Please read this policy carefully to understand how we collect, use and store your personal data.
Railway Children is a charitable company registered in England and Wales with registered company number 1058991.
At Railway Children we take your privacy very seriously and are committed to protecting your personal information.
If we are working directly with you and/or your family through one of our Safeguarding on Transport projects, the way we use your information is slightly different. Your worker will provide you with an information sheet and explain this to you.
Our Data Protection Officer is David Brookes.
The Data Protection Officer
1 The Commons
Cheshire, CW11 1EG
Or call our Supporter Care team: 01270 757 596.
This policy includes:
- How we collect information
- Where we collect information from
- What personal information we collect
- How we will use your personal information
- Children’s data
- How we keep your data safe and who has access to it
- How we keep your information up to date
- Your right to your information
- Changes to this policy
How we collect information
We may collect information about you whenever you interact with us, for example when you:
- Enquire about our activities or services, visit our website or donate to us
- Sign up to receive updates on our work or our activities
- Post content to our website/social media sites (including Facebook)
- Apply for a job or volunteer for us
- Attend a meeting with us and provide us with information about you
- Take part in one of our events or fundraise on our behalf
- Contact us through the following channels: online, email, phone, social media or post
Where we collect information from
Railway Children may collect information in the following ways:
- When you give us information directly: You may provide your details to us when you request specific information, make a donation, or participate in one of our events.
- When you have given other organisations permission to share it: You may have provided your details to another organisation that works with Railway Children. For example, in order to sign up to a third party event, or if you purchased a product via our online shop. However, when working with other organisations, we work to ensure it’s completely clear to you that your information will be shared with Railway Children. The information we get from these services depends on your settings or the response choices you give, so you should regularly check what you have agreed to with third party organisations.
- Social media: Depending on your settings or the privacy policies for social media and messaging services like Facebook and Twitter, you might give us permission to access information from those accounts or services.
- When your information is available from other public sources: We may review other information about you that is available to the public through internet searches, social networks, such as LinkedIn, subscription services, news archives or public databases (e.g. Companies House, the electoral, political and property registers), such as information about corporate directorships, shareholdings, published biographic information, employment and earnings, philanthropic interests and networks, charitable giving history and motivations and relevant media coverage, so that we can engage with you in a more personalised way. Please see the section below for more details on how we use this information.
What categories of personal information we collect
The type and quantity of information we collect and how we use it depends on why you are providing it.
If you support us, for example by making a donation, volunteering, registering to fundraise, or signing up for an event we may collect where relevant:
- Your name
- Your contact details (full address, email address and phone number)
- Your date of birth
- Your bank or credit card details (only if you are making a donation)
- Where it is appropriate, we may ask for your reason for giving and your specific interests relating to Railway Children’s work
If you visit our website anonymously, we may however still record information about:
- the areas of the website you visit
- the amount of time you spend on the site
- whether you are new to the site, or have visited it before
- how you came to our website – for example, through an email link or a search engine
- the type of computer, browser, network location and internet connection you use.
How we will use your personal information
We will use your personal information in a number of ways, including for the following purposes:
- To provide you with the services or information you have requested
- To update you about any changes to our services
- To administer your donation, including Gift Aid processing
- To maintain our organisational records and ensure we have your most up-to-date marketing preferences
- To help us improve our services, campaigns or information-offering
- To analyse and improve the operation of our website
- To analyse your website behaviour
- To tailor advertising that is presented to you on the internet according to your interests, preferences and other characteristics
- To contact you where you have been identified as a contact person for an organisation, such as a school (if we obtain your contact details in this way, we will only use them to contact you in the ways in which you have agreed to be contacted)
- Where we have identified that you may have the capacity or affinity to support Railway Children at a higher level, we may use the information we hold about you to identify connections between you and our existing circle of key supporters
We promise to make all reasonable efforts to keep your details secure and will only share them with suppliers or professional agents working on our behalf, for example professional fundraising organisations sending out letters of appeal, or telephone agencies making fundraising calls on our behalf.
Except as required by law, we will never share your details with other organisations to use for their own purposes.
We may participate in Facebook’s ‘Custom Audience’ programme which enables us to display adverts to our existing supporters when they visit Facebook. This will entail providing your email address, mobile number and address to Facebook in an encrypted way so as to anonymise the information but 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.
Find out more information about 'Custom Audiences' and Facebook’s Data Policy.
While we do not actively collect information from supporters aged under 18, we appreciate that our supporters are of all ages. Where appropriate, we will always ask for consent from a parent or guardian to collect information about supporters who are children. All Railway Children events will have clear rules on whether or not children can take part, and the collection of data will be managed in accordance with each individual event, with appropriate safeguards in place.
If we are working directly with a child and/or their family through our Safeguarding on Transport projects, the child and their parent/carer will be provided with more detailed information about how their data is managed.
How we keep your data safe and who has access to it
We place great importance on the security of your personal information and will always try to take appropriate precautions to protect it.
We ensure that there are appropriate technical controls in place to protect your personal details. For example, we use encryption technology on our websites and carry out regular security reviews on our network.
We always ensure only authorised personnel (for example Railway Children staff, volunteers or contractors) have access to your information, and that they are appropriately trained to manage your data.
Despite all of our precautions, no data transmission over the internet can be guaranteed to be 100% secure. So, while we strive to protect your personal information, we cannot guarantee the security of any information you disclose to us online, and you must understand that you do so at your own risk. However, any payment card details (such as credit or debit cards) we receive through our website are passed securely to our payment processing providers who meet the required Payment Card Industry (PCI) Security Standards.
You also consent to us transferring your information to countries or jurisdictions which may not provide the same level of data protection as the UK, if necessary for any of the above purposes. If we do transfer your information in this way, we will comply with our legal obligations as a data controller under the Data Protection Act 1998 and, if we need to, put in place a contract with the companies we use to process information to ensure your details are properly protected.
Where the law requires, we will only send you marketing information by email, SMS, or phone if you have given us specific consent to do so. If you withdraw your consent and then subsequently opt in, then your most recent preference may supersede.
If you have provided us with your work email address, we may communicate with you as a 'corporate subscriber' without your consent, if we believe the communication will be relevant and interesting to you, on the basis of our legitimate interests. However you are always given the option of unsubscribing from email communications at any time.
If you have responded to a letter of appeal, you may also receive fundraising mail, which you can opt out of at any time.
You can opt out of us using your personal details for marketing at any time either by calling us on 01270 757 596 or emailing firstname.lastname@example.org or writing to Railway Children, First Floor, 1 The Commons, Sandbach, CW11 1EG – our Supporter Care team will be happy to answer any queries you may have.
How we keep your information up to date
Where possible, we try to keep your records up to date. However, we really appreciate it if you let us know when your contact details change.
How long we keep your information for
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of any donations you have made for at least six years.
If you ask us to stop sending you marketing materials, we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Our legal basis for processing your information
Although in many cases we will seek consent to process your personal data, in some instances we may process your information without consent when we are legally allowed to do so. This will only be where it is in our legitimate interests to do so and where we are confident that such processing is not likely to prejudice your legitimate interests or rights and freedoms.
Where we are processing your personal data on the basis of consent that you have given us, you are entitled to withdraw that consent at any time such that we can no longer rely on it as a basis for continuing to process your personal information.
To use your personal information in the ways described, Railway Children relies on two main legal reasons.
1: Your consent to receive communications by mobile phone, email or text message. We use this consent to send emails and texts as well as targeted advertising, marketing and information including social media sites like Facebook. These communications help us to show supporters the impact of their donations and raise further funds to support children at risk on the streets.
2: The legitimate interest legal basis allows you to receive communications by post or telephone when you support Railway Children with a donation or when you request to receive information about our work, events or services or if you are a corporate subscriber (see above). Railway Children has a legitimate interest to use your personal information in order to communicate with you but will respect your right to opt out of any communication should you wish to do so.
If you are registered with the Telephone Preference Service (TPS) the only time we’ll contact you by telephone is if you have consented directly to us making phone calls to you or for administrative purposes.
You retain control of how we use your data and you have the right to ask us to stop processing your personal information, which we will do. In some circumstances, we may legally be required to retain your personal information for audit purposes. However, this will be discussed with you depending on your requirements. Please contact email@example.com or call us on 01270 757 596 if you have any concerns.
You also have the right to request a copy of the information we hold about you. If you want to access your information, please contact: The Data Protection Officer, Railway Children, First Floor, 1 The Commons, Sandbach, Cheshire, CW11 1EG or email firstname.lastname@example.org.
Under the General Data Protection Regulation, which came into effect in the UK in May 2018, you are also granted a number of additional rights. These include:
- The right to access your personal information – known as a subject access request
- The right to have your personal information that we no longer need erased from our records
- The right to have inaccurate personal information amended
- The right to ask us to stop using your information in certain situations
- The right to object to your personal information being used for marketing or profile
- A right to have a copy of your personal information provided for reuse in another service
For more information on these rights please read the relevant guidance issued by the ICO at https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/individuals-rights/
If you would like to make a complaint about how we process your personal data, please contact our Data Protection Officer.
If you are not happy with how your complaint is dealt with, you should contact the Information Commissioner’s Office. Alternatively, you are entitled to make a complaint to the Information Commissioner’s Office without first referring your complaint to us.
For further information please see the Information Commissioner’s guidance.
This policy may change from time to time. If we make any significant changes to this policy, we will publicise these changes clearly on our website or contact you directly with more information.