- 1. Important information and who we are
- 2. The data we collect about you
- 3. How are 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
- 10. Subject Information Statements
1. Important information and who we are
1.1.1. The Website may be used by children; however we do not knowingly collect data relating to children which have not registered with us. We operate in accordance with the Age Appropriate Design Code. The majority of information for children is provided in the secure section of The Website and a login is required. If you are an adopted child or are a child needing information on adoption, please contact us on the telephone number below.
1.3. Contact details
1.3.2. Full name of legal entity: Family Society
1.3.3. Email address: firstname.lastname@example.org
1.3.4. Postal address: TS3, Pinewood Business Park, Coleshill Road, Marston Green, Birmingham, B37 7HG
1.3.5. Telephone number: 0121 779 0891.
1.3.6. 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.
1.4.2. 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.
1.5. Third-party links
1.5.1. the Website may include links to third-party websites, plug-ins and applications.
1.5.2. 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.
2. The data we collect about you
2.1. 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).
2.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
2.2.1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
2.2.2. Contact Data includes billing address, delivery address, email address and telephone numbers.
2.2.3. Financial Data includes bank account and payment card details.
2.2.4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
2.2.5. 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 the Website.
2.2.6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
2.2.7. Usage Data includes information about how you use the Website, products and services.
2.2.8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.4. If you are a potential adopter, we do collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, information about your health, and genetic and biometric data). We also collect information about criminal convictions and offences. This is covered in our Adopter Subject Information Statement.
2.5. If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How are your personal data collected?
3.1. We use different methods to collect data from and about you including through:
3.1.1. 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:
126.96.36.199. apply for our products or services;
188.8.131.52. create an account on the Website;
184.108.40.206. subscribe to our service or publications;
220.127.116.11. request marketing to be sent to you;
18.104.22.168. enter a competition, promotion or survey; or
22.214.171.124. give us feedback or contact us.
3.1.3. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
126.96.36.199. Technical Data from the following parties:
(a) analytics providers such as Google based outside the UK; and
(b) search information providers based inside and outside the UK.
188.8.131.52. Contact, Financial and Transaction Data from providers of technical, payment and delivery services Stripe, PayPal, Apple Pay, VISA or Mastercard based inside and outside the UK.
184.108.40.206. Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. How we use your personal data
4.1. 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:
4.1.1.Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.2.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.
4.1.3.Where we need to comply with a legal obligation.
4.2. Please see below to find out more about the types of lawful basis that we will rely on to process your personal data:
4.2.1.Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
4.2.2.Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
4.2.3.Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
4.3. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party 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.
4.4. Purposes for which we will use your personal data
4.4.1.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.
4.4.2.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, upon which we are relying to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new supporter or contact||
|Performance of a contract with you or our mutual legitimate interests in providing the information required to meet your expectations of an adoption and fostering agency.|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how supporters and contacts use our services)
|To undertake fundraising services and to enable you to partake in a prize draw, competition or complete a survey||
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how supporters and contact use our services, to develop them and grow our activities and fundraising)
|To administer and protect our operations and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how supporters and contacts use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve the Website, products/services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of supporters and contacts for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our services and grow our activities)|
4.5.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
4.5.2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
4.5.3. You will receive marketing communications from us if you have requested information from us or purchased [goods or services] from us and you have not opted out of receiving that marketing.
4.5.4. We do not intend to share your personal data for marketing purposes. However, should we believe that this is necessary e.g. for specialist adoption or fostering services, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
3.5.5. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
4.5.6. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, adoption or fostering registration, service experience or other transactions.
4.6.1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
4.7. Change of purpose
4.7.1. 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.
4.7.2. 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.
4.7.3. 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.
5. Disclosures of your personal data
5.1. We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
5.1.1. Internal Third Parties are set out below:
220.127.116.11. other companies which we control including linked charities and any trading companies used for fundraising and trading purposes, which are based in the UK; and
18.104.22.168. companies acting as joint controllers or processors and which are based in the UK and provide support services to Adoption Focus.
22.214.171.124. Service providers acting as processors based in the UK who provide IT and system administration services.
126.96.36.199. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
188.8.131.52. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
184.108.40.206. Local Authorities, OFSTED, Regional Adoption Agencies, other registered adoption agencies, the Consortium of Voluntary Adoption Agencies, all based in the UK for the purposes of the protection of children, facilitating the adoption and fostering of children and the promotion of adoption and fostering services.
5.2. 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.
6. International transfers
6.1. Please note that information displayed on The Website or sent to Adoption Focus over the Internet may be transferred outside of the UK and/or the European Economic Area (the EEA), where data protection laws are not as strong as within the UK and the EEA. If you have any concerns in relation to such transfers, you should not use the Internet as a means of communication with Adoption Focus
6.2. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
6.2.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
6.2.2. 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.
6.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
7.1. 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. In addition, we limit access to your personal data to those employees, agents, contractors 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.
7.2. 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.
7.3. Your telephone calls and e-mails to us may be recorded and monitored for quality control purposes. We may also intercept communications made to individual members of staff or consultants at Adoption Focus when this is required for our charitable or safeguarding purposes.
8. Data retention
8.1. How long will you use my personal data for?
8.1.1. 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.
8.1.2. 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.
8.2. Details of retention periods for different aspects of your personal data are available by requesting this information from us by contacting us.
8.3. In some circumstances you can ask us to delete your data: see [your legal rights] below for further information.
8.4. 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.
9. Your legal rights
9.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
9.1.1. 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.
9.1.2. Request correction of the personal data that we hold about you. 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.
9.1.3. Request erasure of your personal data. This 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. Please note that the right of erasure does not apply in respect of those that have enquired or applied to adopt or foster children through a voluntary adoption agency or local authority.
9.1.4. 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.
9.1.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
220.127.116.11. If you want us to establish the data's accuracy.
18.104.22.168. Where our use of the data is unlawful but you do not want us to erase it.
22.214.171.124. 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.
126.96.36.199. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
9.1.6. Request the transfer of your personal data to you or to a third party. 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.
9.1.7. Withdraw consent at any time 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.
9.2. If you wish to exercise any of the rights set out above, please contact us.
9.3. No fee usually required
9.3.1. You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
9.3.2. 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.
9.4. What we may need from you
9.4.1. 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).
9.4.2. This is a security measure to ensure that personal data are not disclosed to any person who has no right to receive it.
9.4.3. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.5. Time limit to respond
9.5.1. We try to respond to all legitimate requests within one month.
9.5.2. 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.
10. Subject Information Statements
10.1. In accordance with Article 13 of the General Data Protection Regulation, which has been incorporated into UK law, we are required to issue a subject information statement for each category of data subjects on whom we process personal data. These are sent to the individuals on whom we process personal data and are updated from time-to-time.
10.2. If you would like a copy of the current information statement setting out how we process Personal Data relating to you, please click on the appropriate link below relating to your relationship with Adoption Focus:
10.2.1. a person expressing interest in adopting;
10.2.2. a person approved by Adoption Focus as an adopter;
10.2.3. a family member of a person expressing interest in adopting or who has been approved as an adopter;
10.2.4. a supporter;
10.2.5. a general contact;
10.2.6. a contractor;
10.2.7. a contact of a contractor;
10.2.8. a volunteer.
10.3. We are currently developing additional information statements and will place links to these here for ease of access over the coming months.
10.4. Please remember that if you fall into more than one category more than one Privacy Notice may apply to you.