Privacy statement

Centrepoint takes your privacy seriously. Here's how we collect, share, process and store your personal information.

At Centrepoint we rely on the support of individuals like you to carry out our vital work with homeless young people. This is why we want to be completely transparent about why we need the personal details we request when you communicate with us and how we use the data once we collect it.

Developing a better understanding of our supporters through their personal data allows us to fundraise more efficiently. This ultimately helps raise more money that can go towards helping homeless young people. We have made improvements to this notice so that accountability and transparency is at the core of what we do, especially around our policy on profiling and wealth screening in "How do you use my information?" section below.

We take protecting your privacy very seriously and will always take all reasonable steps within our power to make sure your information is safe.

Website privacy

Who are Centrepoint?

Centrepoint Soho, a company limited by guarantee (Company Number: 01929421) and a charity registered with the Charity Commission for England and Wales (Charity Number: 292411) which is also registered as a Housing Association (No. H1869) and its trading company CP Trading Limited, a company limited by shares, Company Number: 02951328 both of which have their registered office at The Rowe, 59-63 Whitechapel High St, London, E1 7PF (together Centrepoint) process your Personal Data in accordance with the UK Data Protection laws, specifically GDPR as defined below and the Data Protection Act 2018 (together the DPL) and the information set out in this information statement.

Centrepoint Soho (the Charity) is the UK's leading youth homelessness charity. We support young people aged 16–25 across 60 services in London, Yorkshire, Manchester, and the Northeast of England. The Charity undertakes trading activities through CP Trading Limited (CP Trading).

What the law says Centrepoint must do

GDPR means EU Regulation 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the General Data Protection Regulation) which has been directly imported into the law of England and Wales, Scotland and Northern Ireland (UK Law) by virtue of section 3 of the European Union (Withdrawal) Act 2018 as amended by the Data Protection, Privacy and Electronic Communications (Amendment Etc.) (EU Exit) Regulations 2019.

We are registered as a ‘Data Controller’ with the Information Commissioners Office (ICO). The ICO is the regulator with the responsibility for protecting the personal data rights of people within the UK, under the General Data Protection Regulations 2016/679 and Data Protection Act 2018 (DPA). Our Registration No. is ZA5455259. As a Data Controller we decide what information we collect, how we collect it, the purpose for which we collect it and what we do with it. This means we have specific responsibilities in relation to the personal data we collect.

This statement sets out how Centrepoint processes your Personal Data. We have a number of specific privacy notices in relation to young people, donors, volunteers, supporters, employees, trustees, celebrity ambassadors, Upstream England and Centrepoint wide and these can be found at https://centrepoint.org.uk/privacy

What information do we collect?

We may collect your:

Name;
Address and previous three addresses;
Email address;
Telephone number (mobile);
Contact preference;
Gender identity;
Racial or ethnic origin;
Religious or philosophical beliefs;
General health, physical and mental health information;
Sexual orientation;
Actual or alleged criminal offences;
Employment details;
References and disciplinary history;
Work history;
Education history, including school, college etc. and qualifications;
Unique learner reference number;
Outcome of initial assessments;
Current housing status and housing history;
Information in relation to your hobbies and interests;
Details of your next of kin;
Bank account details;
Debit/credit card details;
Date of birth;
Biographical details;
National Insurance Number;
Identification details, such as passport, driving licence etc.
NHS number;
Next of kin/emergency contact information;
Health care providers (GP, Dentist etc.)’
Key worker information from external support agencies;
Immigration status;
Language requirements;
Survey responses;
Vehicle information;
Trade union membership;
Political opinions;
Records of your engagement and communication with us;
Your photo and CCTV image;
Any content featuring you that has been produced for our website, publications, social media, articles, and blog posts;
Donation information and Gift Aid details;
Photographs and video recordings, and;
Information you have entered on to our website.

Why do we collect your information?

Centrepoint processes your personal data and special category data, where you have provided it, for the following purposes:

To provide and administer Centrepoint’s accommodation services;
To provide information, advice, and guidance services;
To respond to enquiries;
To further our charitable aims;
To process personal details to administer training courses;
To comply with all statutory and regulatory compliance;
To process any enquiries or complaints raised by you and responding to any communications from you;
To share your information to third parties with whom we have a relationship under which your personal data is protected;
To processes donations, grants received, sponsorship and administer Gift Aid;
To administer Centrepoint’s bursary fund;
To administer events;
To communicate with you about our fundraising, campaigns, and the work that Centrepoint does;
To manage your communication preferences;
To process job applications, and/or volunteering opportunities and manage the recruitment process;
To undertake research, conduct surveys and gather feedback;
To undertake research to find out more about the background and interests of our supporters and prospective supporters;
To ensure we comply with our contractual obligations to our funders, and;
To undertake profiling and analysis of your information, for example by aggregating your information with other donor’s information, and that from other fundraising platforms, to understand where our donors come from, what you do and what you care about.

This informs our fundraising and marketing campaigns, helps us to effectively communicate with our donors and to fundraise. You can object to your personal information being used this way by contacting supportercare@centrepoint.org

You can object to your personal data being used by Centrepoint by contacting our Data Protection Team.

Processing your data

In order to process personal data the law says Centrepoint must have a legal basis to do so.

The lawful basis on which the above processing takes place is legitimate interests shared by Centrepoint, and you as set out below, processing is necessary for the performance of a contract, to comply with legal obligations and, to protect your vital interests or those of another person.

The lawful basis which permits the processing set out above to take place are:

You are accessing our services;

You have made an application to become a volunteer, trustee, or employee at Centrepoint;

You have made a donation, or sponsorship;

We need to comply with regulatory requirements;

That the processing is reasonable in relation to the activities to which they relate;

The processing is such as you would reasonably expect to be undertaken by Centrepoint in respect of the management of our operations;

That the processing is necessary in respect of the activities that are undertaken and is in the interests of Centrepoint and the relevant third parties and does not limit your interests or fundamental freedoms guaranteed by the DPL;

That if you sought to terminate your consent to Centrepoint processing your personal data, we would still be required to retain some information for a time that is reasonable to fulfil the purpose in this notice, meaning that consent is not freely available.

When you made contact with Centrepoint you created a relationship between us. Where you have opted in to receiving electronic communications from us, we have treated your action as consent to send you communications electronically (commonly called “a soft opt in”). As the lawful basis of the processing, Centrepoint undertakes in relation to electronic communications is your consent, please note that you may withdraw this consent at any time.

Where do we get your personal data from?

We may receive your personal data from:

You directly, by completing forms, by contacting our helpline and webchat, by face to face or email conversations with a member of Centrepoint’s staff;
Digital forms completed through our website and online surveys;
From our social media pages;
From your social media pages;
Local authorities who have referred you to one of our services;
Local agencies who have referred you to one of our services, and;
Third party companies and websites.

How do you share and/or transfer my personal data?

Centrepoint may transfer your personal data to the following organisations or category of organisations:

Service providers in order to provide you with the services you have requested. For example, web hosting providers, telephone system providers, cloud storage providers, marketing companies, payment companies for the processing of donations and payments;
Third parties with whom we have a relationship including our sub-contractors providing services to us and other charities combatting homelessness;
Regulatory organisations and quality mark organisations to undertake inspections and audit activities, to ensure the quality of our work and to improve the delivery of the services we provide;
Data analysis companies and agents who undertake analysis and profiling activities to help us measure and improve the effectiveness of our marketing, communication, and fundraising activities;
Police, Probation and Social Care Services where we have a legal duty to share information for the prevention and detection of crime;
Local Authorities to report performance indicators on homelessness and to cross reference funding and outcomes for young people;
Department for Levelling-up, Housing and Communities to record details of lettings and sales in social housing and to provide statistical information on trends in social housing, characteristics of tenancies and types of tenancy agreements.
Healthcare related organisations and partners i.e. GP, community health teams etc. in circumstances where we believe we have a duty of care.

It is the intention of Centrepoint that your personal data will remain within the countries forming the European Economic Area (the EEA) and countries where the European Union (EU) has decided that the country has adequate data protection laws in line with those in the UK.

Your personal data will only be transferred outside of the EEA or a country which has been declared as having adequate data protection laws, where:

The transfer is necessary for the performance of any contract with you;

You have entered the information into our website and the information has been transmitted from your server to our server using systems based outside of the EEA;

We have entered into an appropriate contract protecting your rights and freedoms, which is enforceable by you or the data protection authorities; or

We have obtained your explicit consent.

Generally, we do not expect that your personal data will be transferred outside of the EEA.

How long do you keep my personal data?

We will generally store the personal data that we hold in relation to you, for the duration of our relationship with you unless a longer retention period is permitted. We will store personal data in accordance with our data retention policy and procedures.

What are my personal data rights?

You have a right to obtain from Centrepoint confirmation as to whether or not your personal data is being processed and, if your personal data is being processed by Centrepoint, to access your personal data.
This is usually referred to as a Subject Access Request (SAR).
To invoke this right you can email dataprotection@centrepoint.org, call our supporter care team on 0800 23 23 20 or write to The Data Protection Officer, Centrepoint, The Rowe, 59-63 Whitechapel High St, London, E1 7PF.
You have the right to access your personal data from Centrepoint via a Subject Access Request (SAR) as above.
Please note that we will not provide any personal data to you until you have provided evidence to us to establish your identity. This may include a copy of your passport or other identification document.
We will only provide information to you at an address which we have verified as belonging to you.
You have a right to rectification of any inaccurate personal data which we process about you, or where personal data is completed to have the information completed.
To obtain rectification or completion of your personal data you will need to provide the correct information to Centrepoint, an explanation of why you believe the information is inaccurate would also be of assistance.
You are entitled to have Centrepoint erase certain personal data relating to you, on certain grounds. Where you wish to exercise your right of personal data erasure, please contact the Data Protection Team setting out the grounds under which you would like the personal data Centrepoint holds about you erased.
Certain grounds apply when we need to use legal, contract or vital interests as lawful bases for processing your data.
Where certain grounds apply you will be entitled to have Centrepoint restrict the processing of certain personal data relating to you.
Where you wish to exercise your right to restrict processing, please contact the Data Protection Team setting out the grounds under which you would like the personal data Centrepoint holds about you restricted.
You have the right to object to your information being processed, for example, for automated decision making, direct marketing and profiling activities.
You have the right to data portability - that is - you can ask us to transfer your personal data electronically, to another organisation but only in certain circumstances. Those circumstances include where the lawful basis for processing your data includes contract, legal or vital interests.
If you have any queries or concerns on any data protection related issue, please contact dataprotection@centrepoint.org where the team will be happy to help.

How do I complain?

If you have any complaint(s) about the processing of your personal data undertaken by Centrepoint, please contact the Head of Compliance who acts as Centrepoint’s Data Protection Officer (DPO).

Please note that you also have a right to lodge a compliant about the processing of your personal data by Centrepoint by contacting the Information Commissioner’s Office of England (ICO).

The ICO can be contacted at: Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone No. 0303 123 1113. Alternatively, https://ICO.org.uk.

Please address all communications in relation to personal data and data protection to the Data Protection Team.

In order to improve our website, we use ‘cookies’ and similar technologies. Cookies are small pieces of information sent by us to your computer or mobile device and stores on your device to allow us to recognise you when you next visit.

We will ask you whether you give your consent for the use of cookies when you enter our website.

For information, please see our Cookies Policy, which can be found - https://centrepoint.org.uk/cookie-policy.

Provision of Personal Data

Please note that Centrepoint is processing your personal data to provide you our services and to manage our legal obligations, as set above. If you do not provide your personal data, we may not be able to undertake our obligations in relation to the provision of our services to you. This means we will not be able to provide you with some or all of the services you have requested.

Definitions

The following terms have the following meaning in this Statement:

Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

Controller means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

Processor means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the data controller.

Special Category Data means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Contact

The Data Protection Officer can be contacted:

In writing at Centrepoint, The Rowe, 59-63 Whitechapel High St, London, E1 7PF;

By email at dataprotection@centrepoint.org; or

By telephone by calling 0800 587 5158 or

Via our website.

Further Information

It is not intended that Centrepoint will undertaking any further processing of your personal data other than that which is set out in this statement. However, if this position does change, Centrepoint will provide you with further information.

This statement was last updated in September 2024.

Other privacy notices

Read our privacy notices for supporters, donors, volunteers, trustees, Upstream England, celebrity supporters and ambassadors, employees and young people.

Supporters

Donors

Volunteers

Trustees

Upstream England

Celebrity Supporters and Ambassadors

Employees

Young people

Other information

Centrepoint young people

If you're a Centrepoint young person, please refer to this privacy notice.

Children

Our services are aimed at young people aged 16-25, however our Helpline occasionally receives contacts from under 16 year olds. We ask the young person if an adult with parental responsibility can provide consent for us to hold/use the young person’s personal data but if this is not possible, we will make a professional judgement. If it can be justified to be in the public interest to share the personal data, we will lawfully share it to protect the child from significant harm and promote the welfare of the child.

Transfers of your personal information

At all times, we intend to store and process your personal information within the European Economic Area. Should this ever change, we would take steps to ensure your personal information is only transferred once adequate safeguarding is in place. This includes Model Clauses, other adequacy mechanisms or derogations approved by the EU Commission or under UK law.

Third party sites

Our website may have links to other websites we do not operate. You should read the privacy notices on those websites before you submit your personal information.

Changes to this notice

From time to time, we may revise this notice. Updated versions will be posted on the website. If we make any significant changes, we will draw attention to them.

Contact us

If you have any questions about this notice, please contact:

Data Protection Officer
Centrepoint
The Rowe
59-63 Whitechapel High St
London
E1 7PF

0800 232320
dataprotection@centrepoint.org.

If you have a complaint about the way we process your information, please contact complaints@centrepoint.org, where we will aim to address your complaint. However, if you would like to, please direct your complaint directly to the Information Commissioner's Officer.