This policy describes how and why Manchester Pride uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information.
We promise to respect any of your personal information which is under our control and to keep it safe. When we collect your information, we aim to be clear about how we use your data.
We are a small charity and only collect information that helps us better serve our supporters and those who have a genuine interest in the work that we do.
Our use of personal information allows us to keep you up to date on stuff that you’ve told us you’re interested in, such as our events, the activities we undertake, relevant opportunities such as fundraising, volunteering or jobs within our organisation.
This policy is effective from 25th May 2018.
WHO WE ARE
Manchester Pride is a charity which campaigns for equality; challenges discrimination; creates opportunity for engagement and participation; celebrates lesbian, gay, bisexual and transgender life; and fundraises to enrich and empower LGBT+ organisations, charities and communities in Greater Manchester. Manchester Pride is a registered charity (no. 111784) and company limited by guarantee (no. 4671318). The registered address is Manchester One, 53 Portland Street, Manchester, M1 3LF. Manchester Pride comprises of Manchester Pride Events Limited and Manchester Pride Limited.
HOW WE COLLECT INFORMATION ABOUT YOU
We collect information in the following ways:
Information you provide to us directly
You may give us your information in order to sign up for one of our events or activities, make a donation, purchase our products, register as a volunteer, apply for funding or otherwise communicate with us.
In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website 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.
Information you provide to us indirectly
Your information may be shared with us by third parties, for example:
professional fundraising agencies; including fundraising sites like Just Giving; if you sign up as a volunteer for us through a volunteer centre or external volunteering website;
We also may receive data about you from subcontractors acting on our behalf who provide us with technical, payment or delivery services, and from business partners, advertising networks and search/analytics providers used on our website.
Information from other sources
We also use information from the following sources:
Social Media - Depending on your settings or the privacy policies for social media and messaging services like Facebook, Instagram or Twitter, you might give us permission to access information from those services, for example when you publicly tag us in an event photo.
WHAT PERSONAL INFORMATION WE COLLECT
We collect, store and use the following kinds of personal information:
your contact details (including postal address, telephone number, e-mail address and/or social media identity);
your date of birth;
your bank or credit card details where you provide these to make a payment (these are not stored, only used at point of sale);
if you volunteer for us or apply for a job with us, information necessary for us to process these applications and assess your suitability (which may include things like employment status, previous experience depending on the context, as well as any unspent criminal convictions or pending court cases you may have);
if you apply for funding, information necessary to process your application; information about your activities on our website(s) and about the device you use to access these, for instance your IP address and geographical location;
information about events, activities and products which we consider to be of interest to you; information relating to your health (for example if you are taking part in or attending an event for health and safety purposes i.e. a physical activity such at Ten Peak Challenge or running event, such at the 10K) where you have left us a legacy, any information regarding next of kin with which you may have provided us to administer this;
information as to whether you are a taxpayer to enable us to claim Gift Aid;
age, nationality and ethnicity information for monitoring purposes;
and any other personal information you provide to us.
Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this type of sensitive data would be information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality or genetic/biometric information.
We only collect this type of information about our supporters to the extent that there is a clear reason for us to do so, for example asking for health information if you are taking part in a sporting event, or where we ask for information for the purpose of providing appropriate facilities or support. We will also collect this type of information if you make it public or volunteer it to us – for instance if you tell us you have a disability or impairment when applying for a volunteer role.
Wherever it is practical for us to do so, we will make why we are collecting this type of information clear and what it will be used for.
HOW WE USE YOUR INFORMATION TO TELL YOU ABOUT OUR WORK
Sending marketing communications
Our marketing communications include information about our events, activities, campaigns and work and requests for donations or other support. Occasionally, we may include information from partner organisations or organisations who support us in these communications.
We operate an ‘opt-in only’ communication policy. This means that, except as set out below, we will only send marketing communications to those that have explicitly stated that they are happy for us to do so.
We may use information you have given us directly, for example the record of your previous donations to and/or relationship with us, your location and demographics, as well as the type of activity you have been involved with, to tailor our communications with you about future activities.
Events and fundraising
When you have asked for details of a Manchester Pride event, we will send you information including, where relevant, ideas for fundraising and reminders on key information about the activity.
Where you have signed up for an event with a third party (for example the The Manchester 10K) and told the event organiser that you wish to fundraise for us, we may contact you with information and support for your fundraising for that event.
Managing your contact preferences
We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions and we include information on how to opt out when we send you marketing. If you don’t want to hear from us, that’s fine, and you can change your preferences at any time. Just let us know when you provide your data or contact us on 0161 831 7700, email email@example.com, or visit our webform.
If you’ve decided you don’t want to be contacted for marketing purposes, we may still need to contact you for administrative purposes. This may include where we are processing a donation you’ve made and any related Gift Aid, thanking you for a donation or participation in an event, or keeping in touch with you about volunteering activities you are doing for us.
LEGAL BASIS FOR PROCESSING DATA
Data protection laws mean that each use we make of personal information must have a “legal basis”. The relevant legal bases are set out in the General Data Protection Regulation (EU Regulation 2016/679) and in current UK data protection legislation.
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing material via post, phone, text or e-mail). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner or Gambling Commission, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying something from us (for instance some branded merchandise or, in some cases, an event place), applying to work/volunteer with us, or where we are providing funding.
We have a basis to use your personal information where it is necessary for us to protect life or health. For instance if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights).
We consider our legitimate interests to include all of the day-to-day activities Manchester Pride carries out with personal information. Some examples not mentioned under the other bases above where we are relying on legitimate interests are:
analysis and profiling of our supporters using personal information we already hold;
updating your address using third party sources if you have moved house (please see the “Keeping your information up to date” section below for more on this);
use of personal information when we are monitoring use of our website or apps for technical purposes;
use of personal information to administer, review and keep an internal record of the people we work with, including supporters, volunteers and researchers;
sharing of personal information between relevant teams and committees within Manchester Pride;
where you have signed up with us on a charity place for a third party event (for example a sponsored run not organised Manchester Pride),
sharing personal information with the third party event organiser so they can administer the event. We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
When we use sensitive personal information (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
HOW WE KEEP YOUR INFORMATION SAFE
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details. For example our online forms are always encrypted and our network is protected and routinely monitored.
HOW LONG WE KEEP PERSONAL INFORMATION FOR
We keep personal data collected via applications forms (i.e. Volunteer Applications, Parade Applications, Job Applications, etc for 2 years). We keep financial information for 7 years for tax and auditing purposes.
SHARING YOUR INFORMATION WITH OTHER ORGANISATIONS
As set out in the “Sending marketing communications” section above, we will never sell or rent your information to third parties for marketing purposes. However we may disclose your information to third parties in connection with the other purposes set out in this policy. These third parties may include:
business partners, suppliers and sub-contractors who may process information on our behalf; if you are a volunteer or in receipt of a funding grant; if you are a legacy giver, we may share information with co-beneficiaries; advertisers and advertising networks analytics and search engine providers; IT service providers.
Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider this necessary, to protect the rights, property or safety of Manchester Pride, its personnel, visitors, supporters or others.
KEEPING YOUR INFORMATION UP-TO-DATE
Every 2 years we may contact you to see if you are still interested in receiving marketing communications from us. At this point, we will ask you to up-date your contact preferences and to check if the information we have for you is up-to-date. You can do this at any point and the decision to receive information from us will always be yours. Update preferences now.
Under UK data protection law, you have rights over personal information that we hold about you. We’ve summarised these below:
Right to access your personal information
You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply.
If you want to access your information, send a description of the information you want to see by post to Manchester Pride, Suite 9c, Manchester One, Portland Street, Manchester, M1 3LD or by email to firstname.lastname@example.org
Right to have your inaccurate personal information corrected
You have the right to have inaccurate or incomplete information we hold about you corrected. If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and, where applicable, correct any inaccuracies.
Right to restrict use of your personal information
You have a right to ask us to restrict the processing of some or all of your personal information in the following situations: if some information we hold on you isn’t right; we’re not lawfully allowed to use it; you need us to retain your information in order for you to establish, exercise or defend a legal claim; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.
Right to erasure of your personal information
You may ask us to delete some or all of your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done.
Right for your personal information to be portable
If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.
Right to object to the use of your personal information
If we are processing your personal information based on our legitimate interests or for scientific/historical research or statistics, you have a right to object to our use of your information.
If we are processing your personal information for direct marketing purposes, and you wish to object, we will stop processing your information for these purposes as soon as reasonably possible.
If you want to exercise any of the above rights, please contact us at Data Champion, Manchester Pride, Suite 9C, Manchester One, 53 Portland Street, Manchester, M1 3LD or by email to email@example.com. We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office.
CHANGES TO THIS POLICY
If you have any questions, comments or suggestions, please let us know by contacting the Data Champion, Manchester Pride, Suite 9C, Manchester One, 53 Portland Street, Manchester, M1 3LD or email firstname.lastname@example.org
If you have any questions, comments or suggestions, please let us know by emailing email@example.com or by phone on 0161 831 7700.
Manchester Pride has a designated Data Champion, who can be contacted at: Data Champion, Manchester Pride Suite 9c Manchester One 53 Portland Street Manchester M1 3LF