Privacy policy

References to we, our, us or Tender in this privacy policy are to Tender Education and Arts, registered company number 04627846 and registered charity number 1100214.

This privacy policy aims to give you information about how we collect and process your personal data, however obtained. It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 the other notices and is not intended to override them.

We have appointed a Data Protection Officer to oversee our compliance with data protection laws, who has overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect before, during and after your relationship with us. This notice explains how we comply with the law on data protection and what your rights are and for the purposes of data protection we will be the controller of any of your personal information.

Our 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 notice of every website you visit.

Personal information we collect

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 been removed (anonymous data).

We may collect the following types of personal information about you:

Contact details: information that allows us to identify and contact you directly such as your name, address email address, telephone number and addresses.

Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.

Records of your attendance: at any events hosted by us or jointly with third parties.

How you use our website: we collect information about the pages you look at and how you use them, usernames and passwords.

Videos, photographs and audio recordings: which you or other people take and provide to us or we take ourselves.

Details of the correspondence (including e-mail correspondence) you send and receive from us and details of any claims: this includes letters and emails, SMS, MMS and other electronic communication and may in some cases include audio recording of telephone conversations.

Subscription information: for example when you subscribe to one of our newsletters or other materials.

IP address information: your computer’s IP address allows us to track your usage of our website.

Special categories of personal information

We collect information about the race, ethnicity, religion and sexual orientation of staff, facilitators and job applicants in order to better understand the demographics of our workforce. We collect the same information about our beneficiaries to better understand their demographics and how the impact of our services differs depending on special categories of information. We rely on consent to collect and process these data, or in the absence of consent collect and process these data on an anonymised basis.

Sources we collect your personal information from

We will collect personal information from a number of sources. These may include the following:

Directly from you: when you indicate that you may wish to attend an event, complete forms we provide to you, respond to a survey, use our website, enter our competitions and promotions, make a claim, make a complaint or communicate with us directly in some other way.

From referrals and recommendations: usually given by other people who know you or have a working relationship with you.

Our website: provides us with information about how you use it and the devices that you use to connect to our website.

Your employer or the organisation you work for: they may provide us with your name, position contact details and background information about you.

Our social media pages on Facebook, Linkedln, Twitter and lnstagram.

What we use your personal information for

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 services we are providing to you or with your support.

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 or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this. Which lawful basis applies will depend upon the nature of your relationship and interactions with us.

Purpose	Personal information used	Lawful basis
To manage our relationship with you and to operate our organisation	All the personal information we collect	a) Necessary to comply with a legal obligationb) Necessary for our legitimate interests (to keep our records updated and to study how people use our products/services)c) Necessary for our legitimate interests to operate our organisation in an efficient way and to expand our organisation
Maintain and improve our services	All the personal information we collect	Necessary for our legitimate interests to improve our services
Data analytics and statistical analysis to help us improve our online services	How you use our website	Necessary for our legitimate interests to improve the online services we provide and user experience
Determine events and services that may be of interest to you	All personal information we collect	Necessary for our legitimate interests to determine which events and services you may be interested in
To provide you with requested information	Contact details and services and products and other information you have requested that we provide to you or your organisation	To comply with any request made by you
Direct marketing	Contact details and services that we have determined may be of interest to you or your organisation, and/or which you or your organisation has indicated interest in in the past	We may ask for your consent to process your data for this purpose, and you may revoke your consent at any point. Alternatively, if you or your organisation has indicated an interest in our services previously, we may market similar products or services as a legitimate interest in developing our organisation. You have the right to opt out from such marketing at any time.
Holding any events	Your contact details, details of attendance, your comments in response to any surveys or forms and dietary requirements	Necessary for our legitimate interests in holding events and tracking attendance and providing appropriate food and drinks at events.We may also have a legal obligation to comply with health and safety requirements.
To comply with our legal and regulatory obligations	All the personal information we collect	To comply with any legal and regulatory obligation or requirement
Fraud, crime prevention and debit collection	All the personal information we collect	Necessary for our legitimate interests to detect and prevent crime and collect debts
Storage of records relating to you and also records relating to our organisation	All the personal information we collect	To be able to manage and fulfil any contracts, we may have a legal obligation to do so and we also have a legitimate interest to keep proper records

For some of your personal information you may have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to properly perform our contract with you or the organisation you represent or comply with legal obligations and we may have to terminate our relationship. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our arrangements with you or the organisation you represent.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below. We will generally only ask for your consent for direct marketing.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide marketing information to you.

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include, but not limited to, testing our IT systems, research, data analysis, improving our site and developing new products and services.

Who we share your personal information with

We may share personal information with the following parties:

Any party approved by you.

Marketing and public relations companies: to help us to develop, carry out and assess marketing and PR campaigns

Other service providers and advisors to us: such as companies that support our IT, help us analyse the data we hold, organise events for us, process payments, send communications to our customers, provide us with legal, property or financial advice and generally help us deliver our products and services to you or the organisation that you represent or for us to purchase them from you or the organisation you represent.

Police, law enforcement agencies and security services: to assist with the investigation and prevention of crime and the protection of national security.

We may provide third parties with aggregate statistical information and analytics about our beneficiaries but we will make sure no one can be identified from this information before we disclose it.

We do not disclose personal information to anyone else except as set out above unless we have your consent or we are legally obliged to do so. We do not sell your data.

Direct marketing

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products, services, events, or opportunities to donate which we believe you may be interested in.

We will only send marketing messages to you in accordance with the marketing preferences you set when you either create your account, that you tell us you are happy to receive or where you or the organisation you represent have previously consented to receiving marketing messages.

You can then let us know at any time that you do not wish to receive marketing messages by sending an email to us at home@tender.org.uk or by using the details set out in the “Contacting us” section below. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any marketing messages we send to you.

Transferring your personal information internationally

The personal information we collect about you is not transferred to or stored in countries outside of the UK or European Union except as set out in this section.

Our employees and other individuals working for us may in limited circumstances access personal information outside of the UK and European Union if they are on holiday abroad outside of the UK or European Union. If they do so they will be using our security measures and will be subject to their arrangements with us which are subject to English Law and the same legal protections that would apply to accessing personal data within the UK.

In limited circumstances the people to whom we may disclose personal information as mentioned in section 5 above may be located outside of the UK and European Union. In these cases we will impose any legally required protections to the personal information as required by law before it is disclosed.

If you require more details on the arrangements for any of the above then please contact us using the details in the Contact us section below.

For how long do we keep personal information?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements. You can request details of retention periods for different aspects of your personal data by contacting us.

In some circumstances we may 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.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move position or work for a different organisation or change your phone number or email address. you can contact us by using the details set out in the “Contacting us” section below.

Security

We have numerous security measures in place to protect the loss, misuse and alteration of information under our control, such as passwords and firewalls. We review our security measures at least every two years. We cannot, however, guarantee that these measures are, or will remain, adequate. We do, however, take data security very seriously and will use all reasonable endeavours to protect the integrity and security of the personal information we collect about you.

Your rights in relation to your personal information

You have the following rights in relation to your personal information:

the right to be informed about how your personal information is being used;

the right to access the personal information we hold about you;

the right to request the correction of inaccurate personal information we hold about you;

the right to request the erasure of your personal information in certain limited circumstances;

the right to restrict processing of your personal information where certain requirements are met;

the right to object to the processing of your personal information;

the right to request that we transfer elements of your data either to you or another service provider; and

the right to object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

Changes to this notice

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

Contact us

In the event of any query or complaint in connection with the information we hold about you, please email Trupti Reddy (trupti@tender.org.uk) or write to us at Resource for London, 356 Holloway Road, London N7 6PA.

Tender Education and Arts

August 2023