Canine Partners takes your privacy seriously. We are committed to protecting your personal information. This policy sets out how Canine Partners uses the information that you provide us with in order to help further our work in providing amazing assistance dogs to help transform the lives of people with physical disabilities.
Your personal information
We will treat your personal details with care. We will not sell your data to any third parties, but we may sometimes share your information with trusted service providers and selected partners who fundraise or work on our behalf. We ensure that any third parties with access to your data are held to strict standards for data use and security.
Who we are
By Canine Partners (the data controller) we mean Canine Partners for Independence (registered Charity number 803680 and SC039050). Our Data Protection Compliance Officer can be contacted on 01730.716.000
Your Information – what we collect and how we use it
Canine Partners collects information from the public in a number of different ways. For example, we ask for contact and other information when members of the public rehome a dog, sign up one of our dog sponsorship schemes or engage with one of our campaigns. This may include information such as your name, date of birth and contact information. We use this information to help us provide and improve our services as a Charity and to keep a record of our communications with you.
If you are a financial supporter of Canine Partners, by sponsoring a dog or donating to us we will ask for information that enables us to administer your donation. This will normally include information such as your name, contact details such as address, email or telephone number and your payment details and Gift Aid status.
In order to ensure that our communication with you is relevant and tailored to your background and interests, we may supplement what we know about you with information that is available to the public. This allows us to better understand your interests, preferences, and level of potential engagement and/or donation, so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications.
We only use reputable sources, where someone would expect their information may be read by the public. We avoid any data that we believe has not been lawfully or ethically obtained, and we do not use information sources which have not been broadcast or made public.
What the Law says about protection of personal information
The Law on Data Protection is derived from various pieces of legislation. These include the General Data Protection Regulation (GDPR) which comes into force in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities such as collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal reasons under which personal information can be processed or used in a lawful way. For the processing to be permitted by law, at least one of the legal grounds must apply.
The five legal grounds that are most relevant to Canine Partners’ use of your personal information are:
- Legitimate Interest
- Legal Obligation
- Vital Interests
How the law applies to Canine Partners’ use of personal information
Canine Partners will only process or use your personal information if we have:
- asked you and have a record of your express and recent consent for us to do so, or
- a ‘legitimate interest’ to do so in order to support our charitable purposes. Our use will be fair and balanced and never unduly have an impact on your rights, or
- a contract with you that we can only fulfil by using your personal information, for example to send you an item that you have requested, or
- a legal obligation to use or disclose information about you, for example we are required by law to keep records of gifts that are given to us with Gift Aid for 4 years, or
- in extreme situations, such as an accident or medical emergency, we may share your personal details with the emergency services if it is essential for the preservation of life (yours or another person’) for us to do so. This is the ‘vital interest’ ground for using your personal information. After the emergency, we will always try to inform you about how we had to use your information in that extreme situation.
We will not unduly prioritise our interests as a Charity over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.
Canine Partners will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities.
Canine Partners will always ask for your consent before we communicate with you for certain purposes. For example, we will only email or send a text message about our fundraising activities if we have a record of your consent to do so.
You can withdraw your consent at any time by visiting our Communications Preference Centre on our website: www.caninepartners.org.uk/keepintouch or calling us on 01730 716010.
There are times when it is not practical to obtain consent. At those times, we will only process personal information if that processing would meet another legal ground, for example legitimate interests, in which case we would only use your data in accordance with the law’s strict rules on legitimate interest.
What is Legitimate Interest
This means that organisations can process your personal information if they:
- i) have a genuine and legitimate reason for doing so and
- ii) use it in a way that does not harm any of your rights and interests as an individual.
Canine Partners’ Legitimate Interest
We do not unduly prioritise our legitimate business interests as a Charity over your interests as an individual. We always respect your rights. We carry out a balancing exercise of the rights of the Charity with the rights of our supporters.
We believe that the best way to look after the interests of our supporters is to consider their unique interests and expectations. As a result, we have established the following categories of a Canine Partners supporter. This provides us with an additional method for assessing your personal information in a way that matches your relationship with us; your interests; and your expectations about your rights.
The six groups that we use for our assessments are, supporters that have:
- informed us of a legacy pledge
- rehomed a dog with us
- a canine partner or have applied for a canine partner
- a volunteering arrangement with us
- provided financial donations
- demonstrated an interest in our cause by contacting us for more information, for example to find out more about one of our products, services or campaigns.
What we have a Legitimate Interest to do
We believe that Canine Partners supporters are connected to our mission and want to know how they can continue to help us to achieve our charitable aims. Unless you tell us not to, we think you are content for us to process (keep and use) your personal information for the following lengths of time. As of May 2018, we promise not to keep your personal information for longer than necessary.
- i) Lifetime Interest in Canine Partners
For supporters who have pledged to leave us a gift in your will – we will keep your information to ensure that your wishes are fulfilled.
- ii) Canine Partners Rehome
These are supporters that have rehomed a withdrawn canine partner. We think that you and the dog you rehomed from us would like to remain in contact with us throughout their lifetime and we will therefore keep your personal information to allow for this.
iii) Have a canine partner or have applied for a canine partner By providing us with your personal data, including sensitive personal data such as on your health, you consent to the collection and use of this information in accordance with the purposes described above and this privacy statement, and you agree to allow us to share your details with other organisations
- iv) Have a volunteering arrangement with us
- v) Financial Supporters of Canine Partners
These are supporters that help or have helped us by providing financial support to us.
- vi) Demonstrated an interest in Canine Partners via an enquiry
These are supporters of our mission, who have demonstrated an interest in our cause by contacting us for more information, for example to find out more about one of our products, services or campaigns. We think someone that has reached out to us to find out more about Canine Partners and what we do, would like us to provide that information; perhaps a little more information; and even some support in fulfilling their initial query or request.
Supporters demonstrate their support in a number of ways and so could be in more than one, or even all, of the above categories. We will review and refresh these categories and the timescales on a rolling basis to ensure that as times and needs change we continue to do the very best by our supporters.
Legitimate Interest to send you direct marketing
From time to time, we would like to get in touch with updates about our work, products, and services and how you can support us.. Unless you tell us not to, we will rely on our legitimate interest to contact you by post or phone. We are committed to ensuring that we our contact with you is reasonable, fair and balanced and we may analyse your personal data, patterns of support or giving or other information you have provided us, in order to tailor the content or frequency of our communications to ensure they remain interesting and relevant to you. (See Data Analysis, below). You can update your preferences at any time by visiting our Communications Preference Centre on our website, www.caninepartners.org.uk/keepintouch or calling us on 01730 716010.
Legitimate Interest to process your information
We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.
When it is necessary we will contact you for administrative purposes, for example to contact you regarding a payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.
To help you to understand when and why Canine Partners would use Legitimate Interest to process your personal information we provide the following examples:
- To send postal communications (as explained above);
- To enhance, modify, personalise and improve our services and communications for the benefit of our supporters;
- To improve security of our websites and systems;
- To prevent fraud when transacting on our website;
- To process your donations;
- To fulfil online transactions, process and deliver your order(s). In order to take payment and arrange delivery, we need to collect personal information, including your payment details, your full name, delivery address and contact details;
- To analyse your personal information to ensure that our communications are relevant to you.
The above examples are on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop. You can do this by calling us on 01730 716010.
Data accuracy, profiling and analysis
In order to communicate with you more effectively, better understand your preferences and ability to support our work, we may update, profile or analyse the personal data we hold about you.
To maintain data accuracy, reduce costs and wastage and ensure we are able to communicate with you, from time to time we will update your personal information from publicly available external sources, for example; updates to address and contact information
We like to find out about your personal motivation for supporting Canine Partners and your experiences as a supporter. This helps us to give you the information about products and services most relevant to you. In some instances, we may carry out research or analysis of the personal information that you have provided to us, including your preferences & interests, your patterns of support, your geographic location, and potential future level of support. We may add publicly available information (such as public records) and we may use your information in an aggregated format to help us understand the profile of supporters, like you so that we can target our communications more effectively and use our resources cost effectively. Data Aggregation is any process in which information is gathered and expressed in a summary form, for purposes such as statistical analysis.
Canine Partners use information that is already in the public domain (information that has been published in print or online) to identify individuals who may be interested in supporting our work with a major gift. These publicly available sources of information include Companies House, the electoral register, the Charity Commission’s Register of Charities, Who’s Who, LinkedIn, company annual reports and articles in newspapers and magazines.
Canine Partners does not use publicly available sources which we consider would be intrusive such as Facebook, Twitter, JustGiving, the Land Registry, or websites similar to this sample.
Canine Partners uses information that is already in the public domain (information that has been published in print or online) to identify individuals who may be known to our existing major donors and so may wish to support our work with a major gift.
Canine Partners may also use wealth-screening techniques to identify high net worth individuals on our supporter database. These techniques are based on both publicly available information and information our supporters have given us voluntarily (e.g. where they live, who they bank with, what their occupation is).
You have the right to object to your data being processed in this way. If you wish to opt out of being identified as a potential major donor, please contact our Fundraising Team.
To help us communicate the work we are doing and provide these services we use trusted service providers such as mailing houses to fulfil the posting of marketing materials.
Canine Partners does not share, sell or swap your information with other organisations for their own marketing purposes.
In some circumstances it is necessary for Canine Partners to give relevant staff at our service providers’ access to your personal information. This access is only granted to the extent necessary for them to perform their services for us. We require all service providers to comply with strict rules to protect the information you have given us.
All information you give to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Changes to your data
From time to time we may contact you to ensure that the information you have provided us with remains accurate and up to date. In some circumstances we may use external data lists to avoid misdirecting our communications with you, this includes FPS and TPS.
Should you wish to change your preferences you can do this by writing to us at Canine Partners, Ashby Road, Osgathorpe, Loughborough, Leicestershire, LE12 9SR by visiting our Communications Preference Centre on our website, www.caninepartners.org.uk/keepintouch or calling us on 01730 716010.
We comply with requests for the disclosure of personal information where this is required or permitted by law. This could include requests from law enforcement or tax agencies. In these circumstances, the request must be submitted in writing and in accordance with the relevant legal requirements.
If you believe your privacy rights have been violated, you may file a complaint with us or with the Information Commissioners office https://ico.org.uk/
Cookies and Web Privacy
Canine Partners guarantees our commitment to respecting and protecting your online privacy.
This includes your need and your right to know what we do with the personal information you share with us. It also guides our Charity’s policies regarding the management of this data, including how the information is collected, processed, and for what purposes.
The collection of information
Every time you log on to our website your IP (Internet Protocol) address registers on our servers. Your IP address reveals no information other than the number assigned to you. We do not use this technology to get any personal data against your knowledge or free will (i.e. automatically recording e-mail addresses of visitors). Nor do we use it for any purpose other than to help us monitor traffic on our website or to cooperate with law enforcement (in case of criminal activity or misuse of our information).
By using our website, our social media pages (such as Facebook, Twitter, YouTube, and Instagram), subscribing to our services, or donating to us you agree that, unless you have set your computer’s browser to reject them, we can place cookies on your device and use that data in accordance with this policy.
Some emails that we send you have no tracking in at all for, example service emails with invoices attached. Other emails we send we can track, at an individual level, whether the user has opened and clicked on the email. We do not use this information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of our emails which you can do via the unsubscribe link at the bottom of every email we send.
Financial transactions made online to Canine Partners using this site are secure. No one can access your credit card details via the internet.
How our website works
When you have completed your donation or sponsorship, your web browser will be connected directly to our secure server. You can see that the connection is secure by looking at the padlock or key icon in the bottom left hand corner of your browser. Your browser may also alert you to the fact that you are connecting to a secure server, and if so, it will also tell you when you are closing the secure connection once you have donated. This is for your information only.
Our secure server communicates with your browser using SSL (Secure Sockets Layer) protocols, so that all your personal information, including credit card number and your name and address, is encrypted. This process takes the words and figures you enter, and converts them into bits of code that are then securely transmitted over the internet.
All information given on this site is to the best of our ability.
You may print any factsheet on this site for your own information but you may NOT sell it, reproduce it on the Internet, distribute it, alter it, or reprint it in any publication without permission from Canine Partners.
Please note that all material on this website is the copyright of Canine Partners or third parties. You may print any Canine Partners factsheet on this site provided all material is marked “By kind permission of Canine Partners” and the material cannot be adapted for use in any other publication, used for profit or used in any way that will bring the Charity into disrepute.
The name and logo of Canine Partners are registered Trade Marks. Any use of these Trade Marks must be made with the prior express permission of Canine Partners. If you are unsure what material you can or cannot use please contact Canine Partners.
All photography on this site is reproduced with kind permission of the photographers concerned.
What to do if you are not happy
In the first instance, please talk to us directly so we can help resolve any problem or query. Contact Fundraising@caninepartners.org.uk or call us on 01730 716010.
You can register with the fundraising preference service (FPS). This service is run by the Fundraising Regulator and allows you to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at www.fundraisingpreference.org.uk or by calling 0300 303 3517. Once you have made a request through the FPS, your new preferences take effect within 28 days.
You have the right to contact the Information Commissioners Office (ICO) if you have any concerns about Data Protection using their help line 0303 123 1113 or at www.ico.org.uk
From time to time, we will make changes to the information on this page. The amended information will apply from the date it is posted on the site and will govern the way in which we collect and use personal information from then on.
Page last updated 23-01-2019
Job applicant privacy notice
The Charity is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that we collect and hold on you as a job applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
Data controller details
The Charity is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Canine Partners, Ashby Road, Osgathorpe, Loughborough, Leicestershire, LE12 9SR
Data protection principles
In relation to your personal data, we will:
- process it fairly, lawfully and in a clear, transparent way
- collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you
- only use it in the way that we have told you about
- ensure it is correct and up to date
- keep your data for only as long as we need it
- process it in a way that ensures it will not be used for anything that you are not aware of or have not consented to (as appropriate)
- process it in a way that ensures it will not be lost or destroyed
Definition of data processing
Processing covers a wide range of operations performed on personal data, including by manual or automated means. It includes the collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data.
The General Data Protection Regulation (GDPR) applies to the processing of personal data wholly or partly by automated means as well as to non-automated processing, if it is part of a structured filing system.
Types of data we process
We hold many types of data about you, including:
- your personal details including your name, address, date of birth, email address, phone numbers
- your photograph
- marital status
- whether or not you have a disability
- information included on your CV or application form including references, education, academic history, professional qualification, employment history and criminal convictions
- documentation relating to your right to work in the UK
- driving licence
- psychometric tests results (such as a situational judgement test, ability or personality test), interview notes (face to face, telephone or video), behavioural assessments (such as a role play, group exercise or presentation), technical assessments
- pre-employment screening activities carried out for the purposes of criminal records checks, adverse media check.
How we collect your data
We collect data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, interview test results or notes made by our recruiting officers during a recruitment interview. Further information will be collected directly from you when you complete forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other rights to work evidence.
In some cases, we will collect data about you from third parties, such as employment agencies, former employers or referees when gathering references or credit reference agencies, or when a colleague recommends that we consider you for a position. We may collect data from other sources where you have made your personal information publically available for the purposes of recruitment only on jobs boards, LinkedIn (or other publically available employment-related social media networks and databases for the purposes of headhunting suitable candidates). If you provide links to your personal web pages or social media pages in support of your application, we may review these as part of our selection process.
Personal data is kept in personnel files or within the Charity’s HR and IT systems.
Why we process your data
The law on data protection allows us to process your data for certain reasons only:
- in order to perform the employment contract that we are party to
- in order to carry out legally required duties
- in order for us to carry out our legitimate interests
- to protect your interests and
- where something is done in the public interest.
All of the processing carried out by us falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
We need to collect your data to ensure we are complying with legal requirements such as:
- carrying out checks in relation to your right to work in the UK and
- making reasonable adjustments for disabled candidates.
We also collect data so that we can carry out activities which are in the legitimate interests of the Charity. We have set these out below:
- making decisions about who to offer employment to
- making decisions about salary and other benefits
- assessing training needs
- dealing with legal claims made against us
If you are unsuccessful in obtaining employment, your data will not be used for any reason other than in the ways explaining in relation to the specific application you have made. If you wish to be kept up to date with upcoming vacancies, you can opt in to our job alert.
Special categories of data
Special categories of data are data relating to your:
- sex life
- sexual orientation
- ethnic origin
- political opinion
- trade union membership and
- genetic and biometric data.
We must process special categories of data in accordance with more stringent guidelines. Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
We will use your special category data:
- for the purposes of equal opportunities monitoring
- making reasonable adjustments for disabled candidates
We do not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, we may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
Criminal conviction data
We will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment. We use criminal conviction data in the following ways:
- To assess your suitability to work with the vulnerable adults we support
We process this data because of our legal obligation when recruiting for a role for which checks are authorised by law, for example, roles involving work with vulnerable adults or children where a Disclosure and Barring Service check is required, and our obligation to ensure the safeguarding of children and vulnerable adults and where necessary for the purposes of performing or exercising employment law obligations or rights. We will not request criminal conviction data until the appropriate stage in the recruitment process.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out an effective recruitment process. Whilst you are under no obligation to provide us with your data, we may not be able to process or continue with (as appropriate), your application.
Sharing your data
Your data will be shared with colleagues within the Charity where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, the HR department, those in the department where the vacancy is who responsible for screening your application and interviewing you, the IT department where you require access to our systems to undertake any assessments requiring IT equipment. The Director of Finance & Resources and the Finance & IT Manager have access to your recruitment data.
We shall not share your personal information unless we are entitled to do so. The categories of persons with whom we may share your personal information outside the Charity include: Any regulatory authority or statutory body pursuant to a request for information or any legal obligation which applies to us, parties who process data on our behalf, which may include: IT support, storage service providers including cloud, background screening providers, Legal and professional advisers, Insurers, our Applicant Tracking System provider.
In some cases, we will collect data about you from third parties, such as employment agencies, your referees, the provider of our Applicant Tracking System. Our Applicant Tracking System provider has a separate Privacy Notice which can be found here https://hireful.co.uk/privacy-policy/
Your data will be shared with third parties if you are successful in your job application. In these circumstances, we will share your data in order to obtain references as part of the recruitment process, to obtain a criminal record check.
We do not share your data with bodies outside of the European Economic Area.
However, third parties may share your data with bodies outside of the European Economic Area for the purpose of software development. In such circumstances, the third parties concerned do so in line with GDPR requirements.
Protecting your data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such in line with GDPR requirements.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with us.
If your application is not successful and we have not sought consent or you have not provided consent upon our request to keep your data for the purpose of future suitable job vacancies, we will keep your data for 12 months once the recruitment exercise ends.
If we have sought your consent to keep your data on file for future job vacancies, and you have provided consent, we will keep your data for 12 months once the recruitment exercise ends. At the end of this period, we will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.
If your application is successful, your data will be kept and transferred to the systems we administer for employees. We have a separate privacy notice for employees, which will be provided to you.
We will make some decisions about you based on automated decision-making (where a decision is taken about you using an electronic system without human involvement). For example, automated decision making is used on initial pre-application question pages to determine if you meet the minimum requirements of the vacancy. If you do not meet the minimum requirements of the vacancy, you will not be able to continue with your application. Any automated decisions will be highlighted to you in the application process and you will be required to agree that you are happy to proceed using this process.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in a way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so.
If you wish to exercise any of the rights explained above, please contact the Charity’s Data Protection Compliance Officer.
Making a complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Data Protection Officer
The Charity’s Data Protection Compliance Officer is the Finance & IT Manager. They can be contacted on via the recruitment team at email@example.com. Please address your email to the Data Protection Compliance Officer.