Livability is a charity registered with the Charities Commission under charity number 1116530, and a company limited by guarantee and registered in England and Wales under company number 5967087.

Livability was established in 2007 as a merger of The Shaftesbury Society and John Grooms. In May 2016 Prospects for People with Learning Disabilities and its subsidiary At Home in the Community became members of the Livability Group.

Livability is the parent charity of a group of charities and operating companies.

Our registered charity numbers are 1116530 in England and Wales.

Livability is a Data Controller, registered with the Information Commissioner’s Office (Registration Number Z974176X).

Within the context of this policy ‘we’ means both the charity and its subsidiaries. Each of these organisations are data controllers under the data protection rules.

Understanding your rights

It is important that you understand your legal rights around your personal data and how we may use it. If you would like to discuss or exercise any of these rights, please contact our Data Protection Officer at Livability Head Office or email: dataprotection@livability.org.uk

You have the right to be informed

This Privacy Policy ensures that you are informed about how we will process your personal data. You might also see messages on some of our forms (or otherwise when we collect personal data from you) that explain why we ask for specific pieces of information from you.

You have rights of access

You have the right to access a copy of your personal data and receive certain information about what the data is and how and why we are processing it.

Please note that we will require you to prove your identity before we disclose any information.

You have the right to rectify information

If you feel that any of the information that we hold about you is incorrect, do let us know so that we can look into it for you and amend it.

You have the right to object

You have the right to object to the processing of your data that we have outlined in this policy in certain cases. You can object in instances whereby we are processing your personal data on the basis that it is within our ‘legitimate interests’ to do so. Please see further information on this in the Our legal basis for processing your data section below.

You have the right to be forgotten

You have the right to request that we delete your information and you can discuss this with us at any time.

You should know that there are some circumstances where we may need to keep your details, for example, if it is necessary for us to comply with a legal obligation. If this situation occurs, then we will explain and discuss these circumstances with you.

You have the right to restrict processing of your data

You can request that we restrict the processing of your data, as an alternative to deleting it – this means that we will keep the data but stop processing it for most purposes. You may want to exercise this right if you feel that the data is inaccurate, there is disagreement over its legitimate use, or you feel that we have no further use of your data.

You have the right to object to automated decision making

You have rights to avoid being subjected to decisions based solely on automated processing (e.g. using computerised models and algorithms) which may have legal or other significant effects on a person.

You have the right to data portability

You have the right to request a copy of certain personal data to have it transferred to another organisation in certain circumstances.

You should know that there are some circumstances where these rights may not apply, but where this is the case we will always explain this to you. Please do contact us if you have any questions or concerns on how we collect and use your personal data, or on your rights, as we are always happy to speak to you.

You also have the right to make a complaint direct to the UK’s data protection authority, the Information Commissioner’s Office (ICO). The ICO can be contacted at: and concerns can also be logged via the ICO website

The information that we collect

The personal data that we collect about you will be based on how you interact with us, but we collect the following information from many of our supporters and volunteers:

• Your name
• Your postal and email addresses
• Your telephone number or numbers
• Details of any correspondence that we have had with you. For example, if you call our Supporter Services team, they will make a note of the conversation, in case you need anything else on that matter.
• How you would like to hear from us, and when you told us this
• Details of any donations that you have made to us
• Whether or not you have signed up to the Gift Aid Scheme, and when you did so
• Your date of birth
• Any fundraising appeals that you may have responded to
• Events that you have taken part in or enquired about

There is also other information that we may collect and hold in specific circumstances. For example:

• Your bank account details if you set up a direct debit with us
• Health information that you give us if you are participating in an event, to help us ensure your safety
• Details of your connection to our charity or one of the many services we support, should you wish to provide this link. Please see further information on this in the Sensitive personal data section below
• Our telephone system lists the numbers that have recently called or been dialled, but we do not link these to any supporter records
• Information to support our work with high net worth individuals, to understand their philanthropic interests, and complete any necessary due diligence

When we collect information about you

Livability collects information in the following ways:

When you give it to us DIRECTLY: .

You may give us your information in order to sign up for one of our events, tell us your story, sign up to our e-newsletter, fundraise on our behalf, make a donation, pledge a legacy, purchase Christmas Cards and other merchandise or to simply communicate with us. Sometimes when you support us, 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.

When you give it to us INDIRECTLY: Your information may be shared with us by independent event organisers, for example the London Marathon or fundraising sites like Just Giving. These independent third parties will only do so when you have indicated that you wish to support Livability and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

• When you give permission toOTHER ORGANISATIONS to share your information or it is AVAILABLE PUBLICLY:

 

We may combine information you provide to us with information available from external sources in order to gain a better understanding of our supporters and to improve our fundraising methods, products and services.

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. The data we receive depends on your agreement with the third party organisation. We, like all charities and companies, are able to confirm what browser you are using, IP address and computer operating systems that are being used and this information may be used to improve the services we offer. We do not sell or swap data with third parties or other charities.

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.

• When we collect it as you use our WEBSITE & DIGITAL SERVICES:

We collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our websites or view and interact with our ads                      and content. This helps us to understand your interests in our cause and information and to tailor our resources to be more focused on what supporters or service users need.

We assign web browser cookies to enhance each visitor’s use of our website. Cookies are used for saving small amounts of information such as user settings.

We may also work with third parties to help us measure visits to our website in order to improve its usability. The data we measure may contain personal information (an IP address and/or cookies).

Use of cookies and website usage

Our website uses cookies to help provide you with the best online user experience we can. Cookies are small text files that are placed on your computer or electronic device when you browse a website. We use this information to provide you with a good experience when browsing our website and to improve the functionality of our site.

Our cookies help us:

• Make our website work as you would expect
• Remember your settings during and between visits
• Improve the speed and security of the site
• Personalise our site to you to help you get what you need fast
• Continuously improve our website for you

Examples of cookies we use include (but are not limited to):

• Google Analytics: This allows us to collect anonymous information about how visitors use the website. For example, information which pages on the site have been visited and the length of time spent on each page. This information enables us to improve our website for future visitors.
• Session: Session cookies enable us to keep track of your movement from page to page so you do not get asked for the same information you have already given to the site. This allows you to proceed through many pages of our website quickly and easily without having to authenticate or reprocess each new are you visit.
• CQC Widget: This cookie forms part of a widget provided by the Care Quality Commission, which is the independent regulator of all health and social care services in England. The widget displays the result of our service’s most recent CQC inspection and provides a link through to the record of the inspection on the regulator’s website.

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our website

Website users

All Livability websites use cookies to help our websites work well and to track  information about how people are using them.

All Livability websites collect personal information which may include:

• Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblog statistics and other communication data.
• Information that you provide by filling in forms on our website, such as when you make an enquiry about one of our services, or make a donation to
• Email addresses, postal and telephone information if you opt in to receive emails or other resources from us.
• Information provided to us when you communicate with us for any reason.

Third party links

You may find links to third party websites on our These websites will have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Offensive behaviour on our website

If you post or send any content on Livability digital channels that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content on our social media pages, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

Tracking

We use multiple first and third party technologies such as pixel tags and web beacons to track and improve the user experience on our sites, quality of service and to monitor the effectiveness of campaigns and digital marketing

We may use them to:

• See what website content is popular and how people are using the site as they allow us to track users’ movement through our This type of information is amalgamated so that we can build up a picture of how the site is performing.
• Make sure we offer you a consistent service. For example, if we are testing new website content or we want to run a survey, we use tracking to remember what content you have seen or if you have already been asked to join the
• In addition, when we email you, we may place a tag (also known as ‘tracking pixel’) on the email we send These let us monitor performance of our email marketing activity.
• Form the basis of advertisement profile and retargeting as we seek to ensure any adverts displayed on our behalf are as relevant and interesting as possible to the people those adverts are displayed to.

International transfer of data

We may transfer data that we collect from you to locations outside of the European Economic Area for processing and storing. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this Privacy Policy.

Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted.

Why we collect and use your personal data

We collect personal data to help us to process your requests, keep in touch with you and to help us to interact with you in the most effective way.

We will use your personal information:

• To provide you with the services, products or information you have asked for
• To process your donation, and where applicable, including the processing of gift aid
• To support your fundraising efforts
• To ask you to help us raise money or to donate through our appeals
• To provide you with information about our work and activities or to send you materials that you have requested
• To invite you to participate in market research
• To invite you to events
• To manage and administer any legacies that have been pledged or left to us
• To keep a record of our relationship with us
• To ensure we know how you prefer to be contacted
• For internal record keeping, such as the management of feedback or complaints
• Where it is required or authorised by law

Direct Marketing

From time to time, we will contact you to let you know about the progress we are making and to ask for donations or other support. 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. If you don’t want to hear from us, that’s fine. Just let us know when you provide your data or contact our Supporter Services team on 020 7452 2121 or at supporterservices@livability.org.uk

Building profiles of supporters and targeting communications

As part of our major donor fundraising activities we undertake research and profiling of supporters and prospective supporters who may have an interest in, and financial ability to, support Livability and particular aspects of our work. This research helps us to target our communications in a more focused, personalised and cost effective way by giving us greater insight into what donors and prospective donors may find interesting and the level of support they may be able to provide.

When undertaking research or gathering information in order to build a picture about a supporter or prospective supporter, we consider geographic, demographic and other publicly available information such as location, listed Directorships or trusteeships, donations to other organisations and measures of affluence such as typical earnings in a given profession and house values.

Our profiling methods and analysis activities can be categorised in the following four ways:

1. Data Matching

We may use the personal information an individual has given us in conjunction with data that has been obtained from external sources in order to obtain a greater understanding of their likely social, demographic and financial characteristics. This allows us to tailor communications with a greater degree of relevancy to better meet the expectations and desires of the individual and other individuals in similar circumstances. We will not use this data in any way that might intrude upon an individual’s rights or be considered inappropriate.

2. Segmenting

We analyse supporters by group, post code or geodemographic area where supporters may be located. This enables us to better tailor relevant campaigns and mailings for those most likely to be interested and get involved. This is not designed to identify any specific individuals, but rather many individuals who may lie in a particular segment of supporters.

3. Event Planning

We sometimes create short biographies of individuals who are attending our events or meetings for the purpose of understanding more about the people we are engaging with. This includes reviewing publicly available sources such as public registers, broadcast media and online publications and stories.

4. Major Donor Analysis

We analyse our database and use information on how supporters have engaged with us in the past to see if we believe that they would be interested in building a relationship with our fundraisers. We then use publicly available sources of information to understand their philanthropic interests and capacity to give greater support (which includes estimated levels of wealth where available). We may also identify other potential new supporters this way. We may from time to time engage a specialist third party prospect research company to analyse our database against their demographic database for this purpose.

These external data sources are gathered entirely from publicly accessible sources and include examples such as:

• Public Registers: Companies House (directorships, shareholdings and company accounts), The Electoral Commission (Political Donations), The Electoral Roll (Open Register), The FCA (Financial Services Register), The Law Society, The Land Registry
• UK Reference Volumes: Who’s Who, Debrett’s People of Today, Debrett’s Peerage and Baronetage, City of London Livery Company information, Trustfunding.org.uk, Sunday Times Rich List
• Reliable print and broadcast media: newspapers (The Telegraph, Financial Times, The Times and Sunday Times, City AM), magazines
• Trade and Industry References, Professional directories, Charity Commission
• Information that individuals put into the public domain such as on company websites or biographies on professional networking sites
• Geographic and demographic information based on postcode

The information that we then review from these sources includes things such as whether a person is a company director or trustee of a charity, their business profession, and estimated property values.

Using this information means that we can tailor communications to areas of our work that we believe will be of interest to you, as we know that donors want information relevant to their motivation for giving. It enables us to spend less money than we otherwise would to raise more funds. It also allows us to ensure that we do not contact people inappropriately.

If you would like any further information on our profiling and major donor analysis, or do not wish us to use your details in any of the ways described above, please contact our Supporter Services team on 020 7452 2121 or at supporterservices@livability.org.uk

Ethical screening and minimizing risks

As part of our Ethical Fundraising Policy and being an open and ethical fundraising charity, we will from time to time need to carry out due diligence on funders and companies. This is our legitimate interest to ensure the company or funder acts in accordance with our ethical policy and whether we would choose to accept or refuse a donation.

There may also be times where we need to carry out due diligence when a large gift or shares are donated to Livability and we may want to assure ourselves that the money for the gift has been obtained legally by the supporter and that it had been done in a way that does not conflict with our charity values.

It will therefore be necessary screen supporters to minimise the risk of associating ourselves with an individual or organisation that conflicts with the high standards we have set ourselves in our ethical policy.

Sensitive personal data

Data Protection law and the GDPR recognises that certain categories of personal information are more sensitive. This is known as sensitive personal data and covers health information, race, religious beliefs and political opinions.

We do not always collect ‘sensitive personal data’ about our supporters or the people that use our services, unless there is a clear reason for doing so. For example, with supporters participating in a fundraising event or initiative, we would need this information to ensure that we provide appropriate facilities or support to enable individuals to participate in the event.

We are a charity with an inclusive Christian ethos, working with people of all faiths and none. From time to time, we may seek to understand our audiences better by collecting information about religious affiliation.

Sharing your storySome of our supporters may choose to tell us about their health and care experiences relating to disability (for example, if you use our disability care services, call our charity, act as a case study for us, or volunteer to share your story).

Should supporters choose to share this information with us, we will always make it clear to you                   when we collect this information from you, what sensitive personal data we are collecting and what purposes we may use it for.

If we have the explicit and informed consent of the individuals, or their parent or guardian if they are under 18, this information may be made public by us at events, in materials promoting our campaigning and fundraising work, or in documents such as our annual report.

Children and young people under the age of 13

We are committed to protecting the privacy of the young people that engage with us through our disability care and education services.

Our fundraising events also request specific information about the age of participants.

If you are under 13 and would like to get involved, please ensure that you have consent from a parent or guardian before giving us your personal information. When we collect information about a child or young person aged under 13, we will make it very clear as to the reasons for collecting this information and how it will be used.

Please note that more information for students in our education centres and for parents, carers and governors is available in our Schools Privacy Notice.

Web site users

All Livability websites use cookies to help our websites work well and to track information about how people are using them.

All Livability websites collect personal information which may include:

• Details of your visits to our website and the resources that you access, including, but not limited to, traffic data, location data, weblog statistics and other communication data.
• Information that you provide by filling in forms on our website, such as when you make an enquiry about one of our services, or make a donation to us.
• Email addresses, postal and telephone information if you opt in to receive emails or other resources from us.
• Information provided to us when you communicate with us for any reason.

Third party links

You may find links to third party websites on our website. These websites should have their own privacy policies which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Use of cookies

Our website uses cookies to help provide you with the best online user experience we can. Cookies are small text files that are placed on your computer or electronic device when you browse a website. We use this information to provide you with a good experience when browsing our website and to improve the functionality of our site.

Our cookies help us:

• Make our website work as you would expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Personalise our site to you to help you get what you need faster
• Continuously improve our website for you

Non-exhaustive list of cookies

Google Analytics: This allows us to collect anonymous information about how visitors use the website. For example, information on which pages on the site have been visited, and the length of time spent on each page. This information enables us to improve the website for future visitors.
Session: Session cookies enable us to keep track of your movement from page to page so you do not get asked for the same information you have already given to the site. This allows you to proceed through many pages of a site quickly and easily without having to authenticate or reprocess each new area you visit.
CQC Widget: This cookie forms part of a widget provided by the Care Quality Commission, which is the independent regulator of all health and social care services in England. The widget displays the result of our service’s most recent CQC inspection and provides a link through to the record of the inspection on the regulator’s website.

Turning cookies off

You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our website.

Transfer of data internationally

We may transfer data that we collect from you to locations outside of the European Economic Area for processing and storing. By submitting your personal data, you agree to this transfer, storing or processing. We will take all reasonable steps to make sure that your data is treated securely and in agreement with this Privacy Policy.
Data that is provided to us is stored on our secure servers. Details relating to any transactions entered into on our site will be encrypted.

Tracking

We use multiple first and third party technologies such as pixel tags and web beacons to track and improve the user experience on our sites, quality of service and to monitor the effectiveness of campaigns and digital marketing activity.

We may use them to:

• See what website content is popular and how people are using the site as they allow us to track users movement through our websites. This type of information is amalgamated so that we can build up a picture of how the site is performing.
• Make sure we offer you a consistent service. For example, if we are testing new website content or we want to run a survey, we use tracking to remember what content you have seen or if you have already been asked to join the survey.
• In addition, when we email you, we may place a tag (also known as ‘tracking pixel’) on the email we send out. These let us monitor performance of our emails marketing activity.
• Form the basis of advertisement profile and retargeting as we seek to ensure any adverts displayed on our behalf are as relevant and interesting as possible to the people those adverts are displayed to.

Use of credit and debit card information

If you use your credit or debit card to donate to us, buy something 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: www.pcisecuritystandards.org/security_standards/index.php

Our donations are processed using a third party provider. They 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 we receive an email containing any credit or debit card details, it will be immediately deleted, no payment will be taken and you will be notified about this via a telephone call or letter. All purchases or donations should be completed through the donation page or on our web site (www.livability.org.uk/donate) or via our Supporter Services team (020 7452 2121).
Our legal basis for processing your data

Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679).

Consent

Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via, text or e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.

Legal Obligation

We are able to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner or Gambling Commission, or to use information we collect about you for due diligence or ethical screening purposes.

Performance of a contract / take steps at your request to prepare for entry into a contract

We are able to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying a product from us (for instance Livability Christmas Cards or, in some cases, an event place) or applying to work with us.

Please note that for more information on how we use and process your data when applying to work for Livability can be found in our HR privacy policy notice.

Vital Interests

We have a basis to use your personal information where it is necessary for us to protect life or health. For instance, if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.

Legitimate Interests

We may also process your data where we are furthering our legitimate aims and have assessed that the processing is not likely to be too intrusive, or to unduly infringe on your rights and freedoms. In legal terms, this is called the “legitimate interests” basis.

We have a duty to enable people with disabilities to live the life they want to lead: to promote ourselves and our work, to responsibly raise as much money as possible to further our charitable aims, to update our supporters and the general public on our progress, and to operate in an effective way. We always pursue these interests in a respectful manner and with the needs of our supporters as our top priority. We might further our legitimate interests in the following ways:

• To communicate with you about marketing and fundraising materials or products:
• To send you mail by post relating to activities that we think you may be interested in (unless you have told us you do not want this). We will always consider how much mail you receive from us, and what the topic is, to ensure that it is appropriate
• To contact you by telephone for fundraising or marketing purposes where you have provided us with your number. (If you have already told us that you prefer not to receive telephone calls from us, or are registered with the Telephone Preference Service then we will not call you).

To ensure that we understand our supporters and can contact them in a way that is relevant for them, and to make sure that we are using our marketing budgets effectively:

• To segment and analyse our data that we hold so that we can understand who our supporters are and contact them about specific activities. For example, to identify which supporters have previously participated in running events and to send them details of future running activities.
• To undertake research on potential high value supporters (as detailed in the Building profiles of supporters and targeting communications section above), to understand their philanthropic interests and ensure that we only contact people whose interests align with our aims and charitable activities.
To manage our everyday business needs:
• To work with third party suppliers, where we can make use of their expertise in a specialist field, or where they can provide services at a more cost-effective rate than we could manage internally.
• To update our database records to keep them accurate, for example, to amend an address when we receive returned mail.
• To process donations, gift aid declarations and match funding applications.
• To communicate with you in relation to administrative matters (for more information, please see further information on this in the Administrative communications section).
You have the right to object to us processing your data on the grounds of our legitimate interests in certain cases. If you would like us to stop using your data on this basis, please contact our Supporter Services team on 020 7452 2121 or at supporterservices@livability.org.uk

Administrative Communications

There are some administrative communications that we are required to send to you, which are not affected by how you have told us you would like us to contact you for marketing purposes.

Examples of these include (but are not limited to):

• Confirming the details of any direct debit that you set up with us, including your bank account and payment details
• Confirming where you have made a Gift Aid Declaration orally, so that we can give you the information on the tax implications of this

If we send you one of these messages, we will only use it to share the detail that we have to legally provide you with and will not use it for marketing purposes.

How we work with third parties in processing your personal data

At Livability, we sometimes work with third parties. It’s important that you understand the circumstances where this might happen and who we work with.

We never sell or swap your details with any other organisation for their marketing purposes. We will always ensure that contracted third parties comply strictly with our instructions and in accordance with data protection laws. We will also make sure that appropriate controls are in place when third parties are handling your data and will regularly monitor their activities to ensure data compliance needs are met.

These are some examples of how we work with third parties:

• Where we sign a contract with a third party supplier to carry out services for us. These contracts will always hold a supplier to our own high standards of data protection to ensure that they treat your information with the same care as we do.
• Where you register to take part in an event (such as a marathon) and we have to provide your details to the event organiser to secure your place.
• Where a company sends us data because you have given permission for them to share it, for example, where you set up an online giving fundraising page, sign up for an event via a third party or register with the Telephone or Fundraising Preference Services.
• Where we use companies who can help us to enhance the information that we hold about you, for example, to help us to understand which parliamentary constituency you fall into, the size and composition of your household, or the demographic of people living in your postcode area.
• Where we legally have to share information. For example, if you make a Gift Aid declaration to enable us to claim Gift Aid on donations that you make, we have to share your name and address with HMRC so that they can audit our claim.

Third party suppliers

We may use companies to provide services and process your personal data on our behalf, where they have a specific expertise or can offer the most cost-effective solution for us. Some of the activities that third party companies carry out for us are:

• Packing and delivering postal mail
• Making telephone calls to our supporters
• Signing up new supporters for us over the phone, through door to door, street or private site campaigns
• Sending emails
• Processing credit card payments

Whenever we work with a company in this way, we will always have a contract with them, to be certain that they treat your data with the same level of care and respect as we do. We will only send them the data that they need to carry out their specific service and they are required to delete it or return it to us once they have completed this. Your data will only ever be passed to them for the services that they carry out on our behalf and will not be shared for their marketing purposes. Event organisers
Some events require us to pass your personal information to the event organisers to secure your place.

Event companies we currently work with in this way are:

• TCS London Marathon: London Marathon Events Limited
• Rourke Cycles: PVS Event Limited
• The Great Run Company
• Cycle Classic Tours

Third parties who send us data

Some third party organisations collect data on our behalf and share it with us in accordance with their policies and procedures for data protection compliance. Some of these organisations are Data Management companies, which we use to ensure that data you have provided us with is up to date. We do not use this to add new contact data; so if we already have your address, we may update this, but if we do not have your telephone number we will not use one of these companies to find and record it. Whenever you give your data to any organisation, you should always make yourself aware of their Data Protection and Privacy Policies.

Here are some examples of organisations we currently receive this information from:

• Online Giving Providers: JustGiving, Enthuse, MemoryGiving, CAF, Stewardship
• Event Companies: Event Brite,
• Payroll Giving Agencies: CAF payroll, Charities Trust payroll, Charitable Giving payroll
• Data Management Services: Telephone Preference Service, Fundraising Preference Service, National Change of Address Register (managed by Royal Mail), Mortascreen

Companies who provide us with additional information

Understanding our supporters helps us to provide you with a personalized experience and makes sure that we use our marketing budgets in the most efficient way. We may collect the following additional information about our supporters:

• Information on the size and composition of your household
• Information on your financial ability to support us
• Your parliamentary constituency
• Information about your interests and hobbies
• The age band that you fall into

If you do not wish for Livability to use your data in this way, please contact our Supporter Services team on 020 7452 2121 or at supporterservices@livability.org.uk

Where we have a legal requirement

We will always share data where we have a legal requirement to do so. Examples of this include providing audit information to HMRC for our Gift Aid claims or if we are required to do so by law enforcement officials. If we were to merge with another charity or restructure, we may also share your personal details with other entities involved in the merger/restructure for that purpose.

Human Resources

What information do we collect and how?

Livability collects a range of information from you during the recruitment process. This includes:

• your name, address and contact details, including email address and telephone number;
• details of your education and qualifications, skills, experience and employment history;
• information from interviews and phone-screenings you may have;
• information about your current level of remuneration, including benefit entitlements;
• information about your entitlement to work in the UK; and
• equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.

We may collect this information in a variety of ways. For example, data might be contained in paper application forms, our online application system, or CVs (including when these are sent to us as part of speculative applications or queries), obtained from your passport or other identity documents, or collected through interviews or other methods of assessment.
We may also collect personal data about you from third parties, such as references supplied by former employers. We will take your consent before contacting your referees.

How do we store your data?

We use a range of tools and third party suppliers to store your information, including your online application record, HR Management systems and our email system. In all cases we work to ensure that the measures we take and suppliers used are GDPR compliant. We are working to ensure, where we can, that we do not keep paper copies of information and only scan and store information electronically, however in some circumstances, particularly under our statutory requirements, we will need to have available paper copies of documents and ensure these are stored securely.

Why do we need to process your personal data?

Livability has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. We collect and use your personal data for legitimate human resources and business management reasons including:

• identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
• DBS checks;
• recordkeeping in relation to recruiting and hiring;
• ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;
• conducting criminal history checks and health checks as permitted by applicable law;
• protecting our legal rights to the extent authorised or permitted by law; for example, check a successful applicant’s eligibility to work in the UK before employment starts; or
• emergency situations where the health or safety of one or more individuals may be endangered.

Livability may process information about whether or not applicants are disabled so we can make reasonable adjustments for candidates who have a disability. Where we process other special categories of data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is for equal opportunities monitoring purposes. Our processing of these types of data will be carried out to ensure you or us can meet our obligations or exercise our rights under law related to employment or (only where applicable) to enable us to establish, exercise or defend legal claims.

We will not use your data for any purpose other than the recruitment process of which we will take consent either prior to or after you formally apply for a job opportunity.

Who has access to data?

Your information may be shared internally within the company for the purposes of the recruitment process. This includes members of the HR team, interviewers involved in the recruitment process, and managers in the business area with a vacancy. If you are applying for a senior management position with us, we may share your data with our board of directors and trustees.

We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our contractual duties to you.

We may transfer information about you to other group companies for purposes connected with your employment or the management of the company’s business. Third parties we may disclose or transfer your information to include:

• Local Authorities in the event of a safeguarding incident involving you and a person that uses Livability’s services
• The Disclosure and Barring Service in order to process your criminal record check or in the event of areferral
• Occupational Health agency in order to process health checks
• The Home Office (UK Immigration Department) should we need to verify limited leave to remain in the United Kingdom
• On any legal request for your information (e.g. Child Support Agency)
• To request or respond to reference from previous employers or prospective employers

How do we protect your data?

We take appropriate technical and organisational measures against unlawful or unauthorised processing of personal data and accidental loss or destruction or damage to personal data. We make sure that your data is only accessed by authorised personnel only, including third party service providers, in the proper performance of their duties and to treat this information as confidential.

For how long do we keep your data?

If your application is unsuccessful, we will hold your data in file for 12 months. After this period you will receive a system generated email to either allow us to continue to keep your personal data or delete it from our system. In the event we do not receive your response your personal data will be deleted from our systems.

If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which employee data is held will be provided to you in a separate privacy notice.

Children and young people – Under 13

We are committed to protecting the privacy of the young people that engage with us through our disability care and education services.
Our fundraising events also request specific information about the age of participants.

If you are under 13 and would like to get involved, please ensure that you have consent from a parent or guardian before giving us your personal information. When we collect information about a child or young person aged under 13 we will make it very clear as to the reasons for collecting this information and how it will be used.

Note that: More information for students in our education centres and for parents, carers and governors is available in our Schools Privacy Notices.

Web site – offensive behaviours

If you post or send any content on Livability digital channels that we believe to be inappropriate, offensive or in breach of any laws, such as defamatory content on our social media pages, we may use your personal information to inform relevant third parties such as your internet provider or law enforcement agencies.

Breach notifications

The security of your data is important to us. If in the circumstances of a data breach, we will report this to the ICO within 72 hours of the Organisation becoming aware of it if appropriate.

If the breach is sufficiently serious to warrant notification to the public, the charity will do so without undue delay.

How we keep your information secure

Livability takes the care of your data very seriously and we use a combination of organisational and technological security measures to protect your personal information to the highest possible standards. This includes the use of secure servers, firewalls, virus & malware protection, secure socket layer (SSL) encryption and secure file transfer protocol for our work with third parties. We follow payment card industry (PCI) security compliance guidelines when processing credit card payments.

You can find our more information about PCI DSS here: www.pcisecuritystandards.org

Our donations are processed using a third party provider. They 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 or redacted once the payment or donation has been processed. Only staff authorised and trained to process payments will be able to see limited card details belonging to you.

If we receive an email containing any credit or debit card details, it will be immediately deleted, no payment will be taken and you will be notified about this via a telephone call or letter. All purchases or donations should be completed through the donation page or on our web site – www.livability.org.uk/donate – or via our Supporter Services team on 020 7452 2121.
We make sure that only staff who need to access your personal data can do so. Any member of our staff who has access to your personal data is given training to make sure that they understand the importance of keeping your information safe and secure at all times.

Keeping your information up to date

We may use information from external sources such as the post office national change of address database and/or the public electoral roll to identify when we think you have changed address so that we can update our records and stay in touch.

We do this so we can continue to contact you where you have chosen to receive marketing messages from us and contact you if we need to make you aware of changes to our terms or assist you with problems with donations.

This activity also prevents us from having duplicate records and out of date preferences, so that we don’t contact you when you’ve asked us not to.

We’re committed to putting you in control of your data and you can edit your Livability account information, including your address and contact details and change any of your contact preferences at any time (including telling us that you don’t want us to contact you for marketing purposes by telephone or by post) via our website www.livability.org.uk/changepreferences or via our Supporter Services team on 020 7452 2121.

Privacy assessments

Livability will always assess and plan for how personal data and processing will be managed when new projects are being developed. This will occur when the charity is thinking about using a new tool or service with which to process data for example.

Your right to access personal information

Under the GDPR you have a right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
Should you wish to exercise these rights, we promise to respond. There will be no charge for this action.

Please address requests to the Data Protection Officer and we will respond within 30 days of receipt of your written or verbal request. Please contact our Data Protection Officer at Livability Head Office or email dataprotection@livability.org.uk

Please provide as much information as possible about the nature of your contact with us to help us locate your records.

Should you request a copy of the data we hold on you, we will:

• Give you a description of the data we hold
• Tell you why we are holding and using it, and how long we will keep it for
• Explain where we got it from, if not from you directly
• Let you know if we are using your data to make any automated decisions (decisions being taken by a computer or a machine, rather than by a person)
• Give you a copy of the information in an intelligible form

Where you have provided your consent for our use of your personal information, you always have a right to withdraw your consent at any time.

Please note that more information for students in our education centres and for parents, carers and governors is available in our Schools Privacy Notices.

How to control the marketing that we send you

We want to make sure that we keep in touch with you when and how you want. Every marketing communication that we send will outline how you can update us on your preferences and all of our emails have an Unsubscribe link.

You are also always welcome to get in touch with our Supporter Services Team in any of the following ways:
Email: supporterservices@livability.org.uk
Telephone: 020 7452 2121
Post: Livability, Coburg House, 1 Coburg Street, Gateshead, NE8 1NP

We will ensure that our records are updated as soon as possible once we receive your instructions. For our postal communications, it can take up to 21 days for any change to take full effect because of the production times for our appeals, but in most cases we would expect the change to be effective much more quickly. If you do receive any mail within this 21 day window, please accept our apologies and recycle it.

Breach notifications

The security of your data is important to us. If in the circumstances of a data breach, we will report this to the ICO within 72 hours of the charity becoming aware of it if appropriate.
If the breach is sufficiently serious to warrant notification to the public, the charity will do without undue delay.

Privacy assessments

Livability will always assess and plan for how personal data and processing will be managed when new projects are being developed. This will occur when the charity is considering utilising a new tool or service with which to process data for example.

Complaints

If you are not satisfied with our work or something that we have done or failed to do, we want to know about it. We also welcome your views on what we do well. Your comments enable us as a charity to learn and continuously improve our services.

Please find further information about giving us feedback or lodging a complaint by visiting www.livability.org.uk/contact-us/complaints/

You have the right to lodge a complaint with a supervisory authority in accordance with Article 13, paragraph 2 (d), GDPR, and Article 14, paragraph 2 (e), GDPR. – If we are unable to deal with your complaint in a satisfactory manner, you have the right to complain to a relevant supervisory authority such as:

• The Information Commission Office (ICO): Wycliffe House, Water Lane Wilmslow, SK9 5AF, or call 0303 123 1113 or online at www.ico.org.uk/make-a-complaint
• Advertising Standards Authority (ASA): call 020 7492 2222 or online at www.asa.org.uk/make-a-complaint.html

Changes to this policy

From time to time, we may make changes to this Policy and you will always be able to see here when it was last updated. If we make significant changes, such as in how or why we process your personal data, we will also publicise these changes on our website or may contact you directly with more information.

Please do revisit this policy each time you consider giving your personal data to Livability.

The last significant changes to this policy were in July 2022.

Contacting us

We welcome any queries, comments or requests you may have regarding this Privacy Policy and any other relevant policies.

Please do not hesitate to contact us by using the following contact details.

For our Supporter Services Team, please call 020 7452 2121 or email the team at supporterservices@livability.org.uk. You can write to the team at: Livability, Coburg House, 1 Coburg Street, Gateshead, NE8 1NP

Livability also has a Data Protection Officer who can be contacted at dataprotection@livability.org.uk. You can write to our Data Protection Officer by addressing correspondence to Livability Head Office