Read our Privacy Policy and Cookie Policy here. PDF policies are also available to download from the links within each section.

BHS Trust Fund Privacy Policy

Introduction

Welcome to the BHS Trust Fund’s privacy policy.

BHS Trust Fund respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS

Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how BHS Trust Fund collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete our contact form, when you sign up to our mailing list or when you contact us by phone or via social media accounts such as Facebook, Twitter and Instagram.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

BHS Trust Fund is a registered UK charity and our charity number is 1171705. We provide hardship relief grants to former BHS employees.

BHS Trust Fund is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: BHS Trust Fund
Email address: contactus@bhstrustfund.com
Postal address: PO Box 7762, Rothwell, Kettering, NN14 6TU
Telephone number: 07495 723550 or 07908 994146

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 1st February 2021.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has beena removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, title, date of birth and passport number. We also collect your emergency contact details (first name, surname and telephone number).
• Contact Data includes address, email address and telephone numbers.
• Financial Data includes bank account details.
• Transaction Data includes details about payments made to you in the form of refunds for items you have purchased prior to a grant being approved or in respect of settlement of bills/mortgage/rent/council tax arrears etc.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Before arranging holidays abroad, we collect travel insurance details.

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• contact us by any means for general information on our support services, help or assessment to see if you are eligible to receive a grant;
• provide your personal data via our website for inclusion in our mailing list;
• contact us using Facebook, Twitter and Instagram social media platforms;
• subscribe to our mailing list or request other marketing information to be sent to you; and
• enter a survey or give us feedback.
• Automated technologies or interactions. Please see our cookie policy [LINK] for further details on our use of cookies.
• Third parties. Personal Data received from BHS Retired Staff Association and pension holders about BHS retired staff and pension holders.

How we use your personal data

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

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• With your consent.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

You will receive marketing communications from us if you have actively signed up to our newsletter. You can withdraw your consent to receive our newsletter at any time by following the link to unsubscribe.

Where you opt out of receiving the newsletter, this will not apply to personal data provided to us as a result of a service provision or other transactions.

Third-party marketing

We do not share your personal data with third parties for marketing purposes and, if we will do so at any point in time, we will get your express opt-in consent before doing so.

We simply share personal data (name and addresses) with our distributor responsible for addressing the envelopes for the holiday and Christmas communications. The list is then destroyed as soon as the job is completed.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Service providers acting as processors who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Travel agencies when booking annual holidays abroad and UK family breaks.
• Local authorities, utility suppliers, mortgage providers acting as controllers when settling bills on your behalf.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

All of our data is stored in the UK.

Should we ever need to transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those trustees, case workers and administrators, working or volunteering for us and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Data storage is protected by password, both on the computers that hold the data and the software used to operate it. Any data held within electronic address books or on mobile devices is also password protected.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When it is no longer necessary to retain your personal information, we will delete it or anonymise it. For instance, we will delete your passport details, date of birth, travel insurance details and emergency contact details as soon as the holiday abroad or the UK break is over.

When you request to unsubscribe from our mailing list, we will not delete your personal data entirely but rather keep just enough information to ensure that your preferences are respected for the future. The data we retain will only be enough to identify you as a previous contact who has unsubscribed from our mailing list.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your legal rights are as follows:

• Request access to your personal data – Commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of your personal data – This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data – This right enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data – You can object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing your personal data – This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. a) If you want us to establish the data’s accuracy.
2. b) Where our use of the data is unlawful but you do not want us to erase it.
3. c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Right to withdraw consent – This applies where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise any of these rights at any time by contacting us at BHS Trust Fund, PO Box 7762, Rothwell, Kettering, NN14 6TU.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Other websites

Our website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise that you review the privacy policy of every website you visit.

BHS Trust Fund Cookie Policy

You can download a pdf version of our Cookie Policy here.

We ask that you read this cookie policy carefully as it contains important information on our use of cookies or similar technologies on our website. This policy should be read together with our privacy policy which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities in the event you have a complaint.

Information about our use of cookies

Websites generally use cookies to distinguish a user from other users of the website. This helps to provide users with a good experience when they browse websites and also allow to improve a site.

What are cookies?

A cookie is a small file of letters and numbers that are stored on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

For example, we may monitor how many times you visit the website. This information helps to build a profile of users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

You can set your browser not to accept cookies and www.aboutcookies.org or www.allaboutcookies.org tell you how to remove cookies from your browser. However, some of the website features may not function as a result.

For further information on cookies generally visit those sites.

We do not use any of the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of some websites and are essential for users to be able to navigate various websites and use their features.
• Analytical/performance cookies. They would allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps to improve the way a website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise users when they return to a website. This allows a website to remember the choices a user makes and provide enhanced, more personal features.
• Targeting cookies. These cookies record users’ visit to a website, the pages a user has visited and the links a user has followed. However, we do not use this information to make our website more relevant to your interests. We also do not use external advertising within our website.

The only cookies that you will come across when visiting our website are the following:

• Social media cookies. These cookies are used when you share information using your social media accounts.

Consent

In the event that we will in the future start using cookies we will ask for your permission (consent) to place cookies or other similar technologies on your device, except where these are essential for us to provide you with a service that you have requested.

Third-party cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Social media cookies are third party cookies placed on our site. For example, when you click a button or link and visit our profile on their sites. These actions take you away from our main site and onto theirs or opens the site in a new browser tab.

How to turn off cookies

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of a website.

The website www.allaboutcookies.org contains a step-by-step guidance on how cookies can be managed.

How to contact us

Please contact us at contactus@bhstrustfund.com, if you have any questions about this cookie policy or the information, we hold about you.

Changes to this policy

This policy was last updated 1st February 2021.

We may change this policy from time to time and when we do, we will inform you via a notice on our website.

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