The Clifton Children’s Society is committed to protecting your personal information. We want to be completely transparent about why we need the personal details we hold about you and how we use them. The aim of this policy is to help you understand how we collect and use your information, and how you can get in touch with us about your preferences.
If you have any questions about this policy or your personal information please contact our Office Manager on 0117 935 0005 or by emailing email@example.com.
You can also write to us at our registered address: CCS Adoption, 162 Pennywell Road, Easton, Bristol, BS5 0TX.
What this policy covers
It does not cover the direct services we provide to people enquiring about adoption, adopters (in process and approved), adopted children and/or their families. Details of how we collect, manage and store data for these purposes are covered separately in the privacy policies for users of CCS Adoption and The Centre for Adoption Support and Education.
Who are we?
The Clifton Children’s Society is a registered adoption charity with 115 years of experience finding and preparing families who are able to offer permanent, loving homes for children in care.
Our aim is to find homes for children who are waiting to be adopted and our Voluntary Adoption Agency, CCS Adoption, is renowned for its success in finding families for the most vulnerable and hardest to place children, including: older children, groups of brothers and/or sisters who need to stay together, children from minority ethnic groups, children with disabilities and/or medical conditions, and children suffering the emotional effect of early childhood adversity and trauma.
As well as finding permanent loving homes for vulnerable children, we also work hard to provide the specialist services and support that adoptive families need after they adopt. This is provided through our Social Work team, who provide advice and support to CCS Adoption families throughout their lives, as well as through our Adoption Support Service, The Centre for Adoption Support and Education (‘The Centre’).
Until April 2018 The Centre was a separate charity, and our close working partner, established in 1998 to provide services and support to adoptive families. It is now part of the Clifton Children’s Society, and exists to improve the long-term outcomes for adopted children and their families by providing them with the support they need after they are adopted/adopt. Its activities include facilitating regular groups, activities and events for adopted children and their families; running specialist workshops and training for adoptive parents and professionals; and providing highly specialist therapeutic services for adopted children with additional and more complex support needs. These services are a unique offering in the region and are freely accessed by families from across our catchment area.
How do we collect information?
We obtain personal information from you when you enquire about our activities and services, ask a question, register to attend an activity or event, send or receive an email, make a donation or payment, or otherwise provide us with your personal information.
We also gather general non-identifying information when you use our websites to improve them and the experience of their users (for information please see ‘cookies’ section below).
What information do we collect?
The type of information we collect and how we use it varies depending on why you are providing it. It may include:
- Your title, name, gender and date of birth
- Your address, telephone number, mobile number, email address, and your preferences as to how we should contact you in the future
- The information you give us when filling out one of our online forms
- The financial information you give us when making a payment or donation, including information about your Gift Aid status
- Records of your correspondence with us
- Records of your donation history
- Details about your relationships, i.e. your family, partner/spouse, relationships to other donors/adopters or organisations
- Non-identifying information about your visit to our website, including technical information such as your IP address
- Any other information provided by yourself that is relevant to your relationship with us, for instance your motivations for supporting our work.
Sensitive Personal Data
Data Protection Law recognises that certain categories of data are more sensitive than others. These are known as special categories of personal data and include information about a person’s health, racial or ethnic origin, political opinions, religious beliefs, and from 25 May 2018 genetic and biometric data.
The Clifton Children’s Society does not usually collect special categories of data about our supporters, or for marketing purposes, unless there is a clear reason for doing so – for instance we may ask about your health when you book onto an activity to make sure we provide appropriate support and facilities.
Why do we collect your information?
We collect personal information from you in order to:
- Respond to your enquiry, question or complaint
- Register your attendance at an ‘information evening’ or one of our events
- Update you on our work and the services, activities and events we offer
- Communicate with you about aspects of our work that are relevant to you or that you have expressed an interest in
- Communicate with you about fundraising
- Administer your donation or support your fundraising
- Keep you up to date with the work you are supporting and to ask for support
- Process payments for goods and services
- Keep a record of your relationship with us
- Manage your communication preferences
- Comply with our legal obligations, policies and procedures
- Meet financial auditing requirements
- Understand how we can improve our services, products or information
We use the data you provide to build a positive and personal relationship with you, providing you with the information you want when you want it, and involving you in our work and the future development of our services in a way that is relevant to you.
Legal basis and Legitimate Interests
When we collect and use your personal information, we make sure we adhere to at least one of the legal grounds available to us under Data Protection Law.
We obtain your consent to collect and use your personal information for a previously notified purpose, such as to send you email or text marketing, or provide you with the information or services you have requested. We rely on consent as the legal basis to communicate with our supporters and clients by email and/or text.
In certain circumstances we may process or disclose your information because we are legally obliged to do so – for instance where we are legally required to hold your transaction details for Gift Aid or tax purposes.
We believe that the people who support our work have an interest in receiving occasional updates from us, which is why we rely on the legitimate interest legal basis to send them direct marketing communications by post and to contact them by telephone (subject to checking against the Telephone Preference Service or any existing marketing preferences). We also rely on the legitimate interest legal basis to conduct research to better understand and target our supporters and those interested in our services, to monitor who we deal with and conduct due diligence checks to mitigate against potential risks to our agency and service users, as well as to maintain and administer our fundraising database and systems.
We have a legitimate organisational interest to doing this which we balance against your individual rights, making sure we only use your personal information in a way and for a purpose that you would reasonably expect and that does not intrude on your privacy or previously expressed marketing preferences.
Marketing: communicating with you about our work
Whether your interest is in adoption, accessing adoption support, or supporting our work through fundraising or volunteering, there are so many ways that you can help transform the lives of vulnerable children. Being able to communicate with you about our work is therefore extremely important to us.
We use the details you have given to us, in combination with the above legal grounds and any marketing preferences you have provided, to send you information about our vital work with adoptive families, and the services we offer that are relevant to you:
If you provide your consent to us along with your email address, we may communicate with you by email for fundraising or marketing purposes. By opting in to email communication from us or signing up to our e-newsletter, you grant us the right to use your email for this purpose.
As a charity, with limited resources, we currently send the majority of our communications electronically, through our fortnightly e-newsletter and emails sent to you by members of our team. We would therefore advise that you consent to email contact if you wish to receive the most up to date information from us.
If you have provided us with your postal address or telephone number we may rely on the legitimate interest legal basis to send you direct mail or telephone you about our work, unless you have told us that you would prefer not to receive such information.
We use direct mail to communicate with the individuals who support our work, through donating or giving their time. We keep in touch with them through our fundraising newsletter and Christmas Card Catalogue, as well as occasional appeals and updates. When an individual makes a donation we write to thank them for their support and let them know that we may keep in contact with them by post and telephone and provide details on how they can opt-out of, or change this communication.
If you have actively given your consent to post/telephone communications please note that this consent will last for seven years from the date your consent was provided. We will contact you to give you the option to renew your consent and/or amend your communication preferences around that time.
If we rely on legitimate interest to communicate with you we will send you a reminder that we are still processing your data for these purposes every two years. This reminder will give you the opportunity to amend your communication preferences or unsubscribe from all future communications.
Your wishes are important to us
We promise that we will always communicate with you according to your wishes. It’s always your choice as to whether you receive information about our work, how we raise funds and the ways you can get involved.
If you do not want us to use your personal information in these ways please indicate your preferences on the form on which we initially collect your data.
You can change how we use the information you have provided to us at any time by letting us know, or amending, your communication preferences. If you do not want to hear from us that is also fine. Please contact our Fundraising or Marketing Officers on 0117 935 0005 or email firstname.lastname@example.org to change or amend your communication preferences, or ask to not contact you anymore. You can also opt-out of our fortnightly e-newsletter by clicking the ‘unsubscribe’ link at the end of our email.
We will not use your details for fundraising or marketing purposes if you have indicated that you do not wish to receive this communication. However we will keep information such as your name, address and donation history in our database for financial auditing purposes (we need to keep this for 7 years from your last donation) and to ensure that we don’t mail you in the future if you have asked to no longer be contacted.
The Centre e-Newsletter
The Centre e-Newsletter is a fortnightly bulletin for adoptive families. It contains key information and updates about our work and services, as well as details of any forthcoming activities, events and training opportunities. As a charity that relies on fundraising, we may also include occasional updates and requests for fundraising.
The Centre e-Newsletter is sent by email so we need your consent in order to send it to you. When you provide your consent your name, email address and consent information will be added to our e-Newsletter distribution list.
We also send occasional news and updates to CCS adopters by email. Our CCS e-Newsletter was discontinued on 1st June 2018.
Research and profiling
We do not use research or profiling techniques to analyse or add to the information of our donors and supporters. However in certain circumstances we may obtain publicly available information to understand the origin of a donation or conduct due diligence checks. We do this to ensure that there are no conflicts of interest in us engaging with or accepting a donation from a particular individual or organisation, and to mitigate against potential risks to our agency and service users.
How we protect your information
We aim to ensure that there are appropriate controls in place to protect your personal information. As part of our commitment to this we continue to invest in appropriate technologies to secure and appropriately manage your personal information. For example in 2018 we invested in a new CRM (customer relationship management) system to provide additional security and appropriately manage the personal details of our supporters and those receiving our e-newsletter. This system adds an additional layer of security to the information we hold on you and will only be accessed by named staff members who have been trained in data handling.
We also work hard to ensure our network, on which we carry out all of our IT functions across the charity, and websites are protected and regularly monitored.
Who we share your information with
We do not sell or share your personal details to third parties for either fundraising or marketing purposes. We do however use third party suppliers to perform some services on our behalf, e.g. send out our Christmas mailing, process card payments, manage online fundraising pages, take event bookings etc. In these circumstances we do not give these organisations any rights to use your information except to provide services to us in accordance with our instructions and any agreements we have in place. We take care to ensure that our third party suppliers have appropriate policies and procedures in place to safely manage your data whilst working on our behalf.
Links on our website
Our websites may contain links to third party websites. These third party websites will have their own privacy policies so, if you follow a link to any of these websites, please make yourself aware of their privacy policies before submitting any of your personal information as we do not accept any responsibility or liability for the privacy policies or data handling processes of others.
Transmitting information over the internet
Despite all of our precautions to protect our website and network no data transmission over the internet can be guaranteed to be 100% secure. So, whilst we strive to protect your personal information, we cannot guarantee the security of any of the information you disclose to us online and wish to draw your attention that you do so at your own risk.
How long do we keep your information?
We store your information for only as long as is necessary and/or legally required for the relevant activity. For instance we will keep information such as your name, address and donation history on our database for 7 years from your last donation in order to fulfil our tax and auditing obligations.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request to not be contacted by us.
How long does my consent last?
Your consent will remain valid for 7 years from the date you provided it. Your consent and communication preferences will be recorded on our database and you will receive written and/or electronic communications in accordance with your wishes. You can change or withdraw your consent at any time.
For how long will I be contacted under the legitimate interest legal basis?
When you make a donation or place an order with us we will keep your details on our database in order that we can send you our fundraising newsletter, Christmas card catalogue and occasional appeals and updates by post. If you do not want to receive these updates or want to change what you receive please let us know.
If you do not opt-out of these communications we will send you biennial reminders to let you know that we are processing your information, for these purposes, under the legitimate interest basis, and to give you the opportunity to change or stop your communication preferences. Please note that we are legally required to keep information such as your name, contact details and donation history for 7 years after your donation to fulfil our tax and auditing obligations.
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. The sites www.ccsadoption.org and www.ccsadoption.org/the-centre use a small number of cookies mainly connected to Google Analytics and Google AdWords.
Some of these cookies we use allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site and generally track the numbers of people coming to the site. The information we get through the use of these cookies is anonymous and we make no attempt to identify you or influence your experience of the site while you are visiting it. If you do not allow these cookies we will not be able to include your anonymous visit in our aggregated statistics.
Most browsers will allow you to turn off cookies. If you want to know how to do this please look at the menu on your browser. Please note however, that turning off cookies could restrict your use of our website.
How to change the way we contact you
You can change how we use the information you have provided to us at any time by letting us know, or amending, your communication preferences. If you do not want to hear from us that is also fine. Please contact our Fundraising or Marketing Officers on 0117 935 0005 or email email@example.com to change or amend your communication preferences, or ask us to not contact you anymore.
You can also register your details with the Fundraising Preference Service (FPS) if you want to tell us through the Fundraising Regulator that you would prefer us not to contact you. Those without access to the website can call: 0300 3033 517. Requests to the FPS will take up to 28 days to be actioned by the charity, though at the Clifton Children’s Society we aim to action a FPS request within 10 working days.
Your rights to your personal information
Under the Data Protection Act 1998 you have a right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. You also have a right to request us to erase your personal information, ask us to restrict our processing of your information, or object to the processing of your information.
Should you wish to exercise these rights we ask you to prove your identity with two pieces of approved identification. Please address requests to the Data Protection Officer, CCS Adoption, 162 Pennywell Road, Easton, Bristol, BS5 0TX and we will respond within 40 days of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records.
Changes to this policy
This policy was last updated in May 2018. We may update the terms of this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us or by placing a prominent notice on our website(s).