This policy describes how and why The William Little Foundation uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information. We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it.  

As a charity we use personal information on a day to day basis in order to operate.  Our use of personal information allows us to make better decisions, fundraise more efficiently and, ultimately, helps us to reach our goal of seeking to prevent neurodevelopment disorders including cerebral palsy. 

This policy was last updated on 1^st May 2020.

Who we are

In this Privacy Policy, “The William Little Foundation”, “we”, or “our” means:

The William Little Foundation is a charity registered in England and Wales (No. 803551).

How we collect information about you

We collect information in the following ways:

Information you provide to us directly

You may give us your information in order to sign up for one of our events, make a donation, register as a volunteer, media volunteer or ambassador for us, join our priority-setting partnership, apply for research funding, access our research database or otherwise communicate with us. 

When you use our website, we collect your personal information using “cookies” and other tracking methods.  There are more details on the cookies and tracking methods we use in our Cookie Policy.

In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.

Information you provide to us indirectly

Your information may be shared with us by third parties, for example:

• if a friend or family member signs you up for one of our events;
• independent event organisers, for example the London Marathon or fundraising sites like Just Giving or Virgin Money Giving; 
• if you are a researcher and your information is shared with us by the principal investigator or institution.

We also may receive data about you from sub-contractors acting on our behalf who provide us with technical, payment or delivery services, and from business partners, advertising networks and search/analytics providers used on our website.

You should check any privacy policy provided to you where you give your data to a third-party. 

Information from other sources  

We also use information from the following sources:

Social Media
Communication, engagement and actions taken through external social media platforms that we participate on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those services, for example when you publicly tag us in an event photo.

You are advised to use social media platforms wisely and communicate / engage upon them with due care and caution regarding your own privacy and personal details. 

Information available publicly
We supplement information on our supporters with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of The William Little Foundation. For more information, please see our section on “Building profiles of supporters” below.

What personal information we collect

We collect, store and use the following kinds of personal information:

• your name;
• your contact details (including postal address, telephone number, e-mail address and/or social media identity);
• your date of birth;
• your gender;
• your bank or credit card details where you provide these to make a payment;
• if you volunteer for us or apply for a job with us, information necessary for us to process these applications and assess your suitability (which may include things like employment status, previous experience depending on the context, as well as any unspent criminal convictions or pending court cases you may have);
• if you apply for research funding, information necessary to process your application, such as your employment history; the employment history of individuals who will be working on the grant, including any allegations of bullying or harassment and salary information for anyone who’s salary will be funded by the grant;
• information about your activities on our website(s) and about the device you use to access these, for instance your IP address and geographical location;
• information about events, activities and products which we consider to be of interest to you;
• information relating to your health (for example if you are taking part in or attending an event for health and safety purposes, as well as where you share your experiences of cerebral palsy or other neurodevelopmental disorder with us); 
• where you have left us a legacy, any information regarding next of kin with which you may have provided us to administer this;
• information as to whether you are a taxpayer to enable us to claim Gift Aid;
• age, nationality and ethnicity information for monitoring purposes; and
• any other personal information you provide to us. 

Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive.  Examples of this type of sensitive data (known as ‘special category data’) would be information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality or genetic/biometric information.  

We only collect this type of information about our supporters to the extent that there is a clear reason for us to do so, for example asking for health information if you are taking part in a sporting event, or where we ask for information for the purpose of providing appropriate facilities or support.   We will also collect this type of information if you make it public or volunteer it to us – for instance if you tell us you have cerebral palsy when applying for a volunteer role.  

Wherever it is practical for us to do so, we will make clear why we are collecting this type of information and what it will be used for.

How we collect information about you

We will use your personal information to:

• provide you with the services, products or information you asked for;
• administer your donation or support your fundraising, including processing Gift Aid;
• keep a record of your relationship with us;
• respond to or fulfil any requests, complaints or queries you make to us;
• understand how we can improve our services, products or information by conducting analysis and market research;
• manage our events;
• check for updated contact details against third party sources so that we can stay in touch if you move (see “Keeping your information up to date” below);
• further our charitable objectives;
• register, administer and personalise online accounts when you sign up to products we have developed;
• send you correspondence and communicate with you;
• process applications for funding and for administration of our role in the projects we fund;
• monitor the appropriate use of grant funds, including expenditure on individual salaries, and consider any virement requests
• ensure that participants involved in The William Little Foundation’s research are treated with dignity and respect
• if you are or have been a William Little Foundation-funded researcher, invite you to act as a peer reviewer on grant applications in accordance with the conditions of your grant
• administer our websites and to troubleshoot, perform data analysis, research, generate statistics and surveys related to our technical systems;
• testing our technical systems to make sure they are working as expected;
• contact you if enter your details onto one of our online forms, and you don’t ‘send’ or ‘submit’ the form, to see if we can help with any problems you may be experiencing with the form or our websites;
• display content to you in a way appropriate to the device you are using (for example if you are viewing content on a mobile device or a computer);
• generate reports on our work, services and events;
• safeguard our staff and volunteers;
• conduct due diligence and ethical screening;
• monitor website use to identify visitor location, guard against disruptive use, monitor website traffic and/or personalise information which is presented to you;
• process your application for a job or volunteering position;
• conduct training and quality control;
• audit and administer our accounts;
• meet our legal obligations, for instance to perform contracts between you and us, or our obligations to regulators, government and/or law enforcement bodies;
• carry out fraud prevention and money laundering checks;
• undertake credit risk reduction activities; and/or
• establish, defend or enforce legal claims.

Legal basis for 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.

Specific consent

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 marketing material via post, phone, text or e-mail).  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

We have a basis to use 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 regulators such as the Charity Commission, Fundraising Regulator, Information Commissioner or Gambling Commission, or to use information we collect about you for due diligence or ethical screening purposes.

Performance of a contract / take steps at your request to prepare for entry into a contract

We have a basis to 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 are buying something from us (for instance some branded merchandise or an event place), applying to work/volunteer with us, or being funded to undertake research.

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” (provided that what the information is used for is fair and does not unduly impact your rights).

We consider our legitimate interests to include all of the day-to-day activities The William Little Foundation carries out with personal information.  Some examples not mentioned under the other bases above where we are relying on legitimate interests are:

• analysis and profiling of our supporters using personal information we already hold;
• updating your address using third party sources if you have moved house (please see the “Keeping your information up to date” section below for more on this).
• use of personal information when we are monitoring use of our website or apps for technical purposes;
• use of personal information to administer, review and keep an internal record of the people we work with, including supporters, volunteers and researchers;
• sharing of personal information between relevant teams and committees within The William Little Foundation and between The William Little Foundation’s group companies;
• where you have signed up with us on a charity place for a third-party event (i.e. one not organised by The William Little Foundation), sharing personal information with the third-party event organiser so they can administer the event.

We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.

When we use special category personal data (please see the “What personal information we collect” section above), we require an additional legal basis to do so under data protection laws, so will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).

How we keep your information safe

We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details.  For example, our online forms are always encrypted and our network is protected and routinely monitored. 

How long we keep your information for

We consider various criteria when determining the appropriate retention period for personal data including: 

• the purposes for which we process your personal data and how long we need to keep the data to achieve these purposes;
• how long personal data is likely to remain accurate and up-to-date;
• for how long the personal data might be relevant to possible future legal claims;
• any applicable legal, accounting, reporting or regulatory requirements which specify how long certain records must be kept.

Sharing information with other organisations

As set out in the “Sending marketing communications” section above, we will never sell or rent your information to third parties for marketing purposes. 

We may also disclose your information to third parties in connection with the other purposes set out in this policy.  These third parties may include:

• business partners, suppliers and sub-contractors who may process information on our behalf;
• if you are a researcher, volunteer advisory panels, any joint funders of research, host institutions and external members of our committees;
• if you are a legacy giver, we may share information with co-beneficiaries;
• advertisers and advertising networks
• analytics and search engine providers;
• IT service providers.

Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider this necessary, to protect the rights, property or safety of The William Little Foundation, its personnel, visitors, users or others.

We reserve the right to disclose your personal information to third parties:

• if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets; and/or
• if substantially all our assets are acquired by a third party, personal information held by us may be one of the transferred assets.

Keeping your information up to date

As set out in the “Sending marketing communications” section above, we will never sell or rent your information to third parties for marketing purposes. 

We may also disclose your information to third parties in connection with the other purposes set out in this policy.  These third parties may include:

• business partners, suppliers and sub-contractors who may process information on our behalf;
• if you are a researcher, volunteer advisory panels, any joint funders of research, host institutions and external members of our committees;
• if you are a legacy giver, we may share information with co-beneficiaries;
• advertisers and advertising networks
• analytics and search engine providers;
• IT service providers.

Where we are under a legal or regulatory duty to do so, we may disclose your details to the police, regulatory bodies or legal advisors, and/or, where we consider this necessary, to protect the rights, property or safety of The William Little Foundation, its personnel, visitors, users or others.

We reserve the right to disclose your personal information to third parties:

• if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets; and/or
• if substantially all our assets are acquired by a third party, personal information held by us may be one of the transferred assets.

Your rights

Under UK data protection law, you have rights over personal information that we hold about you.  We’ve summarised these below:

Right to access your personal information

You have a right to request access to the personal data that we hold about you. You also have the right to request a copy of the information we hold about you, and we will provide you with this unless legal exceptions apply. 

If you want to access your information, send a description of the information you want to see by post to The Chief Executive, The William Little Foundation, Pinero House, 115a Harley Street, London, W1G 6AR or by email to ceo@thelittlefoundation.org.uk

Right to have your inaccurate personal information corrected

You have the right to have inaccurate or incomplete information we hold about you corrected.  If you believe the information we hold about you is inaccurate or incomplete, please provide us with details and we will investigate and, where applicable, correct any inaccuracies.  

Right to restrict use of your personal information

You have a right to ask us to restrict the processing of some or all of your personal information in the following situations:  if some information we hold on you isn’t right; we’re not lawfully allowed to use it; you need us to retain your information in order for you to establish, exercise or defend a legal claim; or you believe your privacy rights outweigh our legitimate interests to use your information for a particular purpose and you have objected to us doing so.

Right to erasure of your personal information

You may ask us to delete some or all your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done. If we are unable to delete your information, we will explain why this is the case. 

Right for your personal information to be portable

If we are processing your personal information (1) based on your consent, or in order to enter into or carry out a contract with you, and (2) the processing is being done by automated means, you may ask us to provide it to you or another service provider in a machine-readable format.

Right to object to the use of your personal information

If we are processing your personal information based on our legitimate interests or for scientific/historical research or statistics, you have a right to object to our use of your information.

If we are processing your personal information for direct marketing purposes, and you wish to object, we will stop processing your information for these purposes as soon as reasonably  possible.

If you want to exercise any of the above rights, please The Chief Executive, The William Little Foundation, Pinero House, 115a Harley Street, London, W1G 6AR or by email to ceo@thelittlefoundation.org.uk.  We may be required to ask for further information and/or evidence of identity. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.

Please note that exceptions apply to a number of these rights, and not all rights will be applicable in all circumstances. For more details we recommend you consult the guidance published by the UK’s Information Commissioner’s Office (ICO). 

Complaints

If you are unhappy with any aspect of how we are using your personal information we’d like to hear about it. We appreciate the opportunity this feedback gives us to learn and improve. You can find out more and read our Complaints Policy on our web pages.

You also have the right to lodge a complaint about any use of your information with the Information Commissioner’s Office, the UK data protection regulator.

Changes to this policy

We may change this Privacy Policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on The William Little Foundation website or by contacting you directly.