The Naval & Military Bible Society values everyone who engages with us by whatever means and the Society makes every effort to protect the privacy of individuals and organisations. The Society will ensure that any personal data that is supplied is kept safe. This policy explains how we collect data, how we use and store information and what it means for you. We also have specific Terms and Conditions for the use of our website, which you should read as well. We treat all our supporters in line with our beliefs and we welcome any feedback on any of our actions. Just call us on 023 9269 9873 or email [email protected] Who we are Naval & Military Bible Society is a Christian Bible Society, serving military forces and merchant seafarers, regardless of nationality. We are a charity registered in England and Wales (#1102593). We are a Company Limited by Guarantee (#5021052) and our registered office is at Castaway House, 311 Twyford Avenue, Portsmouth, PO2 8RN. For the purposes of this Policy, ‘us’, ‘we’ and ‘our’ refer to Naval & Military Bible Society.
What exactly is the General Data Protection Regulation (GDPR)?
GDPR was adopted by the European Parliament in April 2016 and comes into force on 28 May 2018. In the UK, the current Data Protection Act 1998 sets out how your personal information can be used by companies, government and organisations. GDPR changes how personal data can be used. Both personal data and sensitive personal data are covered by GDPR. Personal data, a complex category of information, broadly means a piece of information that can be used to identify a person. Companies covered by the GDPR will be more accountable for their handling of people’s personal information, which means that organisations will need to implement vigorous data protection policies and possess relevant documents on how data is processed. As well as putting new obligations on companies and organisations collecting personal data, GDPR also gives individuals more power to access the information that is held about them. GDPR will have a varying impact on businesses and organisations. To help prepare for the introduction of GDPR, certain steps such as making business leaders aware of the regulation, determining which information is held, updating procedures around subject access requests and requests for personal information to be removed, and what should happen in the event of personal data breach must be implemented. Policies and procedures for these are below. In short, Naval and Military Bible Society may hold information relating to name, address, telephone number and email, linked to an organisation such as ATC, Royal Air Force, AFCU or Mission to Seafarers (or similar organisations); data held about you can be accessed by writing to us at the Castaway Office address; and you can request removal of any or all information held about you from our records, again by writing to us.
What information do we collect? Directly with us
We collect personal information each time you deal with us. For example, when you make a donation, request materials or information, provide comments, complete surveys or otherwise provide your personal details, we collect the information you provide.
From website interaction with us
We DO NOT collect website usage information but information provided in connection with donations is collected by the Give.Net as necessary to process the donation.
Indirectly from 3rd parties
Where you give your permission to other organisations
We may collect information that you make available on, for example, Twitter, Facebook, LinkedIn or similar organisations. You may wish to check their privacy policies to find out more information on how they will process your data. From publicly available data We may collect information from Companies House, the Charity Commission and information published in articles, newspapers or blogs. Sensitive data Where you provide the information, we may collect sensitive personal data, including, but not limited to, your religious beliefs, or your physical or mental health.
What do we do with it? Processing of requests / donations / calls to action We may use the personal data we collect to:
- Keep you up to date on news and stories about our mission and work.
- Ask for financial and non-financial support, such as volunteering or prayer.
- Process donations you give us, or to support your fundraising for us, including gift aid.
- Provide information or packs, for example books you have requested.
- Provide a personalised service, such as customised website content or personalised emails.
- Keep records of your relationship with us e.g. questions you have asked or complaints you have made.
- Classify supporters by location, for example Scotland, Northern Ireland or Wales; or by organisation, such as Army, Air Training Corps, Sailors’ Society.
- Analyse the personal information we collect about you and use publicly available information to aid our understanding of our supporters, understand the level of potential donations, profile supporters into categories and to help provide the right information at the right time to the right supporters.
- Conduct market research to aid our understanding of our supporters and their views.
We may use publicly available information such as newspaper articles, or information you have given permission to other organisations to share such as LinkedIn, to identify supporters and non-supporters, including trustees, who have expressed an interest in giving major gifts or having a public profile with charities like Naval & Military Bible Society. If you make a major gift to our work, and where you agree to such a relationship with us, we may discuss and agree with you any sensitivity you may have about the personal data we hold and the methods of contact suitable for you. We will do this at the earliest convenient opportunity. Where you do not wish to pursue such a relationship with us, we will not retain any additional publicly sourced personal data about you that we have used for this purpose. Basis of processing your data
- Consent: If you are a new supporter coming on board for the first time, on or after 1 March 2018, we will process your personal data on the basis of the consent you provided us with. You are free to change your preferences at any time by contacting us by telephone, post or email as shown in the section ‘Your choices and telling us when things change’ below.
- Legitimate interest: Contacting you; if you are an existing supporter as at 1 March 2018, we may continue to contact you by email where you have previously given us your consent. We may also contact you by post or telephone where we have a legitimate interest to do so. For example, where you have previously made a donation to Naval & Military Bible Society, we may continue to send you information about the work your donation is making possible or other work we may wish to do. Where you have previously asked us not to contact you in this way, we will continue to respect your contact preferences. You can change your preferences at any time or object to us processing your data by contacting us by telephone, post or email as shown in the section ‘Your choices and telling us when things change’ below.
- Legitimate interest: Contacting the right supporters at the right time; When you make a donation, a series of donations, express an interest in our work, or show a potential to give to our work, we will rely on our legitimate interest in order to collect additional information as noted above in ‘Processing of requests / donations / calls to action’. This helps us to identify those supporters who would benefit from an initial discussion and to ensure we use our supporters’ money in the most effective ways.
Applying for a job or volunteering with us Where you provide personal data and sensitive personal data when applying for a job with us, such as the information on your CV, we will process, store and disclose the personal data we collect to:
- Support the recruitment process.
- Enable you to submit your CV, apply online for jobs and to subscribe for alerts about job types of interest to you.
- Answer any questions you may have.
- Use third parties to provide services such as references, qualifications, criminal referencing, checking services, verification of information you have provided, health screening and psychometric evaluation or skills tests.
Where you provide personal or sensitive personal data, such as dietary, mobility requirements or health information, to volunteer with us we will store, process and disclose the personal information we collect to:
- Deliver the volunteering opportunity.
- Provide information including fundraising materials as we promised in the ‘What we will do?’ section or equivalent of the volunteer role description.
- Provide the administration of these opportunities to serve.
- Monitor the quality of the volunteering opportunity.
- Answer any questions or feedback you may have.
How and where we store your information How long?
We will keep your personal information only for as long as we consider it necessary to carry out each activity. We have a data retention policy to implement this. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned. For example we will retain details of donations for 7 years to meet tax and accounting requirements, but we will only hold sensitive medical personal information provided to participate as a volunteer until the role is completed. Legacy income is an important source of income. We may keep data you provide indefinitely to carry out the administration of legacies and to communicate with the families of those leaving us legacies. If you have any questions about our Data Retention Policy please contact us in writing at Executive Director Naval & Military Bible Society Castaway House 311 Twyford Avenue Portsmouth PO2 8RN Or email to: [email protected].
We ensure that we have in place appropriate technical controls in place to protect any personal data you provide. For example, we ensure that our network is protected and routinely monitored. We ensure that access to personal data is restricted only to those staff members or volunteers whose job roles require such access and that suitable training is provided for these staff members and volunteers. We may make limited use from time to time of external companies to collect or process personal data on our behalf. When we do so, we carry out checks on these companies, put in place contracts to make sure our requirements are clear, and carry out periodic reviews. When we do use external companies, we remain responsible for the storing and processing of your personal data. However, we need to remind you that despite all our efforts, the internet cannot be guaranteed to be 100% secure and that you submit data at your own risk. Credit / debit card security If you use your debit or credit card to donate to us online, your information will be processed securely in accordance with the Payment Card Industry Data Standard. We do not accept donations by debit or credit card by phone or email. We hold bank account details for the purpose of collecting direct debits in accordance with direct debit mandate rules.
Where we store your personal information
We use office based systems to process data, except when sending orders to third-party suppliers. This is done by phone or online and therefore data may be processed outside of the European Economic Area (EEA). We adopt the Information Commissioner’s approved measures and therefore ensure that personal data is held in compliance with European data protection regulations. We take all reasonable steps to ensure that your data is stored and processed securely in accordance with this policy. By submitting your personal data you agree to this transfer, storing and processing of your information.
When we share your information
We do not share or swap your information with any other charities.
We may need to pass on information if required by law or by a regulatory body. For example, a Gift Aid audit by the HMRC, or if asked for details by a law enforcement agency.
Our service providers and third parties
We use third party suppliers to carry out tasks on our behalf, such as fulfilling orders or processing donations. These suppliers are bound by contract to protect your data and we remain responsible for their actions. We may provide third parties with general information about users of our site, but this information is both aggregate and anonymous.
Cookies What are Cookies?
Most browsers allow you to turn off the cookie function. To do this you can look at the help function on your browser.
How we treat children and vulnerable persons Aged 12 or under
We do not actively seek to collect children’s data. If at any time we create any materials which may lead to someone aged 12 or under providing their details, we make it clear that they should make sure that they have their parent’s / guardian’s permission first, before giving us their personal information.
Supporters in vulnerable circumstances
We recognise the importance of identifying and supporting supporters in vulnerable circumstances. Staff who send or respond to supporter emails, mailings or calls are trained to be aware of, to identify signs of vulnerable circumstances and to deal with the supporter appropriately in accordance with our safeguarding policy. Personal information will be recorded so that we may respond appropriately in future, for example by ceasing fundraising requests or no longer making calls.
Your choices and telling us when things change Preferences
You can change your preferences on what you receive from us, including marketing and fundraising materials, or how we contact you, by mail, phone or email, at any time. You can do so by: Calling us on: +44 (0)23 9269 9873 Email us on: [email protected]. Write to us at: Executive Director, Naval & Military Bible Society, Castaway House, 311, Twyford Avenue, Portsmouth, PO2 8RN
Updating your details
We do appreciate it if you keep your details up to date. You can do so in the same way as updating your preferences (above). We may use Post Office address search, postcode lists or other available sources to confirm data that you provide us with, where, for example, we are unsure of what you have completed on a form. We will not use these sources to create data that you have chosen not to provide, for example, if you have left a telephone number blank; nor will we automatically update changes of address, we will normally only update your address when you tell us it’s changed. However, if items such as the news and prayer letters are returned to us, we delete your details from our list.
Telling us to stop processing
You have the right to ask us to erase your personal data, to ask us to restrict our processing or to object to our processing of your personal data. You can do so at any time by writing to us at: Executive Director, Naval & Military Bible Society, Castaway House, 311 Twyford Avenue, Portsmouth, PO2 8RN
Access to your information Your rights under the General Data Protection Regulation
You have the right to request details of the information we hold about you. To receive a copy of the personal information we hold, please write to the Executive Director at the address given above. We will respond within 40 days of receiving your letter. For more information about your rights, you can visit the website of the Information Commissioner’s Office.
Changes to the Privacy & Security Policy Changes to this Policy
This policy was last updated in October 2018. We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other legislation. If we make any significant changes to this policy we will show this clearly on our website, in our news and prayer letters or by writing to you directly. By continuing to use our website, you will be deemed to have accepted these changes. Feedback We welcome your feedback on any issues, concerns or suggestions that you may have.