At the RAF Benevolent Fund, we respect your privacy and take great care with personal information we hold about you. This privacy notice sets out how we collect and handle information about you. The terms of this policy may change, so please check it from time to time. This version published on 14 November 2019, supersedes all previous versions.
Please read this notice carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights and how to contact us or our supervisory authority, the Information Commissioner’s Office, in the event you have any concerns we are unable to address.
Our use of personal information is governed by law. The RAF Benevolent Fund is committed to complying with the principles set out in the General Data Protection Regulation (GDPR), the applicable sections of the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
Who we are
The Royal Air Force Benevolent Fund is the leading welfare charity supporting current and former members of the RAF, their partners and families, providing practical, emotional and financial support. We are a registered charity in England and Wales (1081009) and in Scotland (SC038109) and registered with the Information Commissioner's Office (ZA111002). The following wholly owned subsidiaries also process personal information and are therefore registered with the Information Commissioner's Office:
|Name||Description||ICO Registration Number|
|RAF Disabled Holiday Trust||Providing holidays to disabled serving and former members of the RAF and their dependants||ZA234348|
|RAF Benevolent Fund Housing Trust||Provides and manages properties for beneficiaries of the RAF Benevolent Fund||Z6071914|
|RAF Dependants Fund||Promotes the efficiency of the RAF through relieving dependants of deceased serving personnel from financial distress||Z943187X|
|RAF Dependants Income Trust||For subscribers of the RAF Dependants Fund to make further financial provision for their dependants in the event of death in service||Z9431897|
How do we collect your personal information?
a) When you give it to us directly:
For example, personal information that you submit through our website by making a donation, signing up for newsletters, challenge events or personal information that you give to us when you communicate with us by email, phone, letter or complete an application form.
b) When we obtain it indirectly:
For example, your personal information may be shared with us by third parties including other military or military-related charities; RAF Stations; family or friends who have suggested that you might require our services; websites offering fundraising services; sub-contractors in delivery of our services; or employment agencies.
c) When it is available publicly:
Your personal information may be published on publicly available sources. Our use of publicly available personal data complies with the principles set out in the GDPR.
d) When you visit our website:
When you visit our website, we automatically collect the following types of personal information:
- Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, and your operating system.
What personal information do we use?
There are many different data processing activities across the RAF Benevolent Fund. We will only ever capture the minimum amount of information that we need for the particular reason we are processing your data. The most commonly collected personal information are your name and contact details including postal address, telephone number and email address. We may also process the following:
- Your date of birth and gender
- Your financial information, such as bank details and/ or credit/ debit card details
- National identifiers such as an RAF service number or National Insurance number
- Social relationship data relating to family or social relationships
- Health data and other special category data
- Details of work history and qualifications
- And in some, but fewer cases, information about
- Life history – brief or detailed descriptions of significant life events that could identify you
- Socio-demographic data – for example, information about your role in society
- Preference data – for example, your likes and dislikes
- Photographic and CCTV data
To be within the scope of GDPR, this personal data must be recorded in an RAF Benevolent Fund filing system, or we have an intention of recording it in a filing system. Any personal information you tell us that we do not file, or do not intend to file, for example personal information you may tell us during a telephone conversation that we do not record in any way, is outside the material scope of GDPR.
How and why do we use your personal information?
Your personal data is required to enable the RAF Benevolent Fund to achieve its aims and objectives as a charity. Your personal information, however provided to us, will be used for specific, explicit and legitimate purposes which include:
- to provide you with support or information you have requested;
- to provide services to our beneficiaries;
- to provide further information about our work, services, activities or products (where you have provided your consent to receive such information; or you would have a reasonable expectation to receive such information)
- to process your donations;
- to answer your questions/ requests and communicate with you in general;
- to manage relationships with our supporters and beneficiaries;
- to enable eligible guests to stay at Princess Marina House and Cottages
- to ensure your safety when you visit RAF Benevolent Fund sites
- to further our charitable aims in general, including for fundraising activities;
- to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
- to report on the impact and effectiveness of our work;
- to run/ administer our website, keep it safe and secure and ensure that content is presented in the most effective manner for you and for your device;
- to administer your participation in fundraising events and challenges;
- to process your application for a job or volunteer role with us
- to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
- for the prevention of fraud or misuse of services; and/or
- for the establishment, defence and/ or enforcement of legal claims.
The GDPR requires us to rely on a lawful basis for each data processing activity undertaken with your personal data including those set out in the previous section. These legal bases are:
- Consent - Where you have provided your consent for our use of your personal information in a certain way (for example, where you have provided your consent for us to use your personal information to send you fundraising material by email, or to send you our newsletter).
- Contractual obligation - Where it is necessary for us to process your personal information in order to perform a contract to which you are a party, or to take steps prior to you entering a contract, for example where you apply for a role at the RAF Benevolent Fund.
- Legal obligation - Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. For example, this might be where we have a legal obligation to share personal information with HMRC for Gift Aid claims or tax calculations.
- Vital interests - Where it is in your, or someone else’s vital interests. For example, in the case of a medical emergency suffered by an individual that needs to be reported by us to the emergency services.
- Public Interest – Where it is necessary to perform a task carried out in the public interest
- Legitimate interests - Where applicable law allows us to collect and use personal information on the condition that to do so is necessary for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. In broad terms, our “legitimate interests” means the interests of running the Charity as a charitable entity, and pursuing our aims and ideals; for example
- the administrative activities of providing support to our beneficiaries,
- taking donations,
- acknowledging your kind donations and sending you pin badges,
- administering events,
- receiving applications forms,
- passing data between our wholly owned subsidiaries,
- producing anonymous statistical reporting
- administrative activities related to Princess Marina House
In addition, where we process special categories of data an additional condition of processing is established and documented as required by Article 9 of the GDPR.
We segment donor information based on characteristics such as location, or number and value of donations. This helps us to understand our donors better and we may under some circumstances conduct research using a third party organisation to search publicly available sources and create a profile about you and your interests (this is often called “wealth profiling”). This analysis and research helps us to understand the background of our supporters so that we can make appropriate requests to those who may be willing and able to give more than they already do, enabling us to raise funds and help beneficiaries sooner and more cost-effectively. We may also have an obligation to conduct due diligence checks to reduce the risk of fraud.
If you would prefer us not to use your personal information for supporter research, please let us know by contacting us at firstname.lastname@example.org
Communications for marketing/ fundraising
We may use your contact details to provide you with information about our work, events, or services which we consider may be of interest to you (for example, about services you have used, or are available to you; or updates about fundraising appeals and/or volunteering opportunities via our newsletter). Where we do this via email, SMS or telephone, we will not do so without your prior consent. We may also ask for your consent to send you information by post. You can opt out of receiving emails from the Fund at any time by clicking the “unsubscribe” link at the bottom of our emails or you can tell us by contacting us at email@example.com. In some circumstances, we may send you information in the post under the legal basis of legitimate interests. Again, if you wish to opt out of receiving postal mail from us you can tell us by contacting us at firstname.lastname@example.org.
Will we share your personal data?
We do sometimes need to share your personal information with other third parties in order to effectively provide our services, however we will never sell your personal information for marketing purposes. Non-exhaustively, parties we share data with include:
- Independent occupational therapy and mobility equipment organisations (only with your consent – see section entitled 'Lawful Processing')
- counselling and related support organisations (only with your consent – see section entitled 'Lawful Processing')
- Organisations providing beneficiary holidays and hotel booking systems
- RAF stations
- Professional services including solicitors
- Parties who assist the Fund in the administration of beneficiary enquiries
- Fundraising event organisations
- IT providers and cloud storage providers
- Regulatory authorities, such as tax authorities.
- Order and postal donation fulfilment organisations
- Mailing house providers
- Payroll Giving providers
- Content management system providers
- Organisations specialising in processing financial transactions and direct debits
- Organisations specialising in administering fundraising lotteries and online tribute pages
- Organisations specialising in advertisements to appear in social media newsfeeds
In rare circumstances, where we identify an individual as being at risk of harm to either themselves or others, or has other safeguarding needs, we may need to pass personal data to local authorities, medical professionals or emergency services.
The RAF Benevolent Fund has an online presence through the following third-party social media platforms.
We may provide Facebook with email addresses of those who have signed up to receive newsletters or other fundraising information in order to allow our fundraising advertisements to appear in your newsfeed and the newsfeed of others.Facebook only uses your email address for this purpose. This should not disrupt your experience of using Facebook, but if you would like to opt out of this activity you can do so by emailing our website manager – email@example.com.
We want our blog and social media presence to be a healthy environment for discussion.Our communications team moderate comments on the blog and social media accounts to protect those who view them. We will challenge, rather than delete, inaccurate comments or data, and remove anything that is discriminatory or unlawful.
If you have a complaint or comment about how we moderate social media, please contact our communications team at firstname.lastname@example.org.
When you use our secure online donation function you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.
Children's personal information
When we process children's personal information, where required we will not do so without their consent and use our best endeavours to determine their competency to give consent. Where required,the consent of a parent/ guardian will be sought. We will always have in place appropriate safeguards to ensure that children's personal information is handled with due care.
How long do we keep your personal information?
In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records as shown below:
Personal data connected to Fundraising and Finance
Personal data connected to Welfare (Beneficiaries)
All other personal data
Varies dependant on purpose but kept for no longer than necessary
There are circumstances whereby data may be deleted before the maximum retention period. These are:
- your personal information is no longer required in connection with the purpose for which it was collected for.
- we are no longer lawfully entitled to process it, or
- you validly exercise your right of erasure (see see section entitled "Exercising your rights") and we delete / fully anonymise the data.
We may need to keep your data for statutory purposes, for example, gift aid declarations.
If you request to receive no further contact from us we will maintain a small amount of data on our suppression list, comprising your name and contact details in order to comply with your request and ensure we avoid sending you unwanted materials in the future.
Security and access to your personal information
The RAF Benevolent Fund is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers with features enacted to prevent unauthorised access.
We conduct supplier audits with our main data processors to ensure their information security system is robust and GDPR compliance is in place to ensure the safety and security of personal data we share with them.
International Data Transfers
From time to time, the RAF Benevolent Fund may need to transfer personal data outside of the European Economic Area to effectively provide our services and further our aims and objectives. This may be suppliers or agencies; or users who access our website in non-EEA countries.
The Fund takes necessary steps to safeguard personal data that is being internationally transferred outside the EEA. This includes entering into agreements with the international party by way of unaltered 'standard contractual clauses' which are recognised by the UK's information commissioner's office as being a compliant way of transferring data; or by gaining explicit consent from individuals whose personal data appears on our website.
Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.
Exercising your Rights
The RAF Benevolent Fund may contact you by post unless you request otherwise, and by telephone, email, text, social media or other electronic means depending on the communication preferences you have previously indicated. Where we rely on your consent to use your personal information, you have the right to withdraw your consent. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time.
When we use your personal information, you have the right to:
- Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we can confirm your identity, we will provide you with this personal information.
- Request that we delete the personal information we hold about you, as far as we are legally required to do so.
- Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
- Object to the processing of your personal information where we:
- process on the basis of the legitimate interests ground;
- use the personal information for direct marketing; or
- use the personal information for statistical purposes.
- Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us:
- in reliance on your consent; or
- because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means
- Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage. If you decide you do not want to receive any further emails from us, please tell us and we will remove you from the mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed in the section entitled "How to contact us".
You also have the right to lodge a complaint with the Information Commissioner's Office at www.ico.org.uk/concerns.
Changes to this Policy
We may update this Policy from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an updated Policy on our website. This Policy was last updated on 14 November 2019.
Data Protection Officer
Our Data Protection Officer can be contacted directly at email@example.com
Website links to third parties
This website contains links to third party websites that may collect your personal data. This policy does not cover external websites and we encourage you to read the privacy policies of any external websites you visit via links from this website, or links embedded in any email originating from us. We are not responsible for their privacy practices or website content.
How to contact us
For any enquiries about this privacy notice or our treatment of your personal data, please contact:
Telephone: 0207 307 3313
Post: Royal Air Force Benevolent Fund, 67 Portland Place, London, W1B 1AR