Privacy Policy Privacy and Data Protection Statement BHT is committed to protecting your privacy. This statement explains how we collect and use the personal information you provide to us whether online or via phone, mobile, email, letter or other correspondence. 1. GDPR 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. (See the guidance published by the Information Commissioner’s Office regarding this right) 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, this BHT website is designed to comply with the following national and international legislation with regards to data protection and user privacy: UK Data Protection Act 1998 (DPA) EU Data Protection Directive 1995 (DPD) EU General Data Protection Regulation 2018 (GDPR) 2. Data Protection Act BHT has a designated Data Protection Lead who is tasked with upholding the rights of everyone we collect information about, and ensuring we meet our responsibilities to keep your information safe and use it appropriately. If you would like to ask questions about how your information is used, or raise a concern you can email yourdata@bht.org.uk or write to: Data Protection Lead, BHT, 144 London Road, Brighton BN1 4PH. 3. Collection and use of personal information 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. GA makes use of cookies, details of which can be found on Google’s developer guides. Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website. 3.2 Comments Should you choose to add a comment to any blogs that we have published any personal details you enter with your comment will be saved to this website’s database, along with your computer’s IP address and the time and date that you submitted the comment. This information is only used to identify you as a contributor to the comment section of the respective blog post and is not passed on to any of the third party data processors detailed below. Only your name will be shown on the public-facing website although if the supplied email address is linked to a Gravatar account, your Gravatar photo will also be displayed. Your comment and its associated personal data will remain on this site until we see fit to either remove the comment or remove the blog post. Should you wish to have the comment and its associated personal data deleted, please email us using the email address that you used to comment. 3.3 Email links Should you choose to contact us using an email link only, none of the data that you supply will be stored by this website or passed on to any third party data processors. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices. 3.4 Forms We use online forms to help you contact us, to sell tickets to events and receive donations. The information collected by these forms is sent 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 our third party data processors, Stripe or GoCardless (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. 3.5 Events managers Our website uses event management functionality to enable us to sell tickets to events. Your information will be stored in the website’s database to enable us to manage the event. Payment information will be passed onto the third party data processor Stripe (see section 4 below). 3.6 Shop Occasionally the BHT website contains a shopping facility (to sell event tickets for example) built upon the Woocommerce platform. By making a purchase you are entering a contract with BHT and as a consequence we will store information about you so that we can manage your purchases. Information will be passed onto the third party data processor Stripe (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 six months. 3.7 Email newsletter As part of the registration process for our mailing list, we collect personal information, including your name, email address, and preferences. We use that information for a couple of reasons: to tell you about things you’ve asked us to tell you about, i.e. BHT news, upcoming events and fundraising information; to check our records are right and to check every now and then that you’re happy and satisfied. We don’t share our email lists with any other organisations or businesses. We use a third party provider, MailChimp, to deliver our digital newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see MailChimp’s Privacy Policy. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of our mailings or by emailing Jo Berry at jo.berry@bht.org.uk 3.8 Justgiving donations When you make a donation online via Justgiving or start a fundraising page you will be shown a consent statement from Justgiving. You can update your Justgiving preferences by contacting Jo Berry. See Justgiving’s Privacy Policy here. 3.9 Donor database – Donorfy We use Donorfy as our customer record management system to store personal information about our donors and supporters. The information we provide them with is your name, address, email address and, where applicable, your donation history for our financial records for charity accounting and tax purposes. For more information about Donorfy, please read their Privacy Policy. 4. Credit, Debit card payment information 4.1 Stripe We use Stripe to process payments for any products purchased from our website, and to process one-off donations. If you register for a chargeable BHT event, BHT uses Stripe payment gateway to complete your purchase. In this case Stripe (not BHT) stores your credit card data. Your credit card details are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your credit card information is deleted. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa and Mastercard. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers. For more information, you may also want to read: WordPress Terms of Service WordPress Privacy Statement WooCommerce Use Terms WooCommerce Privacy Policy Stripe Terms of Service Stripe Privacy Policy What is SSL encryption? 4.2 GoCardless If you set up a Direct Debit via GoCardless, your personal data will be stored and processed by GoCardless in line with their privacy policy and systems. Click here to view their Privacy Policy in full. GoCardless will share your contact details with us but your financial details will not be shared with us. 5. 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. 6. 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. 7. Storing your information Although most of the information we store and process stays within the UK, some information may be transferred to countries outside the European Economic Area. This may occur if, for example, one of our trusted partners servers are located in a country outside the EU. These countries may not have similar data protection laws to the UK however, we will take steps with the aim of ensuring your privacy continues to be protected as outlined in this privacy policy. 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. 8. Our website Our websites use cookies to help them work well and to track information about how people are using them. More information on cookies can be found below. 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. Our website contains links to other websites belonging to third parties and we sometimes choose to participate in social networking sites including but not limited to You Tube, Facebook and Twitter. We may also include content from sites such as these on our website however, would advise that we do not have any control over the privacy practices of these other sites. You should make sure when you leave our site that you have read and understood that site’s privacy policy in addition to our own. 9. Cookies 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. How does BHT use cookies? We use cookies to enhance the online experience of our visitors, to better understand how our websites are used (see Google Analytics above). Your rights Our cookies do not store financial information or information which is capable of directly identifying you (such as your name or address). You have the right to choose whether to accept these cookies. You can exercise this right by amending or setting the controls on your browser to reflect your cookie preferences. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of this website. 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: Mozilla Google Microsoft Cookie terminology 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 on this and other websites to serve advertising. 10. Data breaches 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, the Charity shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner’s Office (more information on the ICO website), and we will inform the individuals when required by the ICO. 11. 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 this page. This privacy statement was last updated on 24th May 2018. 12. Your rights 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; 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, obtain a copy of the information we hold about you, or exercise any of the foregoing rights, please contact yourdata@bht.org.uk Note that some of these rights aren’t absolute. For example, we may not be able to forget you if we have to keep some of your data to comply with the law, but we’ll evaluate your request in accordance with applicable data protection laws. BHT will respond to your request within one month of receiving it. Also, note that you have the right to lodge a complaint with the UK Information Commissioner’s Office You can ask us to restrict the processing of your data. We may send you emails with news, event information, fundraising appeals or other messages. If you would no longer like to receive such emails from us, please follow the “Unsubscribe” instructions at the end of each marketing email or contact us and your e-mail address will be removed from our marketing list. 13. Privacy queries If you have any questions or queries about this Privacy and Data Protection Statement, please contact our Data Protection Lead by email at: yourdata@bht.org.uk or write to: Data Protection Lead, BHT, 144 London Road, Brighton BN1 4PH. 14. How do you get my consent? When you provide us with personal information to make a donation, take out a standing order or gift aid declaration, receive information on BHT’s work, register for an event and sign up to volunteer we imply that you consent to our collecting your data and using it for that specific reason only. If we ask for your personal information for a secondary reason, such as marketing, we will ask you directly for your expressed consent. How do I withdraw my consent? If, after you opt-in, you change your mind you may withdraw your consent for BHT to contact you, for the continued collection, use or disclosure of your information, at any time, by emailing us or writing to us at 144 London Road, Brighton, BN1 4PH. 15. Retention Period We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Please note that we have a variety of obligations to retain the Data that you provide to us, including to ensure that transactions can be appropriately processed, to help identify fraud and to comply with other laws and rules that apply to us and to our financial service providers. 16. Other information To see the full scope of activities BHT is engaged in you can see our entry on the Information Commissioner’s Office Register of Data Controllers: Listing Z5222823. Contact Us Housing Advice Contacts Accessibility Complaints Policy Legal Disclaimer Privacy Policy Whistleblowing Policy & Procedure Complaints Form I want to help your work by donating £5 £10 £15 £25 £50 £100 to BHT Sussex Sign up to BHT Sussex's Digital Newsletter Sign up to our free digital newsletter and receive the latest news, events and campaigns straight to your Inbox. 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