This policy describes how and why Finsbury Park Trust 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 about what we will do with it.

We are a small charity with relationships to supporters, volunteers, and partners, 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, deliver appropriate activities and services and fundraise more efficiently and, ultimately, help us to reach our goal of improving the wellbeing for many individuals.

Who we are

Finsbury Park Trust (FPT) is a registered charity in England and Wales (1105638), and a company limited by guarantee (04599482).

We collect information in the following way:

• Information you provide to us directly

You may give us your information in order to take part in an activity or receive a service from us, make a donation, or register as a volunteer or apply for a position.

• Information you provide to us indirectly

Your information may be provided to us by third parties, for example:

• If you are referred to us by a partner for support;
• fundraising sites like Just Giving or Local Giving, if opting to provide your details;
• if you sign up as a volunteer or apply for a job through an external volunteering website or agency.

You should check any privacy policy provided to you where you give your data to a third party.

• Information from other sources

We also use information from social media and our website. Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or X, you might give us permission to access information from those services, for example when you publicly tag us in an event or photo, or when we re-tweet information.

When you use our website, we collect your personal information using ‘cookies’ and other tracking methods. We monitor our website statistics solely for the purposes of improving our website and are not using individual information. We only collect information about the type of device you’re using to access our website or apps and the settings 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’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.

What personal information we collect

We collect, store and use the following kinds of personal information:

• your name;
• your preferred contact details (possibly including postal address, telephone number, e-mail address and/or social media identity);
• your date of birth;
• your gender;
• your bank or credit card details where you provide these to make a payment and when employed by us;
• information as to whether you are a taxpayer to enable us to claim Gift Aid;
• 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);
• information relating to your health and social circumstances if you are receiving a service from us;
• information regarding next of kin with which you may have provided us to contact in an emergency;
• age, disability, 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, disability, race, religion or beliefs, or sexuality. This information is collected in relation to our service users, volunteers and staff to ensure we deliver fair access to our services and are able to provide services which are appropriate to those receiving it, and are a fair and inclusive employer. Wherever it is practical for us to do so, we will make clear why we are collecting this type of information and what it will be used for.

How we use your personal information

Our staff may receive personal information about you, and related to your wellbeing, when you contact them. They will use this information to answer your questions and assess how best to support you. Information you provide to the staff of the Organisation will not be passed to anyone else outside of the organisation without your express permission or in cases where this is required due to the law or safeguarding concerns.

Additional to our support services, we will use your personal information to:

• provide you with the services and support you require and the information you asked for;
• administer your donation or support your fundraising, including processing Gift Aid;
• keep a record of your relationship with us (for example, volunteer, staff member);
• respond to or fulfil any requests, complaints or queries you make to us;
• send you correspondence and communicate with you;
• inform and manage our events;
• further our charitable objectives;
• generate reports on our work, services and events and applications for funding;
• process your application for a job or volunteering position;
• conduct training;
• audit and administer our accounts;
• meet our legal obligations, for instance to perform in our provision of contracts or our obligations to regulators, government and/or law enforcement bodies.

How we use your information to tell you about our work

Sending marketing communications

Our marketing communications include information about our latest news (services, campaigns and events) and may occasionally make request for donations or other support. Occasionally, we may include information from partner organisations or organisations who work with us. We operate an ‘opt-in’ 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.

Events and fundraising

When you have asked for details of a FPT event, we will send you information including, where relevant, ideas for fundraising and reminders on key information about the activity.

Managing your contact preferences

We will never share our contacts with any third party for marketing purposes. If you don’t want to hear from us, that’s fine, and you can opt out at any time. Just let us know by contacting us on 020 7561 5525 or management@finsburyparktrust.org.

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.

Specific consent

Consent is where we ask you if we can hold and use your information in a certain way, and you agree to this (for example when we offer you a volunteer role). 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. This may on occasion impact on the service we can provide to you.

Legal obligation

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 regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner, or to use information we collect about you for due diligence purposes.

Performance of a contract / preparing 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 we are delivering a Local Authority Commissioned contract and are required to gather and submit information regarding our service provision, or you are working/volunteering with us.

Vital interests

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 on individuals and information needed to be shared with emergency services, or a safeguarding issue which required us to contact people due to risk to self or others.

Legitimate interests

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 FPT carries out with personal information. Some examples not mentioned under the other bases above where we are relying on legitimate interests are the use of personal information to administer, review and keep an internal record of the people we work with, including supporters and volunteers.

We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws 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 or another route available to us at law for using this type of information (for example, 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 you 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. For example, our network is protected and routinely monitored, limited access to data systems, and password protection of documents.

How long we keep your information for

FPT 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.

Sharing your information with other organisations

We will usually ask for your explicit consent to share you information. As example, this may be for you to access and receive additional services and support, both as a volunteer or staff member. 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 FPT, its personnel, visitors, users or others.

We reserve the right to disclose your personal information to third parties, 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’re committed to putting you in control of your data and you’re free at any time to contact us to update your information; let us know by contacting us on 020 7561 5525 or management@finsburyparktrust.org. We really appreciate it if you let us know if your contact details change.

Your rights

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 a 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, send a description of the information you want to see by post to Finsbury Park Trust, 225-229 Seven Sisters Road, London N4 2DA.
• Right to have 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 to 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 to object to the use of your personal information; if we are processing your personal information based on our legitimate interests or for evaluation or statistics, you have a right to object to our use of your information.

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 removal of personal information can impact on the relationship we can have with you, for example, we may no longer be able to provide you with individual support specific to your needs and requirements.

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 https://ico.org.uk/ ).

Complaints

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 contact us with feedback by emailing management@finsburyparktrust.org.

You also have the right to lodge a complaint about any use of your information with the Information Commissioners Office ( ICO https://ico.org.uk/ ), the UK data protection regulator

Changes to this Policy

We will review and may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on the FPT website.

Responsible Director: Felicity Ford

Finsbury Park Trust – Privacy Policy

Last reviewed: March 2024

Current review date: March 2025