Privacy policy

About this policy

This policy explains how Fresh Start For Hens CIC uses personal information when you visit our website, contact us, or apply to adopt hens or volunteer.

1. Important information
   1. Adoption applicants must be at least 18. Our volunteer form includes a “below 18” age option, so we may receive information from younger volunteer applicants.
   2. This policy sits alongside our terms and conditions.
   3. Fresh Start For Hens CIC is the controller responsible for your personal data (we, us or our).
   4. To assist you further in understanding this Privacy Policy, we have set out in Part 5 of Schedule 1 a glossary of terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.
   5. If you have questions about this policy or want to exercise a privacy right, please contact us:
   6. By email to: adminteam@freshstartforhens.co.uk
   7. By post to: Fresh Start For Hens CIC, Highland House, Mayflower Close, Chandler's Ford, Eastleigh, Hampshire, SO53 4AR
   8. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
   9. It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
   10. Our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy policies, therefore you should also read their privacy policy to understand what personal data they collect about you and how they use it.
2. The data we collect about you
   1. We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.
   2. We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.
   3. Our volunteer form asks for optional information about health conditions that may affect physical roles. This is health data, which is a special category of personal data. We do not ask for information about criminal convictions.
   4. If we are required by law, or under the terms of a contract we have with you, to collect your personal data, and you fail to provide it, we may not be able to enter into the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.
3. How personal data is collected

   We collect personal data in the following ways:

   direct interactions	You provide personal data when you complete our adoption, volunteer or contact forms, make a donation, or correspond with us by post, phone or email.
   automated technology	Our website records technical information such as IP addresses in server logs. It also uses cookies needed for forms and sessions, as described below.
   third parties	We may receive information from services used to run this website and manage applications, including PayPal for payments and Google Sheets when application export is configured.

4. How we use your personal data
   1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
   2. To perform the contract, we are to enter into or have entered into with you;
   3. To comply with a legal obligation; and
   4. Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   5. Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.
   6. If we send you optional marketing messages, we will explain why you are receiving them and how to stop them.
   7. Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.
   8. We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
   9. 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 use your personal data in this manner.
   10. We may process your personal data (without your knowledge or consent) where this is required or permitted by law.
5. Disclosure of your personal data
   1. We share information with service providers when needed to run the website, manage applications and process payments. Some providers act on our behalf; others, such as PayPal, handle payment information under their own privacy policies. See Part 4 of Schedule 1 for more detail.
6. International transfers
   1. Some services we use, including PayPal and Google Sheets, may involve access to personal data outside the UK. Email us for details of any international transfer and the safeguards used.
7. Data security
   1. 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. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know, and they can only process your personal data on our instructions and will be subject to a duty of confidentiality.
   2. We have procedures in place 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.
8. Data retention
   1. 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.
   2. We keep information needed for accounting and tax records for the period the law requires. Please contact us if you would like details of how long we keep a particular type of information.
   3. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.
9. Your legal rights
   1. You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact us.
   2. You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
   3. We may ask for information to confirm your identity before responding to a request. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.
   4. We try to respond to all legitimate requests within one month. Occasionally it may 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.

Schedule 1: Personal Data

Part 1: Types of personal data

contact data	postal address, email address and telephone number
financial data	payment amounts, payment status and PayPal transaction references; payment card details are entered with PayPal
identity data	first name, last name and account identifier
volunteer application data	age category, role preferences, and any health conditions you choose to tell us about
marketing and communication data	your preferences if you choose to receive marketing from us
profile data	your application answers, photographs you submit, and any account details
technical data	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 our website
transaction data	details about payments to and from you and other details of products and services you have purchased from us

Part 2: Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

Consent	you have given your express consent for us to process your personal data for a specific purpose
Contract	the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you
legal obligation	the processing is necessary for us to comply with legal or regulatory obligation.
legitimate interests	the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity	Type of data	Lawful basis for processing
to receive your adoption application	identity & contact	to perform our contract with you
to manage your adoption request and payment	identity, contact, financial and transaction	(i) to perform our contract with you; (ii) as necessary for our legitimate interests in managing payment records.
to contact you about your application and changes to our terms or privacy policy	identity, contact and application details	(i) to perform our contract with you (ii) as necessary to comply with a legal obligation (iii) as necessary for our legitimate interests in keeping our records updated and managing applications and keeping our records up to date.
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	identity, contact & technical	(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud (ii) as necessary to comply with any legal obligations

Part 3: Your legal rights

You have the following legal rights in relation to your personal data:

access your data	you can ask for access to and a copy of your personal data and can check we are lawfully processing it
correction	you can ask us to correct any incomplete or inaccurate personal data we hold about you
erasure	you can ask us to delete or remove your personal data where: there is no good reason for us continuing to process it; you have successfully exercised your right to object (see below); we may have processed your information unlawfully; or we are required to erase your personal data to comply with local law. We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
object	you can object to the processing of your personal data where: we rely on legitimate interests and you object because of your particular situation. We may continue only if we can show compelling grounds that override your interests, rights and freedoms; we process your personal data for direct marketing. If you object, we must stop using it for that purpose.
restrict processing	you can ask us to suspend or restrict the processing of your personal data, if: you want us to establish the accuracy of your personal data; our use of your personal data is unlawful, but you do not want us to erase it; you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it
request a transfer	you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format
withdraw your consent	you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent

Part 4: Third Parties

service providers	acting as processors or controllers based in the EEA but also around the world who provide services and IT and system administration services.
professional advisors	acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services
HM Revenue & Customs, regulators and other authorities	United Kingdom authorities that may require information from us by law.
third parties	third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy

Part 5: Glossary

aggregated data	information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject
controller	a body that determines the purposes and means of processing personal data
data subject	an individual living person identified by personal data (which will generally be you)
personal data	information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data
processor	a body that is responsible for processing personal data on behalf of a controller
special categories of personal data	information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.
ICO	Information Commissioner’s Office, the UK’s supervisory authority for data protection issues

10. Changes to this Policy
    1. We may update this policy from time to time. The current version will be available on this page.
11. Cookies

    Our website uses cookies to keep your visit working and to protect forms. The cookies set by this website are:

    Cookie	Purpose
    XSRF-TOKEN	Helps protect forms against forgery.
    fresh_start_for_hens_session	Maintains your session, including when you sign in.

    Our location map loads Google Maps when it comes into view, and payments use PayPal. These services may set their own cookies when you use those features. You can manage cookies in your browser settings.