This privacy policy explains how VacProj may collect and use the information you give us. We try to make our policy straightforward and easy to understand, but if you have any questions or there is something you do not understand about please contact us at vacation.project@lincoln.ox.ac.uk.

If you are a child’s social worker or family support worker, please seek permission from a parent or guardian before giving personal information to anyone online.

If you do not agree to this policy, you can refuse to disclose your information to us.

By signing our nomination form, donating to VacProj, or volunteering with us, you accept to your data being processed in accordance with this privacy policy.

We obtain information through our interactions with you and try to be clear when we are doing so. We may also obtain your information through third parties and from public sources. Below, we list how we obtain your information from these sources.

You have the right to request that your information not be used at any point. To do so, please contact us at vacation.project@lincoln.ox.ac.uk. For more information on your rights, please view the ‘Your rights’ section below.

We may obtain information from you through your interactions with us such as when you are:

• applying for/ asking about our holidays
• participating in our holiday (we will collect additional information from participants)
• donating to us
• signing up to receive newsletters, event updates
• participating in a fundraising event
• posting content to our website or social media websites
• volunteering with us
• meeting with us and having provided information about yourself
• contacting us through the website or via any other mode such as online, email, phone, SMS, social media or post

Regarding your rights concerning the information that we have collected, please see the ‘Your rights’ section.

We may obtain information from third parties if you gave them permission to share it with us such as when:

• donating through a third party (e.g. BT MyDonate, Virgin Money, and JustGiving), the third party may provide us with your bank details so that we can process your donation
• you are completing a challenge event to raise money for VacProj and are using a third party to collect sponsorship (e.g. BT MyDonate and Virgin Money), the third party may provide with us your name and contact details (e.g. email, address, and/or phone number) so that we can provide you with support and thank you for your contribution
• using third party lists to help us find trusts, Livery Companies, and corporate foundations we can apply to for funding.
• We may obtain information from public sources to help identify trusts, Livery Companies, foundations, firms, companies, and individuals for possible funding opportunities.
• Specific individuals may be contacted if they are whom the publicly available information directs us to (e.g. the email address for a partner at a firm).

We may contact for additional information:

• college’s Alumni database
• ExVac, a similar scheme at a neighbouring college, to help both parties to select the most appropriate children

Public sources we may use include:

• company websites
• social networks (e.g. LinkedIn, Facebook, and Twitter)
• pre-compiled public lists (e.g. The Legal500)

The information collected will vary depending on the situation (e.g. applying for a holiday, donation administration etc.), but is intended to be the minimal amount needed for the activity (e.g. ensuring your child is as safe as possible on our holiday). We will not sell or rent your personally identifiable information that you provide us.

The personal information collected may include, but is not limited to:

• name
• email address
• postal address (including postcode)
• phone number
• bank or credit card details
• why you have decided to apply?
• Certain types of personal information (e.g. health, race, religious beliefs, etc.) are in a special category under data protection laws, because they are considered to be more sensitive. We only collect this type of information if there is a clear reason for us to do so, (e.g. ensuring your child is as safe as possible on our holiday). We will also collect this type of information if you make it public or volunteer it to us (e.g. through a conversation). Wherever it is practical for us to do so, we will let you know why we are collecting this information and for what purpose.

When collecting information about a child, we will ask a parent or guardian for consent prior to collecting their child’s information.

We do not actively collect and/or use information about your device (e.g. IP address, type of device, etc.) but depending on your device settings, it may be made available to us. Contact your device manufacturer or operating system provider for more information on what information is made available.

We will use your personal information to ensure the suitability of your child for our holiday, maximise their safety and administer our contact databases, to keep you updated with our fundraising efforts, and to contact volunteers. Examples include:

• providing information you requested
• processing a singular or regular donation
• claiming gift aid on a donation
• maintaining a list of people who have previously donated or fundraised so we can contact them to see if they are interested in doing so again
• registering you for an event
• maintaining a list of people interested in receiving our annual newsletter
• understanding what activities you have had with us (e.g. donations, event participation, meetings, etc.) and how you prefer to be contacted (email, post, or phone) to ensure we only send you relevant and appropriate communications
• maintaining a list of people who have explicitly told us that they don’t want to be contacted by us
• analysing your website behaviour in order to improve our website
• identifying funding opportunities (e.g. trusts, foundations, Livery Companies, companies, firms, etc.)
• create reports about our charity
• safeguard staff, volunteers, and clients
• meet legal obligations
• to distribute contact details for the organisation of our holidays
• provide volunteers with essential information about participants on their holidays

At any point, you can let us know how you wolid like to be contacted and what information you would like to receive, as well as update your communication preferences and opt out of communications, by emailing vacation.project@lincoln.ox.ac.uk.

Most of the time, we will obtain your permission for processing your information, but occasionally we may need to process your personal data without your consent. This will only be done when it is in our legitimate interest, it is legal for us to do so, and it will not infringe your legitimate interest, rights, and/or freedoms.

The safety and security of your personal information is important to us and we try to implement the safeguards needed to protect it, ensure it is accurate, and keep it up to date such as:

• Ensuring the VacProj websites have up to date SSL certificates to secure information transferred from you to the webservers.
• Ensuring payment gateways (BT MyDonate, Virgin Money Giving, JustGiving, CAF) meet the Payment Card Industry Data Security Standards.
• Ensuring contracts with third party data processors (e.g. server managers, system support, etc.) have clear expectations and requirements regarding the data they have access to
• Regular anti-virus scanning of hardware devices.
• Recycling hardware through certified vendors to ensure secure deletion of any information on hardware being disposed of.
• Providing GDPR training to volunteers to increase their knowledge and understanding of best practices for data protection.

Unfortunately no matter what safety measures are implemented, information sent via the internet can never be guaranteed to be flily secure. Even though we do our best to ensure your personal information is safe, we cannot guarantee that the information you provide online or via email is flily secure. Information you send via internet is therefore sent at your own risk.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required to do so by law or for regliatory reasons.

General information may be shared with partners in order to aid our research, with personal identifying information removed (e.g. we may share the total number of children attending a given holiday).

We may share the names of children who participate in VacProj with ExVac, a similar scheme at a neighbouring college, to help both parties to select the most appropriate children.

We aim to hold your information for only as long as necessary for the relevant activity (e.g. donation information will be kept for six years in alignment with auditing requirements).

If you opt-out of communications, we normally keep the minimal amount of personal information needed to ensure your request is carried out (e.g. name, email, and address). If you ask us to completely remove all of your information, we will do our best to carry out your request, but may not be able to if we were unable to keep the information required to track your request.

If your personal details change, please help us to keep your information up to date by notifying us at vacation.project@lincoln.ox.ac.uk

For any personal information of yours that we hold, you have the right to request:

• That we verify, correct, restrict use of, and/or erase your information. To do so, email vacation.project@lincoln.ox.ac.uk. Please note, any information you shared via social media channels may remain after we carry out your requests on your information in our systems.
• What information you receive (e.g. holiday information packs, application forms etc.) and how you receive it (i.e. phone, email, and/or post). You can provide us your preferences by emailing us at vacation.project@lincoln.ox.ac.uk.
• A copy of the information we hold about you by emailing us at it vacation.project@lincoln.ox.ac.uk. Please include details of the information you want.

You also have the following rights under GDPR regliation, more information on these can be found on the ICO’s (Information Commissioner’s Office) guidance:

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

We may require proof of identity prior to flifilling your request, and we will respect your requests unless we are unable to do so for legal reasons (e.g. inability to delete donation information for auditing reasons). If we are legally unable to carry out your requests, we will notify you along with the reason(s) why. For more details regarding exceptions to your rights, please view the ICO’s guidance.

Complaints regarding our processing of your personal data can be made to the ICO at any time, however we wolid appreciate the opportunity to address any issues you have with the way we process your data and can be contacted at vacation.project@lincoln.ox.ac.uk.

We are constantly reviewing how we process and protect data. Therefore, changes to our policy may occur at any time, and we reserve the right to amend our Privacy Policy. If we do so, we will post notice of the changes on our website.

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