Privacy Notice for Donors

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 Central House, 25 Camperdown Street, London, E1 8DZ. 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 called Data Protection Law) and the information set out in this privacy notice.

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 North East of England. We also do some 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 Regulation 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 as a donor to Centrepoint. We have a number of specific privacy notices in relation to young people, volunteers, supporters, employees, trustees, celebrity ambassadors, Upstream England and Centrepoint wide. We have made this information available to you following your donation and it is also available through our website at https://centrepoint.org.uk/privacy 

What information do we collect?

We may collect your:

  • Name; 
  • Address and previous three addresses; 
  • Email address; 
  • Mobile number; 
  • Contact preference;  
  • Tax status; 
  • Bank account details;   
  • Debit/credit card details; 
  • Date of birth; 
  • Biographical details; 
  • National Insurance Number; 
  • Identification details 
  • Survey responses;  
  • Copies of your will and your solicitor’s details, for legacy pledgers. 

Why do we collect your information?

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

  • Acknowledging and processing any donation(s) made by you; 
  • Setting up direct debits for recurring donations;  
  • Acknowledgement and processing any sponsorship you have made;  
  • Providing you with information about the activities of Centrepoint and its partners; 
  • Administration in relation to the support that you provide to Centrepoint; 
  • Personalising our fundraising activity;  
  • Statutory and regulatory compliance; 
  • Processing any enquiries or complaints raised by you and responding to any communications from you; 
  • Undertaking due diligence to protect the Centrepoint and our supports from risk of harm;  
  • Sharing your information to third parties with whom we have a relationship under which your personal data are protected; 
  • Transferring your personal data to HMRC in respect of any Gift Aid claims; and 
  • Sending electronic communications to you keeping you informed about the activities and fundraising campaigns falling into any of the above categories. 

This information also 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 dataprotection@centrepoint.org  

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

Processing your data

The lawful basis on which the above processing takes place is  the 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 andwith your consent. 

  • The lawful  basis on which the above processing takes place are: You have made a donation or sponsorship to Centrepoint and as a result have shown a willingness to support the work of Centrepoint; 
  • You have set up a regular donation to Centrepoint;  
  • The need to comply with regulatory requirements in relation to your donation, for example, the need to keep donation records for a minimum of seven years for accounting purposes; 
  • 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 your donation;  
  • 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 information on your donation for at least seven years, meaning that consent is not freely available. 

When making your donation to Centrepoint you created a relationship between us. Where you did not opt out of 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. 

  • Should you withdraw your consent Centrepoint shall cease to send you electronic marketing information. 
  • You may revoke your consent to receive such updates by completing an update form on our website at https://centrepoint.org.uk/about-centrepoint/contact-us,  by using the unsubscribe function included in each communication, by emailing supportercare@centrepoint.org or writing to the Data Protection Officer, Central House, 25 Camperdown Street, London E18DZ or calling our Supporter Care Line on0800 587 5158. 

You may notify us at any time if you wish us to stop contacting you. We will stop all further contact; however, we will be required to continue to process your personal data in relation to any donation(s) made by you until the period where we are no longer required to keep donor information. This is seven years from the date the final donation was made. 

Where do we get your personal data from?

We get your personal data from:

  • You directly. You are the source of all the personal data about you which we process. 

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

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

  • HMRC; 
  • 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;  
  • 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.  

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. United Kingdom. 

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 by law.  We will store personal data in accordance with our data retention policy and procedures.  For donors this is seven years after that relationship ends or seven years after the final donation.  

What are my personal data rights?

You have the  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 232320 or write to The Data Protection Officer, Centrepoint, Central House, 25 Camperdown Street, London, E1 8DZ.  

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 interest 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. 

How do I complain? 

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

  • Please note that you also have a right to lodge a complaint about the Processing of your personal data by Centrepoint by contacting the Information Commissioner’s Office (ICO). 
  • The ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone No. 0303 123 1113.  
  • Please address all communications in relation to personal data and data protection to the Data Protection Team. 

Cookies

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 manage your donation and Centrepoint’s legal obligations, as set out  above. If you do not provide your personal data, we will not be able to undertake our obligations,  you will not be permitted to claim Gift Aid on your donation and we may not be able to provide you with some or all of the services you may 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, Central House, 25 Camperdown Street, London E1 8DZ; 
  • By telephone by calling 0800 587 5158 or 

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 on 26th September 2024.