- Important information and who we are
- The data we collect about you
- How is your personal data collected?
- How we use your personal data
- Purposes for which we will use your personal data
- Promotional offers from us
- Third-party marketing
- Opting out
- Change of purpose
- Disclosures of your personal data
- International transfers
- Data security
- Data retention- How long will we use your personal data for?
- Your Legal Rights
Welcome to the OCCTOPUS privacy notice.
OCCTOPUS respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how OCCTOPUS collects and processes your personal data, including any data you may provide to us when you sign up on our website to get involved, donate or to receive our newsletter.
OCCTOPUS is the controller and responsible for your personal data.
If you have any questions about this privacy notice, please contact our nominated personal representative using the details set out below.
Our full details are:
Full name: Oxford Colon Cancer Trust (known as “OCCTOPUS”), an unincorporated charity constituted by a trust deed and registered with the Charity Commission with charity registration number 1104702: Registered office address: c/o Everyman Legal Limited, 1G Network Point, Range Road, Windrush Park, Witney, Oxfordshire, OX29 0YN
Our Data Protection Officer is Rob Jonckheer Secretary, OCCTOPUS . Email: Rob.firstname.lastname@example.org or by post to Rob Jonckheer, Secretary, OCCTOPUS, c/o Everyman Legal Limited, 1G Network Point, Range Road, Windrush Park, Witney, Oxfordshire, OX29 0YN. In the subject line please state “Data Subject Request”
Our Data Protection Officer (whose contact details are given above) is supported by our administrator, Marianne Julebin. Please contact her in the first instance unless you have any questions on your legal rights concerning the processing of your personal data.
Email address email@example.com
- Oxford Colorectal Centre
- The Surgery & Diagnostic Centre
- Churchill Hospital
- OX3 7LJ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 24th May 2018
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes postal address, email address and telephone numbers.
• Financial Data includes bank account and payment card details in connection with your donations.
• Donation Data includes details about donations, gift aid and other payments received from you.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. When contacting us or making enquiries of us, we will collect your contact details. This could include Identity, Contact and Financial and Donation Data we receive from you when you support us by making a donation, volunteering, registering to fundraise, signing up for an event. Where you make a donation to us, we may ask you why you have decided to do so. You need not answer any such question; we only want to know the answer if you are content to tell us.
• e- Bulletins, News, Event. When you sign up to receive this information, we will collect your Contact Data.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Cookies help us to make our website, and the way we use it, better. Cookies enable the website to remember you.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below. The information we obtain from other organisations may depend on your privacy settings or the responses you give; you should check those regularly:
• Technical Data from analytics providers (such as Google based outside the UK and the EU)
• Identity and Contact Data from patient groups or fundraising sites such as JustGiving or other charities but they will only provide that data with your explicit and informed consent.
• Identity and Contact Data from data brokers or aggregators in the UK and the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register.
• Social media and messaging services such as Facebook, WhatsApp or Twitter if your privacy settings with those organisations give us permission to access information (including personal data) from them.
• if someone contacts us on your behalf, if you are taking part in any fundraising activities with others or if you are introduced to the charity by a friend or family member.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Supporters: We will use your data mainly to provide you with information you asked for, administer your donation (including processing gift aid) or support your fundraising and to keep a record of your relationship with us, ensure we know how you prefer to be contacted and understand better how to improve on the information about us.
• Direct Marketing by email: We apply an ‘opt-in only’ communication policy for direct marketing by email. This means that we will only send direct marketing communications to you by email if you have explicitly consented to us to do so. This will include letting you know about the progress we are making and to ask you for donations or other support. Occasionally we may include information about patient groups and other charities who support us in these communications. We include information on how you can opt out of receiving such communications.
• Patients’ Stories: Some people inform us about their experiences with colorectal cancer, colitis and Crohns, (inflammatory bowel) disease and incontinence including through online giving pages and occasionally in order to have their story told to help others in a similar position to theirs and to promote the charity. This may include sensitive information relating to their health and family life. This is classified under Data Protection Act 2018 as ‘Special Category Data’. If you choose to share this information with us, we will record it as part of our relationship with you so that we can fully understand your relationship with us. We will not use this information in a way that identifies you except in accordance with any explicit and informed consent you may give to us. We do not have access to NHS records.
• Legal and Regulatory Compliance: Where we need to comply with a legal or regulatory obligation.
• Communications (other than direct marketing by email): Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending Direct Marketing communications (which could include patients’ stories) to you via email. Instead, we will rely on our legitimate interest to use your personal data as explained below. You have the right to opt out of receiving our general marketing and other communications at any time by contacting us.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
“Legitimate Interest” means the interest of our charitable activities in conducting and managing our charity and to enable us to shape and guide our future activities, such as events and fundraising initiatives and of the projects that have been made possible by our charity. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where we consider that our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us. if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new supporter||(a) Identity
|Necessary for our legitimate interests (as you have indicated your interest in our charity and to keep you in touch)|
|To send to you our Newsletters, notification of events and information on other opportunities to engage with and make donations to us (other than direct marketing by email)||(a) Identity
|Necessary for our legitimate interests (as you have indicated your interest in our charity and to keep you in touch)|
|To process your donations and respond to your enquiries including managing payments, and gift aid||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to administer your donations and gift aid)|
(d) Marketing and Communications
|(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to keep our records updated and to study how supporters and donors engage with us)|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Necessary for our legitimate interests (as you have indicated your interest in our charity) (b) Necessary for our legitimate interests (to study how supporters and donors engage with us, to develop their support and improve the reach of our charity and to inform our marketing strategy)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our charity, provision of administration and IT services, network security, to prevent fraud) (b) Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications (f) Technical
|Necessary for our legitimate interests (to study how supporters and donors engage with us, to develop their support and improve the reach of our charity and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of supporters and donors for promoting our charity, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about our charity that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (develop support and improve the reach of our charity)|
6. Promotional offers from us
You will receive marketing communications from us if you have requested information from us or made donations to our charity or if you provided us with your details when you entered a competition or registered for an event and, in each case, you have not opted out of receiving that marketing. We will not email or text you with any direct marketing unless you have expressly ‘opted in’ to receive these and have not subsequently withdrawn your ‘opt in’ option.
7. Third-party marketing
We will get your express opt-in consent before we share your personal data with any patients group or other charities to help to promote our charity and for our fundraising purposes. We never sell your personal data to anyone else.
8. Opting out
You can ask us to stop sending you marketing messages at any time by logging into the website and adjusting your marketing preferences or by following the opt-out links on the website or any marketing message sent to you or by contacting us. at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of registering for events or making gift aid donations.
10. Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
11. Disclosures of your personal data
We may have to share your personal data (but not Special Categories of Personal Data unless we have your informed and explicit consent to do so) with the parties set out below for the purposes set out in the table in paragraph 4 above.
• External Third Parties, namely service providers of IT and system administration services, event organisers and providers of charity giving sites, professional advisers including lawyers, bankers, auditors, insurer, fundraising and marketing consultants who provide consultancy, banking, legal, insurance and accounting services, HM Revenue & Customs, Information Commissioner’s Office, the Charity Commission and other regulators and authorities.
• Third party charities with whom we may choose to collaborate on specific projects or to merge the whole or part of our charitable activities or our assets. If a merger happens in respect of any part of our charitable activities, then a new charity resulting from such merger may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. International transfers
We do not transfer your personal data outside the European Economic Area (EEA) in order to promote our charity or for fundraising purposes. However we may use service providers (such as GOOGLE) to store our personal data.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
13. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to our administrators, IT contractors and our Trustees who have a need to know for the purpose of operating the charity efficiently and legally. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
14. Data retention- How long will we use your personal data for?
We keep your personal data in a form that identifies you for as long as we have a legitimate interest to use it and as required by law. If you claim Gift Aid on a donation we are required by HMRC to keep data related to your donation for six years after the tax year in which the donation was made.
15. Your Legal Rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
How to exercise any of these rights: If you wish to exercise any of the rights set out above, please contact our Data Protection Officer, Rob Jonckheer, Secretary, OCCTOPUS . Email: Rob.firstname.lastname@example.org or by post to Rob Jonckheer, Secretary, OCCTOPUS, c/o Everyman Legal Limited, 1G Network Point, Range Road, Windrush Park, Witney, Oxfordshire, OX29 0YN. In the subject line please state “Data Subject Request”