KASP is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect, record and hold personal information about you, in accordance with the General Data Protection Regulation (GDPR).

Please read this Privacy Notice, together with any other privacy notice that we make available, as it contains important information about how we collect, manage, use and protect your personal data.

We may change this Privacy Notice from time to time. Please check this policy frequently to ensure you are aware of the most recent version and the date that it was last updated.

If you have any questions regarding this policy or about our privacy practices, please contact us at: 01592 644217, info@kasp.org.uk or by writing to us at KASP, 38/40 High Street, KIRKCALDY, KY1 1LU. Please mark your query for the attention of Joy Patrick, KASP Manager.

1. Who are we?

Kingdom Abuse Survivors Project (KASP), is a registered charity in Scotland (Scottish Charity No. SC023079) and a company limited by guarantee registered in Scotland (Company No. SC524668) with its registered office at 38/40 High Street, KIRKCALDY, KY1 1LU.

KASP is a “data controller” of the personal data that you provide to us. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

2. Data protection principles

We will comply with data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

3. What information do we collect?

Information that we may collect from you includes your name, address, email address, phone numbers and date of birth.

You may give us such information by making a donation, or by corresponding or speaking with us by phone, email, letter or otherwise. This includes information you provide when you access or otherwise use our website, register as a member, submit a query, make a donation, provide us with feedback or when you report a problem with the website.

We also work with some third parties and may receive information about you from them if you have provided permission to them to share it with us. Before providing permission to such third party organisations to share your personal data, you should check their privacy notices carefully.

4. How we might use your information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
2. Where we need to perform a service we have entered into with you.
3. Where we need to comply with a legal obligation.
4. Where you have given us your consent to do so.

We use information held about you in the following ways:

• To manage and administer our relationship and communications with you.
• To process any donations that you have made to us.
• To claim Gift Aid on donations.
• To provide you with the information that you request from us.
• To provide you with information about our activities and fundraising appeals where you are fundraising in aid of us and need this information.
• To inform you about changes to our service.
• To send our supporters marketing information about our projects, fundraising activities and appeals where we have your consent to do so.
• To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted.
• For the purposes of the establishment, exercise or defence of legal claims.

5. Our Marketing

When you give us your consent to send marketing information, we will usually understand your consent to last for 24 months. After this time, in order for us to continue to update you, we will need your renewed consent. You can withdraw your consent at any time. See section 13 for more information on how to do this.

6. Change of purpose

We will only use your personal information 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 or if we have a legal obligation or public interest requirement to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above provisions, where this is required or permitted by law.

7. Who we might share your information with

We may share your personal information with third parties where it is necessary to administer the relationship with you, required by law, or where we have another legitimate interest in doing so.

We may share your information with selected third parties including:

• When we use other companies to provide services on our behalf, for example, processing donations, such as Just Giving, sending emails, such as Doodlepoll, when using auditors or other professional advisors, or processing credit/debit card payments and cheques.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• IT service providers.

We may disclose your personal information to third parties to:

• Comply with any court order or other legal obligation or when data is requested by our regulators or by government agencies or law enforcement agencies;
• Enforce or apply our terms of use and any other agreements;
• Protect the rights, property, or safety of us, our service users, employees, donors, or others. This may include exchanging information with other companies and organisations for the purposes of fraud protection.

8. How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

9. International transfers of personal data

The data that we collect from you may, from time to time, be transferred to, and stored at, a destination outside the European Economic Area (EEA).

If we do this, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

10. Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

11. How long will we hold your information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We review our retention periods for personal data on a regular basis. 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 requirements.

To comply with relevant legislation, we will keep a record of donations subject to gift aid, and a record of all donations made directly to us for 7 years. We will dispose of this information after 7 years.

If you have consented to receive marketing communications from us, we will retain your name and contact details on our distribution list for 24 months. If you do not wish to renew your consent to receive marketing communications after this period, or if you withdraw your consent during this period, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

12. Your rights

Under certain circumstances, by law you have the right to:

• Transparency over how we use your data and to request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact KASP’s Manager in writing.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights), except in exceptional circumstances, if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

If you would like to find out more about your rights, you can visit the Information Commissioner’s Office website: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr

You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), if you have concerns about how we use your personal information. You can contact the Information Commissioner’s Office at: https://ico.org.uk/global/contact-us/

13. Right to withdraw consent

In circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact KASP Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

14. How you can access and update your information

We strive to maintain accurate, complete, and relevant personal information for the purposes identified in this privacy statement. If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it. It is important that the personal information we hold about you is accurate and current.

15. Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and will make amended versions of this notice available on our website when we make changes to it. We may also notify you in other ways from time to time about the processing of your personal information.

16. Contact Us

If you have any questions regarding this policy or about our privacy practices, wish to exercise any of your rights or wish to make a complaint, please contact our Centre Manager at: Joy Patrick, Manager, KASP, 38/40 High Street, KIRKCALDY KY1 1LU. Telephone: 01592 644217.

Updated April 2020