This policy describes how and why Greater Together Manchester uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information. We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information what we will do with it.
We are a small charity with relationships with volunteers, fundraisers, supporters and other organisations, so we use personal information on a day to day basis in order to operate. Our use of personal information allows us to make better decisions about our services, fundraise more efficiently, and ultimately, helps us in our work to improve the lives of people living in poverty.
This policy is effective from 25th May 2018.
Who we are
- Greater Together Manchester (registered charity in England and Wales (1167704) and a company limited by guarantee in England (09490223))
How we collect information about you
We collect information in the following ways:
Information you provide to us directly
You may give us information in order to register to volunteer, to ask for help or support, to register for an event, to make a donation, to apply for a Near Neighbours grant or to otherwise communicate with us.
In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website and the setting on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you are using and what your device settings are. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
Information you provide to us indirectly
Your information may be shared with us by third parties, for example:
- Fundraising sites like Just Giving;
- If you sign up as a volunteer through an external volunteering website (e.g. Salford CVS or GMCVO);
- Payment services like PayPal or GoCardless.
Information from other sources
We also use information from the following sources:
Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those services, for example when you publically tag us in an event photo.
Information available publicly
We may choose to supplement our information with information from publicly available sources such as charity websites and annual reviews, websites for places of worship, public social media accounts, the electoral register and Companies House.
What personal information we collect
We collect, store and use the following kinds of information:
your contact details (including postal address, telephone number, e-mail address and/or social media identity);
your date of birth;
your bank or credit card details where you provide these to make a payment;
if you volunteer for us or apply for a job with us, information necessary for us to process these applications and assess your suitability (which may include things like employment status, previous experience depending on the context, as well as any unspent criminal convictions or pending court cases you may have);
if you apply for a grant, information necessary to process your application;
information about your activities on our website(s) and about the device you use to access these, for instance your IP address and geographical location;
information about events, activities and products which we consider to be of interest to you;
information relating to your health (for example if you are taking part in or attending an event for health and safety purposes);
information as to whether you are a taxpayer to enable us to claim Gift Aid;
age, nationality and ethnicity information for monitoring purposes; and
any other personal information you provide to us.
Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this type of sensitive data would be information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality.
We only collect this type of information about our supporters to the extent that there is a clear reason for us to do so, for example asking for health information if you are taking part in a sporting event, or where we ask for information for the purpose of providing appropriate facilities or support. We may also use this data when analysing our volunteer base (or similar) for the purposes of equal opportunities monitoring.
Wherever it is practical for us to do so, we will make why we are collecting this type of information clear and what it will be used for.
How we use your information
We will use your personal information to:
provide you with the services, products or information you have asked for;
administer your donation or support your fundraising, including processing Gift Aid;
keep a record of your relationship with us;
respond to or fulfil any requests, complaints or queries you make to us;understand how we can improve our services, products or information by conducting analysis and market research;
manage our events;
check for updated contact details against third party sources so that we can stay in touch if you move (see “Keeping your information up to date” below);
further our charitable objectives;
send you correspondence and communicate with you;
process applications for funding;
administer our websites and to troubleshoot, perform data analysis, research, generate statistics and surveys related to our technical systems;
testing our technical systems to make sure they are working as expected;
display content to you in a way appropriate to the device you are using (for example if you are viewing content on a mobile device or a computer);
generate reports on our work, services and events; guests;
safeguard our staff, volunteers and additional people we work to support e.g. night shelter
conduct required due diligence processes;
monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
process your application for a job or volunteering position;
conduct training and quality control;
audit and administer our accounts;
meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
carry out fraud prevention and money laundering checks;
undertake credit risk reduction activities; and/or
establish, defend or enforce legal claims.
How we will use your information to tell you about our work
Sending marketing communications
Our marketing communications include information about our latest work, projects we have supported and grant availability. We may also include information from our partners. We operate an ‘opt-in only’ communication policy. This means that, except as set out below, we will only send marketing communications to those that have explicitly stated that they are happy for us to do so.
We may use information you have given us directly, for example the record of your previous donations to and/or relationship with us, your location and demographics, as well as the type of activity you have been involved with, to tailor our communications with you about future activities.
Events and fundraising
When you have asked for details about an upcoming event, we will send you information about this event.
Where you have signed up for an event with a third party (for example the Great Manchester Run) and told the event organiser that you wish to fundraise for us, we may contact you with information and support for your fundraising for that event.
Managing your contact preferences
We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions and we include information on how to opt out when we send you marketing. If you don’t want to hear from us, that’s fine, and you can change your preferences at any time. Just let us know when you provide your data or contact us on 0161 828 1409 or click here to email us.
If you’ve decided you don’t want to be contacted for marketing purposes, we may still need to contact you for administrative purposes. This may include where we are processing a donation you’ve made and any related Gift Aid, thanking you for a donation or for attending an event, or keeping in touch with you about volunteering activities you are doing for us.
Legal Basis for Processing
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via post, phone, text, or email). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulations such as the Charity Commission, Fundraising Regulator, Information Commissioner, or to use information we collect about you for due diligence processes.
Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying something from us (e.g. branded items), applying to work/volunteer with us, or being funded to undertake a project.
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities Greater Together Manchester carries out with personal information. Some examples where we are relying on legitimate interests not mentioned under the other bases above are:
analysis and profiling of our supporters using personal information we already hold;
use of personal information when we are monitoring use of our website or apps for technical purposes;
use of personal information to administer, review and keep an internal record of the people we work with, including supporters and volunteers;
sharing of personal information between staff members within GTM, and with our founding partners (The Diocese of Manchester and Church Urban Fund)
where you have signed up for a a charity place for a third party event (for example a sponsored run not organised by GTM) sharing personal information with the third party event organiser so they can administer the event.
Safeguarding issues not requiring the involvement of emergency services but still pose a risk to person/s or property
When we rely on legitimate interests, we consider any potential impact on you (positive and negative); how intrusive it is from a privacy perspective; and, your rights under data protection laws. We ensure that these do not override our (or others’) interests in us using your information in this way.
When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent through provision of the information or another route available to us at law for using this type of information (for example, if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
How we keep your information safe
How long we keep your information for
GTM has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations. For instance we are required to keep some personal information for tax or health and safety purposes, as well as keep a record of your interactions with us.
How we keep your information safe
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details.
As set out in the “Sending marketing communications” section above, we will never sell or rent your information to third parties for marketing purposes. However we may disclose your information to third parties in connection with the other purposes set out in this policy.
These third parties may include:
our founding partners, the Diocese of Manchester and Church Urban Fund;
business partners, suppliers and sub-contractors who may process information on our behalf;
analytics and search engine providers;
advertisers and advertising networks;
IT service providers.
Some of our suppliers run their operations outside the European Economic Area (EEA) - this may include a country which may not be subject to the same data protection laws as companies based in the UK. In these circumstances, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.
Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider this necessary, to protect the rights, property or safety of Greater Together Manchester, its personnel, visitors, users or others.
We reserve the right to disclose your personal information to third parties:
if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets; and/or
if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets.
Keeping your information up to date
We are committed to putting you in control of your data and you are free at any time to opt out from this activity. For more information please call 0161 828 1400 or click here to email us.
We really appreciate it if you can let us know if your contact details change.
Under UK data protection law, you have rights over personal information that we hold about you. We’ve summarised these below:
Right to access your personal information
You have the right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you and we will provide you with this unless legal exceptions apply.
If you want to access your information, please send a description of the information you want to see by post to:
Greater Together Manchester, Church House, 90 Deansgate, Manchester M3 2GH,
Right to access your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and, where applicable, correct any inaccuracies.
Right to restrict use of your personal information.
You have a right to ask us to restrict the processing of some or all of your personal information in the following situations: if some information we hold on you isn’t right; we’re not lawfully allowed to use it; you need us to retain your information in order for you to establish, exercise or defend a legal claim; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.
Right of erasure of your personal information
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object to the use of your personal information
If we are processing your personal information based on our legitimate interests or statistics, you have a right to object to our use of your information.
If we are processing your personal information for direct marking purposes, and you wish to object, we will stop processing your information for these purposes as soon as reasonably possible.
If you want to exercise any of the above rights, please contact us by post: Greater Together Manchester, Church House, 90 Deansgate, Manchester M3 2GH, or by emailing us. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office (ICO).
If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve.
You can find more details about making a complaint in our Complaints Policy.
You also have the right to lodge a complaint about any use of your information with the Information Commissioner’s Office, the UK data protection regulator.
Changes to this policy
If you have any questions, comments or suggestions, please let us know by contacting us on 0161 828 1409, or by emailing us.
Greater Together Manchester also has a Data Protection Officer, who can be contacted at:
Data Protection Officer
Greater Together Manchester