Fundraising and Marketing Privacy Policy
Introduction
Erskine is committed to protecting and respecting your privacy. We want to tell you how we use and protect your personal information. This includes informing you of your rights regarding your personal information that we hold.
This Privacy Notice sets out how we may use, process and store your personal information. We may get that information from you or through contracts, fundraising or donation arrangements you have with Erskine. In other cases, we may get that information from you with your permission and consent, or we may receive your personal information from third parties. We may also obtain mailing and/or telephone lists of potential supporters for our appeals. Note that we rely on legitimate interest as the legal basis for our postal/telephone direct marketing.
The Laws and Regulations
The laws that govern personal data in the UK are:
The Data Protection Act (1998)
General Data Protection Regulation (“GDPR”)
The independent authority that upholds information rights in the public interest in the United Kingdom is the Information Commissioner’s Office (the “ICO”). Further information can be found at https://ico.org.uk.
Who is Erskine?
Erskine is the trading name of Erskine Hospital. Incorporated in Scotland as a non profit making company limited by Guarantee No 174103 (Scottish Charity No. SC006609).
Erskine aspire to be Scotland’s foremost provider of care for veterans and their spouses. Erskine offers unrivalled nursing, residential and dementia care in our four homes throughout Scotland for UK veterans.
Erskine (Erskine Hospital) is registered with the Information Commissioners Office (ICO) as
“Data Controller”.
ICO Registration Number: Z7459440
Contact Details for Erskine’s Data Protection Officer are:
Data Protection Officer
Erskine Home
Bishopton
PA7 5PU
Telephone: 0141 812 1100
email: dpo@erskine.org.uk
website: www.erskine.org.uk
Information we may collect from you
Erskine may collect information from you because we have a legal reason (allowed by law or under contract) to collect the information, or because you have consented for us to do so for a specific purpose.
Information you give us directly:
You may give us information about you, for example:
- By filling in a form or sending us an e-mail
- By attending an event
- Registering as a volunteer
- Making a donation
- When leaving Erskine a legacy
- When donating a Gift in Kind
- Purchasing Erskine merchandise
This information may be personal, financial, military connection/relationship, relating to your interest in Erskine and might be relating to your health (for example if you are taking part in a high risk event).
You may give us information for legal reasons, such as to enter into a contract with us, when you donate, when you are buying merchandise, when you become a supporter or when becoming a volunteer.
Information you give us in-directly:
Your information may be shared with us by:
- independent event organisers, online event sites, online ticket sales.
- independent marketing agencies
- Online surveys
- Mail Order companies
- Publishing companies
- Lifestyle companies
These third parties may share your personal information where you have given consent to pass this information on to us or organisations like us. Or they may share it through Legitimate Interest for Erskine’s mailing/telephone appeals. We will only deal with reputable companies that take privacy and data protection as seriously as we do, and we will always let you choose not to receive further communications from us.
Further information we collect about you
If you visit our website or use a social media platform we may automatically collect information about you, for example:
- Technical information
- IP addresses
- Information about what type of device you use to connect to our website
- How you interact with our website.
Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. There are more details in our cookie policy.
In addition the type of device you’re using to access our website may provide us with:
- information about your device
- what operating system you’re using
Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
If you have already supported Erskine we may collect further information about you from public sources, for example:
- New Address(s)
- New Phone numbers
- New email addresses
Childrens’ Data
We collect and manage information from children and aim to manage it in a way which is appropriate to the age of the child. Information is usually collected when children attend our events or fundraise for us. Where possible and appropriate we will seek consent from a parent or guardian before collecting information about children.
Why does Erskine collect personal information?
Erskine collects information for some or all of following reasons:
- To provide services, products or information
- To register your donation, legacy information
- To support your fundraising, process your gift aid and to send thank you letters
- To help us improve our services, products or information
- For legal reasons, for example, if you have entered into a contract with us
- For contacting supporters to keep them updated on Erskine work
- To record your contact preferences to ensure that only relevant engagement with Erskine is processed
- To invite you to events
- To request your support for particular campaigns that we are running
- For administration purposes
- To keep you up to date with how your support is helping make a difference
- For Gift Aid Processing (HMRC)
Wealth and Profiling Information
We may combine information you provide to us with information available from external sources in order to gain a better understanding of our supporters to improve our fundraising methods, products and services.
The information we get from other organisations may depend on your privacy settings or the responses you gave to them, so you should check them regularly.
We may use profiling and screening techniques to ensure communications are relevant, timely and to provide an improved experience for our supporters. Profiling also allows us to manage our resources effectively.
What legal basis does Erskine have for processing my information?
For the purposes of Fundraising and Direct Marketing – Erskine rely on the legal basis of “Legitimate Interests” to process you data. This means we will process your information in ways you would reasonably expect and which have a minimal impact on your privacy. You still retain your rights see “Your Rights” section below.
Who might Erskine share your information with?
Erskine will NEVER sell or swap the information supporters give us with any other organisation or third party for the purposes of their own marketing. However we may have a legal reason to share your data, for example with:
- Regulatory bodies
- Subcontractors and third parties for the purpose of the performance of a contract that we hold with them or that we hold with you
- With third parties who provide shipping or publishing services because you have purchased goods or services
- With third parties who provide Campaign fulfillment e.g. mailing and telephone appeals
- With HMRC to process Gift Aid
- For crime prevention
Other reasons Erskine may share your personal information with a third party
Erskine will share your personal data with third parties for the following reasons:
- If Erskine must comply with a legal obligation
To enforce or apply our Website Terms of Use, Terms and Conditions of Sale, or other agreements - To protect the rights, property, or safety of Erskine, our residents or others
- The prevention of fraud
Aggregated or anonymized data with personal information removed
Erskine may, from time to time, provide third parties with data that has been aggregated or anonymized.
This means that your personal information that could be used to identify you has been removed from the data. Data provided to third parties in this way is not personal data; however you do keep your right to object.
How we keep your data safe
We primarily store and process your personal data in the UK\EU. If we do transfer your personal data outside the EEA it will be because you have consented or because we have a legal reason to do so.
Some examples of reasons your data may be processed outside of the EEA include:
- Order fulfilment
- Payment processing
- Technical support services.
If your personal data cannot be processed within the EEA, we will:
- Comply with all other data protection principles
- Where possible, be sent to a country that is on the list of the EU Commissions’ countries that provide adequate protections for the rights and freedoms of data subjects
- If the transfer is to the United States of America, we will use reasonable endeavours to make sure they participate in the Privacy Shield program
- Make sure we have assessed the adequacy of protections in all other cases
We use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data.
Access to your stored personal data via password
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Keeping your information up to date
Where possible we use publicly available sources to keep your records up to date:
- for example, the Post Office’s National Change of Address database and information provided to us by other organisations
- We really appreciate it if you let us know if your contact details change
Will you be contacted for marketing purposes?
Email and other electronic channels
We will only contact you for marketing purposes by email or other electronic means such as SMS if you have agreed to be contacted for these purposes.
Telephone
We may contact you for marketing purposes by telephone unless you have told us that you do not wish to receive telephone calls from us.
Post
We may send you correspondence by post about our work unless you have told us that you do not wish to receive such information by post.
If you wish to change your preferences, please contact our Supporter Care Team. On 0141 814 4555 or email fundraising@erskine.org.uk Most preferences will be actioned immediately. However please allow 1 month for your preferences to be updated.
How long will you keep my personal information?
Erskine will not retain your personal information for longer than required.
We will keep your personal information:
- For as long as required by law
- Until we no longer have a valid reason for keeping it
- Until you request us to stop using it
We may keep just enough of your personal information to ensure that we comply with your requests not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data.
There are more details in our Data Retention Policy. Or we can provide you a copy. Please contact: dpo@erskine.org.uk
Your Rights
Erskine will respect your legal rights to your data.
Below are the rights that you have under law and what Erskine does to protect
| Legal right | What Erskine does to protect your rights |
| The right to be informed | Erskine is publishing this Privacy Notice to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data. |
| The right to access | You have the right to access your information. Please contact Erskine’s Data Protection Officer at dpo@erskine.org.uk if you wish to access the personal information Erskine holds about you. |
| The right to rectification | If the information Erskine holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information: dpo@erskine.org.uk |
| The right to erasure | This is sometimes called ‘the right to be forgotten’. If you want Erskine to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact our Data Protection Officer: dpo@erskine.org.uk |
| The right to restrict processing | You have the right to ask Erskine to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want Us to restrict processing of your data, please contact our Data Protection Officer: dpo@erskine.org.uk |
| The right to data portability | Erskine must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this affecting the usability of your data. Please contact our Data Protection Officer if you want information how to port your data elsewhere: dpo@erskine.org.uk This right only applies to personal data that you have provided to Us as the Data Controller. The data must be held by Us by consent or for the performance of a contract. |
| The right to object | You have the right to object to Erskine processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation) and processing for the purpose of statistics. If you wish to object please contact our Data Protection Officer: dpo@erskine.org.uk |
| The right to withdraw consent | You have the right to withdraw your consent at any time and Erskine must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: dpo@erskine.org.uk |
| The right to complain to a Supervisory Authority | In the event that you wish to make a complaint about how your personal data is being processed by Erskine or third parties under contract to Erskine, you can complain to Erskine’s Data Protection Officer: dpo@erskine.org.uk If you do not get a response within 30 days you have the right to lodge a further complaint with the (ICO) Information Commissioners’ Office. |
Useful Contact Details
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Erskine Data Controller Contact Details
Data Protection Officer Erskine Home Bishopton PA7 5PU Telephone: 0141 812 1100 Email: dpo@erskine.org.uk
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Supervisory Authority Contact Details (ICO)
The Information Commissioner's Office - Scotland 45 Melville St Edinburgh EH3 7HL
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Changes to Our Privacy Notice
Erskine may change this notice from time to time in the future. Any such changes will be posted here and, where appropriate, notified to you in writing. We advise you to check back frequently to see any updates or changes.
This notice was last updated in October 2018.
