Privacy Notice - Brighton & Hove Progressive Synagogue

PRIVACY NOTICE

WHO WE ARE
This Privacy Notice is provided by the following organisations jointly:

Liberal and Progressive Synagogue B&H, registered with the Charity Commission under number 1046457, of 6 Lansdowne Road, Hove, East Sussex BN3 1FF

Brighton and Hove Progressive Synagogue, registered with the Charity Commission under number 1149342, and a company limited by guarantee, company registration number 08098379, registered office 6 Lansdowne Road, Hove, East Sussex, BN3 1FF

In this Notice,

Liberal and Progressive Synagogue B&H is referred to as “LPSB&H”

Brighton and Hove Progressive Synagogue is referred to as “BHPS”

LPSB&H and BHPS are jointly referred to as “we”, “our”, “us”

Our community of Members, Friends and supporters (as applicable) are referredto as “the BHPS Community”

Liberal and Progressive Synagogue B&H and Brighton and Hove Progressive Synagogue are committed to maintaining your confidence and trust with respect to your privacy.

BHPS and LPSB&H are Joint Data Controllers.

ABOUT THIS PRIVACY NOTICE

The purpose of this privacy notice is to explain how we hold and use your

personal data for the purposes of our relationship with you and for fundraising.

This is our main privacy policy. We may provide additional, specific privacy

information to you as you interact with us in different ways (e.g. that we will

only use certain information for specific purposes). To the extent that any of that

information differs from what we say below, those specific statements will apply

in those circumstances.

WHAT WE DO

LPSB&H and BHPS are two separate legal entities.

LPSB&H is a membership body with a democratically elected Council and collects personal data of its Members and Friends, principally from Membership Application Forms. BHPS is a company limited by guarantee. BHPS carries out the activities of the Synagogue. The objects of both organisations are the advancement of Liberal and Progressive Judaism and the advancement of

religious and racial harmony. Both organisations are registered with the Charity Commission. We aim to establish and develop lifelong relationships with members, friends and supporters within the context of a Synagogue’s activities. We connect with you with updates, newsletters, volunteering opportunities, pastoral care, religious activities, social activities, educational activities and other activities and communications which you would reasonably expect a synagogue to engage in.

Members and Friends of LPSB&H normally pay a subscription pursuant to the constitution of that organisation. Donations, legacies and grants may be paid to LPSB&H. LPSB&H also receives donations from its Members and Friends destined to be paid on to certain external organisations such as the Board of Deputies of British Jews. We will always advise you if we are collecting donations destined to be paid to another organisation.

BHPS carries out the activities of the Synagogue. Donations, legacies, grants and

transfers may be paid to BHPS. Funds received are principally used to pay the costs of running the Synagogue including salaries and the expenses involved in providing religious services and activities and events associated with our objectives or for the purpose of fundraising.

We occasionally make small grants to other charities or provide small grants or bursaries to individuals.

We fundraise to ensure that, thanks to the generosity of our donors, we can

continue our Synagogue activities and continue to pursue our objectives.

The principal purpose of collecting and processing your data is to provide you with the best possible experience of being a Member, Friend, donor, supporter or visitor of either or both of our organisations, as applicable. It also enables us to ensure that any approaches we make to ask for your support or fundraising goals and any other types of contact we make with you are respectful, professional, and relevant to you. The two organisations work closely together to ensure we engage with you in a coordinated manner.

If at any point you have questions about our privacy notice, or how we are using your data, please contact us. We have decided that our organisations are too small to require a Data Protection Officer – so please contact the Synagogue’sadministration office.

INFORMATION WE COLLECT

We collect information from you in a number of ways: directly from you during your ongoing relationship with us; from information you have provided to the on-line event managing and ticketing website known as Eventbrite; from information you have sent us when communicating with us by email or

telephone; from information you have given us on social media or via our website, from application forms you have completed, from information you give us when you visit; from information you have given us when applying to take part in our events.

The amount of data we collect and hold depends on the frequency and nature of your interactions and engagement with us. Information may be gathered across

the lifetime of our relationship with you and from many different forms of interaction.

We may hold and process the following types of personal data about you:

Biographical information, which may include:

Name, title, contact details, date of birth, gender, marital status, spouse, partner and family details.
Employment details, career history, professional activities.
Interests, activities and accolades, incl. honours, life achievements.
Links to your public social media presence e.g. LinkedIn, Twitter, website or

blog.

Details of our ongoing relationship and your engagement with us, which may include:

Records of your personal interactions with us (e.g. correspondence, notes of meetings or conversations).
Records of communications you have received from us, incl. copies of letters, emails or appeal literature sent.
Data obtained through cookies and similar technologies such as pixels, tags, web beacons, and other identifiers. These help us understand how you interact with our email communications, websites and other online services we provide.
Your attendance (and that of your guests) on visits to, or at events, including details of any payments made, and photographs, audio and video recordings in which you may be included.
A record of offers of voluntary support you have made.
A record of volunteer work you have undertaken.

Information about your giving, which may include:

Current and past donations and pledges, documentation relating to these gifts and records of the projects you have supported.
Financial information required to process your gifts.
If you have given it, an indication of your intent to leave a legacy, including

copies of Wills or sections of Wills.
Any requests you have made for anonymity in relation to your giving.
Thank you letters, donor reports provided relating to gifts you have made,

correspondence and notes of meetings.
Plans for activities and future interactions.
Records of membership of any societies or groups related to your giving.
Your relationship to relevant trusts, foundations and corporates, e.g.

membership on board of trustees.

Information relating to your willingness or financial capacity to support our charitable objectives, which may include:

• Our understanding of your likely philanthropic interests, and a note of particular projects we think may be of interest to you. This understanding may be provided by you or from information in the public domain.

Information about your giving to other organisations, and other support that you provide (e.g. volunteering roles, trusteeships), where this information is given to us by you or publicly reported, and where it helps us to understand your interests and capacity to provide support.
Any estimate we may make regarding the potential scale of your ability to give us financial support on the basis of the above information and your previous giving.
Personal recommendations, where made by other supporters, that you may be willing and able to provide support.

Sensitive personal data, which may include:

• Health information, including any medical conditions – we may use health information provided by you so we can make reasonable adjustments to improve

the facilities we are able to provide to you (e.g. seating or access at an event, dietary requirements). With your permission, we may also hold health data to ensure our engagement with you is based on a suitable understanding of, and care and respect for, your particular circumstances. Again with your permission, we may hold health data so that we can give you pastoral care.

• Criminal convictions, offences and allegations of criminal activity – we may use publicly available information concerning criminal convictions and offences or allegations of criminal activity, including money laundering or bribery offences, to carry out due diligence on donors or prospective donors in line with our guidelines on the acceptance of gifts.

• Race or ethnicity, religious beliefs, sexual orientation, political opinions – we do not seek to obtain these categories of sensitive data, apart from that of religious belief. We may seek and hold data concerning your religious beliefs because we are a synagogue.

Information from CCTV

We operate CCTV both outside and inside our premises. These recordings are live-streamed to an external organisation called the Community Security Trust based in London. They have their own Privacy Policy. Internal and external recordings are saved by us for not more than three months and then overwritten. We will use these recordings for security purposes only.

HOW WE USE YOUR DATA

Your personal data are used by us for the following purposes:

For engagement in our relationship with you

To manage our ongoing relationship with you including a relationship which may involve pastoral care
To keep you up to date with news about the synagogue, activities and events including events being run by other organisations where we think they are of relevance to you as supporters of a synagogue
To let you know of volunteering opportunities

To inform you about events we are organising including fundraising events
To accept and process revenue, e.g. for event tickets.
To undertake surveys
To create classifications and groupings (through manual or automated analyses)

in order to best direct engagement activities.
To analyse the success of our engagement activities, collect feedback, and

manage complaints.

For fundraising and donor stewardship

• To help ensure that our fundraising efforts are conducted as efficiently as possible, and that our approaches to potential donors are respectful,

professional, and made, as far as possible, based on evidence and an

understanding of what may interest you.

To ask you for your support for our fundraising programmes, always mindful of

fundraising best practice.
To provide acknowledgement, recognition and stewardship of your gift.
To inform you of the impact of your gift.
To create classifications and groupings (through manual or automated analyses)

in order to best direct fundraising activities.
To inform fundraising, marketing and donor stewardship strategies.

For operational reporting, management reporting, and governance

• We may use your personal data for the purposes of operational reporting, to produce management information, and for other relevant purposes relating to the governance of our organisations. We will use only the data required and, unless necessary, we will use anonymised or pseudonymised data.

For security purposes
When you visit us, we take a certain amount of personal data from you for security purposes. This entails us asking you security questions, checking your identification at the door against identification documents, and you giving us written personal data either by email or at the door. We may inform our security personnel of your visit.

In our external communications

• With your permission, we may publish your name in donor listings or as part of a guest list

• We may announce your name or publish your name in our newsletter when thanking you, congratulating you, commemorating your birthday or other special life-cycle event, remembering your loved ones, wishing you recovery from illness and in other ways which you might reasonably expect within the context of asynagogue’s activities

If you do not wish your data to be used in any of the ways listed above, or have any questions, please contact us.

WHEN AND HOW WE SHARE YOUR DATA

We may, from time to time, need to share your personal data between our two legal entities, within the BHPS Community or with third-parties working on our behalf. We will only do this in appropriate circumstances, by secure means, and with the relevant data sharing agreements in place. We do not, and will not, sell your data.

Third parties will only process your personal data on our instructions and where they have agreed to treat your data confidentially and to keep it secure. We only permit them to process your personal data for specified purposes. We do not allow our third-party service providers to use your personal data for their own purposes nor to keep your data after the processing is complete. All our third- party service providers are required to take appropriate security measures to

protect your personal information in line with our policies.

Whenever your information is shared, we will always seek to share the minimum amount of information necessary to fulfil the purpose, this includes the use of anonymised or pseudonymised data where that is sufficient.

Your data may be shared in the following ways:

Between our two legal entities

LPSB&H and BHPS share your personal data with each other.

Within the BHPS Community

We may share your data within the BHPS Community. We will do this only where it is necessary in order to carry out any of the purposes listed in this privacy notice. For example, where a group of volunteers work together to offer pastoral care and you are a recipient of the care or where you are part of a group of volunteers working on a particular project; to manage and coordinate relationship management activities with you; to ensure your contact information is up-to-date.

Volunteers

We sometimes create networks of individuals who volunteer their support to us and to Members and Friends of the BHPS Community. The volunteers usually come from within the BHPS Community. We may share relevant data with them, in appropriate circumstances, by secure means, and with confidentiality undertakings in place. Examples:

• Volunteers serving as Trustees

Volunteers offering to serve in the administration office
Volunteers assisting with our computer and other technology
Volunteers offering pastoral care and friendship within the context of a

synagogue
Volunteers assisting with newsletters and other literature
Volunteers assisting with social media

With third-party organisations engaged by the us to provide services:

These include but are not limited to:

Mailing houses, printers, event organisers or venues. Example: We provide your email address and your name to the online marketing platform called MailChimp.
Organisations providing tools such as relationship- or event-management systems; databases and reporting/analysis tools; email or survey tools; payment services (e.g. direct debit, online donation processing).
Storage and backup of your data using cloud based technology. Example: Microsoft One-Drive
Hosting, email and content providers including storage and backup of your data using a third-party organisation’s hard drive or its own cloud based technology –with suitable security undertakings in place
Our professional advisers such as auditors, accountants and lawyers

HOW WE PROTECT YOUR PERSONAL DATA

We take precautions to safeguard your personal information against loss, theft and misuse, unauthorized access, disclosure and destruction through the use of appropriate administrative, physical and technical security measures.

Our digital database is protected by access controls. Access is limited to individuals who need to see and use the data to carry out their duties.

Where you have provided us with your credit or debit card
information, over the phone, or on a printed giving form, that data is stored securely and destroyed after your payment has been processed. Bank details used for processing Direct Debits are stored under the Direct Debit Guarantee Scheme. Online donations are processed via our third-party payment service providers and your credit or debit card information is not collected or stored by us.

Transfers of your data outside of the European Economic Area (EEA) – although most of the information we collect, store and process stays within the UK, some information may be transferred to countries outside of the European Economic Area (EEA). This may occur if, for example, one of our third-party partners’ servers are located in a country outside of the EEA.

Transfers outside of the EEA will only take place if one of the following applies:

• The country receiving the data is considered by the EU to provide an adequate level of data protection.

The organisation receiving the data is covered by an arrangement recognised by the EU as providing an adequate standard of data protection e.g. transfers to companies that are certified under the EU US Privacy Shield.
The transfer is governed by approved contractual clauses.
The transfer has your consent.
The transfer is necessary for the performance of a contract with you or to take

steps requested by you prior to entering into that contract.
The transfer is necessary for the performance of a contract with another person,

which is in your interests.

The transfer is necessary in order to protect your vital interests or of those of other persons, where you or other persons are incapable of giving consent.
The transfer is necessary for the exercise of legal claims.
The transfer is necessary for important reasons of public interest.

HOW LONG WE KEEP YOUR DATA

When determining how long to retain your personal data we take into

consideration our legal rights and obligations, tax and accounting rules,

statutory reporting requirements, legal limitation periods, insurance cover

requirements, and our right to protect ourselves against litigation

Subject to the above, we will adopt the following approach in relation to removal

of your data:

Members and Friends of LPSB&H, we will remove your data within 12 months of

your terminating your relationship with us.

Donors and supporters of our fundraising events, including those who buy tickets

for events: we consider our relationship to be lifelong and will retain your data

indefinitely unless you request otherwise.

Visitors to our premises who complete Information Forms: we will remove your

data within 12 months of your visit unless you have entered into an ongoing

relationship with us.

Employees and casual workers: we will remove your data within 7 years of

termination of your employment.

Other individuals not listed above: we will remove your data within 12 months of

our relationship ending.

If you have pledged a legacy gift, it will be necessary to retain your data until

your gift is received, so that we can identify the gift against that pledge.

When we no longer need to retain personal information, we ensure it is securely

disposed of. We may keep anonymised statistical data indefinitely, but you

cannot be identified from such data.

THE LEGAL BASIS FOR PROCESSING YOUR DATA

We will only use your personal data where the law allows us to do so. Most commonly we rely on the following legal bases for processing your personal data:

• Where we have a legitimate interest to do so for purposes listed within this

privacy notice. Where we use legitimate interest as the basis for our processing we have carefully considered each of the ways we process your data to ensure that we carry out our activities with a focus on the interests of our Members, Friends, donors and supporters (as applicable), and in the most efficient and effective way.

• Where we need to perform any contract we have entered into with you. Information processed for this purpose includes, but is not limited to, the

information you provide when you register for an event, or to enable us to process a donation.

• Where we are required to comply with our legal obligations, such as for: reclamation of Gift Aid on your donations; statutory returns of any kind; Companies House, the Charity Commission or ICO; responses to the Charity Commission or ICO in relation to audits or official investigations, to assist any public authority in a criminal investigation if we are under a duty to do so

• Where your consent is required, for example where sensitive personal data is recorded. You can withdraw your consent at any time and we will stop any processing of your personal data requiring your consent.

Change of purpose

We will only process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another related reason and that reason is compatible with the original purpose. If we need to use your data for an unrelated purpose, we will seek your consent to use it for that new purpose. Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

YOUR LEGAL RIGHTS AND CHOICES IN CONNECTION WITH YOUR PERSONAL DATA

Under certain circumstances, by law you have the right to:

Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of your data and to check that we are lawfully processing it.
Request correction of your data. This enables you to ask us to correct any incomplete or inaccurate information we hold about you.
Request erasure of your data. This enables you to ask us to delete or remove your 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 data where you have exercised your right to object to processing (see below).
Object to processing of your data where we are processing it to meet our public interest tasks or legitimate interests (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. You also have the right to object where we are processing your data for direct marketing purposes.

Request the restriction of processing of your data. This enables you to ask us to suspend the processing of your data, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your data to another party.

Depending on the circumstances and the nature of your request it may not be possible for us to do what you have asked, for example, where there is a

statutory or contractual requirement for us to process your data and it would not be possible to fulfil our legal obligations if we were to stop. However, where you have consented to the processing, you can withdraw your consent at any time by emailing us. In this event, we will stop the processing as soon as we can. If you choose to withdraw consent it will not invalidate past processing.

If you want to exercise any of the rights described above or are dissatisfied with the way we have used your information, please contact us. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

If you remain dissatisfied, you have the right to lodge a complaint with the Information Commissioner’s Office at the ICO website

If you have any questions about this privacy notice or about your personal data, or if you want to provide updates to your data, make any changes to your communication preferences or exercise any of your rights as outlined above, please contact Brighton and Hove Progressive Synagogue at the following address:

6 Lansdowne Road, Hove, East Sussex, BN3 1FF info@bhps-online.org

CHANGES TO THIS PRIVACY NOTICE
This privacy notice was last updated on Insert Date

We reserve the right to update this privacy notice at any time. Any changes to this privacy notice will be posted to this page.