This policy describes how and why Over The Wall 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. We aim to be clear when we collect your information about what we will do with it.
 
We are a national charity with relationships with families, fundraisers, volunteers, supporters and researchers, so we use personal information on a day to day basis in order to operate. Our use of personal information allows us provide free residential camps for children and their families effected by serious illness, make better decisions, recruit the best volunteers and fundraise more efficiently.
 

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 register to attend camp as a camper or family member, register as a volunteer, sign up for one of our events, make a donation, register as an ambassador for us, or otherwise communicate with us.
 
When you use our website, we collect your personal information using “cookies” and other tracking methods. There are more details on the cookies and tracking methods we use in our Cookie Policy.
 
In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website or apps 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 referral agencies;
* Medical information provided by medical professionals in support of camp applications
* independent event organisers, for example the London Marathon or fundraising sites like Just Giving or Virgin Money Giving;
* if you sign up as a volunteer for us through a University, Job 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.
 
You should check any privacy policy provided to you where you give your data to a third party.
 
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, WhatsApp or Twitter, you might give us permission to access information from those services, for example when you publicly tag us in an event photo.
 
Information available publicly
 
We supplement information on our supporters with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of Over The Wall. For more information, please see our section on “Building profiles of supporters” below.
 

What personal information we collect
We collect, store and use the following kinds of personal information:
 
* your name;
* your contact details (including postal address, telephone number, e-mail address and/or social media identity);
* your date of birth;
* your gender;
* your bank or credit card details where you provide these to make a payment;
* 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);
* 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 applying for Camp we collect information to assess eligibility or if you take part in or attend an event for health and safety purposes);
* 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 to assess camp applications or 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 health condition when applying for an Ambassador 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
We will use your personal information to:
 
* provide you with the services, products or information you asked for;
* administer your donation or support your fundraising, including processing Gift Aid;
* keep a record of your relationship with us;
* respond to or fulfil any requests, complaints or queries you make to us;
* understand how we can improve our services, products or information by conducting analysis and market research;
* manage our events;
* check for updated contact details against third party sources so that we can stay in touch if you move (see “Keeping your information up to date” below);
* further our charitable objectives;
* register, administer and personalise online accounts when you sign up to products we have developed;
* send you correspondence and communicate with you;
* process applications for camp places (both camper and volunteer);
* administer our websites and to troubleshoot, perform data analysis, research, generate statistics and surveys related to our technical systems;
* testing our technical systems to make sure they are working as expected;
* contact you if enter your details onto one of our online forms, and you don’t ‘send’ or ‘submit’ the form, to see if we can help with any problems you may be experiencing with the form;
* display content to you in a way appropriate to the device you are using (for example if you are viewing content on a mobile device or a computer);
* generate reports on our work, services and events;
* safeguard our campers, volunteers and staff;
* conduct due diligence;
* monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
* process your application for a job or volunteering position;
* conduct training and quality control;
* audit and administer our accounts;
* meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
* carry out fraud prevention and money laundering checks;
* undertake credit risk reduction activities; and/or
* establish, defend or enforce legal claims.
 

How we use your information to tell you about our work
Sending marketing communications
 
Our marketing communications include information about our camp applications, campaigns 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 an Over The Wall 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 London Marathon) 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 02392 477110 or click here.
 
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.
 
Building profiles of supporters
 
At Over The Wall, our life-changing work is only made possible thanks to the generosity of our supporters – so it’s vital that our fundraising efforts are as effective as they can be. By developing a better understanding of our supporters through publicly available sources we can tailor and target our fundraising events and communications (including volunteering opportunities) to those most likely to be interested in them. This allows us to be more efficient and cost-effective with our resources, and also reduces the risk of someone receiving information that they might find irrelevant, intrusive or even distressing.
 
Which information do we use?
 
We use existing data from Over The Wall’s own database and combine this with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of Over The Wall. We only use reputable sources, where someone would expect their information may be read by the public. We avoid any data that we believe has not been lawfully or ethically obtained, and we do not use information sources which have not been broadcast or made public.
 
We’re committed to putting you in control of your data and you’re free at any time to opt out from this activity. To find out more, please contact 02392 477110 or click here.
 

Legal basis for processing
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.
 
Specific consent
 
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.
 
Legal obligation
 
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 use information we collect about you for due diligence.
 
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 applying to attend camp, buying something from us (for instance some branded merchandise or, in some cases, an event place) or applying to work/volunteer with us.
 
Vital interests
 
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 camp, at one of our events, or a safeguarding issue which required us to contact people unexpectedly or share their information with emergency services.
 
Legitimate interests
 
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 Over The Wall carries out with personal information. Some examples not mentioned under the other bases above where we are relying on legitimate interests are:
 
* Assessing applications to attend camp as a camper of volunteer
* 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 Over The Wall;
* where you have signed up with us on a charity place for a third party event (for example a sponsored run not organised by Over The Wall), 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).
 
Public Task
 
If the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
 

How we keep your information safe
Over The Wall has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations. For instance we are required to keep some personal information for insurance, tax or health and safety purposes, as well as keep a record of your interactions with us.
 

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 researcher, volunteer advisory panels, any joint funders of research, host institutions and external members of our committees;
* 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.
 
Some of our suppliers run their operations outside the European Economic Area (EEA) – this may include a country which may not be subject to the same data protection laws as companies based in the UK. In these circumstances, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.
 
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 Over The Wall, its personnel, visitors, users or others.
 

Keeping your information up to date
We may use information from external sources such as the post office national change of address database and/or the public electoral roll to identify when we think you have changed address so that we can update our records and stay in touch. We only use sources where we are confident that you’ve been informed of how your information may be shared and used.
 
We do this so we can continue to contact you where you have chosen to receive marketing messages from us and contact you if we need to make you aware of changes to our terms or assist you with problems with donations.
 
This activity also prevents us from having duplicate records and out of date preferences, so that we don’t contact you when you’ve asked us not to.
 
We’re committed to putting you in control of your data and you’re free at any time to opt out from this activity. To find out more, please contact 02392 477110 or click here.
 
We really appreciate it if you let us know if your contact details change.
 

Your rights
Under UK data protection law, you have rights over personal information that we hold about you. We’ve summarised these below:
 
11.1 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 Over The Wall, Langstone Technology Park, Langstone Road, Portsmouth, PO9 1SA or by email info@otw.org.uk
 
11.2 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.
 
11.3 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.
 
11.4 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.
 
11.5 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.
 
11.6 Right to object to the use of your personal information
 
If we are processing your personal information based on our legitimate interests 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 Over The Wall, Langstone Technology Park, Langstone Road, Portsmouth, PO9 1SA or by completing this form. 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.
 

1. Complaints
If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve. You can find out more and read our Complaints Policy, which can be found on our website.
 
You also have the right to lodge a complaint about any use of your information with the Information Commissioners Office, the UK data protection regulator.
 

2. Changes to this policy
We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on the Over The Wall Website or by contacting you directly.
 

3. Contact us
If you have any questions, comments or suggestions, please let us know by contacting our team at info@otw.org.uk or by phone on 02392 477110.
 
Over The Wall
Langstone Technology Park
Langstone Road
Portsmouth
PO9 1SAUpdate your preferences.