Privacy notice

This privacy notice describes how and why Alcohol Change UK uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information.

Our aim is to be clear and transparent about what we will do with your information at the point that we collect it. We will respect and keep safe all of your personal information that we hold.

We have relationships with many programme participants, supporters, volunteers, fundraisers and researchers, so 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, raise more funds and, ultimately, helps us to reach our goal to significantly reduce the impact of alcohol harms in the UK.

This policy is effective from 7 December 2018.

Who we are

Alcohol Change UK is the operating name of Alcohol Research UK, a registered charity in England and Wales (1140287) and a registered company in England and Wales (07462605). We refer to our organisation throughout this policy as ‘Alcohol Change UK’, ‘we’ or ‘our’. We also own and run Dry January, a campaign that begins with 31 days free from alcohol with the aim of helping participants to reset their relationship with alcohol over the longer-term.

How we collect information about you

We collect information in the following ways:

Information you give us

You may give us your information in order to sign up for one of our events, sign up for Dry January, use our Try Dry mobile app, make a donation, purchase our products, register as a volunteer, fundraise for us, apply for research funding, use our training, purchase our products, access our alcohol information services or otherwise communicate with us by phone, letter, email or through our website. When you interact with us, we’ll often ask for personal information in order to better process your interaction with us, such as your name, email address, telephone number, date of birth, gender, location, bank account details for setting up a regular direct debit gift, contact preferences, and information about your current drinking pattern.

Information we get from your use of our website

We collect information about which of our online content you use and how you use it, such as which pages you view, where you move on our websites, and how you interact with our content and ads. Like most organisations, we will be aware of what browser you are using, your IP address and your computer operating system. This information may be used to improve the services we offer. Please see our Cookies Policy for more detail.
We also collect information via our various online sign-up forms, such as your name, email address, location, age, gender, and the service or product for which you are signing up.

Information we get from your use of our 'Try Dry: The Dry January app' mobile application

Through 'Try Dry: The Dry January app', we collect information about your name, email address, gender, date of birth, location, app usage, any donations, and drinking patterns, levels and types. Like most app providers, we will also be aware of simple information about the device through which you are accessing the app. This information may be used to improve the services we offer.

Information from known third parties

We may also receive information about you from our third-party partners with whom you choose to interact, for example websites such as Virgin Money Giving and JustGiving, when raising funds. This can include information such as your name, postal or email address, phone number, your geographic location, donation amounts, details of your sponsors, credit/debit card details and whether you are a tax payer so that we can claim Gift Aid. To the extent that we have not done so already, we (or they) will notify you when we receive information about you from them and tell you how and why we intend to use that information.

Information available publicly

We supplement information on our current and potential supporters, customers, and programme participants with information from publicly available sources such as public websites, corporate websites, public social media accounts, the electoral register and Companies House. This enables us to develop a fuller understanding of the interests of these stakeholders and their potential to support our mission and work.

Social media

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.

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, in order to ensure key services can be legally provided to you, that information is tailored to you, and for evaluation and research purposes
  • your gender, to ensure that information is tailored to you and for evaluation and research purposes
  • your location, to ensure that information is tailored for you and for evaluation and research purposes
  • 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, right to work in the UK, 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
  • information about your activities on our website(s) and apps; and about the device you use to access these, for instance your IP address and geographical location
  • information about which of our events, activities and products you have signed up for and attended/used
  • information relating to your health and diet, for example dietary requirements and particular mobility or sensory needs if you are taking part in or attending an event, as well as where you share your alcohol related experiences with us by phone, letter or email or via our website or appwhere you have left us a legacy, any information regarding next of kin and executors who may administer this
  • information as to whether you are a taxpayer to enable us to claim Gift Aid
  • age, income, gender, nationality, sexuality, disability, ethnicity and faith information for research and evaluation purposes and to ensure our services are accessible to all
  • 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. This includes information about health, race, religious beliefs, political views, trade union membership, sex life or sexuality or genetic/biometric information.

We only collect, store and process this type of information 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 with us, about your drinking patterns where you are using our app, interactive elements of our website, our Video Chat Support, or to provide appropriate facilities or support to meet your needs, including in emergencies or when someone is in danger or serious risk.

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

How we use your information

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 and your needs, preferences, etc
  • respond to or fulfil any requests, complaints or queries you make to us
  • understand how we can improve our services, products or information through monitoring, evaluation and research
  • understand who uses our products and services, to improve the accessibility of our products and services and to contact you by email for monitoring, evaluation and research purposes
  • 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
  • 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 you enter your details onto one of our online forms without ‘sending’ or ‘submitting’ the form, to offer help with any problem you may be experiencing with the form
  • 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
  • safeguard our premises and property, including the use of CCTV
  • 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.

How we use your information to tell you about our work

Sending marketing communications

Our marketing communications include information about our latest news about alcohol harm and alcohol change, such as our research, events, campaigns, policy and influencing work, and requests for donations or other support. We may sometimes include information from carefully selected partner organisations or organisations who support us in these communications.

We operate an ‘opt-in’ communications policy for this type of marketing communication. This means that, except as set out below, we will only send marketing communications to people who have explicitly stated that they are happy for us to do so.

We may use information you have given us directly, for example the record of your previous donations to and/or relationship with us, your location and demographics, as well as the type of activity you have been involved with, to tailor our communications with you about future activities.

We do not sell or give away your data to other organisations for marketing purposes, and have never done so.

Events and fundraising

When you have asked for details of an event, we will send you information including, where relevant, ideas for fundraising and reminders on key information about the activity.

Where you have signed up for an event with a third party (for example the London Marathon) and told the event organiser that you wish to fundraise for us, we may contact you with information and support for your fundraising for that event.

Managing your contact preferences

We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions and we include information on how to opt out when we send you marketing. If you don’t want to hear from us, that’s fine, and you can change your preferences at any time. Just let us know when you provide your data or contact us on 020 3907 8480 or email us at: contact@alcoholchange.org.uk.

If you’ve decided you don’t want to be contacted for marketing purposes, we may still need to contact you for other purposes. This may include where we are processing a donation you’ve made and any related Gift Aid, thanking you for a donation or participation in an event, involving you in the evaluation of a product or service, or keeping in touch with you about volunteering activities that you are doing for us.

Building profiles of supporters

Our ability to reduce alcohol harm depends to a large part on our supporters, so it’s vital that our fundraising efforts are as effective and efficient as they can be. By developing a better understanding of our supporters, and by researching them using publicly available sources, we can tailor and target our fundraising events and communications (including volunteering opportunities) to those most likely to be interested in them. This enables us to be more efficient and cost-effective with our resources, and also reduces the risk of you receiving information that you might find irrelevant, intrusive or perhaps distressing.

What information do we collect?

Taking a supporter’s communications preferences into account, we use information we hold on them to research their potential to be a significant donor to Alcohol Change UK and collect additional details relating to their employment and any philanthropic activity. We may also estimate their gift capacity based on their publicly visible assets, history of charitable giving and how connected they are to Alcohol Change UK. This data may be stored electronically.

Which information do we use?

We use existing data from Alcohol Change UK's own database and combine this 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 potential support for Alcohol Change UK. We only use reputable sources, where someone would expect their information may be read by the public. We avoid any data that we suspect has not been lawfully or ethically obtained, and we do not use information sources which have not been broadcast or made public.

We’re committed to putting you in control of your data and you’re free at any time to opt out from this activity. To find out more, please contact 020 3907 8480 or contact@alcoholchange.org.uk.

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, or when we use written or verbal quotes from you to report on the effectiveness of our programmes, products or services). 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 agencies and regulators such as the Charity Commission, Fundraising Regulator, Her Majesty’s Revenue and Customers, the Police, or Information Commissioner, 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 that Alcohol Change UK carries out with personal information. Some examples not mentioned under the other bases above where we consider there to be a legitimate interest are:

  • analysis and profiling of our supporters using personal information we already hold
  • providing support by email to participants of the Dry January campaign
  • use of personal information in research and evaluation, to assess the take-up and effectiveness of our various campaigns programmes, products and services (in such cases your data will be aggregated and anonymised)
  • 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 Alcohol Change UK where you have signed up with us on a charity place for a third party event (for example a sponsored run not organised by Alcohol Change UK), sharing personal information with the third party event organiser so they can administer the event.

In adopting the principle of legitimate interest, we consider the potential impact on you (positive and negative), how intrusive it is from a privacy perspective, your rights under data protection laws and our (or others’) interests in using your information in this way.

When we use sensitive personal information (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. Our offices are secured by an alarm system and CCTV and BS standard locks. We assure the security of the servers or platforms upon which we store your data, which are based only within the EU or US.

How long we keep your information for

Alcohol Change UK has specific criteria to determine how long we will retain your information for, which are determined by legal and operational considerations. For instance, we are required to keep some personal information for tax purposes, as well as keep a record of your interactions with us.

Sharing your information with other organisations

As set out in the “Sending marketing communications” section above, we will never sell or rent your personal information to third parties for marketing purposes and have never done so. However we may 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
  • evaluators and researchers who may monitor and evaluate information to prove or improve the quality of a service, product, project or programme
  • 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
  • Potential applicants for our programmes, who may be interested in your positive experiences of them.

We also share aggregate information about the use of our products and services with others, such as local authorities, alcohol treatment providers, funders, donors, and government agencies. Such information is anonymised and aggregated, so that no individual can be identified except where consent has been given.

Where our suppliers run their operations outside the European Economic Area (EEA), we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law, and appropriate safeguards are in place.

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 Alcohol Change UK, 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 of 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

We may use information from external sources such as the post office national change of address database and/or the public electoral roll to identify when we think you have changed address so that we can update our records and stay in touch. We only use sources where we are confident that you’ve been informed of how your information may be shared and used.

We do this so we can continue to contact you where you have chosen to receive marketing messages from us and contact you if we need to make you aware of changes to our terms or assist you with problems with donations.

This activity also prevents us from having duplicate records and out of date preferences, so that we don’t contact you when you’ve asked us not to or waste resources sending information to an old address.

We’re committed to keeping you in control of your data and you’re free at any time to opt out from this activity. To find out more, please contact 020 3907 8480 or contact@alcoholchange.org.uk

We really appreciate it if you tell us when your contact details change.

Your rights

Under UK data protection law, you have rights over personal information that we hold about you. We’ve summarised some of these below, but for more information read the helpful information on the website of the UK’s Information Commissioner’s Office: https://ico.org.uk/your-data-matters/

To exercise any of these rights, you can write to us at Alcohol Change UK, 27 Swinton Street, London, WC1X 9NW; email us on contact@alcoholchange.org.uk; or phone us on 020 3907 8480. 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.

Right to access your personal information

You have a right to request access to a copy of the personal data and information that we hold about you. These is known as a ‘subject access request’. If you want to access a copy of your information, please tell us your name and one other unique way to identify you (so we can send you your data only), please let us know what type of information you want to know about, and please make sure you tell us where we should send the information. We will meet all simple requests within one calendar month; or more complex requests within three months.

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 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 of your personal information and in certain cases, and subject to certain exceptions, you have the right for this to be done. Please note that where we completely delete your records, we will no longer have information about your marketing preferences, including instructions not to contact you or not to contact you in certain ways, if you subsequently get back in touch with us.

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.

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 all feedback as an opportunity to learn and improve.

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 Alcohol Change UK website or by contacting you directly.

Contact us

If you have any questions, comments or suggestions, please contact us.

Alcohol Change UK has a Data Protection Officer, who can be contacted at:

The Data Protection Officer
Alcohol Change UK
27 Swinton Street
London WC1X 9NW
Email: contact@alcoholchange.org.uk