Our Privacy Policy

1.Introduction

Bounce Back are a Charity and Social Enterprise dedicated to the training and employment of offenders. Registered charity no. 1144297. The company is limited by guarantee (no. 07675301).  Registered address: 130 Wood Street, EC2V 6DL.

Bounce Back is committed to protecting and respecting the personal data that we hold. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data.

Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data.

We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below.

The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources (such as internet searches, Companies House).

Where we receive personal data that relates to an individual from a third party, we request that this third party inform the individual of the necessary information regarding the use of their data. Where necessary, reference may be made to this privacy statement.

2. Security

We take the security of all the data we hold seriously. Staff are trained on data protection, confidentiality and security.

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal data stored on our website and systems.

We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

We store most information digitally using secure software. Special Category Information is kept in digital systems designed with additional security.
Some information (e.g. paper-based) is kept in secure physical storage.
Other information, such as phone messages, are converted to another format for storage.
The management of our charity is designed to enable and ensure compliance with the data protection laws currently in force.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

3. Data that we hold

3.1 Services

We provide services to individuals as well as businesses, non-profits, and other organisations. The exact data held will depend on the services to be provided.

Where we engage with service users for services, we may collect and process personal data to satisfy a contractual obligation. We request that users only provide the personal data that is required for us to fulfil our contractual obligation.

3.1.1 Why do we process data?

Where data is collected for professional services, it is used for a number of purposes, as follows;

  • Providing services to users. We provide a range of services to our users, which includes;
  • User management. When communicating with and assessing the needs of clients, personal data may be processed to ensure that their needs are appropriately satisfied. This may include assessing whether the collection of services is provided to our clients are appropriate.
  • To manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
  • To undertake professional services, we may from time to time be required to collect and process personal data to fulfil regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.
  • To help people into employment.

3.1.2 What data is processed?

The data that is processed is dependent on the service that is being provided and on the recipient of this service.

Personal data may include:

  • contact details and tax identifiers, information about business activities, investments, and other financial interests, payroll and other income, and any other specifically relevant data.

3.1.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

3.2 Business Contacts (fundraising / donations)

Personal data from our contacts / donor / subscribers, which covers both potential and prior contacts, as well as potential and prior employees, are held in our customer relationship management tool (CRM tool).

This information is entered into the system after contact is made between a staff member of Bounce Back.

3.2.1 Why do we process data?

Where personal data on business contacts is held, it is used for several purposes, as follows;

  • process a donation that you have made
  • process an order for an item from our shop
  • to carry out our obligations arising from any contracts entered by you and us/provide services to you
  • inform you about our services and activities
  • send you communications which you have requested
  • process a grant or job application
  • comply with a legal requirement
  • Relationship management.
  • Administration and management.

3.2.2 What data do we hold?

Personal data that may be stored in the CRM tool includes, but is not limited to, name, email address, physical address, job title, and details of the initial meeting.

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

3.2.3 How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose(s) for which it was collected.

We review our retention periods for personal information but please be aware we are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

3.3 Our people

We collect personal data for employees as part of the administration, management and promotion of our business activities.

Where an individual is applying to work for Bounce Back, personal data is collected through the application process. Data is often collected through forms on the website, details of which can be found in the section describing people who use our website. Data collected via the website will be used for the purposes detailed below.

There are several purposes that personal data for applicants are collected.

  • We process an applicant’s personal data to assess their potential employment at Bounce Back.
  • Administration and management. We may also use this personal data to make informed management decisions and for administration purposes.

Personal data collected for applicants is held for as long as necessary to fulfil the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary.

3.4 Suppliers

We collect and process personal data about our suppliers, subcontractors, and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and in some cases to provide professional services to our clients.

3.4.1 Why do we process data?

  • Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
  • Providing services to our clients. Where a supplier is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services in order to administer and manage our relationship with the supplier and the relevant individuals and to provide such services to our clients.
  • Administering, managing and developing our businesses and services. We process personal data in order to run our business, including:

– managing our relationship with suppliers;

– developing our businesses and services (such as identifying client needs and improvements in service delivery);

– maintaining and using IT systems;

– hosting or facilitating the hosting of events; and

– administering and managing our website and systems and applications.

  • Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails.  We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers.  We collect and hold personal data as part of our supplier contracting procedures.  We monitor the services provided for quality purposes, which may involve processing personal data.
  • Promoting our services. We may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
  • Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations.  We need to keep certain records to show we comply with those obligations and those records may contain personal data.

3.4.2 What data do we hold?

We will hold supplier’s names, contacts names, and contact details of suppliers.

3.4.3  How long do we hold data for?

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).  Data may be held for longer periods where required by law or regulation and in order to establish, exercise or defend our legal rights.

4. People who visit our centres

We have security in place at our centres, for the physical security of user information and for the benefit of our staff.

4.1 Why do we process data?

Building access controls may require visitors to our centres to sign in at reception and keep a record of visitors. This is retained for peoples safety in case of theft or other incident and to protect the staff and information in the office.

4.2 What data do we hold?

Our visitor book may include name and times of arrival and departure.

4.3 How long do we hold data for?

Visitor records are accessed on a need to know basis only.

5 People who use our website

When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps (collectively referred to as the websites).

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our website, contacts us about products and services, makes a donation or if they register to receive our newsletter.

Links to other websites

Our website contains links to other websites run by other organisations. This privacy policy applies to our website only‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

5.1 Why do we process data?

There are several reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;

  • fulfilling a product or service request
  • processing a donation
  • registering to receive our newsletter

5.2 What data do we hold?

The data that we hold depends on what data was entered and for what purpose.

Where data was entered to engage with functionality of our website, that personal data may include their name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.

Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Our website uses cookies to distinguish individuals from one another. This helps us to provide a better experience when individuals browse our website and allows us to improve our site.

It is possible to switch off cookies by setting your browser preferences.

5.3 How long do we hold data for?

We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).

In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.

6. Sharing personal data

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

Personal data held by us may be transferred:

  • to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process donations and send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service. We will not release your information to third parties beyond Bounce Back for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
  • When you are using our secure online donation pages, your donation is processed by a third party payment processor (Virgin Money Giving), who specialises in the secure online capture and processing of credit/debit card transactions. If you have any questions regarding secure transactions, please contact us.

Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are in secure data centres around the world, and personal data may be stored in any one of them.

Third party organisations that otherwise assist us in providing goods, services or information

Auditors and other professional advisers

Law enforcement or regulatory agencies or those required by law or regulations

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

7. Locations of processing

Personal data resides within the UK territory. We will take all reasonable steps to ensure that your data is treated securely, in accordance with this privacy statement.

8. Individual’s Rights

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:

  • Individuals may request access to their personal data held by us as a data controller.
  • Individuals may request us to rectify/amend/edit personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
  • Individuals may request that we erase their personal data
  • Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
  • Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
  • Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
  • Lodge a complaint with a supervisory authority.  If you wish to lodge a complaint or seek advice from a supervisory authority please contact The Office of the Information Commissioner.
  • Withdraw your consent to processing at any time.

If you wish to exercise any of these rights, update, change or remove your information, please send an email to admin@bouncebackproject.com or write to Bounce Back, POP Brixton, Unit L05, 49 Station Road, London SW2 1SE.

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent, or by post if you have indicated you do not want to be contacted in that way.

You can change your marketing preferences at any time by contacting us by email: admin@bouncebackproject.com

The accuracy of your information is important. If your details change or any of the information we hold is inaccurate or out of date or you want to access the information we hold about you, please email us at: admin@bouncebackproject.com

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems.

9. Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to admin@bouncebackproject.com

We will investigate and respond to any complaints we receive.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns

Overall Our Aims are to ensure that you:
– know what data we hold
– understand why we hold that data
– know how long we will hold the data
– can change or remove that data on request (subject to requirement of law)
– can see a clear path for help if you feel it is necessary

10. Data Controller and contact information

The data controller for Bounce Back and its associated businesses is Marijke de Jongh.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Head of Data Privacy

Bounce Back, POP Brixton, Unit L05, 49 Station Road, London SW2 1SE

EMAIL admin@bouncebackproject.com

11. Changes to our privacy statement

We review this policy from time to time. Updates to this privacy statement will appear on this website.  This privacy statement was last updated on 21st May 2018.

  • “Bounce Back is, above all, about its people. What is known is that a job and income on release is fundamental to success in coping with day to day life and preventing re-offending. Our drive to change perception in employers and clients is reaping rewards and our professional team is working around London and the Home Counties.

    The mutual trust and respect at the core of our values reflects the growing belief in giving social enterprises and socially disadvantaged people an opportunity to succeed and thrive. We are just one stage in this development, the determination of our participants to start a new life and move on is a formidable ingredient in the recipe for success."

    Francesca Findlater, Founder/Chairman

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