At Sustain, we’re committed to protecting and respecting your privacy
This Policy sets out our data collection and processing practices, the conditions under which we may disclose it, and your options regarding the ways in which your personal information is used.
We may update this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, you’re agreeing to be bound by this Policy.
Any questions regarding this Policy and our privacy practices should be sent by email to email@example.com or by writing to: Sustain, The Green House, 244-254 Cambridge Heath Road, London E2 9DA.
The Policy refers to all of the websites that Sustain runs, currently: sustainweb.org bigdig.org.uk capitalgrowth.org rootstowork.org sugarsmartuk.org and childrenshealthfund.org.uk. It also covers any email and contact lists held by Sustain and by our projects and campaigns, shown at: www.sustainweb.org/projectsandcampaigns.
Our data protection lead is Head of Digital, Gavin Dupee.
This policy was last updated in May 2019.
- Data protection
- When do we collect information about you?
- What type of information is collected from you?
- For what purposes do we collect information about you?
- On what lawful grounds do we process your personal information?
- Do we store your financial details?
- Do we collect data about children?
- How long will we keep your data?
- Is your personal information secure and who can access it?
- What are your rights?
- Does this policy cover third party websites?
- Where can you update your information?
- Where can you find further information?
We will never share your information with another organisation for their own marketing purposes and we will never sell your information for any reason whatsoever.
As you use our website, get in touch with us, or take part in our campaigns and activities, we collect information. Some of this information will be anonymous such as which pages you visit on our websites, and some will contain your personal information such as when you join a campaign or project email list. Be assured that we will always endeavour to be clear, honest and transparent with you about the information we collect, and wherever practical will ask your specific consent.
When you give it to us directly via a website form, email, phone, letter, sign-up sheet or in person.
You may give us your personal data when you join an email list, download a publication, appear on an online map, directory, or calendar, when you donate money to us, or when you add your details to a list at an event. Also when you apply for employment with us, or apply to volunteer, or contact us in another way.
When you visit our website
Typically we will ask for your name, email address and other contact details. Additionally we will collect or request other information where it is appropriate to do so, for example:
- The email list(s) that you have subscribed to
- The publications that you have downloaded
- The location of your organisation/business and services you offer
- Details of your event(s)
- Your job title or profession, if relevant to our work, e.g. journalist
We will also collect anonymous information about your computer and your visits to our website including your IP address, geographical location, browser type, referral source, length of visit and number of page views. We will not link this to you individually. Such information helps inform us about our website and digital communications development.
In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so; and will only do so with your explicit consent.
If you attend a Sustain event it is possible that your photograph may be taken. If you object to a photograph of you being reproduced, please let us know.
If you have made a donation to Sustain and agree to Gift Aid that donation, we must record the fact that you are a UK tax payer and we have to maintain a record of the amount of Gift Aid we have collected.
The overview below summarises the different reasons why we may collect and use your data. We may not use your personal information for all of these purposes, it will depend on the nature of your relationship with us, and how you interact with Sustain:
- Campaigning, promotion and fundraising: Our main communications are to update you on the latest developments of our projects and campaigns and we may invite you to participate in activities such as events, competitions, polls, surveys and actions. The vast majority of our promotional activities are focused on promoting the aims and objectives of Sustain’s projects and campaigns. Occasionally we will also ask for donations (and if you are willing and able to Gift Aid them so that we can increase the value of donations by reclaiming tax), promote crowdfunding or offer items for sale, to support particular objectives or activities. We might ask you for feedback on, for example, an event you have attended or a publication you have downloaded; and we might tell you about other events or publications that we think might be of interest to you. In general these communications will be by email, but may also be e.g. via online and other digital forums, by phone, by post or in person at events.
- Delivery of core charitable services: Delivery of our core charitable activities may require the recording of our beneficiaries' contact details, their eligibility for our charitable services, records of financial transactions and communications.
- Retail trading: Sustain regularly holds ticketed events and training workshops, and occasionally sells products. In general we use outside parties to facilitate the sale of tickets (e.g. Eventbrite) and merchandise (e.g. PayPal). If you attend an event, we may store your personal information to invite you to similar events in future. Sustain also runs a number of networks that require an annual subscription payment. Sustain will store members’ personal information and the period of their membership. Note that Sustain never stores personal financial information, except for some personal financial information of employees to enable, for example, salary and pension payments.
- Analysis and tailoring of communications: We will make use of the information you have given us and your interactions with our services, to help us understand your interests and may tailor and personalise our communications to you.
- Profiling: Very occasionally we may combine the personal information you have given us with information available in the public domain to create a profile of your interests and preferences where they are relevant to us. We may gather this information from publicly available sources such as Companies House, the electoral register and the media. You can opt-out of your personal information being used for profiling or analysis by contacting: firstname.lastname@example.org.
- Volunteering for Sustain: If you volunteer with us we may need to use your personal information to manage your volunteering activities, deliver training, update you on our projects and campaigns and to ensure your safety. This may include sending you invitations to events, information about our work and requests to feedback on your experience volunteering with us.
- Staff administration: We process the personal information of our employees for recruitment, staff administration, remuneration, pensions and performance management purposes.
- Information is processed on the basis of an individual’s consent.
- Information is processed in line with a contractual relationship.
- Information is processed on the basis of legitimate interest.
We may also share your personal information when we are compelled to do so by a legal authority acting in compliance with the law.
We will only send promotional material by email to those who have given consent, usually to send you updates on our projects and campaigns. Occasionally, for some of our projects, our promotional material may – for example – invite you to an event, ask for a donation, provide information about crowdfunding or promote items for sale.
Where you give us consent to process your data we will always keep a clear record of how and when this consent was obtained. You can withdraw your consent at any time, or request that all your personal data be deleted by emailing: email@example.com.
Most interactions with our supporters and beneficiaries are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you apply for employment or to volunteer with us.
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights). We will always work to these principles to process your personal data, including on the unusual occasion when it is not practical or appropriate to ask for explicit consent.
What are Sustain’s legitimate interests?
- Delivery of our charitable purpose: to advocate food and agriculture policies and practices that enhance the health and welfare of people and animals, improve the working and living environment, enrich society and culture and promote equity.
- Reporting criminal acts and compliance with the legal instructions of law enforcement agencies.
- Internal and external audit for financial or regulatory compliance purpose.
- Reporting to our funders and statutory bodies.
Publicity and income generation:
- Conventional direct marketing by post, email and other forms or marketing, publicity or advertisement.
- Unsolicited commercial or non-commercial messages, including campaigns, income generation or charitable fundraising.
- Personalisation to tailor and enhance the supporter experience in our digital and postal communications.
- Exercise of the right to freedom of expression or information.
- Analysis and tailoring of communications to develop fundraising strategy and improve communications.
- Processing for research purposes.
- Understanding better our beneficiaries and supporters, including the use of publicly available information.
- Employee and volunteer recording and monitoring for recruitment, safety, performance management or workforce planning purposes.
- Provision and administration of staff benefits such as pensions.
- Physical security, IT and network security.
- Maintenance of ‘do not contact’ lists.
- Processing for historical, research or statistical purposes.
Financial management and control
- Processing of financial transactions and maintaining financial controls (noting that we do not hold personal financial information, except for some personal financial information of employees to enable, for example, salary and pension payments).
- Prevention of fraud, misuse of services, or money laundering.
- Enforcement of legal claims.
Purely administrative purposes:
- Responding to enquiries.
- Delivery of requested products, resources or information.
- Administration of financial transactions.
- Administration of Gift Aid.
- Providing 'thank you' communications and receipts.
- Maintaining 'do not contact' lists.
When we use your personal information, we will always consider if it is fair and balanced to do so and whether it would be within your reasonable expectations that we would use your data in this way.
We will balance your rights and our legitimate interests to ensure that the way in which we use your data never goes beyond what you would expect and is not unduly intrusive or unfair.
Sustain uses PayPal to process all online financial transactions. We will transfer selected personal data to PayPal – normally your name and email address – that is necessary for the processing of payments. We will never store your personal financial details. The only exception is if you are a Sustain employee – and then only for specific purposes such as payment of salary and pension.
Our website and other communications are targeted at persons over the age of 16. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data. In exceptional circumstances we may store the name and limited personal information about a child under the age of 16, for example to identify them in a photograph or to fulfil our safeguarding and health and safety obligations. We will treat such limited information with all due care and respect and in line with our relevant policies and procedures covering such circumstances.
Unless still required in connection with the purpose(s) for which it was collected – such as for a campaign or project email newsletter list - we will usually remove your personal information from our records ten years after the date it was collected. However, if you or your organisation works with Sustain, or you are linked to a Sustain member organisation, we may keep your personal information on record for longer. This exception usually applies to journalists, policy-makers, researchers, industry contacts and people working in the not-for-profit sector.
If you ask us to stop sending you emails or other forms of communication, we will keep your name on our internal suppression list (a ‘do not contact’ list) to ensure that you are not contacted again.
If you exercise your ‘right of erasure’, we will remove your personal information completely and immediately.
We will only ever publish or share your data with your clear and informed consent.
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure of or access to your personal information.
Your information is only accessible by appropriately trained staff and volunteers, who agree to abide by this policy.
Occasionally we use external service providers to process data on our behalf – such as sending address details to a mailing house to post magazines, or to email broadcast services who will send out our campaign and project updates on our behalf.
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to be unsubscribed from our email list at any time. You also have the following rights:
- Right to be informed – you have the right to be told how your personal information will be used.
- Right of access – you can ask what information we hold on you and to request a copy.
- Right of erasure – you can request that all your personal information is deleted from our records.
- Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
- Right to restrict processing – you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
- Right to data portability – you may ask us to provide your information to you – or another service provider – in a machine-readable format.
To make a complaint about the way we have processed your data to the Information Commissioner’s Office (“ICO”) please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us/.
No, this Policy does not cover external websites and services that we link to and we are not responsible for the privacy practices or content of those sites or services.
Generally you can check the personal data we hold about you, and update it at www.sustainweb.org/email/. Some of our other sites, such as Roots to Work, Capital Growth and Sugar Smart have site-specific dashboards where you can view and update your information.
For further information please email firstname.lastname@example.org or write to:
Sustain, The Green House, 244-254 Cambridge Heath Road, London E2 9DA