SHELTERBOX PRIVACY POLICY


UPDATED February 2021

ShelterBox takes your privacy seriously and we are committed to protecting your personal data. This privacy policy 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. This privacy policy is relevant whether you want to work or volunteer for us, donate, join our book club, act as our supplier, receive aid from us, want information or want to learn more about what we do.

This privacy policy includes the following:

1. Important information and who we are


ShelterBox Trust is a UK charity that believes in a world in which no family is without shelter.
ShelterBox Trust is a charitable company limited by guarantee in England and Wales Company number: 04612652 Charity number: 1096479 ICO registration number: Z928330X.

ShelterBox also runs a wholly owned trading subsidiary, ShelterBox Trading Limited (company number: 07096770).

In addition, ShelterBox has an affiliate in the Philippines, ShelterBox Operations Philippines, Inc., a non-stock, non-profit company with registered number CN201720528.

Controller

This privacy policy is issued on behalf of the ShelterBox Group so when we mention ShelterBox, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the ShelterBox Group responsible for processing your data. Each of the ShelterBox companies acts as a data controller for the personal data they collect, and ShelterBox Trust is responsible for this website.

We have appointed a data privacy lead who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy lead using the Contact Details set out below.

Purpose of this privacy policy

This privacy policy aims to give you information on how ShelterBox collects and processes your personal data, including any data you may provide through this website when you sign up to our newsletter, join our book club, take part in a competition, apply for a job or make a donation.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Contact details
If you wish to contact us about our campaigns, your marketing preferences or information on our website, please contact our Supporter Care Team:
[email protected]
or by phone on +44 (0)300 0300 500.
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy team:
Full name of legal entities: ShelterBox Trust, ShelterBox Trading Limited, ShelterBox Operations Philippines, Inc.
Email address: [email protected]

Postal addresses: Data Privacy Lead, ShelterBox, Falcon House, Charles Street, Truro, TR1 2PH or in the Philippines: Data Protection Officer, ShelterBox Operations Philippines, Inc. Unit 5, 1401 Office, Park Centrale Bldg, Jose Ma. del Mar St., IT Park, Lahug Cebu City, Philippines.

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 as 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 billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • 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, donations, competition entries or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • 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 could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

Special Categories of Personal Data are considered to be more sensitive personal information, requiring more protection (this may include details about your race or ethnicity, information about your health, and genetic and biometric data, criminal convictions or offences). In certain circumstances we may collect this type of information, but generally only if we have your specific consent or data protection law allows for the collection of this type of data, for example, to protect the life of an individual participating in an event.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to enlist you in our book club). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?


We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
    • visit our website;
    • make a donation;
    • sign up to receive updates from us;
    • post content to our website or via our social media (including Facebook);
    • campaign or fundraise for us;
    • subscribe to our book club or newsletter;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey;
    • participate in an event;
    • apply for a role with us as an employee or volunteer; or
    • give us feedback or contact us.
  • Indirect Activity. Personal data may be shared with us by third parties, such as partners, fundraisers or through fundraising sites such as JustGiving. If you participate in an event organised by an external party or make a donation through a processor like JustGiving, then your information may be passed to us by the processor. We would only use it for marketing purposes if you have given your consent for this. The fundraising sites have their own privacy policies, and you should check those policies when providing your personal information.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy | ShelterBox for further details.
  • Third parties or publicly available sources. We undertake research to help us identify people who may give higher amounts or in other ways, for example by leaving a gift in a will. Most of that research is conducted in-house but we may also use research from external organisations like Experian or Factary. We will receive personal data about you from various third parties and public sources as set out below:
    • Public registers (such as the Electoral roll, Companies House, and Charity Commission) and aggregators that collate info from same sources (Duedil, 192.com and Directory Enquiries for example);
    • Subscription services (Directory for Social Change and Trustfunding.org are two examples);
    • Public records of other charities or organisations you might support, for example, if you are patrons of the British Museum;
    • Professional registers, posts on professional networking sites like LinkedIn, and company websites and annual reports;
    • Articles about you in newspapers or magazines;
    • Internet search engine results;
    • Technical Data from the following parties:
      • analytics providers such as Google or Hotjar based outside the EU;
      • social media platforms such as LinkedIn, Facebook or Twitter based outside the EU; and
      • search information providers such as Google based outside the EU.
  • Expanding our Network. We may use the email address you give us to help find more people like you, so that we can grow our supporter base through our online channels. We may also use publicly available information about you to help find other likeminded people who may be interested in supporting ShelterBox. These sources provide broad demographic information based on where you live, for example geographic location, type of household, media consumption, likely interests and hobbies. If we understand these common interests, we can invest our resources more efficiently to reach people who are more likely to be interested in supporting our work.
  • Administering Legacies. We may obtain personal information of beneficiaries to a will while administering legacies gifted to ShelterBox. We may also receive information from probate specialists or other charities that are named in the same will.

4. How we use your personal data


When we collect and use your personal information, we will make sure this is only done in accordance with at least one of the legal grounds available to us under Data Protection law. Most commonly, we will use your personal data in the following circumstances:

  • where we need to in order to perform the contract we are about to enter into or have entered into with you;
  • where we have obtained your specific consent to use your information for a previously notified purpose, such as to send you email/text marketing or to provide you with a product, service or information at your request;
  • 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, including:
    • sending direct marketing material to supporters by post or contacting them by telephone for fundraising purposes (subject to checking against the Telephone Preference Service and any existing marketing preferences);
    • conducting research to better understand who our supporters are and better target our fundraising activity to ensure resources are used in the most cost effective way;
    • monitoring who we deal with to protect our charity against fraud, money laundering and other risks;
    • maintaining and administering our donor database and systems for audit trail purposes and ensuring we are communicating with you in your preferred way;
    • if you are based overseas and we have an affiliate in your jurisdiction, we may share your data with our affiliate in order to offer you better tax treatment or a more efficient method of working with us.
  • Where we need to comply with a legal obligation, for instance, where we are ordered by a court or regulatory authority or we are legally required to hold donor transaction details, for example, for Gift Aid or accounting/tax purposes.

In all cases, we carefully consider your rights as an individual and make sure we only use personal information in a way or for a purpose that you would reasonably expect in accordance with this policy, and that does not intrude on your privacy or previously expressed marketing preferences. We always carefully balance our legitimate interests against your rights as an individual, to ensure the best possible outcome for the families who need our support.

Purposes for which we will use your personal data
The way in which we use your personal data will vary depending on how the data was collected and the purpose for which it was collected. We may use your personal data for the following purposes:

  • To provide you with information about our work;
  • To communicate with you for the reasons set out in this policy;
  • To provide you with information, products or services that you have requested from us or that we consider may be of interest to you;
  • To process donations, we may receive from you. If you use your credit or debit card to donate to us or pay for a registration online or over the phone, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard. You can find our more information about PCI DSS here  https://www.pcisecuritystandards.org/security_standards/index.php. We do not store your credit or debit card details at all, following the completion of your transaction. All card details and validation codes are securely destroyed once the payment or donation has been processed. Only staff authorised and trained to process payments will be able to see your card details;
  • If you have made a Gift Aid election for Gift Aid processing. If you choose to include Gift Aid with a donation to us, then we will also ask for your address and UK taxpayer status. This information is needed for us to fulfil our obligations under tax (sections 413 to 430 Income Tax Act 2007) and charity law. By completing a gift aid declaration form, you consent to the data you have supplied being processed and kept securely for the purposes of reporting of donations for Gift Aid collection and maintenance of accounting records. We must keep records of all Gift Aid declarations, whether they are written, online or verbal for 6 years from the end of the accounting period they relate to. After this period, records will be securely destroyed. This information will be shared with HMRC for tax regulation purposes and may also be shared with the Fundraising Regulator and the Charity Commission in the event of an enquiry or investigation. A donor can cancel their declaration at any time, e.g., because they no longer pay UK tax. Cancellation will not affect Gift Aid donations already made. Once a declaration has been cancelled, any further donations from that donor will not qualify. Donors can’t cancel declarations for one-off donations once they’ve made the donation. We are required by law to keep records of any cancelled declarations, including the cancellation date;
  • To maintain our internal records and ensure that we have up-to-date contact details, including your marketing preferences;
  • To invite you to participate in interactive features on our website, including competitions and prize draws;
  • To help us improve our fundraising campaigns and information content and to improve our interactions with you;
  • To assist you with running a fundraising or volunteer event;
  • To liaise with you in relation to attendance at events we organise. If you participate in an event that we have organised, we may ask you to provide information to make sure we can manage the event safely and efficiently. We may also ask you for details of any accessibility need which you may have, so that we ensure our event is inclusive (in line with the provisions of the Equality Act 2010);
  • To invite you to become involved with us in new ways, raise funds and grow our supporter base;
  • To deal with any enquiries or complaints made by you or about you;
  • To contact you where you have been identified as the relevant contact person of an organisation we are working with, such as a school or club;
  • To identify and expand our network of partners globally;
  • To analyse your use of our website (including the use of cookies);
  • To tailor the campaigns or content that we provide to you based on your interests, preferences and other characteristics and to analyse the effectiveness of the content we provide to you and others;
  • Profiling and analysis: Occasionally, we may use your personal information to conduct profiling of our supporters or potential supporters for the purposes of our legitimate interests. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to such use of your personal information for profiling at any time by contacting us at the details set out in the Contact Details section of this Privacy Notice. Profiling may include the following:
    • Data Matching. We may combine the personal information you have given us with data obtained from external sources, such as the Office for National Statistics, to infer the likely social, demographic and financial characteristics, so we can tailor our communications and services to better meet your needs or the needs of others like you based on the insight we gain from the profile we build. The results of data matching will not be used in a way that intrudes on your privacy or your previously expressed privacy preferences;
    • Major Donor Analysis. We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources such as Google and Companies House, published biographies, and publicly available LinkedIn profiles. The type of information we collect can include areas of interest, career history, history of giving to ShelterBox or other charities and public information on any philanthropic activity.
    • Event Planning. We may produce short biographies of people who are due to meet with our leadership or attend an event that we may be hosting.
    • Ethical Screening. We may carry out due diligence on major donors, check donations and use appropriate financial controls to protect the charity from fraud, reputational risk, or money laundering. In addition, we may ethically screen donors to reduce the risk of becoming involved in an association with a person, entity or group that could undermine our values or damage our reputation.
  • For fundraising or direct marketing purposes. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
    • Email/text marketing If you actively provide your consent to us along with your email address and/or mobile phone number, we may contact you for marketing purposes by email or text message. By subscribing to ShelterBox emails or opting-in to email communication from ShelterBox, you grant us the right to use the email for both email marketing purposes and advertisement targeting;
    • Post/telephone marketing If you have provided us with your postal address or telephone number, we may send you direct mail or telephone you about our work unless you have told us that you would prefer not to receive such information in this way. We also actively check telephone numbers against the Telephone Preference Service. We will only make telephone calls to you where your telephone number is listed on the TPS if you have specifically told us that you do not object to such calls and have consented to receive them.
      We will only write to your postal address if you have provided your address and not opted out of receiving communications, or if we judge it to be in your legitimate interest to be written to, for example to provide a receipt for your donation. You can up-date your preferences and opt out of receiving communication to your postal address at any time, see Contact Details section above;
    • Your choice It is always your choice as to whether you want to receive information about our work, how we raise funds and the ways you can get involved. If you do not want us to use your personal information in these ways, please indicate your preferences on the form on which we collect your data.
      You can let us know at any time if you’d prefer to change how we share this information with you or stop it altogether. Simply use the details we’ve provided in the ‘Contact Details’ section to let us know your preferences. If you receive our e-newsletters, you can also use the unsubscribe link in the emails we send.
      We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted by us for such purposes. However, we will retain your details on an unsubscribe list to help ensure that we do not continue to contact you.
  • For response purposes. We may receive your personal data from regional or local government departments, non-governmental organisations, other relief aid organisations, community organisations or charities if you have been identified as a possible recipient of aid. This data will be used to decide on how best to support potential aid recipients, what aid is required for a particular response and which potential recipients should be prioritised for receipt of aid. If you receive aid, you may be contacted several weeks later in order to assist us in monitoring the effectiveness of our responses.

Opting out
You can ask us to stop sending you marketing messages at any time by clicking on the ‘unsubscribe’ link at the end of our marketing emails or by contacting our Supporter Care team on [email protected], or by calling 0300 0300 500. We will not market to you via SMS without your consent. You are able to unsubscribe at any time by replying to the message with the word STOP or contacting our Supporter Care team.

Social media
We operate a number of social media pages (including Facebook, Twitter, LinkedIn, Instagram and YouTube). This policy covers how we will use any data collected from those pages. It does not cover how the providers of social media websites will use your information. Please ensure you read the privacy policy of the social media website before sharing data and make use of the privacy settings and reporting mechanisms to control how your data is used.

Applying for a role at ShelterBox
Your CV, covering letter and application form for any position with ShelterBox will be used during the recruitment process to short-list suitable candidates who will be invited to proceed to the interview stage, and to select the final candidate that the role will be offered to.
We sometimes use third-party job application platforms to publish and receive applications for roles at ShelterBox. When you apply through these portals the organisation’s privacy information will be available to you. We only work alongside other organisations in this way if we are satisfied that they will keep your information safely and use it only in the same legal ways that we would.
During the recruitment process, we will perform some checks on your identity, your right to work in the UK, your eligibility to work with vulnerable people and your past employment references. If we deem a DBS check necessary for your role, in order to process the check, we will send an application via the Cornwall County Council portal. This keeps confidential, electronic records for a maximum of seven years. This portal’s privacy information will again be available to you.
If your application is successful, this information will then form part of your personnel file.
We delete the personal information of unsuccessful applications six months after the application process ends in case there are follow-up queries about the process, unless a candidate requests that we keep their details for longer. After these six months all details are deleted from our own records, as well as from the external recruitment platform. Statistical information like ethnicity, sexuality and disability is kept to ensure that our recruitment processes are inclusive and not discriminatory, but this is completely anonymised.
If we are required by law to share your information, (for example in response to a warrant or court order), we will do so.
All employee information is kept securely and only if we have a legitimate interest for keeping it (for example payroll requirements). This information is stored securely internally and also via an external HRIS platform (CIPHR). All standard employee records will be deleted six years after your employment ends.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy | ShelterBox.

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

5. Disclosures of your personal data


ShelterBox will not, under any circumstances, share or sell your personal information to any third party for marketing purposes and you will not receive offers from other companies or organisations as a result of giving your details to us. We will never share your details with other organisations to use for their own purposes, other than where we are required to by law, for example with HMRC for Gift Aid auditing purposes.

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 or specialist print production agencies who send out our fundraising or marketing materials, or telephone agencies making fundraising calls on our behalf. We carefully select these partners and will only share information with them if we are confident that they will protect it, and we have a contract in place with them that assures this.

We may also use other companies to provide services and process your personal information on our behalf, including delivering or receiving postal mail, making telephone calls to our supporters, sending emails, sending SMS messages, processing credit card payments and analysing our supporter information as outlined above, to help us offer you communications that are most appropriate to you and your interests. In some cases, our suppliers may use software which analyses publicly available information (as outlined above) to build up a picture about you based on the factors set out in this Privacy Policy.

When delivering a response in a particular country, we may work with regional or local government departments, non-governmental organisations, other relief aid organisations, community organisations or charities in order to coordinate our response. In such a case, aid recipient data may be shared between these organisations. Whenever ShelterBox or SBOP elects to work with a partner organisation in delivering a response, we carry out due diligence on those partners and will only share information with them if we are confident that they will protect it, and we have a contract in place with them that assures this.

6. International transfers


Financial and technical considerations may, on occasion, require us to use the services of a service provider outside the European Economic Area (EEA), which may result in your personal data being transferred, processed or stored outside of the EEA.  This may include a country which does not have the same level of data protection as in the United Kingdom.  However, unless they are located in a country which has been assessed by the United Kingdom as ensuring an adequate level of protection for personal data, we will only use a service provider outside the EEA on the basis of an agreement with the service provider, designed to protect your data, in compliance with data protection laws.  Please contact our Data Privacy Lead if you would like to receive further information about this.  We will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Privacy Policy. 

7. 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 those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We protect your personal information in a range of ways including secure servers, firewalls and SSL encryption. We follow payment card industry (PCI) security compliance requirements when processing credit card payments. We operate a policy of restricted, password controlled, access to any of your information which is stored on our systems. 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 our site and 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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention


How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. Children's information


While we do not actively collect information from children (under 16s) in the UK or in the Philippines, we appreciate that our supporters are of all ages, and many amazing young people decide to support our work and raise funds to help families affected by disaster. All ShelterBox events will have clear rules on whether or not children can take part, and the collection of information will be managed in accordance with each individual event, with appropriate safeguards in place.

We may store contact details for children in the instance they are the donor or fundraiser, however, we will ensure that this contact is marked as not to be contacted for marketing under any circumstances. A personalized suppression will be applied to the record of anyone who is a child to ensure they cannot be contacted.

12. Complaints


If you would like to make a complaint or would like more information about our complaints process, please go to How to Make a Complaint | ShelterBox.

If you wish to make a complaint about the way in which we process your personal data, please contact (i) in the UK, our Data Privacy Lead at [email protected] or (ii) in the Philippines, the Data Protection Officer at [email protected].

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) or if you are dealing with ShelterBox Operations Philippines, Inc., the National Privacy Commission (NPC), the Philippine supervisory authority for data protection issues (www.privacy.gov.ph). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the NPC so please contact us in the first instance.

13. Changes to the privacy policy and your duty to inform us of changes


We keep our privacy policy under regular review. [This version was last updated on [12 February 2021]. Please review this policy every time you consider giving your personal information to ShelterBox.
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.