Child Brain Injury Trust
Privacy Notice 2018
You’re in safe hands
The Child Brain Injury Trust (CBIT) takes your privacy seriously. We are committed to protecting your personal information. This policy sets out how CBIT uses the information that you provide us with to help further our work in supporting families following childhood acquired brain injury (ABI).
About us: CBIT is the UK’s leading children’s ABI charity in the UK. Since 1991 we have existed to support families and professionals following ABI. We have integrity, professionalism and are committed to achieving the very best outcomes through our work. This includes how we treat the information and personal details that you share with us.
We will not sell your data to any third parties, but we may sometimes share your information with trusted service providers and selected partners who work closely with us and are trusted by the charity. We ensure that any third parties with access to your data are GDPR compliant and they hold strict standards for data use and security.
Who we are
CBIT (the data controller) and our subsidiaries we mean:
- The charity
- Our subsidiary trading company (Child Brain Injury Rehabilitation Service)
- Suppliers such as consultants working on our behalf
our Data protection officer can be contacted on 01869 341075
Your Information – what we collect and how we use it
CBIT collects information from the public in a number of different ways. For example, we ask for contact details and other information when members of the public refer or are referred to our service, sign up to a fundraising event, a conference, learning events or request information about our services or subject matter. This may include information such as your name, date of birth and contact information. We use this information to help us provide and improve our services as a charity and to keep a record of our communications with you.
If you are a financial supporter of CBIT, through direct debit, as a one-off gift, or donating to us we will ask for information that enables us to administer your donation. This will normally include information such as your name, contact details such as address, email or telephone number and your payment details and Gift Aid status.
If you have given us your consent, we will contact you with information and updates on our work, events, services and how you can support us. This may be by post, email, telephone or text message, depending on your preferences. We will also continue to ask about your marketing preferences, to ensure that you are still happy to be contacted by us and by which means.
If you enquire about our charitable services, with your consent, we may collect some sensitive personal information such as your children’s information and health information to ascertain how we might best be able to support you. For people wishing to work or volunteer for the charity, we will collect information about any criminal convictions (eg job or volunteer applications).
What the Law says about protection of personal information
The Law on Data Protection is derived from legislation – General Data Protection Regulation (the ‘GDPR’) which will become enforceable in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the legal grounds must apply.
The five legal grounds that are most relevant to CBIT’s use of your personal information are:
- Legitimate Interest
- Legal Obligation
- Vital interest
How the law applies to CBIT’s use of personal information
CBIT will only process (use) your personal information if we have:
- asked you and have a record of your express and recent consent for us to do so;
- a ‘Legitimate Interest’ to do so in order to support our charitable purposes. Our use will be fair and balanced and never unduly have an impact on your rights.;
- a contract with you that we can only fulfil by using your personal information, e.g. to send you an item that you have requested;
- a legal obligation to use or disclose information about you, e.g. we are required by law to keep records of gifts that are given to us with Gift Aid for 4 years; and we are compelled to disclose information relating to safeguarding.
In extreme situations, such as an accident or medical emergency, we may share your personal details with the emergency services if it is essential for the preservation of life (yours or another persons’) for us to do so. This is the ‘vital interest’ ground for using your personal information. After the emergency, we will always try to inform you about how we had to use your information in that extreme situation.
We will not unduly prioritise our interests as a charity over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.
CBIT will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities.
CBIT will always ask for your consent before we communicate with you for certain purposes. For example, we will only email or phone you about our fundraising activities if we have an accurate record of your recent and freely given consent to do so.
You can withdraw your consent at any time by phoning 01869 341075 or emailing firstname.lastname@example.org
There are times when it is not practical to obtain and record consent. At those times, we will only process personal information if that processing would meet another legal ground e.g. Legitimate Interests, in which case we would only process in accordance with the law’s strict rules on legitimate interest processing.
What is Legitimate Interest
This legal ground for processing means that organisations can process your personal information if they 1. have a genuine and legitimate reason for doing so and 2. That use does not harm any of your rights and interests as an individual.
CBIT’s Legitimate Interest
We do not unduly prioritise our legitimate business interests as a charity over your interests as an individual. We always respect your rights. Which is why we carry out a balancing exercise of the rights of the charity with the rights of our supporters.
We believe that the best way to look after the interests of our supporters is to consider their unique interests and expectations. As a result, we have established the following categories for CBIT supporters. This provides us with an additional method for assessing that we use your personal information in a way that matches your relationship with us; your interests; and your expectations about your rights.
- Legacy donations
- provided financial donations
- demonstrated an interest in our cause by contacting us for more information, e.g. to find out more about one of our products, services or campaigns, or have attended an event.
What we have a Legitimate Interest to do
We believe that CBIT supporters and beneficiaries are connected to our mission and want to know how they can continue to help us to achieve our charitable aims. Unless you tell us not to, we think you are content for us to process (keep and use) your personal information for the following lengths of time. As of May 2018, we promise not to keep your personal information for longer than we specify below. This is not the length of time that we will continue to contact you – this could be a shorter period of time (see below for an explanation on our personalised approach to communications).
Are anyone affected by childhood acquired brain injury; adults, children, young people and professionals that access our services, request information or attend an event. We think that you would like us to stay in contact throughout a child’s development, which we consider to be when a child reaches 24.
- Financial Supporters
Donations you’ve made to us for 7 years since the date of your last donation
- legacy donations
If you indicate that you’d like to leave us a legacy gift we will retain personal data until 7 years after the legacy is received
- Purchasing services, like training or consultancy
We will retain your information for 3 years
- Subscribing to a newsletter
You can unsubscribe at any time
- Making an enquiry to the Information and Learning team
We will retain your information for 5 years after the last event you attended
- Making an enquiry to the Information and Referral service
We will retain your information for 5 years after the last contact with you
It is always your choice. If you don’t think this is quite right for you, you can tell us to change your communication preferences and our use of your information. You can do this at any time by phoning 01869 341075 or emailing email@example.com
Legitimate Interest to send you direct mail
Unless you tell us not to, we will rely on our Legitimate Interest ground (explained above) for sending you direct mail. From time to time, we would like to send you exciting updates about our work, products, services and how you can support us, including fundraising activities and events. Unless you have requested that we do not send you some, or all of this, our direct mailings include marketing and fundraising asks which further the aims and objectives of CBIT.
We are always mindful of trying to only send you what you are interested in and only as often as is appropriate. If we do not appear to be sending communications that are of interest, we will review this and will endeavour to reduce and then stop these types of communications in a much shorter time than the above defined period of Legitimate Interest.
Legitimate Interest to process your information
We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.
When it is necessary we will contact you for administrative purposes, e.g. to contact you regarding a specific service or payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.
To help you to understand when and why CBIT would use Legitimate Interest to process your personal information we provide the following examples:
- To send direct mail via email or by post communications
- To enhance, modify, personalise and improve our services and communications for the benefit of our supporters and beneficiaries.
- To improve security of our websites and systems.
- To prevent fraud when transacting on our website.
- To process your donations.
- To fulfil online transactions; process and deliver your order(s). To take payment and arrange delivery, we need to collect personal information, including your payment details, your full name, delivery address and contact details.
- To provide appropriate and personalised support to you
- To analyse your personal information to ensure that our communications are relevant to you.
The above list of examples is on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop. You can do this at any time by phoning 01869 341075 or emailing firstname.lastname@example.org.
In order to communicate with you more effectively, better understand your preferences and ability to support our work, we may analyse your data.
We like to find out about your personal motivation for supporting CBIT and your experiences as a beneficiary and or as a supporter. This helps us to give you the information about products and services most relevant to you. In some instances, we may carry out research and/or analysis of the personal information that you have provided to us and add publicly available information (such as public records or social media) to help us tailor our communications to you, this may include wealth screening. We do this to create a fuller picture of our supporters, to improve our service and to manage our contact with you in an appropriate and cost-effective way. This information could include things like your interests, preferences and the level of any potential donations.
To help us communicate the work we are doing and provide these services we use trusted service providers such as fundraising consultants.
CBIT do not share, sell or swap your information with other organisation for their own marketing.
Changes to your data
From time to time we may contact you to ensure that the information you have provided us with remains accurate and up to date.
Like all organisations, we comply with requests for the disclosure of personal information where this is required or permitted by law. This could include requests from legal providers, law enforcement or tax agencies. In these circumstances, the request must be submitted in writing and in accordance with the relevant legal requirements.
If you believe your privacy rights have been violated, you may file a complaint with us or with the Information Commissioners office https://ico.org.uk/
You can contact us at any time by phoning 01869 341075 or emailing email@example.com to discuss changes to your data
Cookies and Web Privacy
We at CBIT guarantee our commitment to respecting and protecting your online privacy.
This includes your need and your right to know what we do with the personal information you share with us. It also guides our company’s policies regarding the management of this data, including how the information is collected, processed, and for what purposes.
The collection of information
Every time you log on to our website your IP (Internet Protocol) address registers on our servers. Your IP address reveals no information other than the number assigned to you. We do not use this technology to get any personal data against your knowledge or free will (i.e., automatically recording e-mail addresses of visitors). Nor do we use it for any purpose other than to help us monitor traffic on our website, or (in case of criminal activity or misuse of our information) to cooperate with law enforcement.
We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.
The list below describe the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete the cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari etc.)
First Party Cookies
These are cookies that are set by this website directly.
Find out more about Google’s position on privacy as regards its analytics service.
Third Party Cookies
These are cookies set on your machine by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks. Cookies are currently set by LinkedIn, Twitter, Facebook, Google+ and Pinterest. In order to implement these buttons and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website.
You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
If you choose to join our mailing list, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor. The email address that you submit will not be stored within this website’s own database, but we store our t in our own database.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal, please send your email to us using the email account that is subscribed to the mailing list.
While your email address remains within the MailChimp/Salesforce database, you will receive specific emails relating to the content that you have requested to receive, this may include but is not limited to emails regarding fundraising, campaigns, events and information & learning events or elearning activities. Emails will be sent approximately twice monthly.
Some emails that we send you have no tracking in at all e.g. service emails with invoices attached. Other emails we send we can track, at an individual level, whether the user has opened and clicked on the email. We do not use this information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked, then you should opt out of our emails which you can do via the unsubscribe link at the bottom of every email we send.
Financial transactions made online to CBIT using this site are secure (Paypal). No one can access your credit card details via the internet.
All information given on this site is to the best of our ability.
Whilst CBIT is happy to supply any information and guidance regarding childhood acquired brain injury to members of the public, it must be appreciated that CBIT will NOT be liable for injury, loss or damage arising from such guidance supplied.
You may print any factsheet on this site for your own information, but you may NOT sell it, reproduce it on the Internet, distribute it, alter it, or reprint it in any publication without permission from CBIT.
Please note that all material on this website is the copyright of CBIT. You may print any CBIT factsheet on this site for your personal use, private study or for teaching purposes in schools colleges or universities provided all material is marked “By kind permission of the Child Brain Injury Trust” and the material cannot be adapted for use in any other publication, used for profit or used in any way that will bring the charity into disrepute.
The name and logo of CBIT are registered Trade Marks. Any use of these Trade Marks other than for private study or teaching purposes as stated above must be made with the prior express permission of CBIT. If you are unsure what material you can or cannot use please contact the Marketing department on 01869 341075
This information was last updated in June 2018. From time to time, we will make changes to the information on this page. The amended information will apply from the date it is posted on the site and will govern the way in which we collect and use personal information from then on.