Last updated: May 2018     

  1. Introduction

This privacy policy relates to how Power to Change uses information collected through our grant applications, surveys, events, or partner referrals and how we use publicly available information. This information is collected for the promotion of Power to Change’s charitable purpose through our projects and programmes.

Your privacy is important to us. This policy informs you what personal information we collect from you and how we use it.

  1.       Information We Collect

Power to Change collects your information to process applications for our programmes and projects; to enhance and develop our programmes and projects; and to widen wherever possible participation in those programmes and projects from communities across England.  We aim to provide you with the best experience when working with us and our partners.

Some of this data will be provided by you.  For example, when you complete an application form for a grant or project, you fill in a website contact form, or you may hand a business card to us at events.

Some of this data will be collected about you, for example, via cookies, from third-party public sources or when you open one of our emails.  We may also, from time to time, ask for your participation in one of our surveys and or research interviews, by way of web-based survey management tools. These surveys are always optional, consent will be sort before asking for your participation, and at no time is any of your personally identifiable information asked for, processed or stored.

Information you provide to us:

  • Information that you provide us with regards to a grant or project application, either directly or via one of our carefully selected partners (including, but not limited to; name, address, email address, direct dial phone number, mobile phone number company/organisation name, job title, areas of interest, financial data pertaining to the organisation you are applying on behalf of, and other information deemed necessary in order to process the application.  This will include mandatory monitoring of any grant/project that is successful following the application process)
  • Information that you provide to us when contacting us through our websites (including name, address, email address, direct dial phone number, mobile phone number company/organisation name and job title)
  • information that you provide to us for the purpose of requesting information, including programme and marketing communications, subscribing to our email notifications or newsletters (including name, address, email address, direct dial phone number, mobile phone number company/organisation name and job title)
  • information contained in or relating to any communication that you send to us or send through our websites (including the communication content)
  • any other personal information that you choose to send to us.

 

Information that we may collect about you:

  • metadata information about your computer and your visits to and use of our websites (as per our cookie policy). For example, when someone visits our websites we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various pages on our sites.  This general information is processed in a way which does not identify anyone. If an individual does not want us to be able to link them back to this information they can contact us directly on info@powertochange.org.uk rather than completing the online form
  • information about you that we collect from other public sources such as your Twitter handle or LinkedIn profile. For example, Company Name, Company Address, Sector, Job Title and Company Size
  • information provided to us by our email service provider which includes when you open one of our emails and the links you clicked on.

 

  1.        Use of Your Data

We may use your data for the purposes specified in this policy or the relevant pages of the websites to provide you with the information that you have requested of us. We may also use your personal information to comply with our legal obligations.

We may use your personal information to:

(a)       administer our websites, and business;

(b)       personalise our websites for you;

(c)       enable your use of the services available on our websites;

(d)       send you email notifications, newsletters and sales and marketing communications that you have specifically requested;

(e)       deliver a better or more tailored application experience;

(f)        deal with enquiries and complaints made by or about you relating to our websites;

(g)       keep our websites secure and prevent fraud;

(h)       verify compliance with the terms and conditions governing the use of our websites.

(i)      to optimise our marketing campaigns.

 

  1.       Our Legitimate Interests

Power to Change is a charity funded by an endowment made by the Big Lottery Fund in 2015.  Power to Change uses most of its endowment to directly support community businesses. We distribute our funding through open and targeted programmes, to help new community businesses start up and existing ones be more resilient. Power to Change also runs a community business Research Institute.  The Research Institute seeks to support the charity’s charitable purposes and vision of ‘better places created through community businesses by commissioning high-quality research, promoting rigorous analysis and stimulating critical scrutiny and debate. In doing so we aim to shape both policy and practice. To enable Power to Change to distribute and manage grants, we need to market our programmes and projects to new potential applicants (prospects), make existing applicants aware of new programmes and projects, and report both to the funders and the public as to the success of the charity and its successful applicants.

To achieve these aims Power to Change has a legitimate interest to process personal data to properly and lawfully and without prejudice manage the full cycle of the application process from your first submission to either Power to Change or one of the selected partners (as referenced in section 5.2), through to the application being approved or not. Subsequently, your personal details will be stored, in a secure software platform, in order to manage your application or project through to conclusion. Power to Change will then keep the details of the application or project, the amount, the business name etc. but will, on request, omit the personal details of the actual applicant and other associated individuals who details have been collected as part of the application process.

Power to Change may also identify potential applicants who are in job roles that are likely to require its programmes and projects and communicate this to them, either by phone, email or post. We will share your personal information with our selected partners in order to fulfil their role with regards to the applications, the selection of successful grantees/project participants and the management of those grants or projects.  No personal data is shared with any other companies/organisations other than those that have been carefully selected by Power to Change and who are wholly relevant to the work we do and the application process we perform. If you choose to object to these communications, we will update your permissions accordingly. To establish Legitimate Interest as a lawful basis for processing personal data for these purposes a Legitimate Interest Assessment was conducted and is available upon request by emailing info@powertochnage.org.uk

Subject to this, we will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.

 

  1.        Disclosing Personal Information

We may disclose your personal information to relevant parties as described in this policy.

We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

Where relevant, and as stated previously, we may disclose your personal information to our selected partners who work with us insofar as reasonably necessary for the purposes set out in this policy.  Your personal information will only be shared with the relevant partners with regards to your application and or grant, information will not be passed to these partners where there is no good cause.

The list of Power to Change Trust’s grant management partners are available upon request by emailing info@powertochnage.org.uk

We may disclose your personal information:

(a)       to the extent that we are required to do so by law;

(b)       in connection with any ongoing or prospective legal proceedings;

(c)       to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);

(d)       to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

  1.         Data Storage

We also use a select number of suppliers to support the provision of our services. For example, data is processed using a customer relationship management provider, email service provider and website host provider. Where we use any such sub-processors, we undertake prior due diligence to confirm that they meet recognised adequacy standards for data protection; this includes any that are located outside of the European Union.

Personal information that you publish on our websites or submit for publication on our websites may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.

You expressly agree to the transfers of personal information described in this Section.

  1.         Data Retention

This Section sets out our approach to data retention, which is designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that specific purpose or those purposes.

Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

(a)       to the extent that we are required to do so by law;

(b)       if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c)       in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

 

  1.         Security of Personal Information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our websites confidential; we will not ask you for your password (except when you log in to our websites).

 

  1.         Changes to This Policy

This policy may change from time to time. The latest effective date will be highlighted at the top of the policy information.

We will update this privacy policy when necessary to reflect customer feedback, changes in our programme/projects and services or legal changes. When we post changes to this policy, we will revise the “Effective Date” at the top of the privacy policy and will describe the changes in the Change History page.

If there are material changes to the privacy policy or in how Power to Change will use your personal data, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy policy to learn how Power to Change is processing your information.

  1.        Your Control of Your Data

Managing how we contact you:

Your personal information belongs to you. You can adjust how we contact you for the purposes outlined in Section 3 by emailing us at info@powertochange.org.uk or by phoning our head office on 0203 8577270. You can also write to us at the address detailed in Section 12.

Managing your data:

You may request from us, details of the personal information we hold about you and how we are processing it.

Where notified, we will amend your data, including where you provide us with additional information to complete your record.

Where you have previously consented to Power to Change using your data, you may withdraw this consent at any time.

You may request that we restrict the use of your data, where you believe:

(a)       the data we hold about you is inaccurate;

(b)       the processing of your data is not lawful;

(c)       your data no longer needs to be used for the purpose that it was originally provided;

(d)       where you object to the use of your data for specific purposes.

You may have the right to request to transfer your data in a machine-readable format to your own store or another provider.

Should you no longer wish to engage with Power to Change, you may have the right to request erasure of your details from our systems.

To submit any such request, please send your request by email to:

info@powertochange.org.uk – Please state: DATA PROTECTION as the email title,

or in writing to:

The Lead Data Manager
Power to Change

6 St. Georges Circus

London

SE1 6FE

  1.       Third Party Websites

Our websites include hyperlinks to, and details of, third party websites.

We have no control over, and are not responsible for, the privacy policies and practices of third parties. 

  1.       Data Protection Registration

Power to Change Trust Limited is registered as a data controller with the UK Information Commissioner’s Office.

Our data protection registration number is ZA169594.

  1.       Our Details

Power to Change Trust Ltd website and its associated websites are owned and operated by Power to Change Trust Ltd.

We are a registered Charity in England and Wales under registration number 1159982, and our registered head office is Power to Change, Clarence Centre For Enterprise & Innovation, 6 St. Georges Circus, London, SE1 6FE.

You can contact us by writing to the business address given above, by using our websites’ contact forms, by email to info@powertochange.org.uk or by telephone on 0203 857 7270.