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Blue Cross Volunteer Privacy Policy

1. INTRODUCTION

At Blue Cross, we are committed to protecting your privacy. This Policy explains how and why we use your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally), to ensure that you remain informed and in control at all times. This policy applies to volunteer applicants, current and former volunteers.

We will never sell your personal data. We will only ever share it with organisations who help us deliver our services and projects where strictly necessary and only if they comply fully with data protection law.
Please read this privacy policy together with any other information that we may provide on specific occasions when we ask to collect or process your personal data so that you are fully aware of how and why we are using it.

Any questions?

If you have any data protection questions in relation to this Policy, about how we use your personal data in general, or if you would like to make a request to exercise any of the rights you have over your personal data (see section 11 of this policy for more details), please send them to the Data Protection Officer at Blue Cross. The Data Protection Officer can be contacted by e-mailing [email protected], calling  0300 777 1897 or in writing to:

The Data Protection Officer
Blue Cross
Shilton road, Burford,
Oxfordshire, OX18 4PF

How to Contact us

If you would like to update the personal data we hold about you, you can let us know in the following ways:

  • By updating your own profile on Connect for Pets, our volunteer database. Ask your volunteer manager if you need help with how to do this.
  • By writing to Volunteering Development, Blue Cross, Shilton Road, Burford, Oxfordshire, OX18 4PF or by email [email protected] or phone us on 0300 777 1980.
  • If you would like to request or opt out of receiving marketing communications from us, you can let us know by writing to Customer Services at Blue Cross, Shilton Road, Burford, Oxfordshire, OX18 4PF or by email [email protected] or phone us on 0300 790 9903.

2. ABOUT BLUE CROSS
We are Blue Cross, a registered charity (charity no. 224392 in England and Wales or SC040154 in Scotland). Like many charities, we are a company limited by guarantee (company no. 00363197). We also have a wholly-owned subsidiary, Blue Cross Trading Company Limited, a company registered in England and Wales  (company no. 2203092), which only operates in ways which help to further our charitable aims. Our registered office is at Shilton Road, Burford, Oxfordshire, OX18 4PF. For the purposes of data protection law, we are a controller of your personal data. This means we make decisions about how and why it is used, and have a duty to ensure your rights are protected.

Our Purpose

Blue Cross is a charity that has been helping sick, injured, abandoned and homeless pets since 1897. We help thousands of pets in need, providing veterinary care, expert behaviour help and finding them loving homes. We also give advice and education for current and future pet owners and offer pet bereavement support.

3. INFORMATION WE COLLECT ABOUT YOU

3.1  Personal data you provide
We collect personal data that you provide to us, when you apply to become a volunteer, and during the course of your volunteering involvement.  Most of this information is collected through our online or paper based application and recruitment process and through entering your data on your own profile on our volunteer database, Connect for Pets.  

Connect for Pets is provided by Better Impact Inc. Inc. and helps us to administer your volunteer relationship and communicate with you.  Better Impact Inc. Inc. are based in Canada and we have taken steps to make sure they have in place adequate levels of privacy protection, in line with UK data protection law.  You can read how they use and store your data on their website here.

We will collect, store and use the following personal information about volunteers:

Data collected

What we use it for

Shared with third parties?

Legal basis for processing data

Personal contact details such as name, title, addresses, telephone numbers and email addresses

To be able to contact you about your volunteering with us

Better Impact Inc.

Legitimate Interest

Emergency contact details

To contact someone if you have an emergency when you’re with us

Better Impact Inc.

Legitimate Interest

Date of birth

To check whether you meet the age requirements for the role you’ve applied for.  For anyone under 16 we will require consent from a parent or guardian

Better Impact Inc.

Legitimate Interest

Recruitment information e.g. references, work permits, visas and other information collected as part of the recruitment process

To make a decision about your suitability for volunteering with us in your chosen roles. 
References aren’t taken for all roles. Work permits are for young people.

Better Impact Inc.
Work permits are shared with local authorities

Legitimate Interest

Where did you hear about Blue Cross

To review the effectiveness of our volunteer recruitment channels

Better Impact Inc.

Legitimate Interest

Why you want to volunteer with us

To review whether we can offer you a suitable volunteer role

Better Impact Inc.

Legitimate Interest

Your skills and experience

To make a decision about your suitability for volunteering with us in your chosen roles

Better Impact Inc.

Legitimate Interest

Information about your health  through a health questionnaire

To comply with our health, safety and wellbeing obligations, and to ensure we can keep you safe in your volunteer role and make any necessary and reasonable adjustments to your role

Consent

Risk assessments

To check your suitability for the role you will be undertaking and so we can meet our health, safety and wellbeing obligations, make any reasonable adjustments and keep you safe in your role

Legitimate Interest

Dates and information about the key stages of our recruitment process

To ensure that we have been through the correct recruitment process with you and to ensure you have what you need for your volunteer role (e.g. ID badge and uniform issued)

Better Impact Inc.

Legitimate Interest

Information about criminal convictions and offences as part of the recruitment process (collected on application form)

To make a decision about your suitability for volunteering with us in your chosen roles. 

Consent

Information about criminal convictions through a DBS check – for volunteer roles that include “regulated activity” such as Educational speakers

To check you are not barred from working with young or vulnerable people and to make an informed choice about your suitability for the role

Diva Care Ltd (the partner agency we use for DBS checks)

Consent

Driver details

To make sure that you have the necessary driving checks in place for any roles that involve driving on behalf of Blue Cross, to meet our legal health and safety requirements

Better Impact Inc.

Drive Tech – the partner agency we use for checking driver details

Consent

Dates that you have read and understood key policies and signed our Volunteer Charter

To ensure compliance with our key policies

Better Impact Inc.

Legitimate Interest

Start date for volunteering

To ensure we know your official start date and to give you access to the relevant Blue Cross systems to do your role

Better Impact Inc.

Legitimate Interest

Mailing Preferences

To understand whether and how you would like us to contact you about Marketing or Fundraising that does not relate to your volunteering role

Better Impact Inc.

Consent

Information about your dogs if you intend to use them as part of your role

To ensure your dogs are suitable for the role

Better Impact Inc.

Legitimate Interest

Information about our home, household and other pets

To ensure we only send you foster pets that are suitable for your home environment and family circumstances

Better Impact Inc.

Legitimate Interest

End date for volunteering, and reason for leaving

To ensure we know your official date of leaving, and the reason you are leaving so we can send you a leavers’ survey. To remove your access to any Blue Cross systems

Better Impact Inc.

Legitimate Interest

If you are a Trustee - Name, title, address, telephone number, personal email address, date of birth

For the Register of Directors and Members

Companies House,
Charity
Commission

Legal obligation

 

3.2 Personal data created through your involvement with us
Your volunteering activities and involvement with Blue Cross will result in other personal data about you being created. This will usually be collected on Connect for Pets our volunteer database, and Blue Horizons, our online training platform.  Some records will be created and stored in hard copies and kept securely.  This may include the following:

Data collected

What we use it for

Shared with third parties?

Legal basis for processing

Information about what you have done in your volunteer role,  how many hours you’ve given, and the outputs of your time
This is collected on our system but also through signing in sheets

To manage your volunteering experience, to feed into reward and recognition processes and for anonymised management information about our volunteer programme

Better Impact Inc.

Legitimate Interest

Qualifications relating to the role you want to undertake

To assess whether you have the qualifications or  experience for specific roles

Better Impact Inc.

Legitimate Interest

Training, Induction and events records

To ensure we know what training and events you have completed in your role, and for compliance with our training policies

Better Impact Inc.

CallidusCloud – the partner agency who provide Blue Horizons our online training platform

Legitimate Interest

Review meeting records and other performance information

To ensure we know when your last review meeting was and to check we put in place any agreed changes.

Better Impact Inc.

Legitimate Interest

Details of any other BX system access and your ID on that system

To match your record across any other Blue Cross systems where relevant and ensure you have the correct access when you need it

Better Impact Inc.

Legitimate Interest

Bank account details

In order to reimburse any expenses via bank transfer

Legitimate interest

Details of any accidents or incidents, or near misses occurring on our property or involving our volunteers.

A record of what happened and the action we have taken will be kept and may include personal and sensitive data

Legal obligation

Email communications

To communicate with you about your volunteer role

Better Impact Inc.

Legitimate Interest

Engagement and culture survey

We will periodically invite volunteers to take part in surveys about their volunteering experience. These are to understand more about our volunteers’ experience in order to make improvements. Results are treated confidentially and are not attributable to individuals. 

Online survey tool e.g. SurveyMonkey or professional survey partner

Legitimate interest

Leavers’ survey

Volunteer leavers are invited to complete a survey so we can learn more about why they are leaving. It can be answered anonymously and an anonymised report is presented to managers so improvements can be put into place.  Volunteers can choose to have their feedback shared with the local service manager and can add their personal details if they want someone to get in touch to discuss their feedback

Online survey tool e.g. SurveyMonkey

Legitimate interest

Diversity survey

We will invite volunteers every two years to take part in a diversity survey so we can monitor our diversity and inclusion processes and to identify trends.  This will include special category data but will be collected in an anonymised way and will not be attributable to individual volunteers.

Online survey tool

Legitimate interest

 

3.3 Personal data created by other Blue Cross teams
Additionally to your volunteering experience, there may be other data created about you through other interactions through Blue Cross.  For example this may include details of any pets you have rehomed or who have been treated through us, any appeals you have supported, donations made or when buying something from one of our charity shops or information gathered through your interactions with our website.  You can read more about this type of data, unrelated to your volunteer role, in our Privacy Policy on the website https://www.bluecross.org.uk/privacy-and-cookie-policy

3.4 Information from third parties
We sometimes receive personal data about individuals from third parties. In volunteering this includes brokerage services or recruitment partners such as Duke of Edinburgh, Do-it.org.uk or local Volunteer Centres who volunteers have chosen to apply through. Volunteers from these channels will be required to complete the same application and recruitment processes as other volunteers and their data will be collected and used in same ways outlined above.

We also receive data from third parties such as Diva Care when we need to carry out a criminal record  check if you are in a role that is regulated activity, for example, working in schools as an Education Volunteer.  

3.5 Special categories of personal information
We collect special categories of personal data relating to volunteers’ health through a health questionnaire and sometimes through individual risk assessments for young and vulnerable people, in order to meet our health, safety and wellbeing responsibilities; and to ensure volunteers are provided with any necessary support or reasonable adjustments to complete their role successfully.  We take extra care to ensure that your privacy rights are protected ensuring that we have obtained your explicit written consent to process this data, and by storing this information securely.   Other special categories of personal information relating to diversity are collected as described above via anonymous surveys and not attributable to individual records.

3.6 Our obligations as a workplace provider
Where you have provided us with your particularly sensitive personal information, we will use it in the following ways:

  • We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to volunteer and to provide appropriate workplace adjustments.

3.7 Accidents or incidents
If an accident or incident occurs on one of our properties or involves one of our volunteers, our record of what happened and the action we have taken as a result may include personal and special categories of personal data.

3.8 Information about criminal convictions
We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our data protection policy.

We will only undertake an official criminal record check for volunteers if it is appropriate given the nature of the role and where we are legally able to do so.  We will always inform you in advance if the role is subject to such a check.  We will use information about criminal convictions and offences as part of the recruitment process to assess whether you can work in any roles that have considerable contact with young or vulnerable people.
We are able to use your personal information in this way to carry out our obligations.

4.  LEGAL BASIS FOR COLLECTING AND USING VOLUNTEER PERSONAL DATA

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

4.1 Legitimate Interest

To administer, manage and support volunteers, we rely on the legitimate interest ground provided that your fundamental rights do not override those interests. Our legitimate interests are:-

  • to keep our records updated;
  • to administer our relationship with you;
  • to determine how our limited resources might be used in the most effective way;
  • to protect our security, guard against fraud and other wrongdoing; and
  • to support engagement and participation

In order to offer you a volunteer role, and manage and support your volunteer relationship we may:-

  • process volunteer applications and offer volunteer roles
  • contact you about your volunteering role
  • maintain databases of our volunteers to make sure the personal data they contain is accurate and up to date
  • keep you up to date as part of the Blue Cross team
  • manage feedback and complaints
  • ask you to take part in a survey

4.2 Consent

We use the legal basis of consent to contact volunteers about national marketing and fundraising initiatives or events.  If you choose to hear from us about national marketing and fundraising we will maintain records of your choices and preferences so we can adhere to them.


4.3 Other situations we may use your personal data

  • We may also use your personal information in the following situations:
  • where it is necessary in order enter into, or perform a contract with you where we need to comply with a legal obligation
  • to protect your vital interests for example in a life or death situation;
  • where it is needed in the public interest or for official purposes
  • In any event, we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes).

4.4 Using your information to enforce and comply with the law

We must ensure our activities comply with the law. Therefore we may need to share your personal data if we are required to do so by law, e.g.in connection with a court order. We may use your personal data for other purposes such as fraud prevention, to comply with money laundering regulations and to protect people’s rights, property or safety.

If certain levels of financial donations are made, the Fundraising Regulator’s Code of Fundraising Practice requires all charities in the UK to perform certain checks regarding the individual who has made the donation. More details can be found at www.fundraisingregulator.org.uk.

Please note that we may process your personal data without your knowledge or consent.

4.5 Who we share your personal information with and why

We take all reasonable efforts to keep your details safe and secure and will only share them with suppliers or professional agents working on our behalf, for example:

  • Software providers such as Better Impact Inc. who help us store and manage our volunteer data, and CallidusCloud who deliver our learning management system (e-learning)
  • Agencies such as DriveTech who provide driver checking services for us and DivaCare who undertake criminal records checks on our behalf
  • Professional fundraising organisations who send out our fundraising or marketing materials (when you have given permission to receive such information)

We carefully select our partners and will only share information with them if we are confident that they will protect it and comply with data protection law. We will always have a contract in place with them that assures this.

We will never share your details with other organisations to use for their own marketing purposes.

5. MARKETING

When you apply to volunteer you are invited to indicate your marketing preferences as to whether and how you would like to hear more about Blue Cross work, outside of your volunteering experience – this includes marketing and fundraising information.  If you select yes for email or phone communications, or if you don’t opt out of postal communications, you will be added to our supporter database and treated as a supporter as well as a volunteer. This section explains how we will use your data as a supporter, for more information you can read our main privacy policy on our website here 

You can change your marketing preferences at any time by emailing [email protected] or phoning on 0300 790 9903.

5.1 Profiling

Occasionally we may look at our volunteer data to better understand what sort of volunteer roles are attractive to which people. This may include looking at any existing relationship we have with them, their address including distance from a particular Blue Cross location and the frequency and type of volunteering role that they undertake. This enables us to target new and existing volunteers with information about roles that they may find of most interest.

  • If you do not wish your data to be used in this way or have questions about this, you can notify us by emailing [email protected].

6.  OUR WEBSITE AND COOKIES

We collect or process personal data about visitors to our website when they choose to provide it, such as when signing up to our newsletter.

We may also collect or process data about visitors to our website to help us optimise and improve the website for everyone. This information might include the Internet Protocol address, the browser being used, the device (e.g. its operating system) and the connection type (e.g. the Internet service provider). None of this information is likely to directly identify you.

6.1 Automated decision making

We employ CallidusCloud to provide online training for us as part of which automated methods are used to assess whether a volunteer has passed a particular course. There are no significant consequences of this decision making and participation in this course is optional.

7. KEEPING YOUR INFORMATION SAFE

We employ a variety of physical and technical measures to keep your personal data safe and to prevent unauthorised access to, or use or disclosure of it. Electronic data and databases are stored on secure computer systems and we control who has access to them (using both physical and electronic means). Our employees and volunteers receive data protection training, and we have a set of detailed data protection procedures which they are required to follow when handling personal data.
We cannot absolutely guarantee the security of the internet, external networks or your own device, accordingly any online communications (e.g. information provided by email or through our website) are at your own risk. 

8. STORAGE AND RETENTION

We only store personal data as long as it is required for the purpose(s) we collected it for (or for a related compatible purpose, such as keeping a record of a donation). Legal requirements mean that we have to retain certain items of personal data for a given period of time e.g. gift aid declarations must be retained for seven years. 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 it, the purposes for which we process it and whether we can achieve those purposes through other means, together with the applicable legal requirements. We regularly review what data we have and delete that which is no longer necessary. In certain situations you have the right to request that your personal data be deleted (the ‘right to be forgotten’); please see section 10 for further details.
Volunteer records will be held for up to a year for any applicant that didn’t start, and for 3 years after the end of the volunteer role for active volunteers.

8.1 International transfers

Except as set out above, we normally only store personal data within the European Economic Area (EEA). If one of our subcontractors (such as a payment processor) needs to transfer it outside of the EEA then we will take steps to make sure adequate levels of privacy protection, in line with UK data protection law, are in place. These safeguards will usually be contractual and/or the result of a European Union decision which allows the transfer (for example, a US organisation which is certified under the EU-US Privacy Shield framework).

9.  CHILDREN’S PERSONAL DATA
We are committed to protecting the privacy of the young people that volunteer, fundraise, attend events organised by us and at schools or clubs or engage on our website. Where appropriate we will ask and obtain the consent of a parent or guardian.

10.  YOUR RIGHTS 

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

  • where data is processed on the basis of consent, the right to withdraw that consent;
  • the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of it (subject access);
  • the right to have inaccurate data rectified;
  • the right to object to your data being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
  • the right to restrict how your personal information is used; and
  • the right to be forgotten, which allows you to have your data erased in certain circumstances. Please note this is not an absolute right and may not apply if we need to continue using it for a lawful reason.
  • the right to data portability, which allows individuals to obtain and reuse the personal data they have supplied to Blue Cross for their own purposes across different services in a safe and secure way.

If you would like further information on your rights or wish to exercise them, please write to the Data Protection Officer using the details given in section 1, with details of your request.
Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the personal data no longer exists or there is an exception which applies to your request).
If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner's Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.

11. UPDATES TO THIS POLICY

We may update this Policy at any time. When we do, we will post a notification on the Volunteering pages of our website and revise the updated date at the bottom of this page. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we hold.
This Policy was last updated on 23rd May 2018

— Page last updated 24/05/2018