Consent and Legitimate Interest

For some data processing activities we may need your consent before we can contact you. For processing your data for different purposes (for example, sending direct marketing) we will always check we have an appropriate lawful basis. This will most often be ‘consent’ or ‘legitimate interest’. To do this, we consider both the content of the personal data that we collect and the way in which we wish to use that data.

Consent

• For some direct marketing channels (email and text communications) we need to have your consent to send you direct marketing – e.g., by you ‘opting in’ to future communications. Where we ask for your consent, it will be a freely given, specific, informed and an unambiguous indication of your wishes and provided by a statement or by a clear affirmative action.

Legitimate interest

• In some cases, Haven House will process personal information under the lawful basis of ‘legitimate interest’ as long as we are sure it does not override your individual privacy rights. To assess this, we will carry out a ‘balancing exercise’ to ensure that the communication is fair and lawful. For example, we may wish to contact a donor who has given to Haven House in the past to ask them for further support, because people who have previously given are statistically more likely to support the same charity again, and this will help us to increase our funds raised.  Our balancing exercise shows that:
  
  • We may contact such a supporter by post without seeking express consent, so long as the number of letters is proportionate to how recently the donor gave to Haven House (for example a donor who gave to us five years ago would not expect to receive more than one letter a year).
  • But the donor’s right to privacy and reasonable expectations over-ride Haven House’s interest in continuing contact with them by telephone or by email, and we would not therefore make any contact by these means without express consent.
• Where we do not need an individual’s consent for future direct marketing, we may use legitimate interest to keep you up to date with the work of Haven House and give you further information on how you can support the charity. For example, where you have previously donated to Haven House, or requested to receive some information or services, we have legitimate organisational interest to use your personal information to respond to you and to contact you in the future. However, we will ensure there is no overriding prejudice to you by using your personal information for this purpose. The processing that we might carry out includes some or all of the following:
  • Where the processing enables us to enhance, modify, personalise or otherwise improve our services / communications for the benefit of our customers or supporters
  • To identify and prevent fraud
  • To enhance the security of our network and information services
  • To better understand how you interact with our website
  • To provide postal communications which we believe will be of interest to you
  • To determine the effectiveness of promotional campaigns and advertising.
• Wherever Haven House process data for these purposes, we will always ensure that your rights take precedence. We will give you fair and clear information on how your data is going to be used and make clear that you have the right, at any time, to object to Haven House processing your data in this way.