomplete or inaccurate address;
- From time to time We may use external data sources to create a profile of your interests so that Our communications to you are as appropriate and cost effective as possible;
- With your consent, We will send you occasional information to let you know about the work of the charity, the services We provide, to ask for support, or to send details about fundraising events and activities;
- Sharing your story. If you give your consent to share your experience of Sensory Trust, this may be made public by Us at events, in materials promoting Our charity and fundraising work, or in documents such as Our annual report.
We will only retain such profiles for as long as it is appropriate to do so and will always delete this data responsibly in line with Our data retention procedures.
If you cease to have an active relationship with us or request no further contact, we may retain some basic information to avoid sending you unwanted materials in the future and to ensure that we don’t accidentally duplicate information.
5. Who do We share your personal data with?
Except where We use third party services to collect information, when you are asked for personal data by Us, you are sharing that information with Us alone, unless We specifically state otherwise below. As explained above, 'Us' includes Sensory Trust, Orange Spiral Limited and other companies that may be incorporated as the part of the Sensory Trust Group of companies. Our group shares various operations and business processes so We need to share data within our group in order to fulfil our contractual obligations to you, or because it is in our legitimate interests to do so.
We may also provide your personal data to third parties who may process your data as part of the services they carry out on Our behalf. In order to provide you with the services that you have requested from Us, the following third parties may also need to process your personal data:
- third party product and service providers who We engage on your behalf to provide the products or the services that you have agreed to purchase (such as the purchase or delivery of goods purchased on Our website. This may include, for example, courier companies (such as DPD), Royal Mail;
- any statutory, governmental or regulatory body that requests the personal data and that We are obliged (by law or by regulation) to provide;
Please be aware that web sites that have links on Our site may collect personally identifiable information about you. This privacy statement does not cover the information practices of those web sites.
As Our requirements change, We may need to change the third parties that process your personal data to meet those requirements.
We do not sell or rent your personal data to anyone, We will never provide your personal data to another company or charity for their marketing purposes without your explicit consent.
6. How do We protect your personal data?
We will always do Our best to keep your personal data secure. Steps We take in order to do this include the use of technical controls (such as secure servers, firewalls and network protection), limiting the number of people working for Us who have access to your data and ensuring that they are trained in protecting your personal data.
Where We use external suppliers to process your personal data, We put contracts in place to make sure that they treat it as carefully as We would and use it only in accordance with the instructions that We give to them. Where these suppliers operate outside of the European Economic Area (EEA), We will make sure that the levels of protection provided are at least equal to those required by UK law.
7. Retention of your personal data
We will only retain your personal data for as long as We need to keep it. In considering how long to retain your data we will always take into account factors such as any ongoing obligations We have to You, the nature of Our relationship with You, legal requirements (e.g. in relation to HMRC statutory retention periods) and contractual requirements. We will not keep Your data indefinitely and will always dispose of it carefully when it is no longer necessary for Us to retain it, in line with defined schedules in Our data retention procedures.
8. Your Rights – What are the choices available to you regarding collection, use and distribution of your personal data?
The law gives you a number of rights in relation to your personal data and Our use of it. You have the right:
- to ask Us not to use your personal data for direct marketing purposes;
- to ask to see what personal data We hold about You and to find out about the way that We process the data (and in some circumstances, You can ask Us to provide a copy to a third party);
- to ask Us to correct or update any personal data which is inaccurate;
- to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for Us to continue to process it;
- to ask Us to temporarily stop using your data if You don't believe that We have a right to use it, or to stop Us from using your personal data where there is no good reason for Us to continue to use it; and
- not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
If you are unhappy with the way We have dealt with your personal data or if you have any further questions about how We process and retain personal data please contact Us in the first instance so that We can try to put this right.
If you are still not satisfied, you have the right to lodge a complaint with the Information Commissioner’s Office. Further information on how to do this is available on the ICO website.
9. Changing this policy
We may make changes to this policy from time to time. If We make any significant changes to this policy that impacts the way in which your personal data is treated, We will post the changes on this page or, where We feel that the changes are really significant, We may contact you directly. Changes will apply from the time We post them (either here on Our website or when We contact you). This policy was last changed on 16 May 2018.
10. How can you access, update or delete your personal data?
In addition to the click options throughout this policy, You may change or update any or all of the personal data that We hold about you by contacting Sensory Trust’s Information Manager by email to [email protected], by post to Information Manager, Sensory Trust, Fig Leaf Building, Eden Project, Bodelva, Cornwall PL24 2SG, or by telephoning 01726 222900.
Last Updated 15 April 2020