Privacy Notice
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This Privacy Notice explains how and why we collect and use your personal data. It also tells you about your privacy rights and how the law protects you.
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
If you have any questions about this Privacy Notice, or if you want to get in touch with us about something relating to your personal data, please send an email to hello@breadandbutterthing.org or text us on 07860 063304.
You have the right to make a complaint at any time to the Information Commissioner's Office (www.ico.org.uk), but we would appreciate the chance to respond to your concerns so we ask that you contact us first.
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When we talk about “we”, “us” or “TBBT” in the Privacy Notice we mean The Bread and Butter Thing.
We are a Charitable Incorporated Organisation registered with the Charity Commission with charity number 1169383.
We are the controller of your personal data, which means we are responsible for deciding how and why we use your personal data.
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Our website includes 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.
If you pay your membership fees through Apple Pay and Android Pay, or by debit card, your payment details will be processed by a third party – we do not collect or retain this information.
We do not control these third-party websites so, when you leave our website, we encourage you to read the privacy notice on every website you visit.
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Personal data means information that identifies you, such as your name or your personal email address. Personal data does not include information where your identity has been removed (anonymous data).
Special category data means personal data about your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation.
Criminal offence data means personal data relating to criminal convictions and offences. It also covers related security measures, such as data about penalties and conditions or restrictions placed on an individual as part of the criminal justice process.
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Our website and our services are not intended for children and we do not knowingly collect personal data relating to children.
When you use our website:
When you use our website, we may collect and use your:
• Identity Data including your first name and last name.
• Contact Data including your phone number, address, email and telephone number.
• Technical Data including your 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 the website.
• Usage Data including information about how you use our website.
• Communications Data including a request to send you our news updates and a record of your communication preferences.
We also collect Aggregated Data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. Aggregated Data is not normally personal data because it cannot be used to identify you. 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 in accordance with this Privacy Notice.
When you engage with our services, including as a member or volunteer:
When you engage with our services, including as a member or volunteer, we may collect and use your:
• Identity Data including your first name and last name.
• Visual Data including photographs or videos.
• Contact Data including your postcode, a record of your local hub, your email and telephone number.
• Usage Data including your use of our membership services.
• Profile Data including your communication preferences, feedback and survey responses.
• Communications Data including a request to let you know about our weekly shopping bags.
• Any other information that you choose to share with us, including any special category personal data (for example, if you tell us about a health condition), or criminal offence data (for example, if you tell us about any restrictions placed on you as part of the criminal justice process or if we carry out criminal record checks on our volunteers).
We also collect Aggregated Data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of members using a particular service. Aggregated Data is not normally personal data because it cannot be used to identify you. 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 in accordance with this Privacy Notice.
If you don’t provide your personal data:
If we need to use your personal data in order to provide our services to you, or if we are required by law to use personal data, and you fail to provide that data when requested, you may not be able to become a member, use our services, or volunteer with us.
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We usually collect personal data directly from you, for example when you fill out a form on our website, complete a survey, or send us a text message or email.
When you use 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 information about cookies below.
If you work or volunteer for us, we will automatically collect Visual Data via our CCTV systems in our warehouses and vans.
We receive Technical Data from third party analytics providers such as Google. We may also sometimes receive personal data from other third parties, such as the Disclosure and Barring Service if we ask you for a criminal record check when you volunteer with us.
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We will only use your personal data when the law allows us to. We refer to this as our ‘lawful basis’. Sometimes there may be more than one lawful basis for using your personal data.
• Membership – we rely on the legitimate interests lawful basis to use your Identity Data and Contact Data to:
o process your application to become a member of TBBT;
o send you weekly text messages to ask if you want a shopping bag or to tell you about services that are available in your local area (including services provided by other organisations);
o contact you if a particular item or service that you’ve told us you need is available;
o let you know when we are carrying out a survey to invite you to take part.
It’s up to you to decide whether you want to take us up on any offer – you don’t have to respond. If you don’t want to receive any of these member notifications from us, you can contact us to opt-out.
• Queries and Feedback – if you contact us with a query or to provide feedback, we’ll use your Contact Data and any other information that you give us to consider the matters you’ve raised and to respond to you. We rely on the legitimate interests lawful basis to do this.
• Photographs and Videos – from time to time we take photos and videos of the work we do, and the events we put on or take part in. We’ll always ask for your consent to use your Visual Data in photos or videos that we take.
• Operational Reasons – we rely on the legitimate interests lawful basis when we use your Usage Data to improve our website or services, to support our business operations.
• Marketing – if you’ve signed up to receive news and updates from us, we’ll use your Contact Data and Communications Data to send these to you. We’ll only send these sorts of marketing communications with your consent. We will not share your personal data with any third parties for marketing purposes.
• Volunteers – when you volunteer with us, we’ll use your Identity Data, Contact Data and any other information you give to us to keep volunteer records, to carry out any necessary checks (for example, criminal records checks) and to get in touch with you about volunteering opportunities. We usually rely on the legitimate interests lawful basis to use your personal data in this way, except where are required to use your personal data in order to comply with a legal obligation. If we carry out criminal records checks on volunteers, we rely on the substantial public interest condition for any criminal offence data that we receive.
· CCTV – if you work or volunteer for us, we will capture Visual Data via CCTV. Our CCTV is used to capture images only; we do not make audio recordings. We use CCTV cameras in our warehouses and vans. We do not use CCTV in areas which can reasonably be expected to be private, such as staff rooms, toilets and changing facilities. We rely on the legitimate interests lawful basis to collect and use CCTV footage, including for use: in the event of an investigation; or in connection with disciplinary action. We may share CCTV footage with third parties, such as the police, if we are satisfied there is a legitimate interest or if we are required by law to do so. We keep CCTV footage for 28 days unless we need to retain it for longer, for example if it is being used in connection with an investigation.
• Safeguarding and Emergencies – in rare situations we might rely on the vital interests lawful basis to use your personal data. This might happen in an emergency situation (for example, if we need to call the emergency services and you are not able to consent to your personal data being shared) or if we have a concern that you or another person may be in serious and imminent danger (for example, if we need to make a report to the local safeguarding authority or the police and we can’t ask for your consent).
If you choose to give us special category data or criminal offence data (other than as set out above) you consent to us keeping a record of that data and using it to provide our services to you. You have the right to withdraw your consent at any time by contacting us.
We may sometimes ask you to provide information for equalities monitoring purposes, including information about your age, health, race and ethnicity, sex and gender. You will always have the option of choosing not to give us this information and we never collect this information in a way that could be used to identify you.
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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 we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis that allows us to do so.
We may use your personal data without your knowledge or consent where this is required or permitted by law.
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Our website uses cookies and similar technologies, which are small files or pieces of text that download to a device when you access a website or app.
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, some parts of our website may become inaccessible or not function properly.
For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.
These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
These analytics and performance cookies are used on this website only when you consent via our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.
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We may share your personal data with:
• Service providers including third parties that we use to help us provide our membership services (for example, to send text messages to you) or to support the delivery of, provide functionality on, or help to enhance the security of our website.
• Professional advisers acting as processors or joint controllers including our lawyers, bankers, accountants, auditors and insurers.
• HM Revenue & Customs, our regulator the Charity Commission, and other public authorities acting as processors or joint controllers who may require reporting of processing activities in certain circumstances.
• Third parties to whom we are required to disclose such information by law (for example, if required by a court order to share personal data).
• Other charities and organisations that we work with to assist us in providing our services to our members.
• As part of a sale, transfer or merger of parts of our organisation or our assets. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with UK data protection law. We do not allow our third-party service providers to use your personal data for their own purposes.
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Some of our external service providers may use servers which are based outside the UK and European Economic Area (EEA), which means your personal data may be transferred outside the UK and EEA.
Whenever we (or one of our service providers) transfer your personal data out of the UK or EEA, we ensure safeguards are in place to ensure your personal data continues to be protected:
• Some countries have been deemed to provide an adequate level of protection for personal data. You can find a list of those countries here.
• Transfers of personal data to countries without adequacy regulations are carried out under the International Data Transfer Agreement or European Standard Contractual Clauses.
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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.
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How long will we keep your personal data for?
We will only keep 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.
If you are a member of TBBT and we don’t hear from you after a period of time, we may get in touch to let you know that we will remove you from our membership list unless you contact us to tell us you’d still like to be a member.
In some circumstances we will anonymise your personal data for research or statistical purposes, in which case it will no longer be personal data.
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You have the right to:
• Request access to your personal data (commonly known as a 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.
• Ask us to correct personal data that we hold about you which is incorrect, incomplete or inaccurate.
• Withdraw your consent at any time if you have given consent to us using your personal data.
In certain circumstances, you also have the right to:
• Ask us to erase your personal data from our files and systems where there is no good reason for us continuing to hold it.
• Object to us using your personal data to further our legitimate interests (or those of a third party), or where we are using your personal data for direct marketing purposes.
• Ask us to restrict or suspend the use of your personal data, for example, if you want us to establish its accuracy or our reasons for using it.
• Ask us to transfer your personal data to another person or organisation
• Data protection law gives you rights in relation to any automated decision making which has a legal effect or otherwise significantly affects you. We do not currently make any decisions using solely automated means which produce a significant legal effect.
If you want to exercise any of these rights, please send an email to hello@breadandbutterthing.org.
No fee usually required
You will not usually have to pay a fee to exercise any of these rights, unless we believe your request is unfounded, repetitive or excessive. In such cases, we can choose to charge you a reasonable fee for complying with your request or we can refuse to comply with your request.
What we may need from you
We may need to request 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.