Privacy Policy

Contents

• Introduction
• How we collect personal information from you
• What information we collect about you
• How we might use your information
• Fundraising
• Social media
• Basis of processing your data
• Applying for a job or volunteering with us
• How and where we store your information
• Security
• Where we store your personal information
• When we share your information
• Cookies
• How we treat children and vulnerable persons
• Your choices and telling us when things change
• Your information – your rights
• Changes to this policy

Introduction

Thank you for the support you give to our precious children at the Cherry Brierley Children’s Home (CBCH) through our UK charity, Kisumu Children Trust (KCT). Your gifts, prayers and actions give practical help as well as courage and strength to all of us involved in this vital work.

We have updated KCT’s privacy policy to reflect new regulations and to explain how we collect, store and use your data securely. KCT has always sought to follow best practice and treat each supporter respectfully, in keeping with our beliefs and values and according to your expressed preferences.

Our Privacy Pledge

• We store your personal data securely.
• We ensure your data’s security when dealing with banks and the postal service.
• We won’t share your details with anyone else.
• We won’t call you asking for donations.
• You can change your preferences or opt out from communications at any time.
• If you have any questions, comments or want to change your mailing or contact preferences, contact office@kisumuchildren.org.uk

About Kisumu Children Trust (KCT)

KCT is a UK based charity serving the needs of the children looked after by Kisumu Children Ministries (KCM), Kisumu, Kenya.  We are a charity registered in England and Wales (1091477).

Our correspondence address is:
Kisumu Children Trust
1, Thorpe Avenue
Tonbridge
Kent
TN1 4PW

For the purposes of this Policy:
‘KCT’, ‘us’, ‘we’ and ‘our’ refer to Kisumu Children Trust.
‘CBCH’ means Cherry Brierley Children’s Home
‘KCM’ means Kisumu Children Ministries

How we collect personal information from you

Personal information is collected directly from you when you interact with KCT. For example,

• Making a donation
• Sponsoring a child or project
• Purchasing a gift
• Sending or receiving an email
• Making an enquiry
• Visiting our websites
• Applying for a role at KCT
• Taking part in an event
• Volunteering for KCT
• Signing up to a campaign or newsletter
• Where we have a face to face relationship with you

Information may be collected in person, over the phone, through our websites, social media, email or from something you’ve posted to us.

What information we collect about you

The information we hold will typically include some or all of the following:

• Your name
• Postal address
• Email address
• Phone number
• Your year or date of birth, to ensure we send you age appropriate materials
• The activity that you have completed or the information you have requested

If you make a donation, we may collect:

• Bank details
• Credit card details
• Gift Aid Declaration details

If you interact with us online, we collect:

• non-personal data such as IP addresses
• details of pages visited
• details of files downloaded.

Website usage information is collected using cookies: see the section on Cookies below.

We collect information from third parties such as event organisers (e.g. a marathon event) or fundraising sites like Just Giving, when you have agreed to support KCT and have given your consent. You may wish to check their privacy policy to find out more information on how they will process your data.

We may collect information from Companies House, the Charity Commission, and information published in articles, newspapers or social media.

Where you provide the information, we may collect personal data such as:

• your denomination or church
• your religious beliefs

For employees and supporters travelling with KCT, we may store and share with a travel organiser or company your medical details, and 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 needs you may have, so that we ensure our event is inclusive, in line with the provisions of the Equality Act 2010.

We may also receive information about you from other sources (including public sources). This is explained in the ‘How we might use your information’ section below.

How we might use your information

We may use the personal data we collect to:

• Keep you up-to-date on news and the impact of KCT’s work
• Ask for financial and non-financial support, such as volunteering or prayer
• Process donations you give us, or to support your fundraising for us, including Gift Aid
• Provide information or resources, such as church packs, you have requested
• Provide a personalised service, such as customised website content or personalised emails
• Keep records of your relationship with us eg, feedback you have given or complaints you have made
• Classify supporters by location, for example Scotland, Ireland or Wales
• Conduct market research to aid our understanding of our supporters and their views, so we can provide a better service.

FUNDRAISING

Tailoring our communications

We have a duty to make sure that we’re spending your donations wisely, and that means doing some research and analysis to ensure we send you the most appropriate communications, including acknowledging your past support and actions, demonstrating accountability and impact. In order to work out whom to contact, what to say and when to get in touch, we carry out the following activities:

• We look at information such as postcodes of supporters
• We look at whether donations have been given regularly

This helps us to tailor appropriate communications to you, to demonstrate the impact of your support, as well as improve your experience as a supporter.

We may use your information to invite you to become involved with us in new ways or raise funds.

Personalising our interactions with you and responding to information about you.

Major gifts require a higher level of accountability both in presenting funding proposals and in demonstrating impact. We may undertake in-house research and may engage other organisations to help us identify organisations and individuals who wish to support our work, using information donors have given us and publicly available records. We may also collect information on donors’ interests, for example board memberships, hobbies, or articles in newspapers or magazines. We use this information to tailor our communications and to invite potential supporters to meetings, groups and events which may be of interest to them.

Here are some examples of the sources we might use:

• Public registers (eg, Electoral roll, Companies House, Land records)
• Articles in newspapers or magazines
• Subscription services (eg, Directory of Social Change, opencharities.org, Trustfunding.org, New Trust List service)
• Internet search engine results
• Open postings on social media sites such as LinkedIn and Twitter
• The Charity Commission, Local Authority and government websites
• Public websites and blogs
• Professional registers (eg, NHS employees (doctors), Academics, Solicitors, Accountants, Chartered Surveyors, House of Lords Register of Interests, City of London Directory and Livery Companies Guide, Office of the Scottish Charity Register (OSCR), ACF (Association of Charitable Foundations), Smee & Ford), Deaths and marriages registers (eg, Mortascreen or National Deceased Register)

Social media

Your settings or the privacy policies for social media and messaging services might give permission to access information from these sources. If we do access this data, for example to assess the effectiveness of our communications, we will not add this to your personal details that we hold. We advise you to check the privacy settings on your social media provider to ensure you are happy with the level of privacy you have chosen.

BASIS OF PROCESSING YOUR DATA

Consent

If you are a new supporter, on or after 25 May 2018, we will process your personal data on the basis of the consent you provide us with. You are free to change your contact preferences at any time by contacting us by telephone, post or email, as shown in the section ‘Your choices and telling us when things change’ below.

Contract Performance

This means we will send you whatever you’ve asked for, e.g. a resource you’ve ordered – or write a letter to acknowledge a gift. This doesn’t affect your other communications preferences.

Legitimate Interest

• If you are an existing supporter, as at 25 May 2018, and have requested emails, we will continue to send emails to you. GDPR calls this legitimate interest.
• We may also contact you by post or telephone where we have a legitimate interest to do so – for example, to follow up a request you have made. We will never call to seek a donation. For example, where you have previously made donations to KCT, we may continue to send you information about the work your donation is making possible or other ways to get involved.
• Where you have previously asked us not to contact you in this way, we will continue to respect your contact preferences.
• You can amend your preferences at any time by contacting us via telephone, post or email as shown in the section ‘Your choices and telling us when things change’ below.
• When you make a donation or a series of donations, express an interest in our work, or show a potential to give to our work, we will rely on our legitimate interest in order to collect additional information as noted in the Fundraising section above. This helps us to identify those supporters who would benefit from an initial discussion with a Relationship Manager and to ensure we demonstrate appropriate levels of accountability for how we use donors’ funds.
• We may also share details of the difference our work makes and update you on other ways you could support our work, for example letter writing, using new resources or raising funds.

Applying for a job or volunteering with us

If you apply for a job with us, and you provide personal and sensitive personal data such as the information on your CV or Application Form, we will process and store the personal data we collect to:

• Support the recruitment and selection process
• Answer any questions you may have
• Use third parties to provide services such as references, qualifications, verification of information you have provided, health screening and psychometric evaluation or skills tests
• Undertake checks on criminal convictions
• Provide anonymised data to monitor compliance with equal opportunities policy.

If you work for KCT via an agency that KCT has a contract with, we commit to ensure that the agency is also compliant with GDPR regulations.

If you submit your personal information to a job board, online recruitment tool, social media platform, headhunting agency etc. your details could then be passed to KCT. We recommend that you ensure you have given your consent to that organisation who may share your data. If we receive your details via a third party and are unclear about consent, we may either check with you before using your data further or fully delete the information.

If you do not join us as an employee or volunteer for any reason, your data will be stored for a proportionate length of time in line with the KCT HR Data Retention Policy to ensure compliance with best practice, fairness and legislation.

If you volunteer or travel on a trip with us, and provide personal or sensitive personal data, such as dietary, mobility requirements or specific health information, we will store, process and disclose the personal information we collect to:

• deliver a safe trip or event for you and others involved, including the disclosure of sensitive data, such as medical information, to our partner(s) where necessary.
• provide the administration of these events or opportunities to serve.
• monitor the quality of the volunteering opportunity or trip provided.
• answer any questions or feedback you may have.
• provide anonymised data to monitor compliance with our equal opportunities policy.

Legal basis of processing your data

If you provide personal and sensitive data when applying for a job or to volunteer with us, we will process that data based on consent given by you at the point that the data is collected, or if existing information, based on legitimate interest.

How and where we store your information

We will keep your personal information only for as long as we consider it necessary to carry out each activity.

We have a Data Protection Policy to implement this. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned.

For example, we will retain details of donations to meet tax and accounting requirements, but we will only hold sensitive medical personal information provided to participate in an overseas trip until the trip is completed.

Legacies are an important way that many supporters choose to be remembered by enabling a lasting change to the communities we work with who are currently suffering in extreme poverty. We may keep data you provide indefinitely to carry out the administration of legacies – sometimes we have to prove how long someone has supported KCT – and to communicate with the families of those leaving us legacies.

If you have any questions about our Data Protection Policy, please contact us in writing at:

Data Controller
Kisumu Children Trust
1, Thorpe Avenue
Tonbridge
Kent
TN1 4PW

Email: office@kisumuchildren.org.uk

Security

We ensure that we have appropriate technical controls in place to protect any personal data you provide. For example, we ensure that our website hosting is with a reputable supplier who ensures that the network is protected and routinely monitored. Despite all our efforts, the internet cannot be guaranteed to be 100 per cent secure, and there is always a risk when you submit data. Nevertheless, we have done all we can to protect your data in full compliance with best practice.

We ensure that access to personal data is restricted only to those staff members or volunteers whose job roles require such access and that suitable training is provided for these staff members and volunteers. All employees and volunteers sign a confidentiality agreement when they commence working with KCT.

We may make limited use from time to time of trusted external companies to collect or process personal data on our behalf, such as fulfilling orders or processing donations. When we do so, we use reputable companies and take reasonable precautions to ensure they will handle personal data securely and safely. When we do use external companies, we remain responsible for the storing and processing of your personal data.

Credit / Debit card security

If you use your debit or credit card to donate to us, purchase something or pay for a trip, whether online, over the phone or by mail, we will process your information securely in accordance with the Payment Card Industry Data Standard.

We do not store your debit or credit card details once your transaction has been completed.

We hold bank account details for the purpose of collecting direct debits in accordance with direct debit mandate rules.

Where we store your personal information

The data we process and store is within the European Economic Area (EEA). It may be that some of our suppliers use cloud-based storage; however, we take steps to make sure they provide an adequate level of protection in accordance with UK data protection law. We adopt the Information Commissioners approved measures and therefore ensure that personal data is held in compliance with European data protection regulations. We take all reasonable steps to ensure that your data is stored and processed securely in accordance with this policy. By submitting your personal data you agree to this transfer, storing and processing of your information.

Should you travel with us to our project in Africa, we may share personal information with partners who plan and prepare the arrangements for your trip. For example, this may include sensitive personal data such as medical information and passport details. When we do so we will make you aware of the data being transferred and gain your consent to do so.

When we share your information

We do not share or swap your information with any other charities or organisations for the purposes of their marketing – as this would conflict with our core values and desire to treat supporters with respect.

Legal Duty

We may need to pass on information if required by law or by a regulatory body. For example, a Gift Aid audit by the HMRC, or if asked for details by a law enforcement agency.

Our service providers and third parties

From time to time we may employ trusted suppliers to carry out tasks on our behalf, such as fulfilling orders, managing events, supporting our systems, or processing donations. These agents are bound by contract to protect your data and we remain responsible for their actions.

We may provide third parties with general information about users of our site, but this information is both aggregated and anonymous. However, we may use IP address information to identify a user if we feel that there are or may be safety and/or security issues or to comply with legal requirements.


COOKIES

What are cookies?

We collect data using cookies. A cookie is a text file that is sent from our website as soon as you visit the site. It is stored on your computer’s hard drive and helps us to identify your computer (not you) and collects information in an aggregate, anonymous way.

We collect cookies:

• To enable users to complete actions on our website without creating an account
• For account registration and logging in

How do we use cookies?

Cookies may be used to collect information about your visit to our website, such as:

• traffic data
• location data
• device information
• the date and time of your visit
• the pages that you visit

We may use this information to:

• customise the content on our website and help to understand visitors’ current and future needs
• process any requests, applications or transactions you may make
• aid internal administration and analysis

You can find out more about cookies at Cookiepedia and at aboutcookies.org.uk

Managing Cookies

Most browsers allow you to turn off the cookie function. To do this you can look at the help function on your browser or visit aboutcookies.org.uk.

To experience the KCT website to the full, we recommend that you leave cookies turned on. If you turn off cookies then you may not be able to enter parts of the site.

Third Party Cookies

KCT works with a number of third party suppliers who set cookies on our website to enable them to provide us with services. These are mainly used for reporting and advertising purposes so we can improve the way we communicate.

We use websites such as YouTube and Vimeo to embed videos and you may be sent cookies from these websites. We do not control the setting of these cookies, so we suggest you check the third party website for more information about their cookies and how to manage them.

KCT also uses third party suppliers such as Facebook, Google Analytics, and these providers may use cookies. They may also use tracking pixels, which are commonly found in advertising to track the effectiveness of adverts.

As some of these services may be based outside of the UK and the European Union, they may not fall under the jurisdiction of UK courts. If you are concerned about this you can change your cookie settings (see above) and can find more information about this here.

HOW WE TREAT CHILDREN AND VULNERABLE PERSONS

Aged 12 or under

We do not actively seek to collect children’s data (other than those under our care with CBCH and KCM) and require a date of birth for anyone under 21.

Supporters in vulnerable circumstances

We recognise the importance of identifying and supporting supporters in vulnerable circumstances. Members of our Inspire Team who send or respond to supporter emails, mailings or calls are trained to identify signs of vulnerable circumstances and to deal with the supporter appropriately in line with our ‘Guidelines for safeguarding vulnerable supporters’ policy.

Personal information will be recorded so that we may respond appropriately in future, for example by ceasing fundraising requests or no longer making calls.

YOUR CHOICES AND TELLING US WHEN THINGS CHANGE

Preferences

You can change your preferences on which communications you receive from us, including marketing and fundraising materials, or how we contact you, by mail, phone or email, at any time.

You can do so by:

Calling us on: +44 (0)1732 369 303

Writing to us at:
Data Controller
Kisumu Children Trust
1, Thorpe Avenue
Tonbridge
Kent
TN1 4PW

Email: office@kisumuchildren.org.uk

 

Updating your details

We want to communicate with you effectively. It’s much easier if your details are up to date, so we really appreciate it if you let us know when your details change. You can do so in the same way as updating your preferences (above).

If we are unsure of the details you have entered on a form, or if you have changed address and given the Post Office permission to share this, we may use Post Office address search, postcode lists or other available sources to confirm data that you provide us with.

However, if you continue to give regularly and items such as the KCT magazine are returned to us, we may use external sources to update your address details, if we are unable to reach you in any other way. This is so that we may update you on how your money has been spent through our news and stories.

YOUR INFORMATION – YOUR RIGHTS

For any of the following areas, please contact the Data Controller:

Data Controller
Kisumu Children Trust
1, Thorpe Avenue
Tonbridge
Kent
TN1 4PW

Email: office@kisumuchildren.org.uk

Telling us to stop processing

You have the right to ask us to stop using your personal information for marketing purposes or for any other purpose where there is no legal requirement for continued processing.

How to request a copy of the information that we hold about you, otherwise known as a Subject Access Request

You have the right to ask for a copy of all the information related to you that we hold.

How to ask us to amend or delete your information

If your information is out of date, or if there is no longer justification for us to hold it, you can ask for it to be updated, removed or blocked by contacting the Data Protection Officer in writing.

How to request your information

You can ask for a copy of any personal information that you have provided to us in the past. We will provide it in a clear and easy to follow format.

Changes to this policy

This policy was last updated in May 2018. We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other associated legislation. If we make any significant changes to this policy we will show this clearly on our website, and/or by contacting you directly.