Your personal data is in safe hands with Penny Brohn UK.
We do: use your personal data to help us provide a great experience for you. This includes tailoring the information we share to ensure you find it relevant, useful and timely.
We do: respect your privacy and work hard to ensure we meet strict regulatory requirements.
We don’t: sell your personal data to third parties.
Penny Brohn UK is the only charity in the UK specialising in an integrated whole person approach to cancer, known as the Bristol Whole Life Approach. The Bristol Whole Life Approach recognises that someone with cancer needs more than medicine and provides a powerful combination of physical, emotional, psychological and spiritual support that is designed to help anyone affected by cancer at any stage of the disease. Working with the NHS and alongside standard medical treatment, Penny Brohn helps people to help themselves and reclaim control of their health and wellbeing.
In this policy, whenever you see the words ‘we’, ‘us’, ‘our’, ‘Penny Brohn’, it refers to Penny Brohn UK, the working name of Penny Brohn Cancer Care (Reg. Charity No. 284881).
Penny Brohn Cancer Care is a company limited by guarantee (registered number 01635916). Shop@Penny Brohn Ltd undertakes trading activities. All of its profits are donated to Penny Brohn Cancer Care. Shop@Penny Brohn Ltd is a company limited by shares, registered in England & Wales (registered number 03983263) and operates under the same policies as the charity.
Your personal data (ie any information which identifies you, or which can be identified as relating to you) will be collected and used by us. We’ll only collect the personal data that we need and we’ll make it clear at the point of collection why we are collecting it.
2.1 What types of personal data we collect
In whatever way you interact with us, such interaction may create items of personal data. This could include details of how you’ve helped us by volunteering or by supporting our campaigns and other activities. If you decide to donate to us, we’ll also keep records of when and how much you give to support our cause. Examples of personal data collected by us include:
- Personal details (name, date of birth, email, address, telephone, and so on) when you book onto our courses or complete a referral form
- Financial information (payment information and whether donations are gift-aided)
- Reference and employment details by completing a job or volunteer application form
- Your opinions and attitudes about Penny Brohn UK, activities and interests, and your experiences of Penny Brohn UK
2.2 Personal data created directly from your involvement with us
We collect personal data in connection with specific activities such as enquiring about our services and activities, registration requests or bookings on courses, placing an order, making a donation, volunteering or taking part in research for us, ordering an image, applying for employment and signing up to ‘My Penny Brohn’ account.
You can also give us your personal data by filling in forms on our website, registering to use our website, participating in discussion boards, subscribing to take part in research on our website or other social media, entering a competition, promotion or survey or by corresponding with us (by phone, email or by joining as a member/supporter/customer).
2.3 Personal data created indirectly from your involvement with us, or when you’ve given other organisations permission to share it
When you connect with us on social media sites, 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 accounts or services.
We may automatically collect information as you use our digital service such as the website. This may include the pages you have visited, information about the device or browser you are using, any errors you encountered and data relating to any online transactions such as donations, event bookings and online shop purchases.
2.4 Administering legacies
If you’ve told us that you have left a gift in your will, or are thinking about doing so, we will keep details of this.
We will collect personal data from:
- Executors, Trustees, solicitors and any other professional third party instructed in the legacy administration process.
- Third parties, such as the Smee & Ford notification service
- Copies of wills either provided by Executors, Trustees or other professionals acting in the administration, or publicly available online.
- Other co-beneficiaries of the will
- The public domain
2.5 Information from third parties
When undertaking supporter analysis we may analyse geographic, demographic and other information relating to you. We may use additional information from third party sources when it is available. Such information is compiled using publicly available data about you, for example addresses, listed Directorships or typical earnings in a given area. In addition, we may buy anonymous external data (e.g. census data, Experian MOSAIC, TGI) and combine it with your personal data at an aggregated level to build profiles which help us work out what you’re most likely to want to hear from us about and how.
2.6 Sensitive personal data
We sometimes have to collect and use ‘sensitive personal data’ from our clients, employees and volunteers. This is defined as information about racial or ethnic origin, political opinions, religious or other similar beliefs, physical or mental health, sexual life, and criminal allegations, proceedings or convictions.
For those using our services, we collect sensitive personal data about your cancer diagnosis and the general state of your health in order to enable us to provide a safe and supportive environment for you.
At times we’ll collect sensitive personal data to help us monitor equal opportunities, and to research whether we deliver great experiences for everyone, regardless of their background or beliefs, but this is only ever analysed at an aggregate rather than individual level.
2.7 Employees, Volunteers and Service Providers
We may collect extra information about you (such as references, criminal records checks, details of emergency contacts or medical conditions). We will keep this information for legal or contractual reasons, to protect us (including in the event of an insurance or legal claim), and for safeguarding purposes.
We have Closed Circuit Television (CCTV) at the National Centre and you may be recorded when you visit.
CCTV is used to provide security and protect both clients and visitors and the National Centre. CCTV will only be viewed when necessary (for example, to detect or prevent crime) and footage is stored for a set period of time, after which it is recorded over. Penny Brohn UK complies with the Information Commissioner’s Office CCTV Code of Practice and we put up notices so you know when CCTV is used.
We will use your personal data for the purpose or purposes outlined at the time you gave it to us. Your personal data may be collected and used to help us deliver our charitable activities, help us raise funds, or complete your order or request.
As a cancer support charity we use personal information to help us understand our supporters and potential supporters, tailor our communications and use our resources effectively.
3.1 The main ways we use your data
- To provide you with the services or information you have requested
- To maintain organisational records and ensure we have up-to-date marketing and communication preferences for individuals
- To send you information about our work
- To update you about any changes to our services
- To help us improve our services
- To invite you to participate in surveys or research
- To administer donations, including Gift Aid processing
- To support individuals’ fundraising activities
- To invite you to make donations to support our work
- To invite you to participate in fundraising activities and attend events
- To support our volunteers
- To ensure the safety of all that attend our events and activities
- To analyse and improve the operation of our website
- To analyse your use of our website
- To share your story to help further our work
- To make a purchase from our shop
- Hold dietary requirements for courses and events
- To administer your volunteering or employment application
- To contact you where you have been identified as a contact person for an organisation, such as a
Cancer Support Nurse
We conduct research and analysis on the information we hold which can in turn create further personal data. For example, by analysing your interests and involvement with our work we may be able to build a profile which helps us decide which of our communications are likely to interest you. The section Supporter Analysis (section 3.4) gives more detail about how we use information for profiling and targeted advertising, including giving you more relevant digital content. We use this information to identify ways in which you could support Penny Brohn UK and invite you do to so if appropriate.
This analysis may be carried out by us or by third party organisations working for us.
We carry out research with our supporters and donors to improve the experiences we offer and ensure we know what you find relevant and interesting. We carry out research with our clients, staff and volunteers to get feedback on their experience with us so that we can improve. This includes looking at quality assurance to develop our services for people with cancer, and to demonstrate the impact of our services to funders and supporters.
If you choose to take part in research, we’ll tell you when you start what data we will collect, why and how we’ll use it. All the research we conduct is optional and you can choose not to take part. For some of our research we may ask you to provide sensitive personal data (for example, ethnicity, and cancer diagnosis). You don’t have to provide this data and we also provide a ‘prefer not to say’ option. We only use it at an aggregate rather than individual level (for example, for reporting on equal opportunities).
3.3 Communicating with you
- Administrative communications
We will communicate with you using the contact details you have provided for essential administrative purposes, such as to administer a donation or provide you with information regarding a fundraising event you have asked to take part in.
- Marketing communications
We want to keep our supporters up to date with our fundraising and marketing activities. If you have given your consent to do so, we will contact you for marketing purposes by email, SMS message and telephone calls. We may also send you communications by post on the basis it is in our legitimate interests to do so, unless you ask us not to.
If you agree to receive marketing information from us you can always change your mind at a later date. For more on withdrawing your consent, please see the information in section 7 under Your data protection rights. We’ll never share your information with companies outside Penny Brohn UK who want to use it for their marketing.
- Marketing to young people
We won’t send marketing emails and letters or make marketing calls to people under 13. We won’t send any marketing communications requesting donations to young people aged between 13 and 17, but we will send them information on how to fundraise on our behalf if they specifically request this.
3.4 Supporter analysis
We know it’s important to our supporters that we use our resources in a responsible and cost-effective way. This is why we use automated profiling and targeting to help us understand our supporters and make sure that:
- our communications (for example, emails) and services (for example, our website) are relevant, personalised and interesting to you.
- our services meet the needs of our clients and supporters
- we only ask for further support and help from you if it’s appropriate
- we use our resources responsibly and keep our costs down
To do this we’ll analyse how you interact with us. For example, on our website we use both geographic and demographic information to let you know what’s happening in your local area and understand your interests. The personal information we collect includes transactional information for donations and event sign ups.
Much of the information we collect is aggregated, which means we look at it as a whole rather than at an individual level. However, we may also collect some personal data to personalise your experience, tailor our marketing campaigns to your interests, and ensure the website is functioning as we want it to.
If you’ve agreed we can contact you for marketing purposes, we may also gather additional information about you from external sources, for example; updates to address and contact information, or publicly available information regarding your wealth, earnings and employment at an aggregate level.
Data Aggregation is any process in which information is gathered and expressed in a summary form, for purposes such as statistical analysis. A common aggregation purpose is to get more information about particular groups based on specific variables such as age, profession, or income.
We may also use personal data to create profiles which help us target our communications, to you and to other people. For example, we may use your personal data to find online users with a similar profile to you who may also be interested in our products or services.
We may sometimes use third parties to capture some of our data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and in line with the requirements set out in the GDPR.
We won’t profile anyone under the age of 18.
We may participate in Facebook’s ‘Custom Audiences’ programme which enables us to display adverts to our existing supporters when they visit Facebook. We provide your email address, mobile number and address to Facebook so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account. Facebook’s data policy can be found here.
3.6 Location services
We use the location data provided by the devices you use to access our main website. You can change your location settings at any time in your device or computer settings.
3.7 Cookies and links to third party websites
- How do I change my cookie settings?
In your web browser you can control which types of cookies you allow. You can turn cookies on or off using your browser’s settings. You can also delete cookies and clear your browser’s cache (history).
Whether our cookies are used will depend on your browser settings, so you are in control. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please use the following links:
- Internet Explorer cookies information
- Chrome cookies information
- Firefox cookies information
- Safari cookies information
Links to other websites
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, they will have their own privacy policies for which we do not accept any responsibility or liability.
3.8 Recruitment and employment
If you work for us, or apply for a job with us, we will process your personal data, including sensitive personal data, to comply with our contractual, statutory and management obligations and responsibilities.
This data can include, but isn’t limited to, information relating to your health, racial or ethnic origin, and criminal convictions. In certain circumstances, we may process personal data or sensitive personal data without explicit consent. You can find further information on the data we collect and why below.
- Our contractual responsibilities include those arising from a contract of employment. This includes, but is not limited to, data relating to: payroll, bank account, postal address, sick pay, leave, maternity pay, pension and emergency contacts.
- Our statutory responsibilities are those imposed by law on us as an employer. This includes, but is not limited to, data relating to: tax, national insurance, statutory sick pay, statutory maternity pay, family leave, work permits and equal opportunities monitoring.
- Our management responsibilities are those necessary for the way the organisation functions. This includes, but is not limited to, data relating to: contact details, terms of recruitment and employment, training and development, absence and disciplinary matters.
3.9 Managing volunteers
We need to use your personal data to manage your volunteering, from the moment you enquire to the time you decide to stop volunteering with us.
This includes contacting you about a role you’ve applied for or which we think you might be interested in, processing expense claims you’ve made, recording shifts you’ve booked, recognising your contribution, asking for your opinions on your volunteering experience and next of kin details.
3.10 Use of sensitive personal data about employees and volunteers
As explained in Section 2, in certain limited circumstances, we may legally collect and process sensitive personal data without requiring the explicit consent of an employee or volunteer.
(a) We will process data about an employee’s health where it is necessary, for example, to record absence from work due to sickness, to pay statutory sick pay, to make appropriate referrals to the Occupational Health Service, and to make any necessary arrangements or adjustments to the workplace in the case of disability. This processing will not normally happen without the employee’s knowledge and, where necessary, consents.
(b) We will process data about, but not limited to, an employee’s or volunteers racial and ethnic origin, their sexual orientation and their religious beliefs, but only where they have volunteered such data and only for the purpose of monitoring and upholding our equality and diversity policy.
We want to keep our clients, donors, volunteers, employees and contractors safe, so the security of your data and of our information systems is incredibly important to us.
External threats to our data security are changing all the time, so we have a robust process for assessing, managing and protecting all of our new and existing systems to ensure they are up to date and secure. Our staff complete mandatory information security and data protection training when they start with us and every year afterwards, to reinforce their responsibilities and requirements.
We ensure that there are technical controls in place to protect your personal details on our websites and Office 365 network. We always ensure that only authorised personnel (for example Penny Brohn UK staff or volunteers) have access to your information and that they are appropriately trained to manage personal information.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
4.1 Storing information
Penny Brohn UK’s operations are based in the UK and we store most of your data within the European Union (EU). Some organisations which provide services to us may transfer your data outside the European Economic Area but we’ll only allow this if your data is adequately protected. Some of our systems are provided by US companies and while it is our policy that we prefer data hosting and processing to remain in the EU, it may be that using their products results in your data being transferred to the USA. However, we only allow this when we are certain your data will be adequately protected in accordance with US Privacy Shield or Standard EU contractual clauses.
4.2 Payment card security
Penny Brohn has an active PCI-DSS (Payment Card Industry Data Security Standard) compliance programme. This is the stringent international standard for safe card payment processes. As part of our compliance, we ensure that our IT systems do not directly collect or store your payment card information, such as the full 16-digit number on the front of the card or the security code on the back.
Our online donations solutions are carried out using a ‘payment gateway’ (such as Blackbaud Netcomms, Sagepay or PayPal) which is a direct connection to a payment service provided by a bank. This means that when you input card data into the payment page, you are communicating directly with the bank and the bank passes your payment to us. This means that your payment card information is handled by the bank and not processed or held by us.
We do not sell or share your personal information for other organisations to use.
When we allow third parties acting on behalf of Penny Brohn UK to access your information, we will always have complete control of what they see, how long they see it for and what they are allowed to do with it.
Where necessary, we may share the personal data we collect and process with:
- Third party research organisations
- Third party IT providers, for example who host the website or provide IT support
- Our trading subsidiary Shop@Penny Brohn Ltd
Also, under strictly controlled conditions, we will share personal data with:
- Service providers
- Data processors associated with legacy administration services
We may provide your email address to digital advertising or social media companies who work on our behalf, such as Facebook and Instagram. This is so we can reach you and others like you with information about how you can support our cause. This data is always provided in an encrypted format and is deleted immediately after use. If you don’t want to see targeted advertising from us on social media, please refer to the instructions provided by the social media site, for example on Facebook, Instagram, Twitter and Google.
We may also disclose your personal information to third parties in order to comply with a legal obligation, or to enforce other agreement. It may also be used to protect the rights, property or safety of Penny Brohn and our clients, supporters and visitors. This includes exchanging information with other companies and organisations to protect against fraud.
5.1 Sharing employee and volunteers’ personal data
In order to carry out our contractual and management responsibilities, we may, from time to time, need to share an employee’s personal data with third party suppliers.
To meet an employment contract or fulfil our statutory responsibilities, we are required to transfer an employee’s personal data to third parties, for example, to pension providers and HM Revenue & Customs.
5.2 Anti-money laundering
Charity Commission rules require us to know where funds have come from, as well as any conditions attached to them. We follow a due diligence process, which involves researching the financial soundness, credibility, reputation and ethical principles of donors who’ve made, or are likely to make, a significant donation to Penny Brohn UK, using publicly available information and professional resources.
We will only use and store your information for as long as it is required for the purposes it was collected for. How long it will be stored for depends on the information in question, what it is being used for and, sometimes, statutory legal requirements.
You retain control of how we use your data and you have the right to ask us to stop processing personal information, which we will do.
You have the following rights under the General Data Protection Regulation in relation to the information that we hold:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling
7.1 Access to personal data
You have a right of access to personal data held by us. This right may be exercised by emailing us at email@example.com, or write to us at Penny Brohn UK, Chapel Pill Lane, Bristol, BS20 0HH or call us on 0303 3000 118 (local call rates apply), 9.00am-5.30pm weekdays.
You may be asked to provide the following details:
- The personal information you want to access
- Where it is likely to be held
- The date range of the information you wish to access.
We will need you to confirm your identity. If we hold personal information about you, we will give you a copy of the information in an understandable format together with an explanation of why we hold and use it. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (30 days). This timeframe may be extended by up to two months if your request is particularly complex.
7.2 Withdrawal of consent
Where you have given consent for Penny Brohn UK to use your personal data, you have the right to withdraw that consent at any time. You also have the right to ask Penny Brohn to stop using your personal data for direct marketing purposes. To stop receiving an email from a Penny Brohn UK marketing list, please click on the unsubscribe link in the relevant email received from us or you can manage your marketing contact preferences online here.
7.3 Amendment of personal data
Where possible we try to keep records up to date but we would appreciate it if you would let us know if your contact details change. We want you to remain in control of your personal data. You can update or amend your personal data here.
Alternatively, you may email us at firstname.lastname@example.org, write to us at Penny Brohn UK, Chapel Pill Lane, Bristol, BS20 0HH or call us on 0303 3000 118 (local call rates apply), 9.00am-5.30pm weekdays.
The verification, update or amendment of your personal data will take place within 30 days of receipt of your request.
7.4 Other data subject rights
We will only use your personal information if we have a legal basis to do so. This will usually be either from when you have given your consent, where we have undertaken a legitimate interest assessment or where the use of your data is necessary to comply with a legal or contractual obligation or to protect an individual’s vital interests.
We ask for a positive opt- in for consent to allow us to stay in touch with you about our services and products and to tell you about fundraising appeals, events and other opportunities to help. Our requests for consent give you real choice and control and enable you to choose how we contact you, whether by email, post, phone, SMS (text message) or to not contact you at all. Our requests for consent are kept separate from our terms and conditions.
We require clear and explicit opt in of consent to allow us to collect sensitive personal data. This is used for improving and informing our service delivery through our research and evaluation work. This information helps us to apply for funding for our services and to make sure we are reaching as many people as possible.
We will ask you to review and confirm your consent on a regularly basis.
Where we are processing your personal data on the basis of consent, you are entitled to withdraw that consent at any time by sending an email to email@example.com, write to us at Penny Brohn UK, Chapel Pill Lane, Bristol, BS20 0HH or call us on 0303 3000 118 (local call rates apply), 9.00am-5.30pm weekdays.
8.2 Legitimate Interest
We sometimes use Legitimate Interest as our legal basis for processing personal data. We always conduct a Balance Test when doing this, weighing the protection of your rights and personal data with our use of your data to continue supporting our interests. These Balance Test are assessed by our Data Protection Office, to ensure that the rights of our supporters are maintained.
We use Legitimate Interest in some limited circumstances, in the following areas of our work: Volunteering, Services, Data Analysis, Our Website, Fundraising, Marketing.
In the first instance, please talk directly to us, so we can learn from and resolve any problem or query. You can send an email with the details of any data protection complaint to firstname.lastname@example.org. We will respond to any complaints we receive.
You have the right to contact the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to ico.org.uk.
You may also register with the following services to stop receiving unsolicited marketing communications from a selected charity or charities:
- The Mail Preference Services (MPS) in relation to postal communication
- The Telephone Preference Services (TPS) in relation to phone calls
- The Fundraising Preference Services (FPS) in relation to email, telephone, addressed post and/or text messages. We will ensure any new FPS preferences take effect within 28 days.
How to contact us