Independent Age promises to respect and look after all personal data you share with us or that we get from other organisations. We will always keep it safe. We aim to be clear when we collect your data about what we’ll use it for, and not do anything you wouldn’t reasonably expect, whether you are a supporter, volunteer, service user or campaigner. We never sell your personal data to other organisations, and will only ever share it in appropriate, legal or exceptional circumstances (see section 10, ‘Your Information and Third Parties’ to find out more).
The purpose of this policy is to give you a clear explanation about your data protection rights and how Independent Age collects and uses the personal information you provide to us. It explains what we collect, whether online, via the phone, email, in letters or in any other correspondence or from third parties, and how we process and use it to provide vital services to our customers.
By allowing us to use personal data, you are helping us to make better decisions, improve our services for older people, fundraise more effectively and ultimately achieve our goal of a society where older people can live the lives they aspire to and contribute actively to their communities.
1. Who is Independent Age?
Independent Age is comprised of both a charity and a trading subsidiary. Any information we collect may be used by both entities.
Independent Age is the operating name for The Royal United Kingdom Beneficent Association (RUKBA), a charity registered in England and Wales and incorporated by Royal Charter (charity registration number 210729).
Independent Age Enterprises Ltd (registered company in England and Wales no. 04735201) is the wholly owned subsidiary of RUKBA which trades on our behalf (for example the selling of merchandise).
The Campaign to End Loneliness (CTEL) is a department within Independent Age with a broad remit to tackle loneliness in older age through a network of national, regional organisations and people working together through community action, good practice, research and policy. CTEL operates under the same legal entity as Independent Age, and consequently has the same legal, statutory and governance controls.
2. What are your Data Protection Rights?
In all cases you have the:
Right to be informed whether or not we process your information and how that information is stored and used by us.
Right to access your information at any time by submitting a ‘Subject Access Request (SAR)’ to the data protection lead. Information will be provided to you within a month of your request being received.
Right to correct the information we hold about you if it is incorrect or incomplete.
Right to delete the information we hold about you, this being termed the ‘right to be forgotten’. It is not always possible to delete all information due to legal reasons or processing requirements, but where this is the case this will be explained to you further.
Right to restrict processing of your information at any time by contacting the relevant department as indicated below or the data protection officer. This may be to change how you support us and how we contact you in the future.
Right to port (move) the information you have provided to us to another organisation. We will provide this to you in a form that is accessible to another organisation.
Right to object to any processing where you feel appropriate consents have not been sought by ourselves. In these circumstances we will investigate your concerns and the decisions we have made accordingly.
Right to object to automated decision making where your data is processed by machines and decisions made without human intervention. This is also applicable to profiling where decisions may be made automatically to evaluate certain things about you.
Right to withdraw consent if we have obtained your consent to process your data, you can withdraw this consent at any time by contacting the Data Protection Lead. This will not affect the lawfulness of processing based on consent before its withdrawal.
To request further information on your rights or to request a change as per your rights above, please contact the Data Protection Lead at firstname.lastname@example.org.
3. How and when we collect information about you
We collect information in the following ways:
3.1 When you give it to us directly
You may give us your details when you sign up for one of our events, receive support from our helpline or another service, volunteer with us, order an information booklet, tell us your story, make a donation, purchase our Christmas cards or communicate with us. Sometimes your information is collected by an organisation working for us (e.g a professional fundraising agency) but we are responsible for your data at all times.
3.2 When you give it to us indirectly
3.3 When you use our website
Like most websites, we use ‘cookies’ to help us make our site, and the way you use it better. Cookies means that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields.
As well as this, cookies can tell us the type of device you’re using to access our website and the settings on that device may provide us with information including what type device it is, what operating system you’re using, what your device settings are, and why a crash has happened. This information helps us understand how people are using our website and show us how to make it better.
Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
3.4 When you access Independent Age’s social media
We might also obtain your personal data through your use of social media such as Facebook and Twitter depending on your settings or the privacy policies of these social media messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this:
3.5 When the information is publically available
We might also obtain personal information about individuals who may be interested in giving major gifts to charities or organisations like Independent Age. In this scenario, Independent Age may seek to find out more about these individuals, their interests and motivations for giving through publically available information. This information may include newspaper or other media coverage, open postings on social media such as LinkedIn, and data from Companies House.
4. Lawful Processing
Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:
Where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing.
Performance of a contract
Where we are entering into a contract with you or performing our obligations under it.
Where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example where we are ordered by a court or regulatory authority like the Charity Commission or Fundraising Regulator.
Where it is necessary to protect life or health (for example in the case of medical emergency suffered by an individual at one of our events) or a safeguarding issue which requires us to share you information with the emergency services.
Where it is reasonably necessary to achieve our or others’ legitimate interests (as long as what the information is used for is fair and does not duly impact your rights).
We consider our legitimate interests to be running Independent Age as a charitable organisation in pursuit of our aims and ideals. For example to:
- send postal communications which we think will be of interest to you;
- conduct research to better understand who our supporters are to better target our fundraising;
- monitor who we deal with to protect the charity against fraud, money laundering and other risks;
- enhance, modify, personalise or otherwise improve our services /communications for the benefit of our customers; and
- understand better how people interact with our website.
When we legitimately process your personal information in this way, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where our interests are overridden by the impact on you, for example, where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
When we use sensitive personal information, 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 example, if we need to process it for employment, social security or social protection purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
5. What information do we collect and how do we use it?
The type of information we collect and how we use it depends on how you support Independent Age through the following ways:
5.1 Financial Supporters
If we wish to engage with you and approach you as a financial supporter or if you support us, for by, registering to fundraise, signing up for an event or buying something from us, we will collect:
- Your name
- Your contact details
- Your date of birth
- Your bank or credit/debit card details (only for confirmed supporters)
- Your current interests and donor activities
- Your employment situation
Where it is appropriate we may also ask for:
- Information relating to your health (for example if you are taking part in an event)
- Why you have decided to support us. We will never make the question mandatory, and only want to know the answer if you are comfortable telling us.
We will use your data to:
- Administer your donation or support your fundraising and participation in our activities, including processing Gift Aid
- Keep a record of your relationship with us
- Ensure we know how you prefer to be contacted
- Manage feedback or complaints we receive from you
- Work with third parties to send you relevant marketing materials based on your preferences and our analysis of your interests (please refer to sections on Direct Marketing and Building Profiles)
- To share your story with fellow supporters, with your consent (see section on Sharing your Story)
Some of our supporters choose to give higher donations, and this enables Independent Age to have even greater impact on the lives of older people and their families. To help us identify individuals, trusts or companies who may have a philanthropic interest in our work, we undertake in-house research and may also work with reputable external organisations such as Factary. This research is based on information provided to us by our supporters, along with publicly available sources such as the electoral roll, Companies House records, newspaper articles, company websites, internet searches etc. Knowing more about our supporters and their interests enables us to tailor our communications in the most appropriate way, and to better engage those who have an interest in helping older people and becoming more involved with Independent Age.
Our Volunteers make a real difference to the lives of older people in the many ways they choose to support us – this may be in visiting an older person at home, providing regular friendship services via the telephone, or by raising awareness in their local community of the work that Independent Age does. There are many more types of volunteer and to become one you will need to provide information to allow us to assess your suitability for a particular role, to provide training and to correspond with you about your chosen role and provide additional information about Independent Age and its various activities.
The types of information we may collect include:
- Your basic contact details including your name, address, date of birth, telephone number and email address;
- Your bank details will be required in order for you to claim expenses;
- Identification including passport, drivers licence, birth certificate, utility bills etc. in order to carry out Disclosure and Barring Service checks;
- Your photo will be required for identification purposes when carrying out some volunteering roles;
- Details of any Next of Kin/trusted contact and any special needs we may need to be aware of for Health and Safety purposes;
- Details of any referees that support your application to become a Volunteer.
Some of the information collected will be Special Category Data (sensitive data) that will be destroyed once the purpose for its initial collection has been served. This includes data for DBS checking which is destroyed once appropriate checks have been completed.
Your data is stored securely on Independent Age systems, and the systems of third parties who we currently have a working relationship with. In these circumstances appropriate data protection agreements will be in place with any third party organisation safeguarding any information they may have access to. Sensitive data is only available internally to those staff that needs to view it as part of their job role.
We will only use your data for administering your volunteering role with Independent Age and also for keeping you informed of the work that is being carried out by other areas of the organisation.
If you campaign on our behalf, by signing one of our petitions or sending an email to an MP for example, we will collect:
- Your name
- Your contact details including your address when necessary
- A record of the action you have taken
- A record of who your MP is, where applicable
We may also ask for:
- Your story, which may include including information about your health and other circumstances. Sharing this information will always be optional.
- Your permission to use your story in our campaigns
We will use your data to:
- Keep a record of your relationship with us
- Ensure we know how you prefer to be contacted
- To share your story with fellow supporters, with your consent (see section on Sharing your Story)
However, you support us we will not:
- Sell your data to another organisation
- Swap your data with other organisations
The type of information we collect and how we use it depends on how you receive support from Independent Age through the following ways:
5.4 Users of our Helpline and Information Services
The Independent Age Helpline provides older people and their families with clear, free and impartial information on the issues that matter: care and support, money and benefits, health and mobility, they also offer signposting and refer callers to an advice team for in depth advice.
The helpline service may record a variety of information about the user which may include their basic contact details (name and telephone number), age, and any health, disabilities and mobility issues which are directly related to the advice being sought or issues discussed. This information will be stored (including the telephone conversation itself) for training and quality purposes and will not be used or viewed by any other area of the organisation who do not need to know it as part of their work. Our advice line also makes use of third party tools to help us provide the best advice possible to our customers, an example being an online benefits checker. Where these are used an internal copy of the results may be stored on the user’s record on our database.
The information recorded may be shared with other third-parties to enable us to review the quality of our services and to safeguard the security and wellbeing of the individual in emergency situations - to prevent harm or to assist the emergency services in preventing or detecting a crime. The public interest in safeguarding may override confidentiality interests in this regard. However, all information will be shared on a need to know basis only, this being decided by a qualified, designated person at the time.
We will at times call users to the service to ensure we have dealt with their requests and concerns in an effective and diligent manner to evaluate the quality of our services, but also to seek specific consent to use their experiences where we feel would be of benefit to others.
5.5 Users of our Friendship Services
Our friendship services are a vital resource which allows us to alleviate loneliness in the many older people we support – this being accomplished by providing regular telephone calls, face-to-face visits and telephone discussion groups throughout the United Kingdom through the help of our network of dedicated volunteers.
In order for us to carry out these services we need to collect, store and process a variety of information about you, some of which will be personal and special category (sensitive) information. The types of information we may collect include:
- Your basic contact details including your name, address, date of birth, telephone number, email address and any emergency contact information;
- Information about any health, medical and disability issues, including any mobility problems which may affect the types of services we can provide;
- Information about your property, its location e.g. rural, city etc., and whether other individuals live at the property – this helps us to manage the risks to any potential visitors;
- Information of any pets you may have for health and safety purposes of our visitors;
- Any interests and hobbies you may have in order for us to deliver the services to you of most value;
- Additional information may be collected to enable us to provide personal support, this being decided on a case-by-case basis and discussed with the individual at the time.
Many of the services provided e.g. the regular telephone befriending services and telephone and book groups, may be recorded in order for us to monitor and evaluate the quality of the services provided. In addition, as part of our face-to-face services an individual’s name, address and telephone number will be given to a trusted contact of the Volunteers in order to respond to any unexpected events in the course of their visit.
We may make use of third parties to evaluate the services provided and any information shared with these parties will be done so only as required (the minimum amount of information), and appropriate data processing agreements will be in place for this purpose.
5.6 Users of our Beneficiary Services
Our Beneficiaries benefit from support of a financial nature, including regular payments, one-off-grants, and are also able to receive equipment (as needs dictate) from an extensive range of mobility items aimed to improve the quality of their lives. This group of older people also have access to our range of friendship and helpline advice and information services.
In order for us to carry out these services and offer financial assistance we need to collect, store and process a variety of information, in addition to that collected for our helpline and friendship services. Some of this information will be personal and special category (sensitive) information. The additional types of information we may collect include:
- Detailed financial information, including benefits they may be in receipt of, these being collected periodically for assessment of financial needs;
- Bank account information in order to make payments;
- Detailed health, mobility and disability information which will allow us to assess needs more thoroughly;
- Information pertaining to any legal Power of Attorneys which may be setup and allows us to communicate with other individuals or agencies;
- Information referencing any religious beliefs, interests, hobbies;
- Information pertaining to any safeguarding concerns and action taken as a result of a safeguarding issue;
- Information of additional contacts you may have given us for reference purposes or contacts who can be contacted in the event of any emergencies you may experience (we assume these contacts will have been informed by yourself in these circumstances).
5.7 Employees and Job Applicants
We will store contact and financial details of suppliers in order to manage and process contracts and payments.
6. Keeping your information up to date
Where possible we use publically available sources to keep your records up to date; for example The Post Office’s National Change of Address database and information provided to us by other organisations as described above (see the How and When we collect data from you section). Where we use external sources of data to help us provide more accurate communications with you, we will seek assurances from these third parties that any information provided would have been collected lawfully and appropriate consents sought to share that data with other organisations like ourselves.
7. How long we keep your information for
We keep your personal data only for as long as we need to use it for the purposes set out in this Policy.
We have adopted a data retention policy that sets out the different periods we retain personal data for in respect of these relevant purposes. The criteria we use for determining these retention periods is based on various legal requirements; the purpose for which we hold data and whether there is a legitimate reason for continuing to store it (such as in order to deal with any future legal disputes); and guidance issued by relevant regulatory authorities including, but not limited to, the Information Commissioner’s Office (ICO).
Personal data that we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it. Some personal data may be retained by us in archives for statistical or historical purposes although we will do this in a manner that complies with applicable data protection law.
We continually review what personal data and records we hold, and delete what is no longer required. We never store payment card data after the transaction has been completed.
8. Direct Marketing
We only want to contact supporters, campaigners, service users and volunteers who want to hear from us in the ways that they have told us. Our forms have clear marketing preference questions and we include information on how to opt out when we send you marketing.
If you have given us your consent to contact you by email, telephone and text message, we may contact you for marketing purposes by using that channel. We may also contact you by email or telephone or text message for administration purposes (e.g. where you make a donation).
If you have provided us with your postal address then we may use our legitimate interest to send you direct mail for fundraising or campaigning unless you told us that you would prefer not to hear from us in this way.
If you don’t want to hear from us, that’s fine. Just let us know when you provide your details, click the ‘unsubscribe’ link in any email we send or update your communication preferences on our website.
We will retain your details on a suppression list to help ensure that we do not continue to contact you in future unless we receive a direct response otherwise.
We do not sell or share personal details to third parties for the purposes of marketing. But if we run an event in partnership with another names organisation your details may need to be shared. We will be very clear what will happen to your data when you register.
9. Building profiles of supporters and targeting communications
We use profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience for our supporters. Profiling also allows us to target our resources effectively. 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 profile, we may analyse geographic, demographic and other information relating to you in order to better understand your interests and preferences in order to contact you with the most relevant communications.
If you would prefer us not to use your personal data for building profiles, please let us know by using the contact details in section 13.
10. Sharing your story
From time-to-time we use real-life case studies to demonstrate the impact of our work with external bodies, key stakeholder groups and the general public as a whole. This information may have been directly provided by our customers or indirectly through the various services we offer. This is extremely powerful and where we feel your information can make a real difference to others, we will ask you for your specific consent to use it. We will always make sure we have explicit and informed consent from the individuals concerned for the specific use of this information. We will always keep this information safe and secure. This information may be shared at events, in promotional materials of fundraising campaigns or in documents such as our annual report.
11. How we keep your data safe and who has access
Independent Age stores all the information held about you on its own systems located at its head office in London, which is within the UK and the European Economic Area and protected by UK data protection law and other associated legislation.
We may engage the services of third-party processors and on occasion these may reside outside of the European Economic Area. Where this happens appropriate Data Protection agreements will be in place with any third-party before any processing of your data is carried out.
Independent Age take the security of your data very seriously. The organisation has internal policies and controls in place to try and ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. This includes strict access controls and security of its network and databases (and the information within), and rigorous change controls to ensure only those people who have a need to view, amend or process your information, can do.
12. Your information and Third Parties
Independent Age does not trade names with other organisations, 'list swap' or rent out contact information or other personal data provided to us. We will never pass your details to a third-party to use in the course of their own business activities.
Independent Age uses third parties to process data on its behalf, which may include your personal data. Only information that is necessary for a particular purpose is provided to any third party, with a clear expectation that all data, used and stored, is subsequently destroyed when any processing has been completed.
Independent Age may disclose your details to a third party if there is a legal obligation to do so. Only that data which is required to fulfil the obligation may be provided and no other information.
13. Who to contact for more Information
If you would like to contact us for more information about this policy or any other data protection related matter or to make a ‘Subject Access Request (SAR)’ please contact the Data Protection Officer at the address or email indicated below.
Please write to:
Data Protection Lead
(Private & Confidential)
18 Avonmore Road,
For matters relating to different areas of the organisation, please mark any correspondence as ‘Private & Confidential’ and address to: Independent Age, 18 Avonmore Road, London, W14 8R
Complaints regarding Data Protection
|Data Protection Lead
Head of Individual Giving & Legacies
Policy & Campaigns
Head of Policy & Campaigns
Helpline Services, Volunteering & Friendship Services
|Services Admin Team
Complaining to the Information Commissioners Office
If you are not satisfied with our reply and/or outcome, or with our handling of your complaint you have the right to make a complaint to the ICO. You can find out more information about reporting a concern on the ICO website or by contacting their helpline number on 0303 123 1113.