1. About us
We are Bromley Borough Foodbank (“we” or “BBF”), an independent charitable organisation which is part of the Trussell Trust Foodbank Network.
We are a charitable incorporated organisation, a registered charity (with registration number 1167961) and registered (as a “data controller”) with the Information Commissioner’s Office with registration number ZA195992.
Important terms have been underlined throughout this notice. Descriptions can be found in the “More information” section to the end of this document.
2. What Information do we collect about you?
Where we have collected information directly from you it will usually be obvious what this is, as you will have given it to us freely. If you have been referred to us, we will receive your information from the referral organisation that you have engaged. It is the responsibility of the referral organisation to ensure that you are aware of our engagement before they make your data available to us.
The personal information we hold about you may include the following:
- Basic identifiers: such as your name, address and phone number
- Background information: information associated with your personal/household circumstances that can be used to provide you with a better service
- Usage information: information about your visits to and other dealings with us and other foodbanks, including any relevant grievance records.
- Feedback and survey information: information provided where you have chosen to participate in surveys or to provide any other feedback.
Donors, supporters and others
If you have donated to us (food or money), support us by receiving newsletters or similar updates or are otherwise in contact with us, we may retain the following information:
- Basic identifiers: your self-declared identification and contact details such as email address
- Usage and donation information: information about your dealings with us and, if you make a money donation, we retain account records showing your name and the date and amount of the donation; we may also have your bank account details.
Sensitive Personal Information
We do not need any Sensitive Personal Information about you for the provision of our services or the receipt of donations.
On occasion Sensitive Personal Information may be volunteered to a member of our team where special circumstances require this to be taken into consideration or acted upon, for example information regarding a client’s health, including dietary requirements. In these situations, we may ask to note those special circumstances but will not seek to retain the information beyond its utilisation in connection with those special circumstances.
3. What we do with your personal information
a. Using our services: in order to provide you with the services and help you require and to ensure an appropriate service level is maintained we need to use your personal information:
- to contact you when information regarding your service is available
- to administer your engagement with us and other service providers
- to provide the agreed service
In addition to obtain further help and to check how many times you have been to a foodbank. Our lawful basis for these uses is our legitimate interests in lawfully and efficiently responding to your need for help and in ensuring that we and other foodbanks are providing help when and where it is most needed
b. Improving our services: we may use opinions you express, including any verbal or written feedback and opinion, to improve our client experiences, including:
- to ensure our staff constantly give a highly professional service
- to receive and act on feedback including grievances
- to assess the use and needs of the local community
We can use your personal information in this way because it is in our legitimate interests to provide the services in the most efficient way. We will always ensure that we keep the amount of your personal information that we collect and the extent of any processing to the absolute minimum to achieve this efficiency.
c. Promoting our work: we may with your agreement use your personal information to promote our work. For example, we may use it, including photographs or videos, in case studies and stories that we publish or share with the media.
We will only use your personal information for this purpose if you have given your consent for us to do so; our lawful basis for this is therefore your informed consent.
d. Protecting against misuse: (fraud) misuse of our services has an impact on all Client’s as it decreases the services we are able to offer to those truly in need. We may use your personal information to ensure that our services are not being misused. This information may also be shared with other foodbanks you visit and/or the agency that referred you to us.
We may use your personal information in this way because it is in our interests to detect fraudulent behaviour and in all our clients’ interests to ensure that we are able to provide services to those who truly need our services the most in a transparent manner.
e. Emergency situations: we may also use your personal information to assist where your, and/or another person’s, life or health is in danger and obtaining your permission is not possible (e.g. seeking emergency assistance where immediate action is required).
f. Third Party Service Providers: in addition to the services we provide directly to you, we may have arrangements with third-party service providers who are able to provide you with additional or alternate support. When there is a relevant third-party service provider in place, we will inform you and seek your consent to share your personal information with them to make use of their service.
Information regarding our third-party service providers as at the Adoption Date can be found below:
Donors, supporters and others
g. Donation records: if you have made a financial donation, we will use your payment information to keep track of your payment. Our lawful basis for this is our legitimate interest in maintaining appropriate and lawful records of our activities.
If we are able to reclaim Gift Aid in respect of your donation, we will also keep Gift Aid forms, so that we can prove the amount of Gift Aid we are entitled to reclaim from HMRC. Our lawful basis for this is our legal obligation to collect relevant personal information in respect of Gift Aid.
h. Important updates: your identification and contact details may be held as part of our record of donors and supporters, which we use to keep in contact, including through distribution of our newsletter and similar updates. Our lawful basis for this is our legitimate interest in developing a close relationship with those who support us, including for fundraising purposes.
i. Recording our dealings: we may use the personal information we hold about you to process and record our dealings with you and any organisation that you represent. Our lawful basis for this is our legitimate interest in dealing appropriately, lawfully and efficiently with the issues in relation to which you are in contact with us.
j. Marketing communications: we will only send you marketing communications via email or text where you have opted in to receiving them. Our lawful basis for this is your informed consent. You can unsubscribe at any time by contacting us at [email protected].
4. How long we keep your personal information
We will hold your personal information only for as long as is necessary; generally this will not be longer than 7 years from last use of our service. Access to information is removed over time to ensure only those that need access to your personal information have access to it. In some circumstances, we may legally be required to retain your personal information, for example for finance, employment or audit purposes.
5. Sharing your personal information
We share personal information in these ways, in addition to those mentioned above:
- With the Trussell Trust (“TT”): TT supports over 1200 food bank centres in the UK which together represent the Foodbank Network. We share personal information about clients, volunteers and employees with TT, with whom we have a data sharing agreement. TT works to support the Foodbank Network and uses anonymised statistical data to campaign nationally to challenge structural issues locking people into poverty. Our lawful basis for this sharing with TT is our legitimate interests in operating lawfully and efficiently, in cooperating with TT to help ensure that we and other members of the Foodbank Network can provide help when and where it is most needed and more generally in supporting the work of TT around the UK.
- With the authorities, to comply with our legal obligations: for example, to assist the police and other competent authorities with investigations including criminal and safeguarding investigations and to keep our details up-to-date with Companies House and the Charity Commission.
- With our bank and professional and other advisers: for example, providing payment details to our bank to process payments and sharing personal information with our professional advisers and with our IT support and data storage providers. Our lawful basis for this sharing and for our sharing with third party processors is our legitimate interest in operating lawfully and efficiently.
6. Transferring your personal information outside the UK
UK data protection law places controls on the transfer of your personal information outside the UK. For countries, such as those in the EU, which have a similar standard of data protection law to that which applies in the UK, there may be “adequacy regulations” in place which permit the transfers; for other countries, the transfers may only be made if certain conditions are satisfied.
We seek to comply with UK data protection law in this regard, including by putting in place appropriate contracts and arrangements with TT and other third party processors that we use requiring them to transfer or permit the transfer of your personal information only to countries or territories in respect of which there are adequacy regulations in place or if the requisite conditions are otherwise satisfied.
7. Your rights
a. The rights that you have
You have various legal rights in relation to your personal information. They include the right to be given the information set out above. In addition:
- Right of access: you can request us to give you a copy of the personal information that we hold about you and supplementary information about how we are using it. If it helps, we will give you this copy in a computer file.
- Right to rectification of inaccurate personal information: you can request us to correct your personal information if it is incomplete or inaccurate.
- Right to be forgotten: in some situations, you can request us to erase your personal information. One example is that if our only lawful basis for our use of your personal information is your consent, you may withdraw that consent.
- Right to object: in some situations, you can object to our use of your personal information. One example is if we are relying on having a legitimate interest as our lawful basis for doing so. Another is that you can object to our using your personal information for direct marketing purposes.
- Right to restriction of our use: in some situations, you can request us to restrict our use of your personal information. One example is while we are checking your claim that the personal information we hold on you is inaccurate.
- Right to data portability: you can request that we provide you with the personal information we hold about you which you have provided to us, in a reasonable format specified by you, so that you can provide it to another organisation.
b. The exercise of your rights
For all such requests or to exercise your right to object, please contact us by email at [email protected]. We will seek to resolve your request within one calendar month.
c. Right to complain to the Information Commissioner’s Office
You can complain to the Information Commissioner’s Office if you are not satisfied with our response to any query you raise with us or if you believe we are using your personal information in an unlawful way. Their helpline number is 0303 123 1113.
8. Changes to this Notice
We may change this Notice from time to time. We recommend that you visit our website periodically to keep up to date with the changes in this Notice.
9. Contacting us
You can contact us about anything related to this Notice by emailing us at [email protected].
Appendix More information
Adoption Date: the date on which this Notice as most recently updated; currently January 2023.
Lawful basis a legal justification for our use of your personal information. The permissible legal justifications are listed in the data protection legislation.
Legitimate interest: a lawful basis for our use of your personal information – that the use must be necessary for legitimate interests which we have that are not overridden by your interests and rights.
Personal information: information we hold about you on our IT systems and in our files from which you can be identified. It’s “personal” because it’s about you as an individual – not information about any organisation you’re connected to. The legislation calls this personal “data”, but we think “information” is clearer.
Sensitive Personal Information: your personal information relating to particularly sensitive matters identified by the data protection legislation for additional protections, including your race, ethnic origin, religious or philosophical beliefs, health, sex life, sexual orientation or criminal record.
Use, using: this includes collecting, storing, using, disclosing or doing anything else with your personal information. The legislation calls this “processing”, but we think “using” is clearer.