Our Privacy Promise
We take our duties when processing your personal data very seriously. We promise that we will tell you what data we are collecting and why. We will make every reasonable effort to collect, process, store and share your data safely and securely. We will also make sure that our trusted partners do the same. We also promise that we will be open and clear with you about our use of your personal information and that you will be able to control your personal information with ease.
In order to provide support and services to you, we need to collect and keep a little data about you, like your name, contact details, preferred means of communication or, when appropriate, payment details. Some of this information we may need to share with 3rd parties such as payment agencies or government departments or our trusted partners, such as event organisers, specialist service providers and professional advisors. This is to provide you with the support and services you require from us.
We use your data to deliver our services
As a Member, we use your personal information to provide you with the tailored, lifelong practical and emotional support you expect and to support your wider interests. We may also, with your consent, use your information to help us to market the charity and fundraise so that we can offer our support to even more blind veterans. As a tenant, we use your data to manage our estate safely and to meet your tenancy needs.
You are in control
If you would like to make any changes to the way we are processing your data, if you believe it is inaccurate or incomplete, or you have any concerns regarding how it is being processed you can amend your preferences at any time. Whether a Member or a tenant you can contact us using the details in Section 9 of this policy “How to Contact Us”. As a Member you can always start by speaking to your community worker or as a tenant with the estates team. If you prefer, or wish to make a complaint, you can e-mail our Data Protection Officer whose details are also in Section 9.
Changes to this Policy
We may change this document from time to time to reflect the latest views of what we do with your information and legal and regulatory changes. Please check back frequently. You will be able to see changes have been made by the date it was last updated.
This policy is split into 9 sections, which can be accessed below. This policy explains:
1. Who we are
Since 1915, Blind Veterans UK has held to the belief that no-one who has served our country should battle blindness alone. That's why we're here to help with lifelong practical and emotional support for blind veterans, regardless of when they served or how they lost their sight. We help veterans recover their independence and discover a life beyond sight loss.
References to "Blind Veterans UK", ‘the charity’, “our’, ‘us’ and "we" mean Blind Veterans UK registered charity 216227 in England and Wales and SCO39411 in Scotland.
This also includes: our wholly owned subsidiary charitable trading company, Blind Veterans UK Trading Limited (registered company in England & Wales No. 06446944) which trades on our behalf to raise funds; Four Seasons NWMC Housing Limited (registered company No. 01882050); and the St Dunstan’s Retirement Benefits Plan (1973).
2. What personal data we collect and why
What we need to collect
The term ‘personal information’ (or data) means information that relates to you or another individual that means you can be identified, either directly or in combination with other information that we may hold. We need personal information about our Members and tenants to allow us to provide you with the services and support that you require in the ways that you want.
As a Member, we will usually collect personal data about you in order to establish your eligibility to join and then to provide you with the appropriate services and support and to safeguard our staff and volunteers. This information may include:
- Postal address, telephone number, email address.
- Date and place of birth.
- Your service record, war pension, national insurance number.
- Payment details (if there is a requirement for financial transactions).
- Whether you have pets or smoke (as a duty of care to our staff and volunteers).
- Your preferences for communication, publicity and attendance at events.
- Voluntary information to assist us in building an understanding about our Members, such as your early life, professional career, your military background, hobbies, interests and aspirations.
As an authorised tenant of one of the charity’s properties, we will collect personal data about you in order to manage your tenancy and to provide you with the appropriate services and support. This information may include:
- Postal address, telephone number, email address.
- Payment details (if there is a requirement for financial transactions).
- References and credit rating analysis.
We will be very clear with you that we wish to collect such information, our reason for collecting such information and we will only do so when we have a lawful basis for processing the information. You retain the right to change your preferences at any time.
Data protection law and regulation recognizes certain information as ‘special category’ data and as being particularly sensitive. This includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, certain biometric data, data concerning health or a person's sex life or sexual orientation. Sometimes we may need to collect or may indirectly obtain such sensitive personal data. For example:
- As a Member you will be asked for sensitive personal information regarding health matters to allow us to provide the appropriate services and support and to safeguard your welfare. This will include: Information regarding your visual impairment; general health (including mental health) and any disabilities; social and health care needs; contact details of emergency or carer contacts, eye care and health professionals, other care or health agencies you are receiving services from.
- As a tenant, health related information could be revealed during the management of your tenancy either directly in order to meet your specific needs or indirectly.
- You may reveal some of this sensitive information if you share photos or personal information in our Review magazine, on our website or social media channels.
The accuracy of your personal information is really important to us. If you wish to update or correct any information we hold, please contact us using the details in Section 9 “How to Contact Us” at the end of this policy or speak with your community worker or estate team representative.
Why we need it
We need your personal information in order to perform functions such as:
- Manage your relationship with us. To establish your eligibility and suitability to receive our support and services. To keep a record of your relationship with us and any direction you give on how we are to comply with your preferences and rights. To deliver the services and support required to administer and manage your Member services or property services and tenancy. To safeguard your welfare and interests.
- Communicate with you. To know how you prefer to be contacted and to make adjustments as you specify. To provide you with specific and, where appropriate, personalised services, products, updates, newsletters, feedback and information. To assist with technical problems related to our services or properties.
- Manage your broader relationship with us. If you chose to support the charity through marketing or fundraising, then we will keep a record of your relationship with us and any interests or preferences you have. To administer any donations or support your fundraising, including processing Gift Aid.
- To personalise and improve your Member or tenant experience. We may use your personal data in order to improve our information and services. To understand how we can improve our services, products or information. Where appropriate, to provide communication in a way that you control and that suits you.
- To improve our services and administration. To ensure the most efficient and appropriate use of the resources we have. To drive efficiency through statistical and market analysis.
If you choose to withhold certain personal information, we may not be able to provide you with the information, support or services you would like.
3. How we collect your personal data
We collect information about you in a variety of ways. We may collect information you provide directly to us as well as information indirectly available from other sources, such as care or health agencies or previous landlords or letting agencies.
Direct from you
You may give us personal data directly yourself: in order to join as a Member or take up a tenancy; if you use our websites or apps; sign up for one of our events; make a payment; purchase one of our products (such as tickets, raffles, merchandise); or communicate with us. Sometimes when you support us, your information is collected by an organisation working for us (e.g. an event organiser or agency contractor).
Indirectly from other sources
We may obtain your personal data indirectly when you give permission to other organisations to share it or it is publicly available:
- Third party organisations or individuals. We may obtain information from third parties if you have agreed that we can approach them for example the NHS, Ministry of Defence, eye health specialists, other care or health agencies, former landlords or letting agencies (for references). You may have provided permission for a company or other organisation or agency to share your data with third parties. This could be when you buy a product or service or register or sign up to a website. We can only use this data where we have been named as a recipient of the data or the third party has named a charity subsection into which we fit. We may also be provided with credit/debit card details. Like all companies, through our website and mobile apps, we may collect information about what browser you are using, your IP address and computer operating system and may use this information to improve the services we offer.
- Independent event organisers. Your information may be shared with us by independent event organisers, for example the London Marathon or fundraising sites like Just Giving or Virgin Money Giving. These independent third parties will only pass on your data when you have indicated that you wish to support Blind Veterans UK and with your explicit consent.
- Social media. Depending on your settings or the privacy policies for social media and messaging services like Facebook or Twitter, you might give us permission to access information from those accounts or services.
- Publicly available sources. Public information may include information from places such as Companies House, the electoral register and information that has been published in articles / newspapers. Additionally, the Post Office’s National Change of Address database allows us to keep your information up to date.
4. The lawful basis for processing
Data protection law and regulation require us to have a lawful basis for processing your personal information. These include:
- Where you have given explicit consent to do so for notified purpose(s). This may include sending you e-mails, texts, marketing material or to provide you with a product, service or information that you have requested or require. Where we need your consent, it will be clearly identifiable as a consent for a specific purpose.
- To comply with a legal obligation. For example, where we are required to do so by a court, regulatory authority the police or security services or we are legally required to, such as to comply with Health and Safety law.
- To protect the vital interests of yourself or another person. If we believe that the vital interests of you or a third party is at risk, we have a duty to protect.
- The performance of a contract. If we are setting up or have a contract with you we will process your data to comply with the obligations of the contract.
- Where we as a charity have a legitimate interest. Where we have a legitimate interest, we must ensure that we are not harming any of your interests or rights and only use it in a manner that you would reasonably expect us to. For example, we have a legitimate interest in using our Members’ and tenants’ data, contacts and preferences for the purposes you would expect; for providing support and services that you have requested or could reasonably expect from us including to meet our responsibilities as a charity, care organisation and landlord. We also have a legitimate interest in fraud prevention and informing authorities about possible criminal acts or security threats.
Where we process ‘special category’ personal information (such as health) we will ensure we do so in accordance with the additional conditions required such as having your explicit consent, provision of health or social care or carrying out obligations and exercising specific rights or where you have manifestly made the information public yourself.
5. Sharing and Protecting your information
How we keep your personal data safe
We ensure that there are reasonable and appropriate technical and organisational controls in place to protect your personal details against unauthorised or unlawful processing and against accidental loss, destruction or damage. For example, our computers, online systems and our network are protected and routinely monitored. We have policies and procedures in place which staff and volunteers are expected to comply with and for which they receive training.
- Password security. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping the password confidential. You agree not to share that password with anyone else.
You should be aware that the use of the Internet is not entirely secure and although we will do our best to protect your personal data we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet. Any transmission is at your own risk.
Who has access to your personal data
We undertake regular reviews of who has access to information that we hold to ensure that your information is accessible only by the necessary and appropriately trained staff, volunteers and trusted third parties. Where we share your data with a third-party, we require that they have appropriate technical and organisational measures in place to protect your information. However, we may be compelled by law to disclose your personal data to a third-party, such as law enforcement agencies, courts or government bodies and have limited control over how it is protected by that party.
Occasions, other than by law, when we may share your data include:
- If you have agreed that we may do so.
- When we use external service providers to collect or process personal data on our behalf, for example, providing services; property and contractor agencies and advisors; processing, mailing or delivering orders; answering questions about products or services; sending mail and emails; when using auditors/advisors or processing credit/debit card payments or online tracking and analysis.
- To our subsidiaries (i.e. the companies owned by Blind Veterans UK).
- If we receive a complaint about any inappropriate content you have posted or transmitted to or from one of our sites, forums, social media pages or apps we may share your personal data with your internet provider or law enforcement agencies.
- We may disclose aggregate statistics about our Members and tenants to describe our services and operations to prospective supporters, partners, advertisers and other reputable third parties and for other lawful purposes, but these statistics won’t include any personally identifying information without your explicit consent.
- If we run an event in partnership with other named organisations your details may need to be shared. We will be very clear what will happen to your data when you register.
- If we merge with another organisation to form a new entity, information may be transferred to the new entity.
We will never rent or sell your personal information. We will not share or swap it with other organisations for their own purposes or to make money out of your data without your consent.
Where we store your information
The information that you provide to us will be held in our systems and servers, which are located in our premises or those of a trusted third-party who processes data on our behalf.
We may need to use the services or provide access and processing to service providers and other organisations located outside of the European Economic Area (EEA). This may mean your data is transferred, processed and stored outside of the EEA. However, we will put in place appropriate safeguards to protect your data and rights, such as asking for your explicit consent, using appropriate contractual clauses and / or Privacy Shield (for the US) with our third-party supplier and / or by using encryption. With the appropriate safeguards in place, by submitting your personal information, you agree to this transfer, storing or processing at a location outside the EEA. In cases when we use external websites provided by other organisations such as Twitter or Facebook, then we would ask you to consult their privacy policies too.
6. Retaining your information
We hold your information for only as long as is necessary to fulfil the purposes for which the data was collected and our legitimate interests or in order to comply with legal or regulatory rules and requirements.
If you decide to end your Membership or terminate your tenancy with Blind Veterans UK or request that we have no further contact with you, we will keep some basic information in order to record this to ensure we comply with your request in the future and / or meet any legal or regulatory requirements for us to retain information.
7. Your details on the internet and website
Like most organisations, our website and apps use “cookies” and other tracking software to help us make our site and the way you use it better and more relevant to you. We will not be able to personally identify you from the information gathered but it may help us improve our online services.
- Cookies mean that a website will remember you. They’re small text files that are transferred to your computer (or phone or tablet). They make interacting with a website faster and easier, for example by automatically filling your name and address in text fields. Please read our cookies policy for more information. You can change your cookie preferences whenever you wish.
- When visiting our website or apps we may collect information about the type of device you’re using to access them and the settings on that device. This might also include the IP address and your operating system and certain device settings as well as diagnostic information.
8. What are your rights?
The new General Data Protection Regulations (GDPR), effective from 25 May 2018, gives everyone a number of very important rights. In abbreviated form these are:
- The right of access. Request information that we hold about you.
- The right of rectification. Update or amend the information we hold about you if it is incomplete or inaccurate.
- The right to erase or ‘right to be forgotten'. Ask us to remove your personal information from our records where there is no compelling reason for its continued processing.
- The right to restrict processing. Ask us to supress the processing of your information.
- The right to data portability. Obtain and reuse your personal data for your own purposes.
- The right to object. Object to the processing of your information for certain purposes (such as marketing, research, statistics or our legitimate interests).
- Rights in relation to automated decision making and profiling.
If you would like to know more about your rights under the data protection law see the Information Commissioner’s Office (ICO) website.
Remember, you can exercise your rights in relation to your personal information at any time by contacting your community worker (Members) or estate team representative (tenants) or through the contact details set out in the ‘How to contact us’ section of this policy.
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law and your rights, you can complain directly to the Information Commissioner’s Office.
9. How to contact us
If you are a Member of the charity:
- Post: Member Services, Blind Veterans UK, 12-14 Harcourt Street, London, W1H 4HD
- Phone: Please call your own community worker
- Email: Please email your own community worker
If you are a tenant:
- Post: Estates Department, Blind Veterans UK, 12-14 Harcourt Street, London, W1H 4HD
- Phone: 020 7723 5021 (Main switchboard, please ask for the Estates Team)
- Email: email@example.com (Please add 'For Estates Team' in subject header)
If you wish to enquire further about your rights, ask for information to be provided, or to raise a complaint, please contact our Data Protection Officer.
- Post: Data Protection Officer, Blind Veterans UK, 12-14 Harcourt Street, London, W1H 4HD
- Email: firstname.lastname@example.org