Data Protection and Privacy Policy

This Privacy Notice summarises, and forms part of our Data Protection and Privacy Policy which immediately follows it. At Family Right Group we protect your rights and we provide you with a clear route to contact us about the data we process that relates to you personally.

In carrying out our day-to-day activities, we process and store personal information whether you are visiting our website to seek information, to partake in research, as a supporter, shopper, or campaigner. We adhere to the requirements of the UK Data Protection Act (DPA) 1998 and on implementation, the General Data Protection Regulations (GDPR) 2018.

For the purposes of this Privacy Notice and our full Data Protection and Privacy Policy:

• ‘Processing data’ means obtaining, recording or holding information, or carrying out an action such as organising, disclosing or destroying the information.
• ‘Direct marketing’ means the communication of any advertising or marketing material which is directed to particular individuals.
• ‘Administration’ means the processing of data which excludes any element of direct marketing. Examples include: sending a thank-you letter to acknowledge a donation; contacting and sending information to applicants during a recruitment process, sending charity sport activity details to participants; sending out materials requested for fundraising, research, training and events purposes; sending out advance-notification letters for direct-debit purposes and invoicing.

The type of communications and information you receive about our charity and the ways in which you can get involved are your choice. You can change your mind at any time, or ask to see the information we hold about you, by contacting: Family Rights Group, 101 Pentonville Road, London, N1 9LG, or by phone on 0207 923 2628 or via email at office@frg.org.uk.

We collect information about:

• Visitors to our website (WordPress), discussions forums (phpBB) and owned social-media channels (Family Rights Group’s Facebook page, Twitter, Instagram, LinkedIn and YouTube channel).
• Our subscribers via e-marketing newsletter tools (Vertical Response and Mailchimp).
• Respondents to surveys (Survey Monkey), website training and events forms and applications (WordPress, Yammer, Eventbrite and Wufoo).
• Our customers who have purchased products via our online shop (WordPress) i.e. credit/debit card details (if making a purchase or donation – PayPal, Enthuse, BACS).
• Our supporters (including our past and present donors, event participants, individuals giving non-financial assistance), prospective supporters, beneficiaries and members of the public who make contact with us, including those who share their personal information with us.
• Complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry.

We collect:

• Personal data. Examples are names, dates of birth, email addresses, telephone and postal addresses. We also collect Internet Protocol (IP) addresses. This is information a computer uses to identify a networked computer to which it transmits.
• Non-personal data. An example is the web pages accessed on a computer. We collect this information so that we can help tailor future content and provide insight into problems in current implementations.

Consent:

• We seek your consent if consent is necessary. To assess whether consent is necessary we carry out a balancing exercise between your rights and expectations, and our legitimate interests to carry out the data processing activity, consistent with the law. Confidentiality will normally be assured to anyone seeking advice or advocacy or with whom we have contact.
• Workers who are employed in any capacity by Family Rights Group will not pass on information to other agencies without the direct permission of the client. In most situations this permission will be requested in writing, unless it is agreed that there is a matter of urgency and then verbal permission will suffice in which case written confirmation will be sought as soon as possible.

Your data:

• We will never sell your data to any individual or organisation.
• We keep the information we hold about you accurate and up-to-date so far as we are able.
• We follow the Code of Fundraising Practice for the UK, issued by the Fundraising Regulator, to ensure that we treat all donors, including vulnerable donors, fairly.
• If you ask us to remove your personal information from our records, we will make efforts to ensure we have identified the correct record on our system, and we will review the data to ensure that we are not required to hold it for legal reasons. If, once these actions have been taken, we determine that we have no legal obligation to keep your data, we will retain your key details – i.e. your name, home address and email address – on a suppression list to make sure that we do not contact you again, and we will destroy all other information we hold about you. (If we were to remove your details completely we would have no record of your wishes, and therefore someone from Family Rights Group might inadvertently contact you again.) The only exception to this will be if we are required to keep a record of your gifts for Gift Aid and financial audit purposes, in which case we will anonymise your record and retain the relevant data in a locked note which can only be accessed by a relevant employee.
• We use a secure server for all areas of our website which collect personal information.
• We use cookies to help us track the success of our online advertising and to monitor the use of our website.
• We review and update our application of this policy at least every four years.

Family Rights Group was established in 1974, by a group of lawyers, social workers and academics who were concerned about how families were treated when social services were involved with their children.

As a charity, Family Rights Group’s main objective is to enable children to be raised safely and thrive within their family and community. We work with parents whose children are in need, at risk or are in the care system and with members of the wider family who are raising children unable to remain at home.

To further this objective, Family Rights Group delivers a number of business functions, some of which involve the collection, gathering and processing of information that is considered personal information. The way in which Family Rights Group processes this type of information must comply with the requirements of the Data Protection Act (1998) (DPA) where it constitutes personal data and, from 25 May 2018, the General Data Protection Regulations (GDPR).

The purpose of this data protection, privacy and communications policy is to explain how your personal information is processed and provide information about the rights you have under data protection legislation. For each of Family Rights Group’s business activities that use personal information, details are provided about what information we collect, how we use that information, and what happens to your information when it is no longer required.

In carrying out our day-to-day activities we process and store personal information relating to our supporters and we adhere to the requirements of the UK Data Protection Act (DPA) 1998 and, on implementation, the General Data Protection Regulations (GDPR) 2018.

We take our responsibilities under data protection regulation seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with those regulations and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.

We hold and process personal data:

• To send our supporters marketing information about our projects, upcoming training and events and appeals where we have their consent or are otherwise allowed to.
• To fulfil contractual obligations entered into with customers e.g. on-line purchases via our web shop (WordPress) i.e. credit/debit card details (if making a purchase or donation – Paypal, Enthuse or BACS).
• On visitors to our website (WordPress), discussions forums (phpBB) and owned social-media channels (Family Rights Group’s Facebook page, Twitter, Instagram, LinkedIn and YouTube channel).
• On subscribers via e-marketing newsletter tools and to ensure we do not send unwanted information to members of the public who have informed us they do not wish to be contacted i.e. unsubscribed lists (Vertical Response and Mailchimp).
• To contact respondents who have expressed consent in surveys (Survey Monkey), website training and events forms and applications (WordPress, Yammer, Eventbrite and Wufoo).
• To keep a record of donations made and actions taken by our supporters and our communications with them and to claim gift aid on donations.
• To contact supporters (including our past and present donors, event participants, individuals giving non-financial assistance), prospective supporters, beneficiaries and members of the public who make contact with us, including those who share their personal information with us.
• To contact complainants and other individuals in relation to a data protection or freedom of information complaint or enquiry.

For information about why and how our advice and advocacy service collects and uses personal data see here.

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

We ensure that there are appropriate technical controls in place to protect your personal details. For example our online forms are always encrypted and our network is protected and routinely monitored.

For financial and technical reasons we may, on occasion, need to use the services of a supplier outside the European Economic Area (EEA). If this were to occur we would ensure that your information is held in compliance with the Data Protection Act and the General Data Protection Regulations. By submitting your personal information you agree to this transfer, storing or processing at a location outside the EEA. We will take all reasonable steps to ensure that your data us kept secure and in accordance with this privacy policy.

We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules and we reserve the right to change it to reflect subsequent changes in those rules and 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 not to be contacted by us.

Under the GDPR, you have a number of rights in relation to your personal information. You have the right to:

• request access to your personal information;
• request rectification of your personal information which means you are able to have inaccurate personal information corrected without undue delay;
• request erasure of your personal information when certain conditions apply;
• restrict processing under certain circumstances;
  object to processing;
• data portability in some circumstances.

There may be occasions when Family Rights Group is unable to comply with requests to exercise the rights above. Should this apply to a request you make, it will be explained to you why Family Rights Group is unable to comply with the request and any options available. For some data processing activities we may need your consent before we can contact you. We carry out a balancing exercise to assess whether or not we need your expressed consent to conduct our activities. To do this, we consider both the content of the personal data that we collect and the way in which we wish to use that data.

Where your personal information is being processed using consent, one further right is the right to withdraw your consent at any time. You should be aware that, while Family Rights Group will stop using your information for that purpose with immediate effect, it may not always be possible to remove information from the public domain, for example where it has been used in hard copy publications. You should also be aware that the ability to withdraw consent only applies to information considered to be personal. It does not usually apply to information about groups or organisations.

We may supplement or add to the information we hold about you with information that is available through, or we receive from, other sources, e.g. public registers, or third-party information services. This allows us to send you the most relevant information and promote those fundraising opportunities that we believe you are most likely to be interested in.

You may withdraw your consent at any time for allowing your information to be used for marketing purposes.

If you share a personal story with us via our website, advice service or social media channels we may invite you to consent to future communications from us and to sharing your story more widely. Occasionally Family Rights Group is invited by journalists to contribute to news stories relating to our cause, and in this situation we may invite you to participate or to allow us to use your story for these purposes.

If you are not happy with the way we have handled your data, and are unable to resolve the issue with us personally, you can complain to the ICO.

The following third parties are involved with our website. They will only use your information for the processes specified. They will not use your personal data for their own purposes and take their own measures to protect it.

• MailChimp and Vertical Response. They handle our mailing lists and hold your e-mail address, if you give your consent.
• Enthuse (formerly known as Charity Checkout). They securely handle the processing of your online donations.
• PayPal. They process payments for our training and events on our site. Any financial details are handled by PayPal.
• JustGiving. They handle donations or fundraisers via their own website.
• Eventbrite. They manage our event guest list.
• Google Analytics. They track the time spent on our website and what pages you have visited so as to allow us to improve our website based on user feedback.

To ensure that we communicate with our supporters through their preferred channels, and to enable us to share updates about our work, we need to collect different types of information, including personal data.

If you consent to receive regular updates relating to the activities of Family Rights Group via our e-newsletters, your data will be processed and shared with and you will be contacted by the third party organisations Vertical Response and Mailchimp. Your data will be on Vertical Response’s and Mailchimp’s servers and offices which are located in the United States, so your information may be transferred to, stored, or processed in the United States.

We use Vertical Response and Mailchimp to gather statistics about the number of emails opened and clicks made using industry standard technologies. This helps us monitor and improve our mailings. You can unsubscribe to our mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by emailing: office@frg.org.uk. For more information, please see Vertical Responses’ privacy policy here and MailChimp’s privacy policy here.

We use SurveyMonkey to conduct research on behalf of the organisation. When completing online research surveys for Family Rights Group, most surveys will be anonymous. However depending on the nature of the research to be carried out, Family Rights Group from time to time will ask for your contact details i.e. name, address, organisation, telephone number and email address. Surveys are currently completed via a secure external online survey called Survey Monkey which is password protected. In compliance with the Data Protection Act, Survey Monkey complies with the EU-US Privacy Shield Program and will take all steps, reasonably necessary to prevent the loss, misuse or alteration of personal information. The data collected through these surveys will be used for research analysis for Family Rights Group and its associated projects only. SurveyMonkey’s Privacy policy can be found here.

As part of any recruitment process, Family Rights Group collects and processes personal data relating to job applicants.

When you visit our work for us page, you may be asked to provide certain information about yourself, including your name, contact details, date of birth and job history. Some of the information is mandatory in order for the organisation to consider an application for a vacancy or meet its statutory monitoring and reporting responsibilities.

Family Rights Group collects a range of information about you:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current level of remuneration; and
• whether or not you have a disability for which Family Rights Group needs to make reasonable adjustments during the recruitment process.

Family Rights Group may collect this information in a variety of ways. For example, data might be contained in application forms, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

Family Rights Group may also collect personal data about you from third parties, such as references supplied by former employers, information from employment background check providers and information from criminal records checks.

Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Google Analytics:

A significant number of websites across the globe use Google Analytics in order to analyse data relating to the number of unique visitors visiting their websites on a daily basis. Google Analytics gathers information about website use by means of cookies. The information which Google provides enables companies to monitor the success of the website which in turn enhances the users’ visiting experience.

We use Google analytics as it enables us to monitor how long each user spends on each individual page, meaning that we can observe carefully, the length of time each visitor spends on each page. We can therefore remove any content which is not viewed and replace this material with more helpful material therefore enhancing both the users’ visiting experience and the functionality of our website. For more information on Google Analytics please see here.

Cookies:

In order to provide you with the best, tailored experience of frg.org.uk, our site will need to place small text files, or ‘cookies’, on your computer. Cookies are effectively small text files comprising of letters and numbers which are downloaded on to a user’s computer device whenever the user visits certain websites. Although Cookies do not provide personally identifiable information the purpose of the recently implemented legislation is to protect the privacy of internet users.

Most cookies that we use are ‘session’ cookies and only exist for the time that you are using our site. They perform functional tasks – such as remembering that you are logged in as you move from page to page, or to pre-load your personal details into forms to save you time.

We also track cookies anonymously to fuel our site analytics and learn how to improve your frg.org.uk experience and hone the relevance of our products and services.

We also use cookies in our emails to track open rates and other performance indicators – again, so that we can continually improve the relevance and experience of our offering to you.

Most web browsers automatically have Cookies enabled by default. This does not mean that you cannot change your default setting. You can easily do so by locating the ‘Help’ menu on your device.

Links to other sites:

Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using our ‘Contact us’ details (located at the footer of our website).

If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered by the Family Rights Group’s Privacy Policy. We suggest you read the privacy policy of any website before providing any personal information.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with Family Rights Group.

If you would like to request information about our privacy policy, you can email us on office@frg.org.uk, telephone 020 7923 2628 or write to:

Family Rights Group
101 Pentonville Road
London N1 9LG

Changes to this Privacy Policy:

This Privacy Notice was last updated on 15 May 2018 and will be reviewed and updated from time to time. Older versions can be obtained by contacting us.

In relation to your data:

• We will never sell your data to any individual or organisation.
• We keep the information we hold about you accurate and up-to-date so far as we are able.
• The private notice sets out how we will respond to any request to remove personal information from our records.
• We use a secure server for all areas of our website which collect personal information.
• We review and update our application of this policy at least every four years.