We promise to only contact you in a way that works for you, and make it easy for you to tell us how you would like to receive information from us.
You are a crucial part of the Sands story and its work supporting bereaved parents, making change happen and working to ensure that fewer babies die. We need to ensure we can reach you in the right way and at the right time for the moments that matter. As such, we promise to only contact you in a way that works for you, and make it easy for you to tell us how you would like to receive information. We want you to always be completely comfortable with how your personal data is gathered and used. We also follow all applicable fundraising and data protection legislation and guidelines.
We ensure, as a minimum, that we use your data in accordance with all applicable laws concerning the protection of personal data. This policy explains:
- What data Sands may collect about you.
- How we will use that data.
- Whether we disclose your details to anyone else.
- How we manage your personal data – security, storage and retention.
- Your choices regarding the data you provide to us.
2. Questions and changes to this policy
Any questions you have in relation to this policy or how we use your personal information should be sent to firstname.lastname@example.org or addressed to:
Sands Data Protection,
Supporter Care Team,
49-51 East Road,
London, N1 6AH.
Please note that from time to time we may need to amend or update this policy, for example if there is a change in the way that we use personal information or because of updates to the law. You should periodically check this website to make sure that you have seen the most up to date version of this policy.
3. About Sands
Please read the following carefully to understand our safeguards and practices regarding your personal data and how we will treat it.
4. Information we collect from you and how we use it
4.1 Information you give us
This is information about you that you give us by filling in forms on our site or by corresponding with us by telephone, post, email or otherwise. It includes information you provide when you register to use our site, participate in discussion boards, private messaging or other functions on our site, and when you report a problem with our site. The information you give us may include your name, email, address and telephone number and other information as you choose to disclose.
4.2 When you give us information
When you engage with us we may ask for personal information when you: make a donation to us, register for an event or a campaign, subscribe to a newsletter, engage with our social media, communications or support, information and training services, or provide us with personal information in any other way. This information may include:
- Your name, postal address, email address and telephone number.
- Financial data (such as bank account details provided by you, and whether donations are gift-aided. See Section 12).
- A record of the financial donations that you have made and data about your tax status for Gift Aid purposes.
- Details of your indicated interests, opinions, preferences and the ways you support or have supported us – e.g. in relation to any campaigns, events or fundraising activities you have participated in. When you receive a communication we may collect data about how you respond to or interact with that communication, and this may affect how we communicate with you in future.
When you provide your personal information to Sands please ensure that it is accurate and up to date. This will allow us to contact you effectively and efficiently in order to deal with your donations, fundraising, support, information or training questions/needs or provide you with data about our work. Please get in touch if you would like to change the personal details that we hold about you by contacting our Supporter Care Team at the address provided below.
4.3 When you use Sands websites
When you use our websites: Sands.org.uk (including affiliated websites and microsites including saferpregnancy.org.uk and Sands volunteer group websites) we use a third party service, 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 parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow any third party to make, any attempt to find out the identities of those visiting our website.
When you provide your personal details when filling out a registration form, making a donation, sharing your story via webform, communicating with us or signing up for or receiving a service on our websites, we will collect this data and store it in your record so as to fulfil your request, answer your enquiries and keep a record of our correspondence with you.
- The form used on Sands Online Shop will collect data – such as your name, email and postal address – that will allow Sands to identify you on each occasion that you make a purchase or make a donation. Our other online forms also allow us to do this in order to help us provide certain information about you when you complete them. This may help to automatically fill in information about your name, or your contact preferences.
- To allow us to collect statistical and performance data about how the website is used. We may collect geolocation data about your geographic location, the mobile device that is used and to confirm what browser you are using, and computer operating systems that are being used. This data doesn’t contain any identifiable information about people. We use this data to improve the functionality of our website and ensure you have a good experience when browsing it.
- Facebook, Twitter and LinkedIn pixel cookies are used to collect data about which sections of the website are accessed by people who are registered users of these social media services. These service providers collect this data, which then allows Sands to reach new audiences. Sands only has access to aggregated data from these companies, not identifiable personal information.
- When a supporter creates a fundraising page or makes a donation through a third party platform, we will store the data about the donation and who sent it.
4.4 Links on our website
Our site may, from time to time, contain links to third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
4.5 When you use social media
When you view content published by Sands using social media hosted across various platforms, we will collect and receive information that provides aggregate data relating to items such as video views, demographics and location data. Sources of this data may include:
Identifiable personal information about people who access these platforms is collected in order to allow Sands to reach and market new audiences.
We may sometimes collect additional data about you from other organisations or companies that provide data from publicly available sources, so we can make it easier for you to support Sands by providing you with details about the types of activities and services we can offer. We ensure that such data is only collected from legitimate sources on a lawful, fair and transparent basis in accordance with applicable data protection law.
The data about you that we may collect from third parties can include:
- Your name, postal address, telephone number, email, for example from JustGiving, Virgin MoneyGiving, MuchLoved, CAF and Charities Trust, which are our online services for making direct donations and donations generated from fundraising by Sands supporters
- Data to categorise and create supporter categories. This does not include information that identifies people specifically, only creating profiles of general factors that we use to categorise sections of our records.
4.6 When you use the Sands online shop
Where you make an order from Sands shop or make a donation, we will process your personal data to provide these services to you. Our use of your personal data in this way includes, in particular, passing your personal data through our secure database which generates your contact record. We need to process your personal data in this way to record and track your donations and orders
5. Disclosure of your information to third parties
We may also disclose when one or more of the following apply:
- If you have specifically agreed that we may share your personal information to those third parties or individuals for a particular purpose.
- When we use other companies (known as 'data processors') to provide services on our behalf who are only processing personal information in accordance with our instructions. For example, companies that provide: direct mailing or marketing services that send material to you by post, email or text message, customer analysis, assessment, profiling and when using auditors or advisors. Also, we may use third party organisations (again processing data under our instructions) to carry out fundraising on our behalf. For example, we may use a company to call supporters who have agreed to be contacted by telephone about a campaign, appeal or donations.
- If Sands uses Facebook, Twitter and LinkedIn targeted advertising that involves sharing selected supporter information with these social media platforms to create new audiences for advertising. The process is secure and Facebook, Twitter and LinkedIn delete the personal information sent to them once new audience profiles of their users have been created. No new personal information would be added by us to your supporter record as a result of this.
- Processing credit/debit card payments. Sands does not handle or store credit/debit card data itself, but uses secure debit and credit card processing services that are provided by Smart Debit, Sage Pay in accordance with Payment Card Industry (PCI) standards. Debit and credit card data will be collected directly by these card processing service providers when you make a donation to Sands or buy something using Sands Shop.
- We may disclose aggregate statistics about our supporters and online shop sales to describe our services and operations to prospective partners, advertisers, other reputable third parties and for other lawful purposes – these statistics do not include any information that identifies people.
6. Information created by Sands
6.1 Internal supporter research and profiling
We complete research by analysing the success of our campaigns and events, so as to identify patterns, trends and areas for future development. Having this information allows us to better understand our supporters, improve our relationship with you and provide you with a better supporter experience. By doing this, we ensure supporters are only provided with the communications, products and data which are important to them, and that our charity resources are used in a cost effective way.
To achieve this, we analyse and research supporter data to group people together in terms of common characteristics in order to offer you more relevant and tailored information, advertising, services and communications.
We keep track of the amount, frequency and value of each person’s support. If, based on data that has been provided to us (such as geographical location, demographics, or previous donations), it appears you may be willing and able to provide more to support Sands’ mission, then we may contact you to see if you wish to do so.
We may also obtain data from other sources, which is available on public and commercial databases. This may include obtaining data related to life-style and socio-economic categories. This data is analysed and modelled with a view to creating clusters of supporter types. Attributes are not personalised to individuals, but are modelled assessments that ascribe a generalised score or measure to supporter records found in each cluster.
We may also conduct supporter research that includes collecting data from public sources about a limited number of supporters who we think can influence policymakers to promote the interests of bereveaved families and who could affect change that could help reduce the number of babies dying. We may also research supporters who we believe can become significant financial supporters of Sands’s mission, including well-known or influential people. We make sure that the sources we use are reputable public databases such as Companies House, mainstream news outlets or other reliable media sources. These sources may include:
- Civil Society and Fundraiser Magazine
- Electoral Commission
- Management Today
- Sunday Times Rich Lists
We will make sure that we do not use data about individuals that is clearly intended to be private or collect information in a privacy intrusive manner that would not reasonably be expected by you. We will also inform you of this use as soon as is reasonably possible.
7. Sensitive or special category information
Sands may collect what's known as ‘special category’ or ‘sensitive’ personal information about supporters – this includes data relating to someone’s health or type of bereavement they have experienced mainly - but also occasionally ethnic origin, religious beliefs or political affiliation. On the occasions when Sands does collect this type of sensitive personal information it will be for specific activities or events. For example:
- A sponsored marathon race or other fundraising activities, such as trekking. We will however only collect this data with your consent, usually with the aim of providing you with the necessary support and assistance to allow you to safely participate in these types of event (for example, information about health).
- There may also be occasions when you share a story or experience about yourself and/or a bereavement that includes sensitive personal information relevant to Sands’ mission to be used in a campaign or related marketing of a particular service or activity. When your information is collected in this way we will always tell you how your information will be used and obtain your explicit consent to use it in this way.
Sands will not knowingly contact anyone under the age of 18 to ask them for donations or other forms of financial contribution.
We may however send a ‘thank you’ administrative communication to the child if they have fundraised in support of Sands which may or may not be sent via the parent or guardian depending on the contact information submitted.
9. Legal Basis
Sands relies on the following legal conditions that are described in the EU General Data Protection Regulation to use your personal information in the ways described in this privacy notice:
- Consent: when you consent or opt-in to receive information and marketing by email. We use this consent to offer you marketing using email as well as targeted advertising, including through social media sites, such as Facebook, Twitter and LinkedIn.
- Legal obligations: where we are under a legal obligation to process your personal data for a particular purpose. For example, obligations we have to hold information about donations or manage Gift Aid information in compliance with applicable tax laws. We may also sometimes need to process personal information for the purpose of us being able to establish or exercise our legal rights or to defend legal claims.
- Legitimate interest: where we have a legitimate interest. This is the legal basis that we rely on to send information and marketing by email, post or telephone when you take part in supporting Sands’ mission by making a donation, or requesting information about our work, marketing, campaigns and events or other services.
- We will also have a legitimate interest in being able to use and process personal information for internal administrative purposes, and when it is necessary to take measures to protect our IT network and data security or to protect ourselves (and our beneficiaries and supporters) from risks to our charity such as fraud, criminal conduct or reputational damage. When processing your personal information based on a legitimate interest, we will make sure that it is exercised proportionately and is always balanced against the privacy rights and other legal rights you have as an individual.
- Contract: where we agree to provide any products and/or services to you, we will use your personal information in order to arrange for the provision of those products and/or services as well as performing obligations to you or enforcing our rights under any contract we have with you.
- If we are processing any personal information that is regarded as ‘special category’ or ‘sensitive’ as referred to above, we will only do this with your explicit consent; or, where needed to protect your vital interests (or those of someone else) in an emergency; or, where you have already publicised such information (such as your political affiliations); or, where we have a need to use such data in connection with a legal claim relevant to us; or, if you have provided to us information relating to your experience of the loss of a baby to ensure you are targeted with the right services and information.
9.1 Marketing, campaigning and fundraising
We provide direct marketing, campaigning and fundraising communications to supporters which includes news, information and data about:
- Sands and our work with bereaved families, healthcare and other professionals; research, policy and influencing; improving bereavement support and bereavement care; and related events and campaigns.
- Campaigns to support bereaved families; raising awareness of the issues concerning bereavement care and bereavement support; issues and factors relating to safer pregnancy; and research, policy and practice at local and national level relating to reducing the numbers of babies dying and improving bereavement care.
- Online and paper petitions relating to campaigns.
- Opportunities to volunteer (for example as part of Sands Groups activity, befriending, knitting, fundraising related support).
- Appeals and fundraising (including donations, competitions, raffles and similar promotional activities).
- Our events, activities and Sands Groups activities.
- Products and services offered by Sands Online Shop.
- Leaving a legacy.
- Newsletters and updates.
Sands relies on donations and support from others to continue its work on behalf of bereaved families and creating a world where fewer babies die. Being able to contact you for marketing and campaigning reasons is an important part of our fundraising, change activities and purpose.
Fundraising and campaigning for improvement is an important part of our marketing and change activity, but we will not share your data with any other organisation, individual or company to allow them to use your personal information for marketing or campaigning purposes, unless we have obtained your specific, freely given, informed and unambiguous consent to do so.
9.2 Anonymised data
We may aggregate and anonymise personal information so that it can no longer be linked to any particular person. This anonymised data can be used for a variety of purposes (such as recruiting new supporters) or to identify trends or patterns within our existing supporter base. This data helps inform our actions and improve our campaigns, products, services and materials.
10. You are in control
You can change your personal information and preferences about how we contact you whenever you choose.
10.1 How to change or stop us contacting you by post, telephone, email or text message.
You can change or update your contact preferences at any time or contact our Supporter Care team at:
Sands Data Protection,
Supporter Care Team,
49-51 East Road,
London, N1 6AH.
Or telephone 0203 908 5525 or email email@example.com
10.2 How to unsubscribe from Sands email newsletters
If you have previously opted-in to receive email communications from Sands but no longer wish to receive email communications, please click the unsubscribe link at the bottom of any of our emails to be removed from our list or contact our Supporter Care Team.
11. How we protect your personal data
Sands considers keeping your information safe to be vitally important. We employ a variety of physical, organisational and technical measures to ensure we do this, and prevent unauthorised access to – or use or disclosure of – your personal information.
Electronic data and databases that contain supporter personal data are stored on secure computer systems and we manage who has access to that data (using both physical and electronic means). Our staff receive data protection training and we have a set of detailed data protection procedures and policies which staff must follow when handling personal information.
All hard-copy records and data are managed securely in access-restricted storage.
11.1 Payment security
All electronic forms that request financial data will use the Secure Sockets Layer (SSL) protocol to encrypt the data between your browser and our servers.
If you use a debit/credit card to donate or purchase something online your debit/credit card details are transferred securely to our payment card providers Smart Debit and Sage Pay who comply with the payment card industry data security standard (PCI-DSS) published by the PCI Security Standards Council. We do not store any payment card information.
We cannot guarantee the security of your home computer or any information sent over the internet or any publicly accessible communications network and using any online communications services are at the user’s own risk.
11.2 Where we store personal information:
Sands is based in the UK. Wherever possible we store our data in the UK or within the European Union (EU). Some organisations and companies that provide services to us transfer personal data to territories outside of the EU such as Canada, a country whose legal system the EU Commission considers to have adequate data protection standards, or to the United States which does not have such EU approval in relation to its data protection standards. However in that case, we will only allow such a transfer when there is recognised assurance, such as the service provider being a member of the EU-US Privacy Shield Framework (eg Facebook, Twitter, LinkedIn) or we have put other legally appropriate safeguards and/or contracts in place to ensure that your data is adequately protected in accordance with EU privacy standards.
11.3 How long we store data
We will only use and store personal information for as long as it is required for the purposes it was collected for.
Our data protection policy sets out the different periods we retain personal information for in respect of these relevant purposes in accordance with our duties under applicable data protection law. The criteria we use for determining these retention periods is based on various legislative requirements; the purpose for which we hold data; and guidance issued by relevant regulatory authorities including but not limited to the Information Commissioner's Office (ICO). Personal information that we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it. Some personal information may be retained by us in archives for historical research purposes, although we will do this in a manner that complies with applicable data protection law.
We continually review what personal information and records we hold, and delete what is no longer required. We never store payment card data.
12. Your rights
As part of our promise to you, we want to make sure that you are able to make your own choices about how we use your personal information. Part of this is making sure you understand your data protection rights, which are set out as follows:
- You have certain rights of access in relation to your personal information. We will confirm whether or not we have your data and, if we do, provide a copy of the personal information we hold and other information about how we process your information within relevant timescales (usually a month for simple requests and timescales can be extended for complex requests) (Right of Access – Data Subject Access Request).
- The right to have your personal information that we no longer need erased from our records (Right to be Forgotten).
- The right to have inaccurate personal information amended (Right to Rectification).
- The right to ask us to stop using your information in certain situations (Right to Restrict Processing).
- The right to object to your personal information being used for marketing or profiling (Right to Object).
- A right (in certain circumstances) to have a copy of your personal information provided for reuse in another service (Right to Data Portability).
If you would like further details about your rights or would like to exercise them, please write to our Supporter Care Team
firstname.lastname@example.org or addressed to:
Sands Data Protection,
Supporter Care Team,
49-51 East Road,
London, N1 6AH.
We reserve the right to ask for further information to verify your identity (or clarify the information that you are seeking) when we receive such a request.
If you are dissatisfied with the response from Sands you can contact the UK Information Commissioner's Office (ICO) as follows:
Information Commissioner's Office,
Telephone: 0303 123 1113 (local rate) or 01625 545 745
Fax: 01625 524 510
Remember, you can change the way you hear from us or withdraw your permission for us to process your personal details at any time by contacting our Supporter Care Team on 0203 908 5525 or at email@example.com