1. What is the purpose of this document?
2. Data protection principles
3. The kind of information we hold about you
4. How is your personal information collected?
5. How we will use information about you
6. Marketing preferences
8. If you fail to provide personal information
9. Change of purpose
10. How we use particularly sensitive personal information
11. Our obligations as a workplace provider
12. Information about criminal convictions
13. Automated decision making
14. Data sharing
15. Data security
16. Data retention
17. Rights of access, correction, erasure, and restriction
18. Data protection officer
Sue Ryder (registered company 00943228 and charity number 1052076 in England and Wales and SC039578 in Scotland) is committed to protecting the privacy and security of your personal information.
Sue Ryder is a ‘data controller’. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
It is important that you read this policy, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
We will comply with data protection law. This says that the personal information we hold about you must be:
- 2.1. Used lawfully, fairly and in a transparent way.
- 2.2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- 2.3. Relevant to the purposes we have told you about and limited only to those purposes.
- 2.4. Accurate and kept up to date.
- 2.5. Kept only as long as necessary for the purposes we have told you about.
- 2.6. Kept securely.
Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been removed (‘anonymous data’). There are ‘special categories’ of more sensitive personal data that require a higher level of protection.
We will collect, store, and use the following categories of personal information about all volunteers:
- Personal contact details such as your name, title, addresses, telephone numbers, and personal email addresses, so we can contact you.
- Your date of birth, so we can ensure you are not under the age of 17; to help us review the effectiveness of marketing and campaign materials and so we can celebrate special birthdays with you.
- Emergency contact information, so we can contact a family member or a friend in case of an emergency.
- Recruitment information, such as references and other information collected as part of the application process. This is so we can make a decision about your recruitment as a volunteer.
- Confirmation of whether or not you have criminal convictions for specified offences. This is to help us make a decision about your recruitment as a volunteer for the role you have applied for. We have four excluded offences and there may be specific requirements for particular roles.
- Performance information, to be used for references to provide to third parties if requested. Performance information can also be used as supplementary evidence if a complaint is received.
- Information about your race or ethnicity, religious beliefs and sexual orientation. This is so we can monitor our diversity and inclusion processes and identify trends.
- Information about your health, including any medical conditions, so we can comply with our health and safety obligations and enable any reasonable adjustments to be made.
Our lawful basis for processing this information is legitimate interest, with the exception of the last two points, where the lawful basis is consent.
We will collect, store, and use the following categories of personal information about all volunteers aged 17 and over, with the exception of volunteers from our Prison Volunteer Programme (PVP):
Your marketing preferences
Email and text:
We collect your name, email address and mobile number to send you marketing communications, when you provide us with these details for this purpose. We share this information with MailChimp, which is an automated email platform, to send you emails and keep these details in Raiser’s Edge, which is an externally hosted database. Our lawful basis for processing your information is consent.
Post and telephone:
We collect your name, postal address and telephone number to send you marketing communications either by post or by telephone. We share this information with mailing houses and keep these details in Raiser’s Edge (an externally hosted database). Our lawful basis for processing this information is legitimate interests.
- Although we ask whether you want to hear from us by email/text or not hear from us by post/telephone, if you are under the age of 18 we will not send you marketing communications with information about how you can support Sue Ryder.
We will collect, store, and use the following categories of personal information about volunteers who work in our hospices and neurological care centres:
- DBS details when you first join as a volunteer, to check that you are not barred from working with vulnerable people. The date of your DBS check is kept on file.
- Training records, for compliance with our training policies and for insurance purposes.
Our lawful basis for processing this information is legitimate interest.
We will collect, store, and use the following categories of personal information about volunteers who are part of our Prison Volunteer Programme (PVP) or Community Payback:
- Information about criminal convictions and offences, to check that convictions do not fall under our four excluded offences. Our lawful basis for processing this information is legitimate interests.
We will collect, store, and use the following categories of personal information about volunteers who become trustees:
- Name, address, date of birth, nationality, employment, membership of professional bodies and information on ‘interests’, all as required to comply with our legal obligations under charity and company law. We will share this information as required with Companies House and the Charity Commission. Our lawful basis for processing this information is legal obligation.
We collect personal information about volunteers through the application and recruitment process, directly from candidates. We may sometimes collect additional information from third parties, including former employers, or when we need to carry out a DBS check if your role is a regulated activity i.e. working in one of our hospices or neurological care centres. We will collect additional personal information in the course of activities throughout the period of you volunteering for us.
We will only use your personal information when the law allows us to. We collect information for the purposes set out in section 3 (‘The kind of information we hold about you’), which also includes the lawful basis for which the information is processed. These include:
- 5.1. Where we need to comply with a legal obligation.
- 5.2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The legitimate interest we rely on are:
- (a) To fulfil the charitable purpose of Sue Ryder, which means we need to attract and retain volunteers for our retail shops and healthcare services to enable us to continue to provide services from our hospices, neurological care centres, online community and other community services; and raise funds through fundraising to enable us to continue to provide our charitable activities.
- (b) The health and safety of our volunteers, staff, customers, service users and sites. We may also use your personal information in the following situations, which are likely to be rare:
- 5.3. Where we need to protect your interests (or someone else's interests).
- 5.4. Where it is needed in the public interest or for official purposes.
- 5.5. The prevention or detection of fraud or other criminal offences.
We will only send you marketing information by email if you have specifically agreed to this when you filled in your application.
We may send you marketing information by post or ring you for marketing purposes, unless you have previously opted out or said on the volunteer application form that you don’t want to be contacted. We will always check against the Telephone Preference Service and Mail Preference Service.
Prior to carrying out postal mailings, addresses are checked against the National Change of Address Update database to verify that we have your latest address, where you have given consent to Royal Mail to pass on your new address to existing contacts.
Where you have given us your consent to contact you by email or not asked us to not contact you by post or telephone, then we may use the information you provide us with to match against other sources of data, including publicly available information (as detailed under the ‘Profiling’ section below), to predict the level at which you might be able to support the charity in future.
If you let us know that you don’t want us to do this we will update our records to stop further mailings as quickly as we can, but you may still receive further mailings which were already in progress prior to your asking us to stop.
If you wish to opt out of specific emails, for example our e-newsletter(s), you can use the unsubscribe button on the email in question. If you wish to opt out of all email communications then please email email@example.com or telephone 0808 164 4572.
You can change your marketing preferences at any time by emailing firstname.lastname@example.org or telephoning our Volunteer helpline on 01302 380 067.
Where we have added you to our fundraising database to reflect your marketing preferences as set out in paragraph 6 above, we may use profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience for our supporters. In particular, we carry out profiling of potential donors to ensure that we are engaging with the people most likely to support the charity. Profiling allows us to target our resources effectively, which donors consistently tell us is a priority for them.
When building a profile, we may analyse geographic, demographic and other information relating to you in order to better understand your interests and preferences, so we can contact you with the most relevant communications. In doing this, we may use additional information from third party sources when it is available.
To do this, we use publicly available data about you, for example addresses, listed directorships on Companies House, property prices on the Land Registry or typical earnings in a given area. We may also gather additional data which is freely available in the public domain (for example, newspaper articles or online sources), this may include: details of your career and personal/family background; your philanthropic interests (trusteeships and/or support to other charities); evidence of other similar gifts or involvement with other charities; your networks and potential influencers; your wealth, estimated net worth and gift capacity; and any recent and/or relevant media coverage about you.
We do this because it allows us to understand the background of the people who support us and helps us make appropriate requests to supporters who may be able and willing to give more than they already do and to predict the level at which donors may be able to support the charity in the future. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would.
If you do not wish your data to be used in this way or have questions about this, you can notify us by emailing email@example.com.
If you fail to provide certain information when requested, we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers and volunteers).
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
‘Special categories’ of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:
- 10.1. In limited circumstances, with your explicit written consent.
- 10.2. Where we need to comply with our legal obligations.
- 10.3. Where it is needed to assess your volunteering capacity on health grounds, subject to appropriate confidentiality safeguards.
Where you have provided us with your particularly sensitive personal information, we will use it in the following ways:
- We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work and to provide appropriate workplace adjustments.
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our employee and volunteer data protection policy.
Less commonly, we may use information relating to criminal convictions where it is necessary to protect your vital interests and you are not capable of giving your consent. We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. We will use information about criminal convictions and offences as part of the recruitment process to assess whether you can work in any of our workplaces that have vulnerable people.
We are allowed to use your personal information in this way to carry out our obligations.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
We may have to share your data with third parties as set out in this policy (please see the information in section 3, ‘The kind of information we hold about you’).
We require third parties to respect the security of your data and to treat it in accordance with the law.
If we do, you can expect a similar degree of protection in respect of your personal information.
We have put in place appropriate technical and organisational measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those volunteers, employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our data retention policy which is available on RyderNet or from your manager.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a volunteer for the charity we will retain and securely destroy your personal information in accordance with our data retention policy.
17.1. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
17.2. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Company Secretary in writing at:
17.3. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
17.4. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
17.5. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Helen Organ, Company Secretary, by email at email@example.com, or write to her at: