At the Boparan Charitable Trust we are completely committed to protecting your privacy and we take our responsibilities very seriously. We promise to keep the personal data you share with us safe and secure and only use it for the purposes for which it was collected and not do anything that wouldn’t be reasonably expected. That includes whether you want to work, volunteer or advocate for us, make a donation, fundraise for us, use our services, want information, training or just want to learn more about what we do

Who we are

The Boparan Charitable Trust is a registered charity (RCN 1129992) and a company limited by guarantee Private Limited Company by guarantee without share capital use of ‘Limited’ exemption (company number 06852304). The Boparan Charitable Trust registered address is 2nd Floor, Colmore Court, 9 Colmore Row, Birmingham, B3 2BJ.

We are committed to using your personal information in accordance with our responsibilities. We are required to provide you with the information in this Privacy Notice under applicable legislation which includes:

• Data Protection Act 2018
• General Data Protection Regulations 2018
• Privacy and Electronic Communications (EC Directive) Regulations 2003

Processing of your personal information is carried out by or on behalf of The Boparan Charitable Trust. This notice, together with our website terms and conditions and our cookies policy tells you about how we collect, use and protect your personal information.

If you have any queries about our Privacy Notice, please get in touch with our Charity Director: Email: Gareth.aston@boparan.com Phone: 0121 661 9860 Post: Director of tThe Boparan Charitable Trust

How and when we collect information about you

1. When you directly give us information

We may collect and store information about you when you interact with us. For example, this could be when you:

• support our work through a donation
• fundraise on our behalf
• register for an event
• tell us your story
• submit an enquiry
• register for or use our services
• participate in our training
• give us feedback
• make a complaint
• apply for a job
• register as a volunteer
• enter into a contract with us
• are captured by video or photo recordings at events.

2. When you indirectly give us information

When you interact with us on social media platforms such as Facebook, WhatsApp, Twitter or LinkedIn we may also obtain some personal information about you.

The information we receive will depend on the privacy preferences you have set on each platform and the privacy policies of each platform. To change your settings on these platforms, please refer to their individual privacy notices.

We may obtain information about your visit to our website, for example the pages you visit and how you navigate the site, by using cookies. Please visit our cookies policy for information on this.

3. What information we might collect

When you engage with us by phone, mail, in person or online, we may collect information about you (referred to in this Privacy Notice as ‘personal information’).

This may include your name, address, email address, telephone number, date of birth, job title and details of your education and career, why you are interested in The Boparan Charitable Trust and other information relating to you personally which you may choose to provide to us.

Data protection law recognises that certain types of personal information are more sensitive. This is known as ‘sensitive’ or ‘special category’ personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person’s sex life or sexual orientation.

Sensitive information will only be collected where necessary, for example, we may need to collect health information from you if you apply for a beneficiary grant, when you register for a challenge event or to deliver a community service as a volunteer or member of staff. Clear notices will be provided at the time we collect this information, stating what information is needed, and why. With your explicit consent, we may also collect sensitive personal information if you choose to tell us about your experiences relating to our services for use in a case study.

4. If you’re 16 or under

If you’re aged 16 or under, you must get your parent/guardian’s permission before you provide any personal information to us. We will always seek explicit consent from the person who has parental responsibility for children under 16 years of age.

5. How and why we use your information

We will use your personal information for the following purposes:

Donation processing: We will process personal information you provide in order to administer any one-off or on-going donations you make and claim Gift Aid.

Responding to a request: If you contact us with a query, we may use your personal information to provide you with a response. Fundraising or direct marketing: We will only send you marketing information by email, SMS, or phone if you have given us specific consent. If you withdraw your consent and then subsequently opt in to receive marketing information again, then your most recent preference may supersede. If you have responded to a letter of appeal, you may also receive fundraising mail, which you can opt out of at any time by:

Phone 0121 661 9860 Email events@boparan.com Post The Boparan Charitable Trust, 2nd Floor, Colmore Court, 9 Colmore Row, Birmingham B3 2BJ.

Monitoring and evaluating: We may use your information in order to improve current and future delivery of our services.

Processing an application to work with us: We may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and respond to you. Processing an application for one of our services: We will need to process the information you give to us to enable you to access our services.

Transactional purposes: We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for services, for example, processing payment for a DBS check.

Providing and developing our website: We may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further.

Administration: We may use your personal information to record and deal with a complaint, record a request not to receive further marketing information, record what our volunteers have done for us, and for other essential internal record keeping purposes. Protecting your vital interests: We may process your personal information where we reasonably think that there is a risk of serious harm or abuse to you or someone else.

Market research and surveys: We may invite you to participate in surveys or market research to help us improve our website, fundraising, services and strategic development. Participation is always voluntary and no individuals will be identified as a result of this research, unless you consent to us publishing your feedback.

Legal, regulatory and tax compliance: Where required we are subject to a legal obligation, we may process your personal information to fulfil that obligation

Profiling and analysis: We may occasionally for the purposes of our legitimate interests use your personal information to conduct profiling of our supporters or potential supporters. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to such use of your personal information for profiling at any time by contacting us at the details set out at the end of this Privacy Notice

Our profiling and analysis activities can be broken into five categories:

1. Data matching

We may combine the personal information you have given us with data obtained from external sources, such as the Office for National Statistics, to infer the likely social, demographic and financial characteristics, so we can tailor our communications and services to better meet your needs or the needs of others like you based on the insight we gain from the profile we build. We will not use the results of this data matching activity in a way that intrudes on your privacy or your previously expressed privacy preferences.

2. Segmenting

We conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that campaigns or mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who may fall within a certain segment of supporters.

3. Major donor analysis

We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources such as Google; Companies House; published biographies and publicly available LinkedIn profiles.

The type of information we collect can include:

• career overview
• gift capacity
• areas of interest
• history of giving to us and others
• how the individual is connected with us and others
• public information on any philanthropic activities.

4. High value event planning

We may also use profiling to produce short biographies of people who are due to meet with our leadership team or attend an event that we may be hosting.

This helps our people to understand more about those we engage with and their interests or connection to us.

5. Ethical screening and minimising risk

As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity. This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering.

We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it. We may also ethically screen supporters to minimise risk of creating an association with an individual or group that conflicts with the standards we have set out in our overarching Fundraising Policy.

Who do we share your information with?

We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.

We will only share your data for the following purposes:

1. Third party suppliers: We may need to share your information with data hosting providers or service providers who help us to deliver our services, projects, or fundraising activities and appeals. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.

2. Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else. We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.

How we protect your information

We use technical and corporate organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors. Our online forms are always encrypted and our network is protected and routinely monitored. If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partners. We do this in accordance with industry standards and do not store the details on our website.

However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.

Vulnerable circumstances

We understand that additional care may be needed when we collect and process the personal information of vulnerable supporters and volunteers. In recognition of this, we observe good practice guidelines in our interactions with vulnerable people.

How long will we keep your information?

We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction).

If you request that we stop processing your personal information for the purpose of marketing, we may in some instances need to add your details to a suppression file to enable us to comply with your request not to be contacted.

In respect of other personal information, we will retain it for no longer than necessary for the purposes for which it was collected, taking into account guidance issued by the Information Commissioner’s Office.

Your rights to your personal information

Data protection legislation gives you the right to request access to personal information about you which is processed by The Boparan Charitable Trust and to have any inaccuracies corrected.

You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information.

If you wish to exercise these rights, please complete a Subject Access Request form (PDF) and send it along with copies of two separate identification documents which provide photo identification and confirm your address, such as a passport, driving license or utility bill. Please also provide any additional information that is relevant to the nature of your contact with us, as this will help us to locate your records.

You can send us the documents via post to: Gareth Aston Director The Boparan Charitable Trust 2nd Floor Colmore Court 9 Colmore Row Birmingham B3 2BJ

Alternatively email a copy of the form along with scans or photos of your two forms of identification to: Gareth.aston@boparan.com. We will respond within 30 days, on receipt of your written request and copies of your identification documents.

The Boparan Charitable Trust Children’s Policy

The Boparan Charitable Trust recognises that children have the same rights as adults in relation to why their personal information is needed, how it is processed, kept safe and retained. We have a children’s policy to raise awareness and support children’s understanding of the issues.

How to make a complaint or raise a concern

If you would like more information, or have any questions about this policy, to make a formal complaint about our approach to data protection or raise privacy concerns please contact the Charity Director.

Email Gareth.aston@boparan.com Phone 0121 661 9860 Post The Boparan Charitable Trust 2nd Floor, Colmore Court, 9 Colmore Row, Birmingham, B3 2BJ

If you would like to make a complaint in relation to how we have handled your personal information, please follow our complaints procedure. If you are not happy with the response you receive, then you can raise your concern with the relevant statutory body: Information Commissioner’s Office

Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Alternatively, you can visit their website.

We are registered with the Information Commissioner’s Office as a Data Controller under registration reference number zb126019 Changes to our Privacy Notice

Our Privacy Notice may change from time to time, so please check this page occasionally to see if we have included any updates or changes, and that you are happy with them.

(Last Updated: 045/07/23)