Sebastian Coe Charitable Foundation CIO
As of May 25, 2018
At the Foundation we are committed to protecting an individual’s privacy. This statement describes how the Foundation collects and uses personal information about individuals who visit our websites. Please read it carefully, to understand our views and practices regarding how we treat personal information. The terms of this statement may change, so please check it from time to time.
Generally, we intend to hold personal data on the grounds of ‘legitimate interest’, as explained below. We also consider that by visiting our website at www.sebcoe.co.uk, you are accepting and consenting to the practices described in this Policy.
For the purpose of the Data Protection Act 1998 (“the Act”) and, after May 25, 2018, the General Data Protection Regulation, the data controller is Sebastian Coe Charitable Foundation CIO, Aston House, Cornwall Avenue, London N3 1LF. Our registered charity number is 1160088. Our nominated representative and Data Protection Officer for the purpose of the Act is Terry Miller.
If you have any queries about this privacy statement please contact our Data Protection Officer at Aston House, Cornwall Avenue, London N3 1LF, or email [email@example.com].
When do we collect personal data?
The term ‘personal data’ is any information relating to an identified or identifiable living individual.
We collect and use personal data solely in order to carry on the charitable activities of the Foundation. We are committed to being honest and respectful in collecting and using personal data. We collect personal data from individuals when someone enquires about our activities, registers with us, makes a donation to us, asks a question about our activities or otherwise provide us with personal information. We may also receive information about individuals from third parties, for example from our service providers or from an existing supporter who wants to tell a friend about our websites or the fundraising activities we carry out.
As further examples, we may collect personal data when an individual:
- attends one of our fund-raising events
- makes a donation or become a sponsor
- signs up as a volunteer to help us raise money for the Foundation
- applies to us for a grant to support that individual’s charitable activities
- contacts us to discuss supporting us, for example by becoming a donor or sponsor
- contacts us to discuss applying for a grant
What personal data do we collect?
The type of information we collect depends on the reason for an individual’s relationship with us.
The personal data we collect might include name, date of birth, email address, postal address, telephone number and credit/debit card details. We may also collect health information if an individual tells us about personal experiences or the experiences of a friend or relative.
We may also gather general information about the use of our websites, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in Foundation’s emails. We may use this information to personalise the way our websites are presented when users visit them, to make improvements to our websites and to ensure we provide the best service for users. Wherever possible we use aggregated or anonymous information that does not identify individual visitors to our websites.
As described above, we may collect and hold an individual’s:
- full name
- contact information including email address, telephone number and postal address
- contact preferences
- financial information
- transaction and order details
We do not collect special category personal data from our supporters or those whom we support relating to their health, race, religious beliefs and political opinions unless there is a clear reason for doing so, such as providing additional access requirements at a fund-raising event. We only use this information to ensure we provide the best possible experience and enable individuals to continue engaging with us.
Depending on an individual’s settings or privacy policies for social media like Facebook, LinkedIn, Instagram or Twitter, we may seek that individual’s permission to access information from those accounts or services.
How we may use personal data
We always endeavour to be fair and transparent with how we use information, and to ensure at all times that information is protected.
We will use personal information:
- to provide the services, products or information individuals have requested;
- to create an account for an individual upon registering with us;
- for administration purposes;
- to improve our site, and to ensure content is presented in the most effective manner;
- to further our charitable aims, including for fundraising activities.
As part of this, we may analyse the personal information we collect to create a profile of individual’s interests and preferences so that we can contact individuals in the most appropriate way and with the most relevant information. Where relevant, we may also assess personal information for the purposes of fraud and credit risk reduction.
If an individual enters contact details in one of our online registration forms, we may use this information to contact an individual even if the form is not “sent” or “submitted”, but we will only do this to see if we can help with any problems an individual might be experiencing with the form or with our websites.
We may need to share personal data with our service providers, associated organisations and agents for the purposes described above.
As described above, the personal data provided to us may be used:
- To inform individuals of our activities and upcoming events
- To reserve attendance at our events
- To process payments for events
- For general fundraising purposes (see Fundraising section below)
We will not hold more information than required and will ensure all personal data held is kept up to date and used only for its specific purpose(s) outlined above. The retention policy will vary according to the purpose and may be contingent on circumstances when required to keep the data on the grounds of legal obligation and legitimate interest. Please contact the Data Protection Officer at the Foundation’s registered address or at firstname.lastname@example.org, for further information on how long we may keep data.
As indicated above, we may pass personal data to our service providers, agents and associated organisations for the purpose of completing tasks and providing services to the relevant individuals. Where we use service providers we will make sure there are appropriate controls in place.
We may need to disclose personal data if required by law (for example to government bodies and law enforcement agencies), in order to comply with any legal obligation or with the individual’s permission.
We will not sell any information about individual’s web browsing activity and we will not sell, rent, trade or distribute personal data to any third parties for marketing purposes unless we have received an individual’s prior permission to do so. We do not transfer any personal data to countries outside of the European Economic Area (EEA) without express consent. Under certain circumstances, we may wish to provide personal data to charities that we support, but we will seek prior permission from the relevant individuals before doing to (see “Fundraising”, below).
Generally, we intend to hold personal data on the grounds of ‘legitimate interest’. In broadest terms, this means that we can process personal information if we have a genuine and legitimate reason and we are not harming that individual’s rights and interests.
In using this basis, we carefully consider and balance any potential impact on individuals and their rights.
How we protect personal data
To whatever extent the Foundation uses online forms for collecting information, these forms will be protected by encryption. Any donation or payment via our websites will be done only through secure servers. We take appropriate measures to ensure that the personal information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
The transmission of information via the internet is not completely secure. Although we will do our best to protect personal data, we cannot guarantee the security of data transmitted to our site, and any transmission is at an individual’s own risk. Once we receive personal information, we will use strict procedures and security features to try and prevent unauthorised access.
We also note that our websites may include links to websites run by other organisations. The Foundation is not responsible for the privacy practices of these other websites so individuals should read their privacy policies carefully.
All personal information provided to and retained by is kept confidential and stored in a secure, password protected, database that is only accessible by relevant members of staff.
We will take appropriate technical and administrative steps to ensure the security of personal data about individuals, including policies around use of technology and devices, and will ensure that relevant members of staff are trained in their responsibilities under Data Protection Law.
As a registered charity, we rely on funds raised from a variety of different sources including individuals, companies, charitable trusts and other grant-giving bodies. The generosity of these supporters enables us to carry on our charitable activities.
Where we believe there is ‘legitimate interest’, we may seek additional information before contacting individuals or companies to determine whether there is a suitable reason to engage with them, such as a shared interest or potential connection. We may also use public research to better understand the interests of our current supporters so we may improve our communication and suggest relevant opportunities to increase engagement with us. Additionally, we may hold and process professional details of individuals representing corporate sponsors when there is a legitimate interest to do so. This could be to seek further information from a company or grant-giving body regarding a funding opportunity or to follow up with an organisation to keep them informed of events or programmes they have funded.
In line with our charitable objects and grant-making policies, our Trustees may determine to grant funds to other charities and/or may determine to collaborate with such charities to enhance our joint fundraising capabilities to the benefit of the causes we support. In the case of collaborations, we may wish to provide personal data of our own donors and sponsors to such other charities. However, before doing so we will contact our donors and sponsors to obtain their consent.
Wherever we ask an individual to submit personal data, we will provide an option to select the type of communications that individual wishes to receive and in some cases how the individual wishes to be contacted.
Individuals may choose whether to receive information about our progress and fundraising activities. We will not use personal information for marketing purposes if an individual has informed us that they don’t wish to be contacted for such purposes. Individuals may change marketing preferences at any time by contacting the Data Protection Officer at Sebastian Coe Charitable Foundation CIO, Aston House, Cornwall Avenue, London N3 1LF by post or email [email@example.com].
The accuracy of personal data is important to us and individuals have the right to update the personal data that we hold. We ask individuals to help us keep our records up to date by notifying us when personal data changes by contacting the Data Protection Officer at Sebastian Coe Charitable Foundation CIO, Aston House, Cornwall Avenue, London N3 1LF by post or email [firstname.lastname@example.org].
If an individual asks for his or her data to be removed, we will keep the minimum amount of information to ensure we adhere to that request. Please note however that we may have a lawful reason to hold or use the personal data in question without requiring consent.
Individuals have the right to ask us not to hold or use their personal data, although this will mean that we will not be able to communicate with them at times, and in the manner, that they would expect, for example concerning our activities and events, potential sponsorship opportunities or grant applications
Individuals who have created an account with us may sign into their account to access and update their information. Under the Data Protection Act 1998, or after 25 May 2018, the General Data Protection Regulation, all individuals have the right to request full details of their personal data that is held by us. To make this request please contact the Data Protection Officer at Sebastian Coe Charitable Foundation CIO, Aston House, Cornwall Avenue, London N3 1LF by post or email [email@example.com], with a description of the information requested together with proof of identity.
Updates to This Policy
We will update this policy from time to time. Any substantial changes that affect individual rights will be notified to individuals directly as far as is reasonably practicable.
Any comments or question concerning this notice should be directed to the Data Protection Officer at Sebastian Coe Charitable Foundation CIO, Aston House, Cornwall Avenue, London N3 1LF by post or email [firstname.lastname@example.org].