Please read the following policy to understand how your personal information will be treated. By visiting www.smartcjs.org.uk or www.smartfp.org.uk you are accepting the practices described here. This policy may change from time to time so please check back periodically.
In this policy, whenever you see the words ‘we’, ‘us’ or ‘our’, it refers to ‘SMART Criminal Justice Services’, known as ‘SMART’ (or ‘SMARTcjs’).
1. Introduction
We are committed to protecting your privacy and security online. This policy explains how and why we use your personal data, to make sure you remain informed and in control of your information.
2. Who we are
We provide support to those affected by issues such as substance misuse and homelessness. We are a charitable company, limited by guarantee. Our charity number is 1069087. Our company is registered in England, our registration number is 3398982 and our registered Office is SMART Support Services , c/o PEM Accountants, Salisbury House, Station Rd, Cambridge, MK42 0DH. We are registered with the Information Commissioner’s Office and our data controller number is Z5228920.
3. Information about you
We may collect personal information from you when you:
- Contact us through the website or any other channel
- Complete an online form
- Subscribe to any of our mailing lists
- Make a donation
- Interact with us via social media.
The personal information we collect from you may include, but is not limited to the following information:
- Name (including your first name(s) and surname)
- Date of birth
- Postal address
- Email address
- Phone number
- Information relating to your drug or alcohol use
- Bank and payment details
- Gift Aid Declaration
- IP address.
4. How we use this information
We may use your information to:
- Contact you if you have asked us to. For example, if you have completed our online referral form
- Send you communication which you have requested and that maybe of interest to you, such as e-newsletters, service news, service updates, general information or advice
- Notify you of changes to our services
- Respond to your questions or comments
- Conduct research and analysis on the services we provide and to look for ways we can improve on what we do
- Process a payment, donation or gift aid, confirm it has been received and say thank you.
When you subscribe to receive news and updates from us, we ask you for your consent to store your information and to contact you. We will only send you information for as long as you continue to consent. If you no longer want to receive these updates, please select ‘unsubscribe’ at the bottom of any automated emails sent from us.
We will not share your personal details with third parties, except where companies are providing services on our behalf, such as processing donations or sending out emails.
We contract the following third party providers, who may store and process your information on our behalf:
- Google Analytics to monitor the activity on our website. Google Analytics privacy policy
- Enthuse to manage online events, process donations and claims for gift aid. The information you provide when signing up, such as your payment details and contact information is held in accordance with their privacy policy. If you opt-in to further communications from SMART CJS, your data is transferred to us
- Infusionsoft (a Keap product) to provide our automated email marketing. The information you provide when you opt-in and submit SMART CJS online forms, or when consenting to receive e-newsletter, updates and information is stored and processed in accordance with their privacy policy
- Justin Chapman, an Infusionsoft Consultant to help us develop our automated marketing
- Zapier to transfer your information from enthuse to Infusionsoft. Zapier privacy policy
- Click4Assistance to provide live chat software on our website. Information. Click4Assistance privacy policy.
5. Who has access to your information?
SMART staff have access to your information, to provide services, respond to enquiries and to process payments.
We use third party providers (listed above in section 4), to process or hold your personal data in order to provide some services. For example, if you make a donation your personal data will be held by enthuse and SMART. These activities will be carried out under a contract which imposes strict requirements on our supplier to keep your information confidential and secure.
Occasionally, where we partner with other organisations, we may also share information with them. For example, if you register to attend an event being jointly organised by SMART and another organisation. We will only share information when necessary and we will make sure to notify you first.
There may be occasions when we need to share your details with other professionals if we are legally obliged to, or we if are concerned for your safety or the safety of someone else. For example, if you complete our online referral form and state that you intend to commit suicide, we will notify the relevant public services immediately to protect you.
We will never sell or rent your information to third parties.
We will never share your information with third parties for marketing purposes.
6. Your rights over your information
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate.
If you would like us to access, correct or update any information about you, please:
- Talk to a member of staff at your service
- Send an email to dataprotectionlead@smartcjs.org.uk
- Click ‘Request, review or update your personal information we hold’ link at the end of any e-newsletter or automated email update.
You can request for your information to be erased, please contact dataprotectionlead@smartcjs.org.uk. We may be unable to do this if we have a legal obligation to hold your data.
You can ask for a copy of the information SMART holds about you online (this is known as a ‘subject access request’), please contact dataprotectionlead@smartcjs.org.uk.
You can ask us to stop using your information – the simplest way to do this is to withdraw your consent, which you can do at any time, by clicking the unsubscribe link at the end of any e-newsletter or automated email update. You can also contact dataprotectionlead@smartcjs.org.uk.
7. Security of your information
We take reasonable precautions to prevent the loss, misuse or unauthorised alteration of the information you provide to us.
We use appropriate technical and organisational controls (including physical, electronic, and managerial measures) in place to protect your personal details. We assure the security of the servers or platforms upon which we store your data, which are based only within the EU or US.
When you are on a secure page (e.g. to make a payment), a lock icon will appear on the bottom of web browsers such as Chrome.
Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk.
8. Storage of your information
SMARTs operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we will only allow them to do so if your data is adequately protected.
For example, some of our systems use Infusionsoft (a Keap product). As a US-based company, it may be that using their products result in personal data being transferred to or accessible from the US. However, we will allow this as we are certain personal data will still be adequately protected (Infusionsoft is certified under the USA’s Privacy Shield scheme). Keap Data Security Statement.
We review our data retention periods for personal information on a regular basis. We only keep your information for as long as is reasonable and necessary for the relevant activity, which may be to fulfil statutory obligations (for example, the collection of Gift Aid). Or for example, if you have given us your details to sign up to for updates and news, we will only keep your information for as long as you continue to consent. If you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we may keep a record of your preference not to be emailed).
We continually review the information we hold and delete what is no longer required.
9. Use of Cookies
Like many other websites, the SMART website uses cookies. ‘Cookies’ are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.
This helps us to improve our website and deliver a better more personalised service. It is possible to switch off cookies by setting your browser preferences. Turning cookies of may result in a loss of functionality when using our website.
You can control and/or delete cookies as you wish—for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
10. Links to other websites
Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.
In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.
11. Children aged 13 and under
Our services are available to anyone, however we are concerned to protect the privacy of children. If you are aged under 13, please get your parent/guardian’s permission beforehand whenever you provide us with personal information. If you are experiencing difficulties you do not feel able to discuss with your parent/ guardian we recommend contacting Childline on 0800 1111.
12. Legal basis for information 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.
Informed consent and opt-in
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 general updates and news via post, phone, text or e-mail, or when we use written or verbal quotes from you in printed and online media, or in our public reports. 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
As noted in point 5, we will share 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 agencies and regulators such as the Charity Commission, Fundraising Regulator, Her Majesty’s Revenue and Customers, the Police, or to use information we collect about you for due diligence or ethical screening purposes.
Performance of a contract
We may 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 buy a ticket to one of our fundraising events or when you apply 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 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”.
We consider our legitimate interests to include all day-to-day activities that we carry out with personal information. Some examples not mentioned under the other bases above where we consider there to be a legitimate interest are:
- Analysis of our supporters using personal information we already hold
- Use of personal information to administer, review and keep an internal record of the people we work with, including supporters, donors and volunteers
- Use of personal information in research and evaluation, to assess the effectiveness of our various campaigns
- Use of personal information when we are monitoring use of our website.
14. Changes to this privacy policy
We will amend this Privacy Policy regularly to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.
15. Contact details
If you have any questions, comments or suggestions you can contact us at:
SMART Support Services
c/o PEM Accountants
Salisbury House
Station Rd
Cambridge
MK42 0DH
Email: dataprotectionlead@smartcjs.org.uk.
This Privacy Policy was last updated on the 15th of September 2022.