Data Protection Statement

We collect information in several ways, which will include:

• When you contact us in person, online or by telephone.
• When you attend a Salvation Army event, fill in a paper or online form, respond to an online or offline advertisement, or subscribe to a service or e-newsletter.
• When you make a charitable donation online, by telephone or by filling in a form.
• When you seek assistance from The Salvation Army or use one of our services - for example, at a lifehouse (hostel), community centre or corps (church).
• When you call the modern slavery referral service.
• When you apply for a job or to volunteer at The Salvation Army.
• When you apply for officer training.
• When you work as a Salvation Army officer or chaplain or enrol as a member of a corps.

We will only collect the personal data we need to fulfil a stated purpose. This will vary according to the purpose, and will typically include some or all of the following:

• Your full name.
• Your contact details, including a full UK postal address, an email address and a telephone number.
• Your date of birth.
• Your image (usually as part of a case study or due to your participation at an event).
• Financial details related to a donation or gift.

Some categories of data are more personal to an individual. UK data protection law recognises these as special category data, and we are required to treat them with great care to ensure your rights and freedoms are upheld.

Special category data includes:

• Information related to your racial or ethnic origin.
• Information related to your religious or philosophical beliefs.
• Information that reveals a political opinion.
• Biometric data, used to identify you.
• Your health data.

Where we collect special category data, we will always give you a clear reason why we are processing it and how and, where possible, give you the option to decline to disclose the information to us.

We collect personal data in several ways and for different reasons, including:

• To keep you informed about our work and the different ways in which you can support us.
• To publicise activities and events across The Salvation Army, for example at corps or at Christmas time.
• To support our fundraising operations, including processing a donation and, where applicable, Gift Aid.
• To provide you with assistance at one of our sites, such as a lifehouse, community centre or corps.
• To provide you with assistance through one of our dedicated services such as Employment Plus or Debt Advice.
• To process a referral made to one of our advice lines.
• To support your application to work or volunteer with us and to administer any subsequent employment.
• To manage your pension.
• To support applications for officership and to train new officers.
• To support officers and members in their spiritual life.
• To manage residential tenancies.
• To record your stories and images for use as case studies in our print and online publications, and as part of publicity materials.
• To undertake analysis and reporting to support decision-making in relation to our operations.
• To manage feedback and complaints, including the recording of inbound calls to some of our support teams.
• To secure our premises and protect our people, including through the deployment of CCTV systems on some premises.
• To always maintain the health and safety of anyone working at, or visiting, The Salvation Army.
• To manage ongoing or potential safeguarding concerns.

We always identify a lawful basis before processing any personal data.

The Salvation Army may use your information in several ways to support our charitable work. As well as processing any donations you make, we also work in the following ways:

• Contacting our supporters. We will regularly send you information about The Salvation Army, our work, and the different ways in which you can support us. We do this using various channels and with your permission, including by email and SMS text. Where we have a proven legitimate interest, we may also contact people by telephone (if we do not have consent and your number is not listed on the Telephone Preference Service), post and email (where you have given us your details).

   

• Finding new supporters.

  • We work with a trusted third party agency to access postal mailing lists of individuals who are not known to us. All lists are vetted to ensure that they only contain suitable recipients. We only become aware of a recipient if they contact us. To ensure that we do not purchase the details of those already known to us, we provide our agent with an exclusion list of existing supporters, which will be limited to names and addresses.
  • We also use a similar technique for excluding known supporters from online advertising, served across platforms such as Facebook, Bing and Google, using email addresses or postcodes.
  • Our Philanthropy fundraisers will use publicly available information to ascertain if an individual might be interested in supporting our work. We always tell potential high-value donors why we are contacting them at the first opportunity.

   

• Managing your contact preferences. We maintain a list of people who have told us that they do not want to hear from us again, or would like us to stop contacting them in a particular way (for example, by post or email). We also record when people ask us to restrict the use of their information (for example, as part of analytical work).

• Contractors. We work with several third party suppliers, under contract, and will share your personal data with them to:
  • Manage correspondence and responses to our campaigns, including processing donations. (This includes telephoning you when you use the text-to-call-back service that is offered as part of our larger fundraising appeals.)
  • Print and send you postal packs.

  • Perform analysis that helps us better understand our supporters and to make decisions about future activities, and working practices, based on aggregated data.

    We also use third party platforms to support our fundraising work, and may also share personal data with them under contract. These suppliers include:

  • Westwood Forster for the support and maintenance of our supporter database.
  • M-hance for consultancy on customer relationship management solutions.
  • Edit for the provision of marketing agency services.
  • Dotdigital for the provision of an email marketing system.
  • Fundraise Up for the provision of online donation services.
     
• Tailoring our asks. From time to time, we will analyse our supporter database to identify the appropriate type and level of financial support we ask you for. This allows us to tailor our fundraising communications sensitively and respectfully. As well as undertaking our own in-house research, we may also contract with a third party specialist partner who can provide us with insights and wealth indicators gathered from various sources (for example, Companies House, company websites, press reports and media platforms, such as LinkedIn). Any outcomes of such work with third party agents are confidential to The Salvation Army. If you do not want us to use your personal data in this way, please let us know by contacting our Supporter Care team by email at fr@salvationarmy.org.uk.

The Salvation Army maintains websites at https://www.salvationarmy.org.uk/,  https://www.salvationist.org.uk/ and https://www.strawberryfield.salvationarmy.org.uk/, where we will also collect information from you. This may include your IP address.

All our websites use cookies and similar technology to collect your personal data, often requiring your consent. Please see the respective Cookie Policy for each site, which can be found at the foot of each published page.

The websites collect information to:

• Maintain site security and safety.
• Allow for the speedy diagnosis of faults and technical issues.
• Allow effective presentation of content to you on your device.
• Help us understand how you use our websites and what aspects of our work you are interested in supporting.

We use the following tools to help us manage our websites:

• One Trust – to manage cookie preferences.
• Google Analytics, Google Tag Manager and Hotjar – to understand website traffic, behaviour and uses.
  We use the Facebook Conversion API to share unidentifiable marketing data between our main website and Meta. We do not use this technology on pages deemed to be of a sensitive nature or which are used to process personal data in relation to our corps or services.

The Salvation Army will only share your personal data in certain circumstances and in the following ways:

• With our suppliers who are employed to conduct specific work for us and with whom we have a contract setting out their responsibilities for handling your information securely and in line with UK data protection law.
• Where we are working in partnership with another organisation, such as a local authority, to provide a specific service (for example, in relation to homelessness).
• Where we are under a legal obligation to disclose or share information.
• Where we are under obligation to disclose information, or undertake monitoring of potentially criminal behaviour, under the Regulation of Investigatory Powers Act 2000.

The Salvation Army processes personal data in the United Kingdom. When working with suppliers, contractors and third party agencies, we will always opt to process personal data in the United Kingdom or another geographical region that meets the standards laid out in the UK data protection law, such as the European Economic Area (EEA). Where it is necessary to transfer your information outside of the UK or EEA, we will only allow the transfer to take place if the appropriate measures are in place to ensure the data is always managed in accordance with the UK data protection law. This will include the completion of necessary risk assessments and signing of applicable contractual safeguards.

We manage all personal data according to an internal records management policy. Retention schedules exist for different areas of The Salvation Army and set out timeframes for keeping information. Personal data is only ever retained for as long as is necessary. We try to tell you when we collect your information how long it will be kept for.

Retention periods are often determined by an operational need (for example, we will keep your email address if you are subscribed to a current e-newsletter) or by contractual or legal requirements. We may keep some information indefinitely for safeguarding purposes, and where we believe there is a potential risk to individuals, especially children and vulnerable adults.

Where there is a requirement to keep information in the longer term for the purposes of analysis and reporting, the data will be retained in a format that no longer contains personal data.

Personal data that is captured in records that tell a significant part of The Salvation Army’s story, may be retained permanently at the International Heritage Centre, for historical and research purposes, and under the care of professional archivists. The archive includes information about Salvation Army officers and their careers, as well as corps membership rolls and service residential logs. Personal records of living individuals are always kept closed to external access.

The UK data protection law sets out the principles we must adhere to, and the range of lawful bases we can rely on, when processing personal data.

Some examples of how we use the different lawful bases, and when, are as follows:

• Consent. We will use this basis when sending some targeted fundraising and marketing communications electronically, either by email or SMS text, or to contact you by telephone.
• Contract. We will use this basis when processing employee personal data.
• Legal obligation. We will use this basis to comply with the law – for example, if responding to a court order.
• Vital interests will be the basis we use to share personal data if we believe someone’s life is at risk.
• Public task. We will use this basis to process personal data when giving support to vulnerable individuals, for example in relation to homelessness service.
• Legitimate interests. We will use this basis to send some targeted fundraising and marketing communications by email or SMS text, post, and telephone, pending completion of a balancing test.

The UK data protection law gives you specific rights over your personal data. These are as follows:

• To be informed about how we are processing your data.
• Ask us to provide you with a copy of your personal data (known as a data subject access request).
• To have any mistakes or inaccuracies rectified.
• To request that we delete your personal data.
• Ask us to restrict the use of your personal data in certain circumstances.
• Object to our processing of your data in certain circumstances.
• To object to our use of your personal data for the purposes of profiling.

You also have rights around data portability and automated decision making.

If you want to ask us about any of these rights, please contact the Data Protection Officer using the details listed below (see section 11).

To make a data subject access request, you can contact The Salvation Army by any means that suits you. The most efficient way is to contact the Data Protection Officer, or complete and return this form. Please note that we may ask you to provide us with a copy of your current identification (such as a passport or driving licence) which will be deleted after we have verified your request.

If you have any questions about how we use your personal data to support our fundraising activities, you can speak to our Supporter Care team on 020 7367 4800 or by email fr@salvationarmy.org.uk.

If you have any questions about the content of this statement, or about how The Salvation Army manages your personal data, please contact the Data Protection Officer by post at:

The Salvation Army
1 Champion Park
London
SE5 8FJ.

You can also email data.protection@salvationarmy.org.uk or telephone 020 7367 4500.

If you are in the Republic of Ireland, please email roidataprotection@salvationarmy.ie, with any questions about how your personal data is managed and to obtain a copy of the Ireland-specific statement on data protection.

You also have a right to speak to the United Kingdom’s data protection regulator, the Information Commissioner’s Office, if you have any concerns about how The Salvation Army processes your personal data. They can be contacted by post at:

Wycliffe House
Water Lane
Wilmslow
SK9 5AF.

You can also use their website: https://ico.org.uk/global/contact-us/

The Salvation Army Trustee Company (company number 259322 in England) acting in its capacity as trustee of either The Salvation Army Trust (registered charity in England and Wales (214779) and in Scotland (SC009359))  or The Salvation Army Social Work Trust (registered charity in England and Wales (215174) and in Scotland (SC037691)). Depending on the use of your data, either of these Trusts may be responsible. Our registered office is at 1 Champion Park, London SE5 8FJ.