PRIVACY STATEMENT

We are committed to protecting the privacy of our supporters and stakeholders. Please read this policy which explains how we collect, manage, use and protect your personal information.

Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with the preferences you’ve expressed and in line with this privacy statement

Step by Step may update this statement to remain compliant with Data Protection Law by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

Personal information is collected directly from you when you interact with Step by Step, for example making a donation, sending or receiving an email, making an enquiry, visiting our website, applying for a role with us, participating in an event or when signing up to a campaign or for our newsletter. Information may be collected in person, over the phone, through our websites, social media or from something you’ve posted to us.

The information we hold will typically include some of, or all of, your name, postal and email addresses, your phone number, and may include information like your date of birth and your bank details if you are supporting us financially. We may also receive information about you from other sources (including public sources). This is explained in the ‘How we might use your information’ section below.

We may use your information for administration purposes

Processing your donation
When you make a donation or other payment to Step by Step, we will use your payment and contact details, payment amount, date and time of payment; to process that payment and take any follow-up administrative action needed (for example, sending a receipt).

If you choose to include Gift Aid with a donation to us, then we will also ask for your address and UK taxpayer status as this information is required by law. You can read more about how Gift Aid works here. This information is needed for us to fulfil our obligations under tax (sections 413 to 430 Income Tax Act 2007) and charity law. Information associated with Gift Aid declarations must be retained for 7 years. This information will be shared with HMRC for tax regulation purposes and may also be shared with the Fundraising Regulator and the Charity Commission in the event of an enquiry or investigation.

Responding to enquiries
If you contact us with a question, comment, compliment or complaint then we will keep a record of this correspondence and any associated documents so that we have the information available in the event of a follow-up, dispute or investigation.

Notifying you of changes to policies
If we make significant changes to our policies which may affect you, we will use your contact details to inform you of the changes.

Requesting information if you are attending our events
If you participate in an event that we have organised, we may ask you to provide information to make sure we can manage the event safely and efficiently. We may also ask you for details of any accessibility need which you may have, so that we ensure our event is inclusive, in line with the provisions of the Equality Act 2010.

If you participate in an event organised by an external party or make a donation through a processor like JustGiving, then your information may be passed to us by the processor. We would only use it for marketing purposes if you have given your consent for this.

We may use your information to invite you to become involved with us in new ways, raise funds and grow our supporter base.

Sharing marketing and fundraising materials with you
Marketing and fundraising materials that we might share with you include information about our activities and their impact, our news, events and fundraising appeals, and other ways you can become involved with us.

Where you have provided your postal address or telephone number we may send this information to you by post or by calling your telephone unless you have asked us not to. We may also email you this information if you have agreed for us to do so.

You can let us know at any time, if you’d prefer to change how we share this information with you or stop it altogether. If you receive our e-newsletters, you can also use the unsubscribe link in the emails we send.

We will keep your personal information for no longer than is necessary for the purposes for which it is processed (in accordance with our internal policies/retention policy). If you ask us not to contact you, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

Targeting our communications and researching our supporters

We have a duty to make sure that we’re spending your donations wisely, and that means doing some research and analysis to inform our decisions. We want to send the most effective messages that we can in the most efficient way possible. In order to work out who to contact, what to say and when to get in touch, we carry out the following activities:

Analysing how emails are opened and read – we track emails which we have sent to you to see which messages have the highest response rates and whether there are messages that resonate with particular groups of people. We do this by logging whether emails we send have been opened, deleted and interacted with (for example, by clicking on links within the emails). Although we only use this information to look at general patterns, it is still personal information because it is linked to your email address.

Segmentation – this is where we analyse information such as postcodes of supporters, and whether donations have been given regularly. This helps us to tailor appropriate communications to you, as well as improve your experience as a Step by Step supporter.

Analysing our supporter base to send different communications to people who might choose to give higher donations – we undertake in-house research using information you have given us and publicly available records such as the electoral roll, land records, ‘rich lists’, Who’s Who publications and Companies House records. We may also collect information on your interests, for example board memberships, hobbies, or articles about you in newspapers or magazines. We use this information to tailor our communication with you and invite potential supporters to meetings, groups and events which may be of interest to them.

Here are some examples of the sources we might use...
  • Public registers (e.g Electoral roll, Companies House, Land records,)
  • Articles about you in newspapers or magazines (e.g. ‘rich lists’, Who’s Who publications)
  • Subscription services (e.g. Directory of Social Change, opencharities.org, Trustfunding.org, New Trust List service)
  • Internet search engine results
  • Wikipedia
  • Open postings on social media sites such as LinkedIn, Twitter and Facebook
  • The Charity Commission website
  • Local Authority and government websites
  • Property sites (e.g. Rightmove)
  • Deaths and marriages registers (e.g. Mortascreen or National Deceased Register)
  • Google maps
  • Company websites
  • Public blogs
  • Public records of other charities or organisations you might be affiliated with (e.g.if you are listed as patrons of the royal ballet)
  • Any websites you manage or about you
  • Family tree websites (e.g. ancestory.co.uk, Thepeerage.com)
  • Professional registers (e.g. NHS employees (doctors), Academics, Solicitors, Accountants, Chartered Surveyors, House of Lords Register of Interests, City of London Directory and Livery Companies Guide, Office of the Scottish Charity Register (OSCR), ACF (Association of Charitable Foundations), Smee & Ford)

When might we add information to your record that you may not have given to us directly?
We may also add information or update your record with us, from publicly available sources. This may include your telephone number, address related information, information from death registers, age or the information mentioned in the section above ‘Targeting our communications and researching our supporters’. We use this information to tailor our communications with you and send you more appropriate information.

We may use your information to enforce and comply with the law
As with all charities, we ensure that our activities comply with the law. Therefore we may need to share or use your personal information if we are required to do so by law (for example; in response to a warrant or court order) and we may use information from other sources for the purposes of fraud prevention, for example to comply with money laundering regulations, or to protect people’s rights, property or safety.

If certain levels of donation are made, the Fundraising Regulator’s Code of Fundraising Practice requires us, and all charities in the UK, to perform checks. More details can be found at www.fundraisingregulator.org.uk.

You can change your preferences at any time, see ‘CONTROLLING YOUR PERSONAL INFORMATION’ below.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Our website may contain links to other websites of interest. Once you have used these links to leave our site, you should note that we do not have any control over that external website. We cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, use the check boxes to let us know what you want to hear from us, and how
  • if you have previously agreed to us using your personal information, you may change your mind at any time by writing to us; Fundraising Team, Step by Step, 36 Crimea Road, Aldershot, GU11 1UD, or emailing us at fundraising@stepbystep.org.uk

We will not sell, distribute or lease your personal information to third parties.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to Fundraising Team, Step by Step, 36 Crimea Road, Aldershot, GU11 1UD.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Our legal basis for contacting you and using your personal information
When you sign up to a newsletter or opt-in to our communications using our forms (eg. a donation form or online form) or in person, then you are giving us your consent to send you marketing and fundraising materials by the methods you have chosen (e.g. email or phone call). We will never send you marketing by email or SMS without your consent, and you can withdraw your consent at any time.

If you have provided us with your postal or telephone contact details, but haven’t specifically opted-in to receive our communications (for example, making a donation by post), then we will carry out an assessment of whether it would be fair and reasonable to use them to send marketing and fundraising information to you without your explicit consent (i.e. it is in the interests of our aims as a charity and will not cause undue prejudice to you). This is called a “legitimate interests assessment”. You can opt out of our marketing and fundraising communications at any time if you don’t want to receive them.

We will ensure we have a legal basis to use your personal information for the other purposes mentioned in this policy (usually with your consent, further to a legitimate interests assessment, or because the use of your data is necessary to comply with a legal obligation).”

This policy was last updated in April 2018.

Step by Step reserves the right to make alterations from time to time. Please check this website from time to time for the latest version.