Our Privacy Policy

HighGround Privacy and Cookies Policy

1.   Introduction

This privacy policy provides you with details of how we collect and process your personal data through your use of our website http://www.highground-uk.org

By providing us with your data, you warrant to us that you are over 18 years of age.

HighGround Charity is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below:

Contact Details

Our full details are:

Full name of legal entity: Highground Projects Limited

Company registered in England and Wales No. 08236843

Registered with the Charity Commission Charity Reg 1151225

Name of Data Protection Officer:  Eunice Learmont

E-mail address: GDPR@highground-uk.org

Postal address: c/o London Scottish Regiment, 95 Horseferry Road, London, SW1P 2DX

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by e-mailing us at anna@highground-uk.org


2.  What data do we collect about you, for what purpose and on what lawful ground we process it

Personal data means any information capable of identifying an individual. It does not include anonymised data.

These are the categories of personal data we may collect about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through e-mail, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, and for record keeping. Our lawful grounds for this processing are our legitimate interests which in this case are to reply to communications sent to us and to keep records.
  • User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website and other online services. Our lawful grounds for this processing are our legitimate interests which in this case are to enable us to properly administer our website and grow our Charity.
  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our Charity and website, to deliver relevant website content to you and to understand the effectiveness of our social media communications.  Our lawful grounds for this processing are our legitimate interests which in this case are to enable us to properly administer our website, grow our Charity and inform our communications strategy.
  • Geographical Data that includes data about your geographical location. We process this data to enable you to partake in our events which are relevant to your geographical location. Our lawful grounds for this processing are our legitimate interests which are to improve awareness and grow our Charity.
  • We may use Communication Data, User Data, Technical Data and Geographical Data to deliver relevant website content to you (including Facebook promotions) and to measure or understand the effectiveness of our communications. Our lawful ground for this processing is our legitimate interest to grow our Charity.

Where we are required to collect personal data by law, or when relating to services to our beneficiaries, and you do not provide us with that data when requested, we may not be able to deliver those services to you. If you don’t provide us with the requested data, we may have to suspend the service you are expecting; if we do, we will let you know at the time.
We will only use your personal data for the purpose for which it was collected. For more information on this please e-mail us at anna@highground-uk.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent only where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.


3.  How we collect your personal data

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us e-mails).We may automatically collect certain data from you as you use our website by using cookies and similar technologies. We will attempt to place one or more cookies on your device Cookies are small files that cannot be used to identify you personally, but hold session information that allows us to, for example, keep you logged into our services if you choose to do so. We also use cookies to monitor what pages you might visit and what you do while on our website (via Google Analytics). This allows us to tailor our services to visitors.You can choose to accept or decline cookies.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, and search information providers such as Google based outside the EU, as well as providers of technical, payment and delivery services, such as data brokers or aggregators.

4.  Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interest (namely to grow our Charity).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since.

Before we share your personal data with any third party for their own purposes we will get your express consent.

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 we send you, or by e-mailing us  anna@highground-uk.org at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data supplied for the purpose of providing services to our beneficiaries.

5.  Disclosures of your personal data

We may have to share your personal data with the parties set out below:
As evidence required by our Funders.

Government bodies that require us to report processing activities (Such as the Charity Commission, Disclosure and Barring Service).

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  International Transfers

We use MailChimp for emailing our newsletters, but this is a provider that is part of the EU-US Privacy Shield, and we may transfer data to them, as they have equivalent safeguards in place.

7.  Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees, volunteers and partners who have an operational need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8.  Data Retention

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

When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes if these can be achieved by other means, and legal requirements.

For governance purposes the law requires us to keep information about our Trustees/Directors for six years after they step down from the Board.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please e-mail us at GDPR@highground-uk.org.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. Third-Party Links

The HighGround 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.