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. Please also read our Supporter Promise.
We are very thankful that you are supporting us in providing life-changing assistance to blind veterans. In order to enable that support, 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 HMRC or our trusted partners, such as event organisers or service providers. This is to provide you with the information, products or services you have requested.
We use your data to enable your support
We use the information you provide to keep you informed about how we are providing lifelong practical and emotional support to blind veterans. We also use it to identify your areas of interest and to draw your attention to how you may be able to provide specific support to our veterans. We also use it to help us to fundraise more efficiently; so that every penny we receive can be better used to directly support blind veterans.
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, if you wish to stop receiving certain or all communications from us, you can amend your preferences at any time. Our communications with you offer the opportunity to amend your preferences. In any case whether a supporter or a volunteer you can contact us using the details in Section 9 of this policy “How to Contact Us”. If you prefer; or wish to discuss how your personal information is used or wish to make an individual rights request, 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. Each section can be accessed using the links below to find more information. This policy explains:
1. Who we are
Since 1915, the Blind Veterans UK Group 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 Group", ‘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, Four Seasons NWMC Housing Limited (registered company No. 01882050); managing our properties and tenants; Bravo Victor Limited (registered company No.13144807) conducting Biomedical, Social & Welfare and Innovation research 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 as an identified or identifiable individual. An individual can be identifiable either directly (name, address, mobile number etc.) or indirectly (job title, email address, business phone number). Where there is insufficient information to identify an individual that information is not personal data. We need personal information about our supporters, volunteers and trustees to allow us to provide you with the information and services that you ask us to provide or to allow you to support us in the ways that you want.
As a supporter, for example if you make a donation, register to fundraise, sign up for an event or buy merchandise, , we will usually collect personal data about you such as:
- Postal address, telephone number, email address.
- Date of birth.
- Payment details (if you are supporting us financially).
- Voluntary information to assist us in understanding our supporter base such as your reasons for supporting us or how you heard about the charity.
As a volunteer if you offer your time and will be engaging with our members it may be necessary for us to complete a Criminal Records Check (Disclosure and Baring Service or Disclosure Scotland) to assist us with the making of safer volunteering recruitment decisions. In addition to the above personal data the following may also be processed.
- DBS / DS Reference number, type of disclosure, date of issue
- Volunteering placement confidential references
- Next of Kin contact details in case of emergency.
- Your national insurance number.
- Driving licence and or passport details and where necessary valid visa documentation.
- Bank account details, salary, tax, pension status, pension entitlement and expenses details.
- Profession and Job title.
As a trustee, in addition to the personal data above we need to collect the following additional personal information which is necessary to comply with UK Company and Charity legislation and required to be provided to the Charity Commission.
- Home residential address
- Place of birth (In addition to date of birth)
- Employment / Business Interest information including employed and voluntary position(s), any directorship(s), consultancy role(s).
It may be necessary to ask you for additional personal data for processing purposes specific to serving as a trustee, which you may not expect. If this occurs we will ask you directly for it and we will always explain why we need it.
We will be 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. If you are under 16, we would love you to support us, but please ensure you have the permission of your parent or guardian before giving us your personal information. You retain the right to change your preferences at any time.
Special Category data. Data protection law and regulation recognises 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 sensitive personal data. For example:
- You may reveal some of this information if you share photos or personal information on our website or social media channels.
- If you have signed up to support an event that may be physically demanding, we may ask you to confirm any health conditions that we or the organisers need to be aware of.
- We may gather this information for the purposes of monitoring and ensuring we provide equal opportunities to supporters and volunteers or to cater for your specific requirements when supporting us.
Criminal Conviction data. If as a Volunteer or Trustee your role will include direct face to face engagement with a Blind Veterans UK Group beneficiary, participating in what is defined in the Protection of Freedoms Act 2012 as a “Regulated Activity” it is a legal requirement for us to complete a Criminal Records Check (Disclosure and Baring Service or Disclosure Scotland) to assist us with the making of safer employee recruitment decisions. In addition to the above personal data the following may also be processed. The processing of this criminal records data for this purpose is permissible under DPA 2018, Schedule 1, Part 3. (See: Section 6 for more details).
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 contact details in Section 9 “How to Contact Us” at the end of this policy.
Why we need it
We need your personal information in order to perform functions such as:
- To comply with the law. To comply with the law as a data controller and employer there are data processing purposes which must be completed. These include but are not limited to company, charity, employment, social security, social protection law and due diligence processes. Personal information collected specifically for this purpose cannot be further processed.
- Manage your support relationship with us. To keep a record of your relationship with us and any direction you give on how we are to comply with your data rights. To administer any donations or support your fundraising, including processing Gift Aid.
- 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, information, products, updates, newsletters, feedback, competitions. To assist with technical problems related to our websites or apps.
- Operational requirements. If you are serving as a trustee, we will make use of your collected personal information for the purposes of administering and facilitating your duties and responsibilities as a member of the Board. There may be occasions when we need to make use of your personal data because of your status as a trustee to authenticate operational requirements and executive decisions of the charity, such as providing your home address for financial due diligence validation processes. The operational use of your personal data will be compatible with the original purpose of use. If an unexpected or new purpose of use for your personal data is necessary, we will inform you and / or seek your consent to make use of your personal data for this new purpose.
- Marketing. If you provide us with your email address or telephone number, we may contact you for marketing purposes. We may use your email or SMS text number for both marketing and targeted advertising, but only where we have your opt-in consent to do so. If you provide us with your postal address or telephone number, we may send you direct mail or telephone you about our work. We will not do so if you have told us you would prefer not to hear from us by these means. We check telephone numbers against the Telephone Preference Service (TPS) and if you are registered, we will only contact you if you have specifically consented to us making such calls. We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions and we include clear information on how to opt-out or opt-in when we send you marketing information.
- Fundraising. The lifeblood of serving our blind veterans is fundraising. We are always grateful when people donate. We endeavour to tailor our fundraising activity to ensure that we are as efficient with our resources as possible, keeping as much money available to support our beneficiaries as possible, which donors tell us is a priority for them. It also provides you with the most relevant and timely information and opportunities.
- Profiling. To help us achieve this tailored approach, we use profiling or wealth screening techniques, both ourselves or through trusted third-parties. We use existing information that you have supplied to us and combine this with information from publicly available sources such as charity and corporate websites and Companies House. We only use reputable sources, where someone would expect their information may be read by the public. By doing this, we can understand our supporters better and ensure we only make appropriate requests from each of you. It may help those of you who have the means, and the desire, to give a bit more. For more detail about how and why we build profiles of our supporters please click here.
- To personalise and improve your supporter experience. We may use your personal data in order to tailor our information and services to your specific needs and preferences to ensure a personalised supporter experience. To understand how we can improve our services, products or information. To provide personalised direct marketing and 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, products or services you would like.
If you don’t want to hear from us, or do not want us to use your data for direct marketing or profiled fundraising purposes please call us using the details at Section 9 “How to Contact Us”. We will retain your details on a suppression list to ensure that we respect your preferences.
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. The information we get from other organisations may depend on your privacy settings or the preferences you have selected with them, so you should regularly check them to fully understand how they will process and share your data.
Direct from you
You may give us personal data directly yourself: in order to join as a supporter or volunteer; use our websites or apps; sign up for one of our events; make a donation; 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. a professional fundraising agency).
Indirectly from other sources
We may obtain your personal data indirectly when you give permission to other organisations to share it. We may purchase your personal data in a commercial transaction from a third-party organisation or alternatively make use of personal data where it is publicly available:
- 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 the Blind Veterans UK Group with your explicit consent.
- Third party organisations. We may obtain information from third parties if you have agreed we can approach them, for example to obtain a reference or the Disclosure and Barring Service. You may have provided permission for a company or other organisation to share or sell your data with/to third parties, including charities. This could be when you buy a product or service, register for an online competition or survey, install an application on your mobile phone, or sign up with a comparison site. 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 and whether you are a taxpayer for Gift Aid purposes.
- Digital, Online and Social media. 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. 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
UK Data protection law and regulation requires us to have a lawful basis for processing your personal information. These include:
- Where you have given consent to do so for notified purpose(s). This may include marketing material via e-mail or SMS 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. You are able to withdraw consent at any time by contacting us, if you make this choice it may affect our continuing relationship as some services may no longer be able to be supplied.
- 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 social security or social protection law, such as Health and Safety, a criminal record check or in order to comply with HMRC requirements to process Gift Aid.
- 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 supporters’ data, contacts and preferences for the purposes you would expect; in marketing to supporters; and research to better understand who our supporters are and to better target our fundraising activity. We also have a legitimate interest in fraud prevention and informing authorities about possible criminal acts or security threats.
- Special category. Where we process ‘special category’ personal information (such as health) we will ensure we do so in accordance with a lawful basis under Art. 6 and the additional “exception” condition for processing special category data under Art. 9 of GDPR. An example is, where a data subject has provided explicit consent or where the information has been made public by yourself.
- 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.
5. Protecting and sharing your information
How we protect your personal data.
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. If we believe if it is likely processing will pose a risk of harm to individuals we will complete a risk assessment process known as a DPIA to identify and minimise these risks. 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. A data back-up and recovery process to prevent permanent loss of in the event of corruption, damage or accidental loss, is in place across our IT network.
- 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.
Managing access and the sharing your personal data
We undertake 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 or require you to share your personal data directly with a third-party processor on our behalf, we require that they have appropriate technical and organisational measures in place to protect your information.
We treat all volunteer placement references, either received by us or provided to others by us, as confidential references. Confidentiality is applied to all references because when a referee knows the content will not be shared with the individual to which it refers or with a third party, this allows a referee to provide a candid reference. This is important to us as a charity, as we have a particular focus on safeguarding potentially vulnerable beneficiaries. Confidential references allow us to make good volunteer placement decisions and prevent applicants who may have a detrimental effect on our charitable activities and beneficiaries from joining us.
There are circumstances when we may be compelled by law or where we voluntarily agree to disclose your personal data to third-parties, such as law enforcement agencies, courts, government bodies or regulators or if responding to an individual Right of Access Request (known as DSAR). Examples include, where we believe a crime has been committed or to assist with the apprehension of an offender or when required by company, charity and social welfare law, e.g. The Charity Commission, the Information Commissioner’s Office, the Health and Safety Executive, the Care Quality Commission. We have limited control over how it is processed by these parties, we therefore recommend that you consult their own privacy policies.
There are circumstances when a Trustee’s personal data may be shared to comply with industry standard financial and due diligence processes, such as fraud and anti-money laundering checks, or when the charity engages in financial credit services or makes use of services to enable the electronic transfer of funds. This is limited to the minimum quantity of information necessary to fulfil the task.
We may in certain circumstances share your personal data without your consent for the purpose of fulfilling our safeguarding responsibilities. This doesn’t happen often, but we may share your personal data:
- If we believe there is a serious risk to the public, beneficiaries, our staff or to other professionals;
- To protect a vulnerable person, (child or adult) who we believe may be at risk, for example if they are frail, confused or cannot understand what is happening to them.
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, (a list of processors is included the end of this policy).
- With our subsidiaries, within the Blind Veterans UK Group. (This data sharing process is managed by contract in the form of a sharing agreement between the parties.) This will include Blind Veterans UK Trading Limited, which trades on our behalf to raise funds and Bravo Victor Limited which performs the Group’s research activities as a separate charity while remaining within the Blind Veterans UK Group allowing us to continue to have a collaborative relationship. While our volunteers and supporter details will be shared, for the purposes of marketing to comply with UK data protection regulation separate opt-in choices will be provided when we collect your data.
- 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 supporters, volunteers, site visitors, customers and sales 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, or diversify, forming a separate/new organisation with its own legal identity, information including your personal data may be transferred to the new entity. (NB. If employees are transferred to the new entity, TUPE regulations apply)
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 managed and controlled by us. Where we store your information may differ depending on the purpose for which we are processing it for, as indicated above. Your personal data may be held within in our systems and IT network, which are located in our premises or instead the information may be held within a number of accessible systems of a trusted third parties who process your personal data on our behalf.
Cross Boarder Transfers of Personal Data
We may need to use the services or provide access and processing to service providers and other organisations located outside of the UK. If this is required we will conduct an appropriate risk assessment and put in to place appropriate “additional measures” to safeguard your personal data and your rights, such as the use of Standard Contractual Clauses (SCC), if the transfer is a one off or infrequent we may ask for your explicit consent to conduct the transfer.
The UK has recognised some countries and all of the EEA states as possessing data protection “adequacy” for the purposes of data transfers to these countries. The UK Government has decided no additional safeguards are needed to conduct data transfers to the EEA as these states have equivalent standards of data protection as the UK-GDPR 2020.
The EU has recognised the UK as possessing data protection “adequacy” for the purposes of personal data transfers of EU subject’s personal data into the UK. No additional safeguards are needed as the UK has an equivalent level of protection to that guaranteed under EU law. (EU-GDPR 2016).
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 to determine how your personal data will be processed by these controllers.
6. Retaining your information
We hold your personal 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.
The Data Protection Act 2018 prohibits a data controller from processing and retaining (an individual’s) criminal offence data. However, an exception within part 3 of schedule 1 of the DPA 2018 allows a controller to process criminal record data for the specific purposes of volunteer and employee recruitment and management. Once a recruitment process has been completed for a role, we as a controller, will not retain a copy of the DBS /DS report or any of the Criminal record information from within the report. However, we will retain the following information as evidence of the completion of the DBS: (note this retained information is personal not criminal record data)
- The date of issue of a disclosure
- The name of the subject
- The type of disclosure requested
- The position for which the disclosure was requested
- The unique reference number of the disclosure
- The details of the recruitment decision taken
While processing criminal record data for this purpose, the Blind Veterans UK Group will retain received disclosure information separately and securely. It will not be kept with an applicant's personnel file and access is strictly controlled and limited to only staff entitled to see it as part of their recruitment duties. DBS/DS content information will be securely destroyed after a period of six months (This period allows resolution of any related disputes or complaints) ensuring the information is retained for only as long as is necessary.
Where we have contracted with a 3rd party provider to process your personal data on our behalf these organisations will also retain some basic information in order to meet their own legal requirements, e.g. records of financial transactions and will only retain it for as long as is necessary.
If you decide to end or change your relationship with us as a supporter, volunteer or trustee or request that we have no further contact with you, we will need to retain some basic personal information to comply with our legal and regulatory obligations and to maintain a suppression list to ensure we can comply with your request to receive no further contact from us.
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?
UK data protection legislation includes the UK General Data Protection Regulations 2020 (UK-GDPR) and the Data Protection Act 2018, these two authorities are to be jointly considered as the authority of UK data protection law. This legislation 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 and change the way you hear from us or withdraw your permission for us to process your personal data at any time by:
- Using the ‘Contact Preferences Form’ on our 'Contact Us' web page;
- 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 supporter of the charity:
Supporter Services, Blind Veterans UK Group, 12-14 Harcourt Street, London, W1H 4HD
0300 111 2233
If you are a volunteer:
Volunteer Department, Blind Veterans UK Group, 12-14 Harcourt Street, London, W1H 4HD
020 7616 8373
If you wish to enquire further about how your personal data is processed, wish to make an individual rights request, ask for information to be provided, or to raise a data protection related complaint, please contact our Data Protection Officer.
Data Protection Officer
Blind Veterans UK Group, 12-14 Harcourt Street, London, W1H 4HD
020 4534 1127 (direct dial)
Appendix-List of data processors
Data Processor’s Name
Purpose / service provided
Managing volunteer data
On-line training provision
GB Group PLC Solutions
Access Dimensions / Focal Point
Processing of Financial Accounting
Volunteer Driver/vehicle Validation
Volunteer Licence Validation
Crowe UK LLP
Charity’s Accountant & Auditor
Website and microsites
Legacy data management
Adroit (data and Insight)
Marketing selections and insight
SMILE Fundraising Ltd
F2F RG recruitment
Media planning and buying
Tribute fund site
Social Media Post management
Social Media Channel
Social Media Channel
Social Media Management
Social media Channel
Social media Channel
Print and Mailing Service
Audio Mailing service