Privacy & Cookies Policy

Last updated – 23rd April 2019

240Project would like all of our visitors and supports to feel confident, protected and comfortable with how their personal information will be treated or used. The following Privacy & Cookies Policy outlines how we collect, use and store your personal information.

Personal information as referred to in this Policy means any personal data or information relating to you that identifies or could identify you personally as described below.

1.      Who we are

2.      How we collect information about you

3.      What we collect, why we collect it and how we store it

4.      Legal basis for using your information

5.      Email updates

6.      Sharing your information

7.      Keeping your information safe

8.      How long we hold your information for

9.      Your rights

10.  Cookies


1.       Who we are

240Project are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner in accordance with applicable laws governing protection and privacy of personal data (“Data Protection Law”).

For further information about our privacy practices, please contact us by:

  • Writing to 240Project, Latymer Christian Centre, 116 Bramley Rd, London W10 6SU

  • Calling us on 0207 2217530

  • Emailing info@240project.org.uk

References to “we”, “us”, or “our” in this Privacy Policy are references to 240Project, a charity registered in England and Wales, registered charity number: 1180267.

2.       How we collect information about you

240Project values protecting the privacy of all that come into contact with the organisation.

We may collect minimal information from:

Users seeking our services (“Members”):
When you interact with us directly: When Members visit 240Project’s space at Latymer Christian Centre in person. When Members visit 240Project’s space at Latymer Christian Centre, only first names and signatures are collected manually on a paper sign-in sheet. This data is stored only on original paper copies.

Staff, session workers and volunteers:
When you interact with us directly: When applying for positions and progressing through reference checks and interview stages.

Donors:
When you interact with us through third parties: When you provide a donation through a third party supplier (ie. PayPal, Just Giving, etc.) that we work with and provide your explicit consent for your personal information to be shared with us.

Website visitors:
When you visit our website:  We gather general information through cookies, clicks and pages visited.  

3.       What we collect, why we collect it and how we store it

Members:
When Members visit 240Project’s space at Latymer Christian Centre, only first names and signatures are collected manually on a paper sign-in sheet. This data is stored only on original paper copies. Only the Project Manager and Director of the charity have access to these paper records.

Staff, session workers and volunteers:
Upon direct consent, we gather personal data limited to full name, contact information (email and mobile phone number), relevant qualifications, DBS and reference checks. The limited data collected by 240Project is stored in a spreadsheet saved locally on a password protected laptop. The spreadsheet is password protected and maintained by the Project Manager. Only the Project Manager and the Director of the charity have access to this spreadsheet. Once an applicant is approved, all data except for full name and contact information is deleted.

Donors:
When you provide a donation through a third party supplier (ie. PayPal, Just Giving, etc.) that we work with and provide your explicit consent for your personal information to be shared with us, we receive the name, email address, and monetary value listed in the form you submit. The limited data collected by 240Project is stored in a general contacts spreadsheet saved locally on a password protected laptop. The spreadsheet is password protected and maintained by the Project Manager. Only the Project Manager and the Director of the charity have access to this spreadsheet.

Website visitors:
We use this information to make improvements to our website and to ensure we provide the best service and experience for you. This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:

  • Information about your browser, network and device

  • Web pages you visited prior to coming to this website

  • Your IP address

This information may also include details about your use of this website, including:

  • Clicks

  • Internal links

  • Pages visited

  • Scrolling

  • Searches

  • Timestamps

Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyses the data in a de-personalised form.

This website uses font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you, including:

  • Information about your browser, network, or device

  • Your IP address

Wherever possible we use anonymous information which does not identify individual visitors to our website. We may also track which pages of the 240Project website (www.240project.org.uk) you visit when clicking on links in emails from us. This website also uses cookies. For further information, see “Cookies” below.

Sensitive Personal Information
Data Protection Law recognises that some categories of personal information are more sensitive than others (this is called ‘special category’ or ‘sensitive’ personal data). An example of this is information about ethnic origin. 240Project does not collect Sensitive Personal Information.

4.       Legal basis for using your information

We will only use your personal information where we have one or more of the following legal basis for doing so:

  • Where we have your freely given, specific, informed and unambiguous consent to use this information for a particular purpose;

  • Because we need to use it in order to enter into or fulfil a contract with you (for example, if you apply for a staff or volunteer position);

  • To protect yours or someone else’s vital interests (e.g. a medical emergency);

For us to comply with a legal obligation; and/or

  • Where use of that information is necessary in 240Project’ ‘legitimate interests’ to help us to administer and achieve our work as a charity. Whenever we process your personal information under the ‘legitimate interest’ lawful basis, we make sure that we balance our interests against your legal rights and interests as an individual. In particular, we will not process your personal information in a manner that is privacy intrusive.

5.       Email updates

For donors, we may contact you periodically about our work and how you can support 240Project. We will only send direct communications by email if you have explicitly given consent. You can stop us sending you these communications at any time by contacting info@240project.org.uk or clicking the unsubscribe link at the bottom of the relevant email communication.

6.       Sharing your information

All data is contained to the Project Manager and Director of the charity. The complete data set is not and will not be shared with any third party unless legally obliged to do so.

7.       Keeping your information safe

We take looking after your information very seriously. We’ve implemented appropriate and proportionate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.

Our website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or websites that have links on our website may collect personally identifiable information about you. This privacy statement does not cover the information practices of those other websites or advertisers.

Any debit or credit card details which we receive on our website are collected securely by PayPal our payment processing partner, according to the Payment Card Industry Data Security Standards. We never store any payment card information ourselves.

None of the 240Project Trustees are data protection professionals. Given the scale and nature of the personal data held, it would be a disproportionate use of charitable funds to employ a data protection professional.

The Trustees will seek appropriate professional advice commensurate with its data protection requirement whenever:

  • they are planning to make significant changes to the ways in which they process personal data;

  • there is any national publicity about new risks (e.g.: cyber-attacks) which might adversely compromise the Charity’s legitimate processing of personal data covered by the GDPR.

8.       How long we hold your information for

We only keep your personal information only for as long as is reasonable and necessary for the relevant activity we collected it for.

240Project has a data retention policy that sets out the different periods we retain personal information for in accordance with our duties under Data Protection Law. The criteria we use for determining relevant data retention periods are based on:

  • various legislative requirements (for example, duties to hold transaction details for tax/accounting purposes);

  • the purpose for which we collected that personal information and where we have identified a continued legitimate need to hold that information to serve such purpose (For example: in the case of data subjects who held a role, such as a volunteer, with the charity, the retention period is that for which the Charity reasonably has a legitimate interest in being able to identify that individual’s role in the event of any retrospective query about it.); and

  • guidance issued by relevant regulatory authorities including, but not limited to, the UK Information Commissioner’s Office (ICO).

240Project will regularly – not less than every 12 months – review the personal data that we hold and and remove any data where retention is no longer justified. Such removal shall be made as soon as is reasonably practical. Personal information that we no longer need to hold is securely disposed of and/or anonymised so you can no longer be identified from it.

9.   Your rights

You have various rights in respect of the personal information we hold about you – these are set out in more detail below.  If you wish to exercise any of these rights or make a complaint, you can do so by contacting info@240project.org.uk or calling 0207 2217530.  If you are not satisfied with our response, you can also make a complaint to the UK data protection supervisory authority, the Information Commissioner’s Office (ICO), see – https://ico.org.uk/:

  • Access to your personal information: You have the right to request access to a copy of the personal information that we hold about you, along with information on what personal information we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You can make a request for access free of charge, unless a request is manifestly unfounded or unreasonable.  Please make all requests for access in writing to info@240project.org.uk, and provide us with evidence of your identity.

  • Right to object: You can object to our 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 communication purposes.  Please contact us as noted above, providing details of your objection.

  • Consent: If you have given us your consent to use personal information (for example, for email communication), you can withdraw your consent at any time.

  • Rectification & Erasure: You can ask us to correct or complete any inaccurate or incomplete personal information held about you. You can also ask us to delete your personal information where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.

  • Restriction: You can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

Please note, some of these rights only apply in certain circumstances and we may not be able to fulfil every request due to legal exemptions. We may also need you to verify your identity before we can fully comply with a request.

10.   Cookies

What is a cookie?
‘Cookie’ is a name for a small file, usually of letters and numbers, which is downloaded onto the browser (e.g. Internet Explorer, Safari or Google Chrome) of your device, like your computer, mobile phone or tablet when you visit a website. A cookie, by itself, cannot be used to identify you.

Why do we use cookies?
We use cookies to distinguish you from other users of our website. This helps us to improve the user experience. For further information about viewing the cookies dropped on your device, visit About the cookies Squarespace uses.

  • These analytics and performance cookies are used on this site, as described below, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data.

No cookies, please
You can opt out of all our cookies (except the strictly necessary ones) in your browser settings. But, if you choose to refuse all cookies, our website may not function for you as we would like it to.