Final Straw Foundation Privacy Policy

Final Straw Foundation Privacy Policy GDPR

We are committed to protecting your personal information and being transparent about what we do with it. This includes whether you want to work, volunteer or advocate for us, donate, buy goods or use our services, want information or training.

We are committed to using your personal information in accordance with our responsibilities. We are required to provide you with the information in this Privacy Notice under applicable law which includes:

  • the Data Protection Act 1998, which will be replaced by the General Data Protection Regulation (EU) 2016/679 from 25 May 2018
  • the Privacy and Electronic Communications (EC Directive) Regulations 2003.
  • We won’t do anything with your information you wouldn’t reasonably expect.

In this policy references to Final Straw Foundation, or FSF, or to ‘we’ or ‘us’ are to Final Straw Foundation which is a registered charity in England number 1191500.

This Privacy Notice, together with our website terms and conditions, tells you about how we collect, use and protect your personal information.

If you have any queries about our Privacy Notice, please get in touch with us:

or by email: hello@finalstrawfoundation.org

or by post: Final Straw Foundation, 36 Oak Tree Drive, Emsworth, Hampshire PO10 7UJ

How and when we collect information about you

When you directly give us information – We may collect and store information about you when you interact with us.

Examples of this are:

  • To participate in a registered beach clean
  • To sign up to a campaign
  • When you volunteer with us
  • To participate in Community & Events activities, e.g. runs, swims, marathons etc.
  • If we run a school assembly or workshop with you
  • If you’re involved in one of our educational outreach programs
  • When you report contact us through our website or by email
  • When you sign up to our e-newsletter to receive information about fundraising, campaigns, our shop, volunteering activities
  • To organise a beach clean on behalf of FSF
  • When you provide permission to other organisations to share it with us (including Facebook or Twitter)
  • From publicly available sources (where possible) to keep your information up to date (e.g. the Post Office’s National Change of Address database)
  • When you interact with us on social media platforms such as Facebook, WhatsApp, Twitter or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform.
  • We combine the information from these sources with the information you provide to us directly.
  • When providing permission for third party organisations to share your data you should check their Privacy Policies carefully to understand fully how they will process your data.

We will use your personal information for the following purposes

  • Donation processing: We will process personal information you provide in order to administer any one-off or on-going donations and membership you make and to claim Gift Aid.
  • Responding to a request: If you contact us with a query, we may use your personal information to provide you with a response.
  • Volunteering, events and community projects: We will process your details for the use of contacting you about volunteering, events or community projects that you are involved or are interested in taking part in. In the future, we may also contact you to see if you would like to take part again. If you have taken part as a volunteer, have run an event or have run a community project, we also may contact you for fundraising and marketing purposes in line with this Privacy Notice.
  • Fundraising or direct marketing: We will only send you marketing information by email or SMS if you have given us specific consent to do so. If you withdraw your consent and then subsequently opt in to receive marketing information again, then your preferences may be updated.  We will be using legitimate interest for contacting Final Straw Foundation supporters with regards to telephone and mailings, unless you have expressly told us by opt-out that you do not want to be contacted. if you do not want to be contacted for marketing or fundraising purposes you can opt out at any time by contacting us:
    By email: jacey@FSF.org.uk
  • Monitoring and Evaluating: We may use your information in order to improve current and future delivery of our services.
  • Processing an application to work with us: We may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and to respond to you.
  • Transactional purposes: We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, processing your order and payment for a product from our online shop.
  • Providing and developing our website: We may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further.
  • Administration: We may use your personal information to record and deal with a complaint, to record a request not to receive further marketing information, to record what our volunteers have done for us, and for other essential, internal record keeping purposes.
  • Prevention of crime: We may process your personal information to prevent crime and to keep our people and the public safe.
  • Protecting your vital interests: We may process your personal information where we reasonably think that there is a risk of serious harm or abuse to you or someone else.
  • Market research and surveys: We may invite you to participate in surveys or market research to help us improve our website, fundraising, services and strategic development. Participation is always voluntary and no individuals will be identified as a result of this research, unless you consent to us publishing your feedback.
  • Legal, regulatory and tax compliance: Where required we are subject to a legal obligation, we may process your personal information to fulfil that obligation,  to develop our products, services, systems and relationships with you. When we are legally required to hold certain personal information to fulfil statutory obligations, e.g. the collection of Gift Aid
  • Profiling and analysis: We may occasionally, and for the purposes of understanding our supporter base better, use your personal information to conduct profiling of our supporters or potential supporters, high net value individual and legacy pledgers. This will help us to target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to such use of your personal information for profiling at any time by contacting us at the details set out at the end of this Privacy Notice.

    Our profiling and analysis activities can be broken into five categories:
    • Data matching – We may combine the personal information you have given us with data obtained from external sources, such as the Office for National Statistics, to infer the likely social, demographic and financial characteristics, so we can tailor our communications, marketing and services to better meet your needs or the needs of others like you based on the insight we gain from the profile we build. We will not use the results of this data matching activity in a way that intrudes on your privacy or your previously expressed privacy preferences.
    • Segmenting – We conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that campaigns or mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who may fall within a certain segment of supporters.
    • Major donor analysis – We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources such as Google; Companies House; published biographies and publicly available LinkedIn profiles. The type of information we collect can include:
      • career overview
      • gift capacity
      • areas of interest
      • history of giving to us and others
      • how the individual is connected with us and others
      • public information on any philanthropic activities.
    • High value event planning – We may also use profiling to produce short biographies of people who are due to meet with our leadership or attend an event that we may be hosting. This helps our people to understand more about those we engage with, and their interests or connection to us.
    • Ethical screening and minimising risk – As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity.
  • This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering.
  • We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it.
  • We may also ethically screen supporters to minimise risk of creating an association with an individual or group that conflicts with the standards we have set out in our overarching ethical policy.

Who do we share your information with?

We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.

We will only share your data for the following purposes

Third party suppliers: We may need to share your information with data hosting providers or service providers who help us to deliver our services, projects, or fundraising activities and appeals. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.

Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else.

We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.

What information do we collect

We collect various personal information such as name, postal address, telephone number, email address, date of birth (where appropriate), information about your interests and hobbies etc.

We collect this information only in connection with specific activities, such as campaign updates, newsletter requests, registration or membership requests, product purchases, feedback, donations (regular and one off), competition entries, information you provide in public forums on our sites and applications.

The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our sites. However, if you choose to withhold requested information, we may not be able to provide you with certain services.

Data protection law recognises that certain types of personal information are more sensitive. This is known as ‘sensitive’ or ‘special category’ personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person’s sex life or sexual orientation.

Sensitive information will only be collected where necessary, for example, we may need to collect health information from you when you register for a challenge event or to deliver a community service as a volunteer or member of staff. Clear notices will be provided at the time we collect this information, stating what information is needed, and why.

With your explicit consent, we may also collect sensitive personal information if you choose to tell us about your experiences relating to our services for use in a case study.

Consent by email

On our website and when we collect any personal information, you will be given the option to opt-in to receive communications from us by email. Where you agree, we may send you information about our events, campaigning, membership, volunteering, products, fundraising and other activities. By providing personal data to us you consent to its use as described in this Privacy Policy.

By entering one of our competitions, volunteering, take part in an event and or a community-based project such as beach clean, plastic free communities, FSF education, you will generally be agreeing to receive mailings or emails from Final Straw Foundation for direct marketing and agreeing to this privacy policy.

If at any time you want to alter your preferences or request that we stop communicating with you please let us know by emailing us on hello@finalstrawfoundation.org

Telephone and Mail

For mailing and telephone based direct marketing campaigns, we may contact you by telephone and mailing campaigns under legitimate interest. We will not contact you if you are registered with the Telephone Preference Service (TPS) or Mail Preference Service (MPS) unless you have given us opt in consent that you are happy to receive calls or mailings from us.

You may still receive other types of telephone calls or mails from us as long as they are not for marketing purpose and are admin based, such as checking your direct debit mandate or Gift Aid status.

How we will use legitimate Interest

If we contact you on the basis of legitimate interest, Final Straw Foundation will always create a legitimate interest impact assessment (LIA).  This will be shared and reviewed by senior management. Examples of how we may contact you under legitimate interest for mail or telephone direct marketing campaigns are:

  • welcoming you to the Final Straw Foundation
  • asking for a Gift Aid declaration
  • thanking you for your support
  • asking if you would consider increasing your regularly support or membership
  • asking if you may include leaving a gift in your will to Final Straw Foundation
  • finding out why you left Final Straw Foundation
  • contacting you about renewing your membership or support
  • contacting you about appeals or campaigns that we need financial support for
  • if you have stopped supporting us financially, asking if you may re-join or support us with a donation (but no further back than six months since your last payment)

If at any time you want to alter your preferences or request that we stop communicating with you please let us know by calling us on hello@finalstrawfoundation.org

If you’re 16 or under

If you are aged under 16, please ensure you obtain your parent/guardian’s consent before sending any personal information to any website or to Final Straw Foundation.

We do have activities for those under 16, so we may ask your age when contacting you. Prior to taking part in these activities, please ensure you speak to your parent or guardian.

Please note that we will not knowingly accept online donations, raffle ticket requests or orders for goods or services from persons aged under 16 years.

We encourage you to be aware of the activities in which your children are participating, both offline and online. If your children voluntarily disclose information, this may encourage unsolicited messages. We suggest that you discourage your child from providing any information without your consent.

How we protect your information

We use technical and corporate organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.

We undertake regular reviews of those who have access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partners. We do this in accordance with industry standards and do not store the details on our website.

However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.

Vulnerable circumstances

We understand that additional care may be needed when we collect and process the personal information of vulnerable supporters and volunteers. In recognition of this, we observe good practice guideline in our interactions with vulnerable people.

How long will we keep your information

We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction).

If you request that we stop processing your personal information for the purpose of marketing we may in some instances need to add your details to a suppression file to enable us to comply with your request not to be contacted.

If you have participated in an event or challenge, been a voluntary, taken part in a project, we may keep and use your information to contact you for up to six years in line with this privacy policy.

In respect of other personal information, we will retain it for no longer than necessary for the purposes for which it was collected, taking into account guidance issued by the Information Commissioner’s Office.

Your rights to your personal information

Data protection legislation gives you the right to request access to personal information about you which is processed by Final Straw Foundation and to have any inaccuracies corrected.

You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information.

If you wish to exercise these rights, please email hello@finalstrawfoundation.org and you will also need to provide copies of two separate identification documents, such as a passport, driving licence, or utility bill.

Please also provide any additional information that is relevant to the nature of your contact with us, as this will help us to locate your records.

You can send  the documents via post to: Data Protection Officer, Final Straw Foundation, 36 Oak Tree Drive, Emsworth, Hampshire PO10 7UJ

Alternatively, email a copy of the form along with scans or photos of your two forms of identification to hello@finalstrawfoundation.org

We will respond within 28 days, on receipt of your written request and copies of your identification documents. We reserve the right to charge a fee to process the request.

Storing your information

Information which you submit to us is sent to computers located in the United Kingdom, specifically our registered address. This is necessary in order to process the information and to send you the information you have requested.

Information submitted by you may be transferred by us to other reputable third party organisations as referred to in this Policy. This will be done in accordance with guidance issued by the Information Commissioner’s Office.

Any personal information you supply to us will not be retained for longer than necessary.

Other websites

Our websites contains hyperlinks to many other websites. This Privacy Policy only applies to this website so when you link to other websites you should read their own privacy policies. Please let us know if a link is not working.

In purchasing goods or services from any of the companies to which any Final Straw Foundation sites links, you are forming a contract with the company(s) concerned (agreeing to their terms and conditions), not Final Straw Foundation.

Using our social media pages

While this statement covers our privacy practices and how we will use any information collected from our websites and social media pages, it doesn’t cover how providers of social media websites will use your information.

You should read the social media site’s privacy policies before adding any content to our social media pages. Make use of the social media site privacy settings and reporting mechanisms to control the way that your information is handled.

Posting content on our websites and social media pages

Remember that the internet provides instant worldwide access. Any information that you provide will be worldwide instantly.

We don’t moderate our websites. So, if you post comments about other people it’s not only your privacy that is at stake. Protect your friends’ privacy and reputations. Be careful about uploading any content that may show you or your friends in compromising situations and be aware that other users may abuse the content you have provided. Please don’t provide information about yourself or other people unless you’re sure you and they are happy to have it made public. In particular, don’t provide any information about others without their consent where that information might identify them, such as:-

Names

Tagged photos

Location

Under no circumstances make public other peoples’ home address, email addresses or contact numbers.

Scientific data

If you supply Final Straw Foundation with scientific or environmental records e.g. as part of a citizen science or volunteer project, they will be carefully stored by us and/or our project partners. Such records may include, for example, amount of litter removed from a beach clean, location, dates and litter photographs. Scientific data sharing helps to further research, education and our national understanding of biodiversity and conservation issues. Hence anonymised scientific data may also be shared with third parties such as academic researchers and students.

In some circumstances such scientific data (but no personal information) may be sold, but the income will be directly used to support the running cost of our data-gathering projects. By submitting your scientific or environmental records you are indicating agreement with our approach.

Security

We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. Whilst we can’t ensure or guarantee that loss, misuse or alteration of information won’t occur, we’ll use standard industry methods to prevent this.

Unfortunately, the transmission of information across the internet isn’t completely secure and whilst we do our best to try to protect the security of your information, we can’t ensure or guarantee that loss, misuse or alteration of information won’t occur whilst you or we are transferring this information.

Where you or we have provided a password enabling you to access parts of our websites or use our services, it’s your responsibility to keep this password confidential. Please don’t share your password with anyone.

Cookies and how they benefit you

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Our cookies help us:

  • Make our website work as you’d expect
  • Remember your settings during and between visits
  • Improve the speed/security of the site
  • Allow you to share pages with social networks like Facebook
  • Continuously improve our website for you
  • Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)

Granting us permission to use cookies

If the settings on your browser that you are using to view this website are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below, however doing so will likely mean that our site will not work as you would expect.

How long do cookies last

When a web server sends a cookie, it asks your browser to keep that particular cookie until a certain date and time. These dates can be:

  • Some date in the future – Might be a few minutes or a few hours from now (to track something like your shopping cart in an online store).
  • The cookie might expire many years in the future, to keep track of your
  • browser for a long time
  • When you close your browser – Called a session cookie, the next time you start your browser these will have vanished
  • Some date in the past – This is how the server asks a browser to remove a previously-stored cookie

Our own cookies

We use cookies to make our website work including:

  • Remembering if you have accepted our terms and conditions
  • Allowing you to add comments to our site
  • Remembering if we have already asked you certain questions (e.g. youdeclined to use our app or take our survey)
  • There is no way to prevent these cookies being set other than to not use our site.

Site improvement cookies

We regularly test new designs or site features on our sites. We may do this by showing slightly different versions of our websites to different people and anonymously monitoring how our site visitors respond to these different versions. Ultimately this helps us to offer you a better website experience.

Anonymous visitor statistics cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using, how long they spend on the site, what page they look at, etc. This helps us to continuously improve our website. These analytics programs also tell us, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before, helping us to develop our services for you. Our site uses google analytics.

Advertising or Targeting cookies

These types of cookies are used to deliver adverts which will be more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Targeting or advertising cookies will often be linked to site functionality provided by the other organisation.

We sometimes use ‘Advertising’ cookies on Final Straw Foundation websites to:

  • Link to social networks, like Facebook, who may use information toprovide targeted advertising to you on other websites
  • Used to identify that you have visited a Final Straw Foundationwebsite, to show you relevant adverts from us
  • Provide advertising networks with information on your visit so thatthey can present you with adverts that you may be interested in

Third party functions

Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Our site includes the following third part functions which use cookies:

YouTube, wordpress

Disabling these cookies will likely break the functions offered by these third parties

Turning Cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so, however, will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites.

It may be that your concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.

How to make a complaint or raise a concern

If you would like more information, or have any questions about this Privacy Notice, to make a formal complaint about our approach to data protection or raise privacy concerns please contact us by email at hello@finalstrawfoundation.org

If you would like to make a complaint in relation to how we have handled your personal information, please follow our complaints procedure which is available by contacting us via the contact details above. If you are not happy with the response you receive, then you can raise your concern with:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Alternatively, you can visit their website https://ico.org.uk/

Changes to our Privacy Policy

Our Privacy Policy may change from time to time, so please check this page occasionally to see if we have included any updates or changes, and that you are happy with them.

Last Update: 13/10/2020