Privacy & Cookie Policy

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Important Notice

This Privacy Policy describes how we obtain and use your personal data, why we are allowed to do so by the law, who has access to your personal data and what your rights are. Please review it carefully.

In the event that the Site contains a separate Privacy Statement linked to via the Site homepage, in the case of conflict between that Privacy Statement and this Privacy Policy, the Privacy Statement shall prevail over this Privacy Policy

We take your privacy seriously and use your personal data as further explained in this Privacy Policy. We are the “controller” of the personal data you provide to us.

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including any related profiling). For more information about your rights and how you can exercise them, please see the section Your rights.

Personal Data we may collect and why

Brighter Futures promises to respect any personal data you share with us. We will make it clear what information we are asking you to share, why we asking for it and what we plan to do with it. We will make sure that we only use your personal information in accordance with Data Protection legislation. We will keep any information you share with us safe.

The information you share with us shapes and guides our future activities, such as events and appeals, allowing us to provide the greatest benefit to patients, visitors and staff at Great Western Hospitals NHS Foundation Trust.  We will contact you through your preferred channel – email or post and only if we have received your consent.  At any time you can change your preferences by contacting us on 01793 605631 or gwh.fundraising@nhs.net or writing to Brighter Futures, Great Western Hospital, Marlborough Road, Swindon SN3 6BB.

This privacy policy explains

 

–       What personal information we capture

–       Why we collect this information from you

–       How we use that information

–       Who we share your information with

–       Your choices about the information we hold.

 

What information do we capture?

Personal information is any information that could be used to identify you. This includes information such as your name, email address, postal address or telephone number, financial information such as credit or debit card details, as well as your reasons for supporting our charity and/or information relating to your health such as the experience you or someone close to you have had in hospital. When you make a donation, take part in one of our fundraising event/activities or want to find out more about our work, we collect some of this personal information from you.

Some of this personal information you share with us directly, by email, post or phone. On other occasions this information is shared with us through a third party – for instance an event provider (Entry Central) or an online giving platform.

Data protection law recognises that certain categories of personal information such as health information, political opinion, religious beliefs or racial or ethnic origin, are more sensitive. These categories are referred to as ‘Special Category Data.’

As a hospital charity, many of our supporter’s reasons for giving are related to their own experience, or the experience of someone they love, in our hospitals. Under Data Protection Law, any personal information relating to your health is defined as ‘Special Category Data.’ If you to choose to share that information with us, including through online giving pages, we will record it as part of our relationship with you so we can fully understand the context of your relationship with us.  We would never use this information for anything else. We have no access to your NHS records.

Sometimes, we may also obtain personal information about you from other sources, particularly if someone contacts us on your behalf, if you are taking part in a fundraising activity as part of a team or if you are introduced to the charity by a friend or family member.

If we have your explicit and informed consent to do so, we may also store photos, videos or other media that feature you.

What do we do with the personal information we hold?

We use your personal data to support you as donor and to process your donation, thank you for your gift, sign you up to an event or register you as a volunteer and to fulfil our legal obligations in meeting our audit and internal administrative requirements.

Where appropriate, to claim Gift Aid on your donation.

To keep a record of your relationship with us, to ensure we understand your personal interests and wishes in interactions with you.

To ensure that our charity is meeting the needs and wishes of our supporters in providing the greatest benefit to patients, visitors and staff across the Great Western Hospitals NHS Foundation Trust by being an effective and efficient organisation.

To send you communications about our work and the difference your donations and fundraising make, as well as future appeals.

Do you collect any personal information about children?

We are fortunate to have many supporters who are under the age of 18. If a child chooses to fundraise for us, take part in an event or make a donation, we do collect personal information but aim to manage it in a way that is appropriate to the age of the child. Where possible and appropriate we will seek consent from a parent or guardian before collecting information about children.  

Our events have specific rules about whether children can participate, and we‘ll make sure advertising for those events is age appropriate.

What is the benefit to capturing this data?

In addition to processing your gift and meeting our legal obligations, the information that you share with us allows us to be a more effective organisation. In analysing the patterns and trends of our supporters, we can ensure we are meeting their expectations, communicating with them in the right way and determine the success of our campaigns and appeals. It also means we can tailor our communications with you, to provide a better supporter experience.

The support of our community is invaluable, so to make sure we have a tailored and appropriate relationship with you, we may also gather information about you that is in the public domain, for example from media articles or Companies House to help us understand more about you as a donor and your ability to support Brighter Futures. We may also use information about where you live or your networks to assess how interested you may be in supporting the charity. This way, we can ensure that we have focussed conversations with you about the parts of our hospitals that interest you most.

We might contact you after a significant period of time since your last communication or donation to us to update you about the work you funded or to enquire whether you are still interested in hearing from us.

How do we store your information?

The information you share with us can be categorised in three ways.

Personal information: Including name, contact details, communications with the charity, date of birth and personal interests.

This information is stored on a secure database (Harlequin) which only charity employees have access to.

Financial Information: For instance credit card or cheque details or gift details

Credit and debit card details are destroyed as soon as the donation has been processed. Transactional information in hard copy is kept for seven years to satisfy our audit requirements.

Video, photos and media files:

If we use your image in any media, including social media, newspapers and internal communications, we will ask you to complete a consent form that gives us permission to use it.   At any point you can withdraw your consent however, once it has been reproduced – Brighter Futures have no control about where it is circulated.

We also store an archive of media material in hard copy, to highlight the charity’s activities and achievements over its history.

At any time you can request to see the information we hold on you by contacting us on 01793 605631 or gwh.fundraising@nhs.net

Who do we share your information with?

We never sell/share your details to anyone else. We only ever send your data outside of the charity when we are using a third party to help deliver one of our activities – such as giving the company that prints our appeal mailing letters. We are very careful to only partner with organisations whose privacy policy reaches the high standards we set for ourselves, and we NEVER share sensitive information like the amount you have donated or your credit card details.  We may pass your name and telephone number on to the media but only once we have received your consent to do so.

Policy Review

This policy will be reviewed every two years and changes may arise. If there are any significant changes, we will endeavour to contact you to let you know.

Your rights

At any time, you can request to change your contact preferences by contacting us at Brighter Futures, Great Western Hospital, Marlborough Road, Swindon SN3 6BB, emailing gwh.fundraising@nhs.net or calling 01793 605631. We will endeavour to update all contact preference changes within five working days.

At any time, our supporters’ can ask to see the information we hold about them. In such an instance, we will respond within seven working days. Requests should be made to gwh.fundraising@nhs.net

Cookies

What are Cookies?

We collect information about your use of our Site through cookies. Cookies are small text files which are sent to and stored on your computer, tablet or smartphone that help our site to remember who you are and record information about your visit. Cookies make it easier for you to visit our site again, and configure our site information to make it more useful to you. Most major websites use cookies.

a. What cookies are used on this Site?

The cookies we use on our Site are broadly grouped into the following categories:

  • Essential – Some of the cookies on our Site are essential to enable us to provide you with the service or product you have requested. An example of this could be a cookie used to enable you to log into your account on our Site or which allows communication between your browser and our Site. Our cookie preference cookie (described in the section “How can I reject or opt out of receiving cookies?”) is also an essential cookie. You may not be able to use our Site without these cookies. 
  • Analytics – We use analytics cookies to helps us understand how users engage with our Site. For example, a cookie counts the number of different people visiting our site, or using a particular site feature, rather than simply counting the total number of times the site or feature is used. This allows us to analyse and improve site performance.
  • User Cookies – These cookies improve your experience on our site by remembering your preferences. 
  • Social Sharing – We use third party cookies to allow you to share our content directly on the social networking/sharing sites like Facebook or Twitter. Please see our “Third Party Cookies” section below for more details. 
  • Interest-Based Advertising – You will have noticed that when you visit websites you will be shown adverts for products and services you may wish to buy. The money made by website owners for showing third party adverts on their websites often pays for the cost of running the website and therefore usually allows you to use the website without having to pay a registration or usage fee. To try and ensure that the adverts you see are relevant to you third party cookies may be used to collect information about the types of things that interest you, for example websites you visit and the geography that you are based in. Having these cookies does not increase the number of adverts you will be shown, but simply makes the adverts you see more relevant. Please see our “Third Party Cookies” section below for more details.
 

b. How can I reject or opt out of receiving cookies?

You may opt not to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. This may, however, leave you unable to access all of our site. Without activating this setting our site will issue cookies when you visit. Find out how to refuse cookies by accessing the help menu on your browser. Most browsers also give you the options of being notified when you receive a new cookie, or how to disable cookies altogether. For more information about cookies and how to stop cookies being installed, or how to delete existing cookies from your hard drive, visit the following website: http://www.allaboutcookies.org.

c. Third party cookies

When you visit our site cookies may be issued and stored in your device by third parties to collect information and serve content or advertisements to you. These cookies may emanate from third party websites we interact with (such as data and analytics collection sites). We have no control over these cookies or how the third parties involved use them. 

For more information about these cookies, and how to disable them, please see:

How we use your personal data

We use your personal data for the following purposes:

To provide you with the products and/or services you have requested
We use your personal data to accept you as a new or returning customer to provide you with the products and services you have requested in accordance with the Trading Terms or Terms of Trading.

To communicate with you about the products/services we provide, including notifications about major changes to these, or to our Trading Terms or Terms of Trading.

Direct marketing (including by third parties)
If you have provided your consent, or we otherwise have the right to do so, we may use your contact details to send you direct marketing material and keep you informed of promotional offers by email, SMS, post or telephone, relating to our products and services.

You can unsubscribe from our direct marketing at any time by clicking the “Unsubscribe” link in any of our emails or by contacting us.

If you have provided us with your consent we will share your personal data with our trusted business partners who may use your name, email address, postal address and telephone number to inform you about similar products, services and promotions. You can unsubscribe by clicking “Unsubscribe” in any of their emails or by contacting us.

To track your use of our website, communications, products and services.
We use cookies and similar technologies to track your activity on our Site so that we can provide important features and functionality on our Site, monitor its usage, and provide you with a more personalised experience.

To provide and improve customer support.
We use your personal data to be able to provide and improve the customer support we provide to you (for example, where you have questions about our products and services).

To maintain our records and improve data accuracy.
Like any business, we process personal data in the course of maintaining and administering our internal records. This includes processing your personal data to ensure that the information we hold about you is kept up to date and accurate.

To respond to enquiries, complaints and disputes.
We use the personal data we hold about you to help us respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you, in the most effective manner.

To investigate, detect and prevent fraud and comply with our legal obligations.
In certain circumstances, we use your personal data only to the extent required in order to enable us to comply with our legal obligations, including for fraud detection, investigation and prevention purposes. This may require us to provide your personal data to law enforcement agencies if they request it.

Legal grounds for processing

Data protection law requires us to only process your personal data if we satisfy one or more legal grounds. These are set out in data protection law and we rely on a number of different grounds for the data processing we carry out. These are as follows:

Consent

In certain circumstances, we process your personal data after obtaining your consent to do so for the purposes of:

  • sending you marketing communications about our products and services;
  • sharing your name, email address, postal address and telephone number with our trusted business partners so that they may market to you about their own similar products and services;
  • conducting market research;
  • obtaining your credit score so that we can establish the best possible payment terms we are able to offer to you.
 

Necessary for the performance of a contract and to comply with our legal obligations:

It is necessary for us to process your basic contact details, payment details and – where relevant – information about the business you represent to enact the Trading Terms or Terms of Trading between us. In particular, we rely on this legal ground to:

  • provide you with the products and services;
  • communicate with you about the products and services that we provide to you, including to let you know about major changes to those products and services or to the Trading Terms or Terms of Trading between us or to any related information;
  • provide and improve customer support; and
  • notify you about changes to our service

If you choose not to give some or all of the aforementioned information to us, this may affect our ability to provide our products and services to you.

In certain circumstances, we also use your personal data only to the extent required in order to enable us to comply with our legal obligations, including to detect, investigate and prevent fraud.

Necessary for the purposes of our legitimate business interests or those of a third party:

It is sometimes necessary to collect and use your personal data for the purposes of our legitimate interests as a business, which are to:

  • provide you with products and services that are as useful and beneficial as possible, including by personalising our contact with you and making sure we tell you about all the offers that are relevant to you;
  • better understand our customer base so that we can improve our products/services and marketing activities (which could also benefit you);
  • comply with our contractual obligations to third parties;
  • develop and improve our Site to enhance the customer experience;
  • train our staff so that we can provide you with a better customer service;
  • respond to any enquiries or complaints you have made, or deal with any dispute which may arise in the course of us providing our products and services to you; 
  • to ensure that content from our Site is presented in the most effective manner for you and for your computer;
  • ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.

Where we think there is a risk that one of your interests or fundamental rights and freedoms may be affected we will not process your personal data, unless there is another legal ground for us to do so (either that we have obtained your consent to the processing or it is necessary for us to perform our contract with you or to comply with our legal obligations).

Who we share your personal data with

We may provide your personal data to our suppliers and service providers, including other companies in our group, who provide certain business services for us and act as “processors” of your personal data on our behalf. In addition, we may disclose your personal data if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to protect the rights, property, or safety, of our business, our customers or others. This includes, in specific cases, exchanging information with other organisations for the purposes of fraud protection.

In some cases, the personal data we collect from you may, for the purposes set out above, be transferred outside the European Economic Area (EEA) and such destinations may not have laws which protect your personal data to the same extent as in the EEA. We are required by data protection law to ensure that where we or our “processors” transfer your personal data outside of the EEA, it is treated securely and is protected against unauthorised access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this Privacy Policy.

How long we keep your personal data for

We retain your personal data for no longer than is necessary for the purpose(s) for which it was provided. What this means in practice will vary between different types of data. When determining the relevant retention periods, we take into account factors including:

  • legal obligations under applicable law to retain data for a certain period of time;
  • statute of limitations under applicable law;
  • potential or actual disputes; and
  • guidelines issued by relevant data protection authorities.
 

Otherwise, we securely erase your personal data from our systems when it is no longer needed.

Your rights

You have the following rights regarding your personal data:

Rights

What does this mean?

1.    Rights to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.

2.     Right of access

You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law.

3.    Right to rectification

You are entitled to have your personal data corrected if it is inaccurate or incomplete.

4.    Right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

5.    Right to restrict processing

You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.

6.    Right of data portability

You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

7.    Right to object to processing

You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).

8.    Right to withdraw consent to processing

If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful).

9.    Right to make a complaint to the data protection authorities

You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law.

 

How to contact us

If you would like to exercise your data protection rights or if you are unhappy with how we have handled your personal data, please feel free to contact us by using the details set out on our Site.

If you’re not satisfied with our response to any enquiries or complaint, or believe our processing of your personal data does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) by:

  • writing to: Information Commissioner’s Officer, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF;
  • calling: 0303 123 1113; or
  • submitting a message through the ICO’s website at: ico.org.uk

Links to other websites

Our website may contain hyperlinks to websites owned and operated by third parties. This Privacy Policy does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

Changes to this Privacy Policy

This Privacy Policy was last updated on 10th February 2021. 

This Privacy Policy may be updated from time to time, so you may want to check it each time you provide personal data to us.