Privacy Policy

As the data controller, Unseen UK (“we”) promises to respect any personal data that you share with us or that other organisations share with us and to keep it safe. We want to be clear when we collect your data and not do anything you wouldn’t reasonably expect.

Unseen UK wants to ensure that we fundraise in an engaging and efficient way and understanding our supporters through their personal data is important to doing this. Fundraising is essential to ensure that we can continue to carry out our work and ultimately reach our goal of a world where slavery no longer exists.

We are committed to ensuring that our supporters are receiving the communications you want, in the way that you want. From September 2017, we will be asking each new supporter to let us know what information you would like to hear about and how you would like to receive this. Where appropriate, we will also be asking our current supporters to confirm this information, to make sure that you are completely happy.

Unseen keeps its supporters up to date with news on modern slavery, our life changing work with survivors, appeals and campaigns. To ensure you receive the information you would like, if you haven’t already done so, please contact 0303 040 2888 or preferences@unseenuk.org.

For fundraising and marketing purposes we do not share your information with third parties. In general, for any other purposes, information is only shared when you have given us your explicit permission to do so, or we have a legal requirement to do so.

We also have a mobile app or a webform accessible via www.modernslaveryhelpline.org/report that can be used to tell us about a suspected situation of modern day slavery or request more information about modern slavery and the services provided by Unseen. This policy will clearly set out the data that we collect, our reasons for collecting it and your options around how that data is used.

Data Protection Officer

Our Data Protection Officer is Stuart Mellis - Director of Finance & Operations. He can be contacted via email datacontroller@unseenuk.org.

Where we collect information about you:

We collect 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, make a donation, purchase our products or communicate with us.

  • 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 or Virgin Money Giving. These independent third parties will only do so when you have indicated that you wish to support Unseen UK and with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.

    Our Websites or Apps

    Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. There are more details in our Cookies Policy.

    In addition, the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.

    What personal data we collect, how we use it and the legal basis for processing

    Your consent preferences and our mutual legitimate interests will determine the type of information we will collect and how we process it

    Supporters: individuals

    If you choose to support Unseen, for example through signing up for an event, donating, or volunteering for us, with your consent we will usually collect:

    • Your name
    • Contact details
    • Date of birth
    • Bank or credit card details (if you are making a payment)

    Where it is appropriate we may also ask:

    • If you would like us to stay in touch with you and, if so, what you would like to hear about and in what way (e.g. via email or post)
    • Why you have decided to support us
    • How you heard about Unseen

    We will mainly use your data to:

    • Provide you with the services, information or products you have asked for
    • Administering your donation or support your fundraising, including processing gift aid
    • Keep a record of your relationship with us
    • Ensure we know how you prefer to be contacted
    • Understand how we can improve our services, products, information

    We may also use your information to detect and reduce fraud and credit risk.

    Legal basis for processing individual supporter information

    Unseen will always use consent as the legal basis for processing data when a supporter has shared their preferences with us. We pro-actively collect consent through the website, in letters, verbally and in person where appropriate. Unseen always aims to ask for your consent, including how you would like to be communicated with and what you would like to hear about. We will always respect your consent decisions.

    Sometimes, we may not have explicit consent to contact you. This may happen if you give us a surprise donation in the post for example. When we do not have your explicit consent, we will use legitimate interests as the legal basis in which to contact you. We will only do so by post or telephone. Unseen uses legitimate interest as it’s legal basis to communicate with its active supporters, which is defined as any individual who has donated in the current and last two financial years. Using legitimate interests, we will tell our supporters about the charities news, impact, appeals, campaigns and events, unless they tell us not to. We believe it is in the interests of the charity and its supporters to stay connected about the impact their support is having.

    Unseen will only communicate with donors who have supported us through a third party when we have your explicit consent to do so. We will only send you communications that you have decided you would like to receive.

    How Unseen will collect information about you and what we will do with it.

    We use data you provide, sometimes together with data obtained elsewhere, to manage our fundraising efficiently and effectively so we can raise more to spend on fighting human trafficking and modern slavery. This will include data which helps us effectively target and tailor our communications so that we can make appropriate requests to individuals who may be able to support us at a higher level.

    We use publicly available information to find new potential supporters and invite them to get involved in supporting our cause. We do this by using the data to provide insight so we can tailor specific communications which may be of interest to them. External data sources may include publicly available information such as from Companies House, Charity Commission and other charity registers, Who’s Who and Debrett’s guides, Electoral Roll, reputable newspaper articles, publications, company websites and biographies on professional networking sites as well as geographic and demographic information based on your postcode.

    This approach gives us a better understanding of our supporters and enables us to segment our database so we can provide the most efficient and effective information to our existing and potential new supporters.

    If you would prefer us not to use your data in this way please let us know by emailing preferences@unseenuk.org or calling us on 0303 040 2888.

    Supporters: organisations

    If an organisation you belong to decides to support Unseen, for example through signing up for an event, donating, or volunteering for us, we will usually collect:

    • Organisation name
    • Contact details of the organisation
    • Contact details of a key contact
    • Bank or credit card details (if you are making a payment)

    Where it is appropriate we may also ask:

    • If you would like us to stay in touch with you and, if so, what you would like to hear about and in what way (e.g. via email or post)
    • Why you have decided to support us
    • How you heard about Unseen

    We will mainly use your data to:

    • Provide you with the services, charity information, products or partnership activities that you have asked for
    • Administering your donation or support your fundraising
    • Keep a record of your relationship with us
    • Ensure we know how you prefer to be contacted

    Legal basis for processing an organisation’s data

    Unseen will always use consent as the legal basis for processing data when an organisation has shared their preferences with us. We pro-actively collect consent through the website, in letters, verbally and in person where appropriate. Unseen always aims to ask for your consent, including how you would like to be communicated with and what you would like to hear about. We will always respect your consent decisions.

    Sometimes, we may not have explicit consent to contact you. This may happen if give us a surprise donation in the post for example. As a ‘corporate subscriber’, we will use legitimate interests as the legal basis in which to contact you, via post, telephone, email or text. Unseen uses legitimate interests as it’s legal basis to communicate with its active supporters, which is defined as any organisation who has donated in the current and last two financial years. Under legitimate interests, we will tell our supporters about the charities news, impact, appeals, campaigns and events, unless they tell us not to.

    Building partnerships is vitally important to tackling modern slavery. We may get in touch with organisations using the legal basis of legitimate interests to discuss building a fundraising or strategic partnership.

    App or webform users

    When you submit a report via the mobile app or the webform you may give us the following information:

    • name or a pseudonym
    • Email address
    • Telephone number

    However, the app or webform will also allow you to submit your form without any of these details being included.

    We will use this information to record a suspected incidence of modern day slavery or prepare a response to a question or a request you have raised.

    The app or webform asks whether or not we can contact you. This is to allow us the opportunity to gather further information and determine how best we can help you. We will only contact you if you have given us permission to do so.

    The app or webform asks whether you are happy for the information you have shared with us to be shared with a third party. Third parties who we may wish to pass your information to include police and other law enforcement agencies and local authorities.

    We will only pass your information onto a third party if you have given us permission to do so, subject to the following exceptions:

    • to comply with the law (e.g. the police, Inland Revenue and Council Tax Registration Officer) or a court order, or a request from a regulatory body (Housing Corporation, Social Services, Inspection Unit)
    • where there is a clear risk or risk of harm to an individual
    • anonymously for bona fide statistical or research purposes, provided it is not possible to identify the individuals to whom the information relates;

    In these cases, the client/potential victim will be informed of the need to breach confidentiality prior to this happening or in all instances, as soon as possible afterwards if prior notification is not possible.

    Sharing your story

    Some people choose to tell us about their experiences of modern slavery to raise awareness about the crime. They may take on a role as an Ambassador or volunteer or patron and may choose to share sensitive information related to their experiences in addition to their biographical and contact information.

    Unseen always ensures that we have the explicit and informed consent from individuals, to share their story publicly at events, in materials promoting our campaigning and fundraising work, or in documents such as our annual report.

    Children’s data

    Unseen sometimes collects and manages information from children. Information may be collected when children attend our events or fundraise for us. Unseen always secures parental/a guardian’s consent before collecting information about children under the age of 13 and makes reasonable efforts to verify that a parent or guardian has provided the appropriate consent. Our events have specific rules about whether children can participate, and we will make sure advertising for those events is age appropriate. Unseen will never proactively contact a child whose information has been collected through an event or fundraising.

    How we keep your data safe and who has access

    We ensure that there are appropriate technical controls in place to protect your personal details. For example, our online forms are always encrypted, and our network is protected and routinely monitored. All data is retained within the EEA.

    We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

    Occasionally we use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they have collect or have access to.

    We may need to disclose your details if required to the police, regulatory bodies or legal advisors.

    We will only ever share your data in other circumstances if we have your explicit and informed consent

    Your rights

    Right to be informed

    Unseen wants to ensure that you know how we collect and use your data. This Privacy Policy details our purposes in doing so. We will proactively promote our Privacy Policy to our supporters at the time they give us their data. The Privacy Policy is accessible on the homepage of Unseen’s website, will be promoted on donation acknowledgements, email signatures and all fundraising communications where appropriate.

    Retention period- how long will we keep your information for?

    Unseen actively asks for consent to use your information. We will ask for your consent at least every 3 years to ensure you are still happy for us to communicate with you, and to give you a chance to update what you would like to hear about. If you do not consent to us continuing to communicate with you and you have not donated to Unseen in the last 7 years, your information will be deleted within 28 days.

    If you have donated to Unseen we will retain your:

    • Name
    • Contact details
    • Donation amount and date

    for 7 years, which is in line with HMRC recommendations on accounting for financial records. After this period, if you do not consent to us communicating with you further, your information will be deleted.

    Right to be forgotten

    You have the right to request that your information is deleted. You can request to have your information deleted by calling: 0303 040 2888 or emailing preferences@unseenuk.org.

    Your information will be deleted within 28 days if we do not need to adhere to the financial records policy as detailed above. We will cease communicating with you within 28 days of the request.

    Right to rectification- keeping your information correct and up to date

    We depend on you letting us know if there are any changes to your information. Unseen will not use any third parties to update your personal information. We would really appreciate it if you let us know if your contact details change, so we can continue to keep in touch. Please email preferences@unseenuk.org if you need to rectify any personal information we have.

    Right to access- your right to know what information we know about you

    You have the right to request the data that we hold on you. This is called a Subject Access Request. You can make a request verbally or in writing by calling 0303 040 2888, emailing preferences@unseenuk.org or writing to Unseen, 103, First Floor, Deben House, 1-5, Lawrence Hill Bristol, BS5 0BY. We will respond to Subject Access Requests within 28 days of receipt. There is no charge for this request.

    Right to portability- transferring your data

    Your right to data portability allows you to obtain and re-use your personal data with other organisations. Unseen will ensure that your data is able to be moved, copied and transferred easily from one IT environment to another in a secure way. We will ensure that the information is structured, commonly used and in a machine-readable format, for example in a clearly labelled spreadsheet. Contact us on 0303 040 2888 or preferences@unseenuk.org to exercise your right to portability. We will respond within 28 days.

    Right to restrict processing- ask us to stop using your data

    You have a right to ask us to change or stop processing your personal data and, if it’s not necessary for the purpose you provided it to us for (e.g. processing your donation or registering you for an event), we will do so. Upon receipt of a restriction request, we will not process your data whilst we are implementing your request. Contact us on 0303 040 2888 or preferences@unseenuk.org to exercise your right to restriction.

    Rights related to automated decision making including profiling

    We may build a profile on our supporters to ensure that our communications are relevant and timely, and to provide an improved experience for our supporters therefore legitimate interests is our legal basis for processing data in this way. Profiling also allows us to target our resources effectively, which donors consistently tell us is a key priority for them. For example, if we are running an event in Bristol, we may use our supporters’ profiles to understand which of our supporters are in Bristol and then we will send invites to those people. Importantly, understanding our supporters through profiling, enables us to raise more funds, sooner, and more cost-effectively to continue our mission of tackling modern day slavery. When building a profile, we may analyse geographic, demographic and other information relating to you to better understand your interests and preferences and contact you with the most relevant communications. In doing this, we may use additional information such as other publicly available data about you, for example addresses, listed Directorships or typical earnings in a given area.

    Right to object

    If you wish to change any of your preferences around how we use your personal data or how we communication with you please contact us on 0303 040 2880 or preferences@unseenuk.org. Such changes might include how frequently you wish to be contacted by us, the types of subjects you wish to receive information on from us and the format of these communications.

    Complaints process

    Unseen is committed to providing an excellent service to all stakeholders working in an open and accountable way that builds trust and respect. We have developed a Fundraising Complaints Policy and Procedure that explains our approach to receiving complaints.

    Our Aim

    Unseen’s Fundraising Complaint Procedure is intended to ensure that all complaints are handled fairly, consistently and wherever possible resolved to the complainant’s satisfaction.

    Unseen’s responsibility will be to:

    • acknowledge the formal complaint in writing
    • respond within 10 working days
    • deal reasonably and sensitively with the complaint
    • take appropriate action if required

    If you wish to make a complaint, in the first instance, please contact the person or email address that you usually interact with at Unseen. If this informal approach does not resolve your concerns, then please request a copy of Unseen’s formal Complaints Policy and Procedure via admin@unseenuk.org. This will be sent to you on the day of request. If we hear nothing further from you within 28 calendar days from this date, we will regard the complaint to be closed.

    Upon receipt of Unseen’s Complaints Policy and Procedure, you should write a formal letter of complaint to the line manager of the member of staff concerned that sets out the details of your complaint, the consequences for you as a result, and the remedy you are seeking.

    You can expect the complaint (stage1) to be acknowledged within 4 working days of receipt. You should get a response and an explanation within 10 working days. Following receipt of this letter you will have 28 days in which to ask for the complaint and response to be reviewed if you are dissatisfied with the response they have received.

    If you are unsure which member of Unseen staff to write to, your complaint should be addressed to Unseen’s Data Controller. Our contact details are Unseen, 103 First Floor, Deben House, 1-5 Lawrence Hill, Bristol BS5 0BY. Telephone number 0303 040 2888. Website address www.unseenuk.org.

    If you are dissatisfied with the response to your complaint, then two further levels of escalation are available. Stage 2 will be dealt with by a member of the Senior Management Team and Stage 3 by the Chief Executive and the Chair of the Trustees. The detailed steps and timescales for these stages are contained in the Fundraising Complaint Procedure.

    If you have any questions please send these to info@unseenuk.org, and for further information see the Information Commissioner’s guidance here: https://ico.org.uk/for-the-public/personal-informa...