NET Privacy Notice
We are committed to protecting your personal information and being transparent about what we do with it, no matter how you interact with us. Our commitment to you applies whether you are working, volunteering, donating, an advocate, using our services, receiving information, wanting to simply learn more about what we do or are engaged with us in some other way.
We are committed to ensuring that your personal information is only used in accordance with our responsibilities, which are set out under the following applicable laws:
- the European Union General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) and the Data Protection Act 2018 (‘DPA’) referred to as the ‘data protection legislation’
- the Privacy and Electronic Communications Regulation (2003)
How we will use your information is confirmed within this document, which we call our Privacy Notice. We promised that we won’t do anything with your information you wouldn’t reasonably expect.
Processing of your personal information is carried out by or on behalf of the National Emergencies Trust (NET); registered as a charity in England, Wales and Scotland.
This notice, together with our website terms & conditions and our cookies policy tells you all about how we collect, use and will protect your personal information.
If you have any queries about our Privacy Notice, please get in touch with our Information Governance team:
Post 44 Moorfields, London, EC2Y 9AL
How and when will you collect personal information about me?
When you directly give us information
We may collect and store information about you when you have any contact with us. Examples of this could be when you:
- support our work through making a donation
- undertake fundraising on our behalf
- register for an event
- tell us your story
- submit an enquiry
- register for our newsletter
- give us feedback
- make a complaint
- apply for a job
- register as a volunteer
- enter into a contract with us
- are captured by our CCTV recording.
When you indirectly give us information
When you interact with us on social media platforms, including Facebook, WhatsApp, Twitter and LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have selected on each platform and the privacy policies of each individual platform. To change your settings on these platforms, please refer to the individual platform privacy notices.
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. More information about this can be found in our cookies policy.
What personal information will you collect about me?
When you engage with us by phone, mail, in person or online, we may collect information about you (referred to in this Privacy Notice as ‘personal information’). This may include your name, address, email address, telephone number, date of birth, job title and details of your education and career, why you are interested in NET, and other information relating to you personally which you may choose to provide to us.
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.
Sensitive information will only be collected where necessary, for example, we may need to collect health information from you when you register for a challenge event or to deliver a community service as a volunteer or member of staff. Clear notices will be provided at the time we collect this information, stating what information is needed, and why.
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.
What if I am under 16?
If you’re aged under 16, you must get your parent/guardian’s permission before you provide any personal information to us, it is important that you do this.
How and why will you use my information?
We will use your personal information for the following purposes:
Donation processing: We will process any personal information you provide in order to administer any one-off or on-going donations you make and to enable us to claim Gift Aid.
Responding to a request: If you contact us with a query, we may use your personal information to provide you with a response.
Fundraising or direct marketing: We will only send you marketing information by email, SMS, or phone 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 expressed preference will be used. If you respond to a fundraising appeal by post, you may also receive fundraising mail, which you can opt out of at any time by contacting us using the details below.
Post: 44 Moorfields, London, EC2Y 9AL
Monitoring and Evaluating: We may use your information in order to improve current and future delivery of our services.
Co-production: We may invite you to participate in projects or initiatives that enable you to help develop or review our services, shape our research, media, policy and advocacy activity. Your participation is always voluntary. Your decision whether to participate will not affect you accessing a NET service in the future. We never identify an individual who participates in a co-production project, unless we have gained their explicit consent to this in advance.
Processing an application to work with us: If you apply to work with us, whether on a permanent or voluntary basis, we will only use the information you give us to process your application or to monitor recruitment statistics on an unidentified basis. If we want to disclose information to someone outside the NET, for example, if we need a reference from your previous employer, we will tell you beforehand. The only exception is where the law obliges us to disclose information to a third party (such as the police) and we are not allowed to tell you. If you are unsuccessful in a job application, we may hold your personal information after we’ve finished recruiting for the post you applied for, for up to 12 months to deal with any follow up queries or issues.We keep statistical information about all applicants to develop our recruitment processes however no individual applicant would be identifiable from this information.
If you commence employment with the NET, your personal information will be processed in accordance with your employment contract and other applicable human resources policies we have from time to time.
Transactional purposes: 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
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.
Administration: We may use your personal information 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.
Prevention of crime: We may record your image on CCTV which we use to prevent crime and keep our people and the public safe.
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.
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.
Legal, regulatory and tax compliance: Where required we are subject to a legal obligation, we may process your personal information to fulfil that obligation.
Profiling and analysis: We may occasionally for the purposes of our legitimate interests use your personal information to conduct profiling of our supporters or potential supporters. 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.
Our profiling and analysis activities can be broken into five categories:
- Data matching
We may combine the personal information you have given us with data obtained from external sources, such as the Office for National Statistics, to infer the likely social, demographic and financial characteristics, so we can tailor our communications and services to better meet your needs or the needs of others like you based on the insight we gain from the profile we build. We will not use the results of this data matching activity in a way that intrudes on your privacy or your previously expressed privacy preferences.
We conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that campaigns or mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who may fall within a certain segment of supporters.
- Major donor analysis
We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources such as Google and Companies House, published biographies, and publicly available LinkedIn profiles. The type of information we collect can include:
- career overview
- gift capacity
- areas of interest
- history of giving to us and others
- how the individual is connected with us and others
- public information on any philanthropic activities.
- High value event planning
We may also use profiling to produce short biographies of people who are due to meet with our leadership or attend an event that we may be hosting.
This helps our people to understand more about those we engage with, and their interests or connection to us.
- Ethical screening and minimising risk
As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity.
This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering.
We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it.
We may also ethically screen supporters to minimise risk of creating an association with an individual or group that conflicts with the standards we have set out in our overarching ethical policy.
Who do you share my information with?
We will only use your information for the purposes for which it was obtained and for which we have your consent. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
We will only share your data for the following purposes:
- Third party suppliers: We may need to share your information with data hosting providers or service providers who help us to deliver our services, projects, or fundraising activities and appeals. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.
- Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else.
We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.
How will you protect my personal information?
We use technical and corporate organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.
Our online forms are always encrypted and our network is protected and routinely monitored.
If you use your credit or debit card to donate to us, whether by phone, post or online, we pass your card details securely to our payment processing partners. We do this in accordance with industry standards and do not store the details on our website.
However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.
What if there are vulnerable circumstances?
We understand that additional care may be needed when we collect and process the personal information of vulnerable supporters and volunteers. In recognition of this, we monitor and observe good practice guidelines in our interactions with vulnerable people.
How long will you keep my personal information?
We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes, which may be up to six years after a particular transaction.
If you request that we stop processing your personal information for the purpose of marketing we may in some instances need to add your details to a suppression file to enable us to comply with your request not to be contacted.
In respect of other personal information, we will retain it for no longer than necessary for the purposes for which it was collected, taking into account guidance issued by the Information Commissioner’s Office.
Do you transfer information internationally?
We may, on occasion decide to use the services of a supplier outside the European Economic Area (EEA), which means that your personal information is transferred, processed and stored outside the EEA. You should be aware that, in general, legal protection for personal information in countries outside the EEA may not be equivalent to the level of protection provided in the EEA.
However we take steps to put in place suitable safeguards to protect your personal information when processed by the supplier such as entering into the European Commission approved standard contractual clauses. When we transfer your personal information and process it in the United States, we do so in accordance with the EU-U.S. Privacy Shield Framework and the European Commission approved standard contractual clauses. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.
What are my rights for my personal information?
Data protection legislation gives you the right to request access to any personal information held about you which is processed by the NET and to have any inaccuracies corrected.
You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information.
If you wish to exercise these rights, please contact us and we will take the necessary action to do this. This may involve us requesting further information, you will be advised of this at the time. We will respond to your request within 30 days of receipt.
How do I make a complaint or raise a concern?
Whilst we hope that we do not do anything which would cause a complaint, we appreciate that sometimes problems occur. If you would like more information, have any questions about this policy, or need to make a formal complaint about our approach to data protection or raise privacy concerns please contact the Chief Operating Officer:
Post: 44 Moorfields, London, EC2Y 9AL
If you would like to make a complaint in relation to how we have handled your personal information, please follow complaints procedure. If you are not happy with the response you receive, then you can raise your concern with the relevant statutory body:
Information Commissioner’s Office
Alternatively you can visit their website.
We are registered with the Information Commissioner’s Office as a Data Controller under number ZA559495.
Changes to our Privacy Notice
Our Privacy Notice may change from time to time, so please check this page occasionally to see if we have included any updates or changes, and that you are happy with them.
(Last updated: 02/06/2020)