HRF needs to keep certain information about its employees, users and suppliers for financial and commercial reasons and to enable us to monitor performance, to ensure legal compliance and for health and safety purposes. To comply with the law, information must be collected and used fairly, stored safely and not disclosed to any other person unlawfully.
Human Relief Foundation (HRF) is a registered charity (no. 1126281 & SC038671) based in Bradford, UK. HRF's Registered address is:
Human Relief Foundation
P.O. Box 194
1. Definition of Key Technical Terms
The following list below is of definitions of the technical terms we have used and is intended to aid understanding of this policy.
Data Controller – The person who (either alone or with others) decides what personal information HRF will hold and how it will be held or used.
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation) – The European legislation that provides a framework for responsible behaviour by those using personal information.
Data Protection Officer – The person(s) responsible for ensuring that HRF follows its data protection policy and complies with the GDPR.
Data Subject/Service User – The individual whose personal information is being held or processed by HRF (for example: a client, an employee, a supporter).
'Explicit' consent – Is a freely given, specific and informed agreement by a Data Subject (see definition) to the processing* of personal information* about her/him. Explicit consent is needed for processing sensitive* data.
Notification – Notifying the Information Commissioner's Office (ICO) about the data processing activities of HRF, as certain activities may be exempt from notification.
Information Commissioner's Office (ICO) – The UK's independent authority set up to uphold information rights in the public interest and implement and oversee the GDPR.
Processing – means collecting, amending, handling, storing or disclosing personal information.
Personal Information Collected – we may ask for:
• Your first and last name, title, job title, company/organisation name, email address, postal address, phone number and other similar contact data.
• Log in details – such as username, password and similar security information for authentication and account access.
• Payment information – this data is necessary to process payments including membership fees, event booking, online resources, donations and the like.
• If you are a U.K. Tax payer, for claiming Gift Aid.
• Any information which you choose to share with us in correspondence with you.
'Sensitive' data – means data about:
• Racial or ethnic origin
• Political opinions
• Religious or similar beliefs
• Trade union membership
• Physical or mental health
• Sexual orientation
• Criminal record
• Criminal proceedings relating to a data subject's offences
2. How we use your information
To provide our service – to inform you of relevant campaigns, sector updates, activities, ways you can support, events, notifying you of changes to our services or to address any queries you have raised (please note that we will not spam you and all communication will be aligned to the consent you have given us).
To improve our service – we may contact you to ask for feedback and suggestions that will help us improve the effectiveness and quality of service that you can expect from us in the future.
3. Data Controller
HRF is the Data Controller under the GDPR, which means that it determines what purposes personal information held will be used for. It is also responsible for notifying the Information Commissioner's Office (ICO) of the data it holds or is likely to hold, and the general purposes that this data will be used for.
HRF may share data with other agencies such as the local authority, funding bodies and other voluntary agencies.
The Data Subject will be made aware in most circumstances how and with whom their information will be shared. There are circumstances where the law allows HRF to disclose data (including sensitive data) without the data subject's consent.
1. Carrying out a legal duty or as authorised by the Secretary of State 2. Protecting vital interests of a Data Subject or other person 3. The Data Subject has already made the information public 4. Conducting and legal proceedings, obtaining legal advice or defending any legal rights 5. Monitoring for equal opportunities purposes – i.e. race, disability or religion 6. Providing a confidential service where the Data Subject's consent cannot be obtained or
where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Data Subjects to provide consent signatures.
HRF regards the lawful and correct treatment of personal information as very important to successful working, and to maintaining the confidence of those with whom we deal.
HRF intends to ensure that personal information is treated lawfully and correctly.
To this end, HRF will adhere to the Principles of Data Protection, as detailed in the GDPR.
5. Data Protection Principles
These principles require that personal data must be:
• obtained fairly and lawfully and shall not be processed unless certain conditions are met,
• obtained for specified and lawful purposes and not further processed in a manner incompatible with that purpose,
• adequate, relevant and not excessive,
• accurate and up to date,
• kept for no longer than necessary,
• processed in accordance with data subjects' rights,
• protected by appropriate security,
• not transferred to a country outside the European Union without adequate protection.
HRF will, through appropriate management, strict application of criteria and controls:
• Observe fully conditions regarding the fair collection and use of information,
• Meet its legal obligations to specify the purposes for which information is used,
• Collect and process appropriate information, and only to the extent that it is needed to fulfil its operational needs or to comply with any legal requirements,
• Ensure the quality of information used,
• Ensure that the rights of people about whom information is held, can be fully exercised under the GDPR. These include:
◦ The right to be informed that processing is being undertaken
◦ The right of access to one's personal information
◦ The right to prevent processing in certain circumstances and
◦ The right to correct, rectify, block or erase information which is regarded as wrong information,
• Take appropriate technical and organisational security measures to safeguard personal information,
• Ensure that personal information is not transferred abroad without suitable safeguards,
• Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information,
• Set out clear procedures for responding to requests for information.
6. Data Collection
HRF will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected:
• In person
• Paper form
• Online forms
When collecting data, HRF will ensure that the Data Subject:
• Clearly understands why the information is needed
• Understands what it will be used for and what the consequences are should the Data Subject decide not to give consent to processing
• As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
• Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
• Has received sufficient information on why their data is needed and how it will be used
7. Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised staff and volunteers.
Information will be stored only as long as it is needed or required statute and will be disposed of appropriately.
It is HRF's responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organisation, which has been passed on/sold to a third party.
7.1 Data Access and Accuracy
All Data Subjects have the right to access the information HRF holds about them and must be informed how to gain access to it by the Data Protection Officer. HRF will also take reasonable steps to ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, HRF will ensure that:
• It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection,
• Everyone processing personal information understands that they are contractually responsible for following good data protection practice,
• Everyone processing personal information is appropriately trained to do so,
• Everyone processing personal information is appropriately supervised,
• Anybody wanting to make enquiries about handling personal information knows what to do,
• It deals promptly and courteously with any enquiries about handling personal information,
• It describes clearly how it handles personal information,
• It will regularly review and audit the ways it holds, manage and use personal information,
• It regularly assesses and evaluates its methods and performance in relation to handling personal information,
• All staff are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them.
Your right to withdraw consent:
Under the GDPR and in addition to the above mentioned, you also have the right to request the deletion of your personal data that HRF holds.
You can do this by:
Calling: 0207 060 4422
Emailing: [email protected] or [email protected]
Post: Human Relief Foundation, 2 Claremont, Bradford, West Yorkshire, BD7 1BQ.
Additionally, you have the right to file a complaint with the Information Commissioner's Office (ICO).
This policy will be updated as necessary to reflect best practices in data management, security and control and to ensure compliance with any changes or amendments made to the GDPR.