Privacy Notice

PLEASE READ THE TERMS OF THIS NOTICE CAREFULLY BEFORE USING THE SITE

Welcome to The Bread and Butter Thing's Privacy Notice.  In this Privacy Notice we have referred to The Bread and Butter Thing as TBBT.

This Privacy Notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.  This Privacy Notice applies to all individuals who visit our website https://breadandbutterthing.org (regardless of where you visit it from) or who engage with us in relation to our services (either as a member, volunteer or otherwise) or who otherwise engage with us in the ordinary course of our business.

This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below.

Purpose of this Privacy Notice

We do not knowingly collect data relating to children.

It is important that you read this Privacy Notice together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other notices and privacy policies and is not intended to override them.

Controller

TBBT is a Charitable Incorporated Organisation registered at the Charity Commission with number 1169383. TBBT is the controller and responsible for your personal data (also referred to as, "we", "us" or "our" in this privacy policy).

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact us by sending an email to info@breadandbutterthing.org.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and your duty to inform us of changes

We keep our Privacy Notice under regular review. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links and third party suppliers

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Payment of membership fees through Apple Pay and Android Pay or by debit card means that your payment details will be processed by a third party and will be subject to their own privacy policies. We do not collect or retain this information.  We do not control these third parties and are not responsible for their privacy statements. We encourage you to read the privacy policy of every party that you use in this regard.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Information that we collect when you use our website

In using our website, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, marital status or title.
  • Contact Data includes home or contact address, email address and telephone numbers.
  • Technical Data includes [internet protocol (IP) address, your login data (if any), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We do not collect any Special Categories of Personal Data about you when you use our website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Information we collect when you engage with us as a member of TBBT, as a volunteer or otherwise and when you otherwise engage with us in the ordinary course of business. 

In engaging with us in relation to our services and/or in the ordinary course of our business we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes your first name, maiden name, last name, the company you work for and your position at that firm, any other connections that you may have at that firm, your marital status, title, date of birth and gender.
  • Visual Data: includes photographic images and videos that we may take with your prior consent.
  • Contact Data includes billing address, delivery address, home address, email address and telephone numbers. This may include contact details of individuals who work for or on behalf of our clients.
  • Usage Data includes your use of our membership services.
  • Profile Data includes your interests, preferences, feedback and survey responses.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Any other information that you may choose to provide to us either in relation to you or in relation to any other person.

We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to help us determine whether to adapt our existing services or create new services that we believe will benefit our members. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

We may collect certain Special Categories of Personal Data about you when you engage with us as a member or volunteer such as your race, ethnicity, religious or philosophical beliefs or information about your health, for example if you consider yourself to have a disability or health condition and you have notified us about that. You are not obliged to provide this information to us if you do not want to. We will not process any Special Categories of Personal Data that we have collected about you unless it is necessary for providing our services to you or for performing or exercising obligations or rights in relation to your relationship with us i.e. if you are a volunteer, we will use information about your physical or mental health or disability to assess your fitness to work with us as a volunteer and make appropriate adjustments.

Information about criminal convictions

We may be required to process information about criminal convictions in relation to our volunteers and anyone else who works with us in delivering our services where we do so whilst working with children i.e. where we deliver our services in conjunction with a local school. In these circumstances, we are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable to work with us on this basis.

We have in place an appropriate safeguards which we are required by law to maintain when processing such data.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone (including text messages), email or otherwise. This includes personal data you provide when you:
    • apply to become a member of TBBT;
    • when you engage with us as a member of TBBT;
    • when you engage with us in relation to our member services;
    • when you engage with us in the ordinary course of business;
    • request information regarding our services;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy which is available on our website for further details.

Third parties or publicly available sources. We will receive Technical Data from analytics providers such as Google based outside the EU and will receive information from the Disclosure and Barring Service in respect of criminal convictions (where we are required to carry out these checks, see Information about criminal convictions).

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • when we process your application be become a member of TBBT;
  • where we need to perform any of our membership services or otherwise engage with our members in relation to our services;
  • responding to your queries;
  • managing our relationship with you including notifying you about changes to this Privacy Notice;
  • improving our platform, products and services;
  • supporting our business operations;
  • where we need to perform the contract we are about to enter into or have entered into with you;
  • unless you tell us otherwise, undertaking marketing of any or all of the services that we provide and which we consider may be of interest to you;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data unless it is Special Categories of personal Data, although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising our membership services.

Letting you know about our membership services

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what membership services we think you may want or need, or what may be of interest to you.

You will receive this communication from us if you have requested information from us and you have not opted out of receiving it.

Third-party marketing

We will not share your personal data with any third parties for marketing purposes.  

Opting out

You can ask us to stop sending you messages letting you know about our membership services at any time by emailing info@breadandbutterthing.org.

Where you opt out of receiving these messages, this will not apply to personal data provided to us as a result of your membership with TBBT.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy which can be found on our website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out below:

  • Service providers who provide data processing services to us or whose services are integral for the delivery of our services to you (for example, third parties who work with us to contact you about your membership services i.e. by sending text messages to you) or to support the delivery of, provide functionality on, or help to enhance the security of our website), or who otherwise process personal information for purposes that are described in this Privacy Notice or notified to you when we collect your personal information.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who may require reporting of processing activities in certain circumstances.
  • Third parties to whom we are required to disclose such information by law.
  • Third parties including other charities that we may work with to assist us in providing our services to our members.
  • Other charities that we may transfer parts of our business or assets to.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Some of our external third party service providers may use servers which are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to processing of your personal data
  • Request restriction of processing your personal data
  • Request transfer of your personal data
  • Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.