This Policy sets out how Combat Stress promises to respect all personal data that you share with us, or that we get from other sources. We intend to keep this data safe and we will not do anything you would not reasonably expect.
This policy applies to all information collected, both offline and online, the websites we operate and our use of post, emails, telephone calls and text messages for marketing purposes. It covers what we collect and why, what we do with the information, what we won’t do with the information, and what rights you have.
Who are 'we'?
In this policy, whenever you see the words ‘we’, ‘us’ or ‘our’, it refers to Combat Stress and Combat Stress Trading Ltd.
The full legal information for each entity is:
• Combat Stress, a charity registered in England and Wales (206002), and Scotland (SC038828)
• Combat Stress Trading Limited is a company registered in England & Wales. Registration number 256353
Combat Stress and Combat Stress Trading Ltd are separate companies, each registered as a data controller in their own right.
Combat Stress Trading sells a range of goods and enters into corporate partnership arrangements; all of its profits are passed to Combat Stress.
Both of these companies are wholly owned and controlled by Combat Stress. Many of the staff who work for these two companies – including all the company directors – are Combat Stress employees, and the companies share many of the Combat Stress ‘head office’ functions such as marketing, legal and HR.
Combat Stress is a member of the Fundraising Regulator (www.fundraisingregulator.org.uk) and the Institute of Fundraising (www.institute-of-fundraising.org.uk).
What information do we collect?
We will only ever collect the information we need and only share it with those that need to know – including data that will be useful to help improve our provisions and communications with you.
• Non-personal information such as IP addresses (the location of the computer on the internet), pages accessed and files downloaded. This helps us to determine how many people use our sites, how many people visit on a regular basis, and how popular our pages are. This information doesn’t tell us anything about who you are or where you live. It simply allows us to monitor and improve our online service to you.
• Personal information such as name, postal address, phone number, email address, date of birth and bank details (where appropriate), information about your interests etc. You don’t have to disclose any of this information to browse the online sites. If you donate by direct debit we will store your bank details. We DO NOT store your credit card details. However, some third-party providers may store your card details on their sites. All providers we use are fully compliant with PCI rulings.
It is our policy not to request donations or subscriptions, or accept product orders, from children under 18. If we are contacted by anyone under 18, before we collect data from them we will always ask them to:
• Obtain the permission of a parent or guardian before contacting us, and
• Let an adult know before they use our sites to obtain information about fundraising or supporting our work.
Other people's data
Some of the services we offer allow you to provide the personal data of other people (e.g. providing a friend’s name for event tickets you have purchased or tagging people on photos on social media). Before providing anyone else’s data please ensure they are happy for you to do so and under no circumstances must you make public another person’s home address, email address, or phone number without their permission.
Where we collect information about you from
We collect information in the following ways:
When you give it to us DIRECTLY You may give us your information when you give a donation, purchase our products, register for an event or communicate with us. Sometimes when you support us, your information is collected by an organisation working for us (e.g. fundraising/marketing agencies), but we are responsible for your data at all times.
When you give permission to OTHER ORGANISATIONS to share or it is available publicly We may combine information you provide to us with information available from external sources. This will enable us to gain a better understanding of our supporters, improving our fundraising methods, products and services, and will help us to build a stronger relationship with you.
The information we get from other organisations may depend on your privacy settings or the responses you give, so you should regularly check them. This information comes from the following sources:
•Third party organisations. You may have provided permission for a company or other organisation to share your data with third parties, including charities. This could be when you buy a product or service, register for an online competition or sign up with a comparison site.
• Social Media. 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.
• Information available publicly. This may include information found in places such as the Electoral Register, National Change of Address, Google, Companies House and information that has been published in articles/ newspapers. This allows us to assess and improve the accuracy of the information we hold about you and to better manage our relationship with you.
What do we do with the information we collect?
We will use the information you provide to:
• Verify your identity, and to detect and prevent fraud.
• Provide you with the services, products or information you have requested.
• Administer your donation, event registration or support your fundraising, including claiming Gift Aid from HMRC.
• Process orders, deliver products and communicate with you about orders. • Keep a record of your relationship with us.
• Ensure we know how you prefer to be contacted and where you have agreed to it, provide you with information that we think may be of interest to you including fundraising request.
• Carry out research on the demographics, interests and behaviour of our supporters and website users to help us gain a better understanding of them and to enable us to improve our service and communications.
• Provide a personalised service to you when you visit our website – this could include customising the content and/or layout of our pages for individual users.
• Manage surveys and questionnaires.
• We use your personal information to investigate, and respond to complaints, legal claims or other issues.
We may use your personal information for other purposes which we specifically notify you about and, where appropriate, obtain your consent e.g. sharing your story.
Using your information for marketing
We only want to communicate with you by the method you prefer and send you information that may be of interest to you. Our marketing communications include information about our latest news, campaigns and lifesaving work.
With your consent, we will contact you to let you know about the progress we are making and to ask for donations or other support. Occasionally, we may include information from partner organisations or organisations who support us. 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 communications. If you don’t want to hear from us, we will respect your wishes.
You can change your preferences at any time by completing our consent form at combatstress.org.uk/preferences. Alternatively, if you would like to discuss the communications you are receiving please call Supporter Care weekdays between 8.30am and 4.30pm on 01372 578151 or email email@example.com. Please allow 28 days for us to fully complete your request.
If we contact you by email, every message we send will include a link to opt out of receiving future messages if you change your mind.
If you would like further information on how to record your communication preferences on the official register then please visit The Mailing Preference Service (mpsonline.org.uk), The Telephone Preference Service (tpsonline.org.uk) and the Fundraising Preference Service (fundraisingregulator.org.uk/thefundraising-preference-service).
We will never sell your personal data, or share it with third parties for their marketing purposes.
Building profiles of supporters and targeting communications
Developing a better understanding of our opted-in supporters through their personal data allows us to fundraise more efficiently and make better decisions; ultimately, helping us to reach our goal of making sure veterans can tackle the past and take on the future.
We use profiling and screening techniques, including some automated techniques, such as postcode segmentation, to ensure communications are relevant and timely, and to provide an improved experience for our supporters. Profiling also allows us to concentrate our resources effectively, which donors regularly tell us is a key priority for them. We do this because it allows us to understand the background of the people who support us and helps us to make appropriate requests to supporters who may be able and willing to give more than they already do. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would.
When building a supporter profile, we may analyse the following: the history of your support to us, geographic, demographic and other information relating to you, in order to better understand your interests and preferences and contact you with the most relevant communications. In doing this, we may use additional information from third party sources when available. Such information is compiled using publicly available data.
Storing your information
Information is stored by us on computers located in the UK. We may transfer the information to other offices and to other reputable third party organisations as explained above – they may be situated inside or outside the European Economic Area. We may also store information in paper files.
We place great importance on the security of all personally identifiable information associated with our supporters, customers and users. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal data under our control. For example, only authorised personnel are authorised to access user information and we use secure server software (SSL) to encrypt financial and personal information you input before it is sent to us. While we cannot ensure or guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to try to prevent this.
Unfortunately, the transmission of data across the internet is not completely secure and whilst we do our best to try to protect the security of your information we cannot ensure or guarantee that loss, misuse or alteration of data will not occur whilst data is being transferred.
We will keep your information only for as long as we need it to provide you with the goods, services or information you have required, to administer your relationship with us, to inform our research into the preferences of our supporters, to comply with the law, or to ensure we do not communicate with people that have asked us not to. When we no longer need information we will always dispose of it securely, using specialist companies if necessary to do this work for us.
The Data Protection Act 1998 gives you certain rights over your data and how we use it. These include:
• The right of access to a copy of the information we hold about you (known as a subject access request), and the right to have your data corrected or updated.
• The right to prevent your data being used for direct marketing.
• The right to ask us to stop processing and erase all data relating to you. If there is no other legal ground for the processing (e.g. administration of your donation, or registering you for an event) we will do so.
• The right to lodge a complaint. Please write to: Robert Marsh, Director Income Generation, Combat Stress, Tyrwhitt House, Oaklawn Road, Leatherhead, Surrey KT22 0BX or email firstname.lastname@example.org. We will respond within five days.
If you wish to exercise any of these rights please contact the Chief Information Officer, Combat Stress, Tyrwhitt House, Oaklawn Road, Leatherhead, Surrey KT22 0BX. We do not charge for reasonable or proportionate requests. Please include your full name and address and any details to help us identify and locate your information.
For more information about your rights under the Data Protection Act go to the website of the Information Commissioner’s Office at ico.org.uk.
Combat Stress is not a ‘public authority’ as defined under the Freedom of Information Act and we will not therefore respond to requests for information made under this Act; using the funds generously donated to us by our supporters for such activities is not in accordance with our charitable purposes.