Please read this privacy policy carefully as it sets out how the Centre for Homelessness Impact (“CHI”, “we”, “our” or “us” as relevant) uses your personal information. If you have any questions about this privacy policy, please contact us at admin@homelessnessimpact.org. We may change this policy from time to time so please check our website from time to time for any updates. If we make material changes in the way we use your personal information, we will notify you by posting a notice on our website or sending you an email at the email address you provided us with, where relevant.

This Privacy Policy applies to our affiliates, members, volunteers, event attendees, study participants, academics, universities and local authorities personnel and, with regard to transparency provisions according to GDPR and UK GDPR, to other individuals whose data we may process except for our employees and candidates. If you are under these data subjects’ categories, please check the suitable Privacy Policy or contact us at dpo@aphaia.co.uk.

1. About us

1.1 CHI is a registered charity in both England and Wales, and Scotland. Our registration number for England and Wales is 1183026, and for Scotland it is SCO49501. 

1.2. We are located at The Evidence Quarter, Albany House, Petty France, London SW1H 9EA. Our contact phone number is 0300 3026 7766 and our contact email address is admin@homelessnessimpact.org.

1.3. Our charity was launched in 2018 to act as a catalyst for evidence-led change to enable those working in and around homelessness to achieve breakthrough results. We believe that homelessness is an issue that can be solved sustainably. We want to improve the life chances of people at risk of, or experiencing homelessness by focusing on what works, pushing for interventions to be evaluated, and creating a movement that believes all citizens are better off when policymakers and practitioners value evidence and know how to use it.

2. Overview

2.1. For the purpose of the General Data Protection Regulation (GDPR), the UK GDPR and other applicable UK laws as the Data Protection Act 2018, CHI is the “Data Controller” of your data.

2.2. This privacy policy explains how we use your personal information.

3. The basis for the processing of your data

3.1. When our relationship with you is governed by an agreement, we rely on a contract to process your data. This may be the case where you are an associate, ambassador a volunteer, or when you are conducting a study on our behalf.

3.2. In addition, some data is processed based on CHI’s legitimate interest, notably photographs, audio and video recordings of the events in order to raise awareness and for training, generating interest and funding purposes and gathering feedback about our tools. We have run a Legitimate Interest Assessment that includes the three purpose, necessity and balancing tests in order to ensure our processing is lawful. Legitimate interest would as well be the lawful basis in the case of website analytics for preventing fraudulent or other malicious activities, in terms of cybersecurity and/or error tracking purposes. 

3.3. Your consent will be required in case we share some of your data with third parties for a purpose different from those comprised in this Privacy Policy and that is not indispensable for the performance of the contract or the development of our activities. We may also gather your consent for conducting interviews, sending marketing communications or participating in studies.

3.4. We may ask for your consent in other cases where we process your data. Such consent can be revoked at any time by contacting us at admin@homelessnessimpact.org.

3.5. When it comes to study data, we will process the anonymised and aggregated results. We note that such information is not governed by this Privacy Policy as the GDPR and the UK GDPR does not apply to anonymised data.

4. Collected information

4.1. All personal information you provide to us or any other we collect automatically through your use of our website will be processed and stored by CHI to perform our activities and achieve our goal of helping end homelessness for good. 

4.2. The types of personal information we collect may include:

1. Contact details – including your name, email address, phone number, postal address and date of birth;
2. Location data – we may collect your IP address;
3. Your image or recordings – we may obtain photographs, audio or video recordings of events. We may reproduce and/or publish your image in our website, and in other promotional materials, social networking channels and other materials related to our activities;
4. Your interactions with us – for example if you send us information via email, survey or social media, this may be stored on our systems;
5. Technical information – when you use our website, CHI automatically receives and records information on its server logs from your browser or mobile platform, including the location, IP address, cookie information and details about the page you requested.

5. Use of your personal information

5.1. As well as the purposes described above at Clause 4.1, we use the personal information we collect to:

1. To administer our website or any other purposes required in order to allow us to perform our activities as a homelessness charity;
2. to register you as an associate, ambassador or volunteer;
3. to inform you via email, SMS or telephone about our activities;
4. to send you information about appeals and fundraising activities;
5. to provide support service, including to respond to your enquiries and fulfil any of your requests for information;
6. to gather feedback on our tools;
7. to send you important information regarding our activities, or other technical notices, updates, security alerts, and support and administrative messages; and
8. as we believe to be necessary or appropriate under applicable law, to enforce our rights or to respond to requests from law enforcement and other government authorities.
   
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6. Marketing

6.1. We may send you marketing communications via email. You will receive marketing communications from us if you have signed up to our newsletter or events. If you change your mind and do not want to receive any marketing emails from us, you can unsubscribe from emails by clicking on the opt-out link provided in the footer of each one or by sending us an email to admin@homelessnessimpact.org. 

6.2. Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes, as specified in Clauses 5 and 6 above.

7. Disclosure of your information

7.1. We do not share, rent or sell your personal information to anyone without your explicit consent. However, based on contract and legitimate interest, we use third-party providers to support our activities:

• We may disclose your personal data to the following categories of third-party providers:

8. Security and international transfers of data

8.1. We are committed to ensuring that your information will be treated confidentially and securely, and we have put in place appropriate measures to ensure the security of your personal data.

8.2. When your personal data is transferred to parties located outside of the EEA we shall undertake an assessment and take appropriate measures to ensure such third party will provide adequate security of such personal data and respect your rights to privacy. These safeguards are intended to ensure a similar degree of protection is afforded to your data wherever it may be transferred and may include:

1. only transferring your personal data to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission; or
2. entering into specific contractual terms which have been approved by the European Commission and which give personal data the same protection as within the UK or the EEA. In these cases we will verify, on a case-by-case basis, whether the law in the recipient country ensures adequate protection for data transferred.

For further information on the safeguards used, please contact us at admin@homelessnessimpact.org.

9. Data retention

9.1. We may retain your personal data for as long as we require for the purposes for which it is processed or as is otherwise required by applicable law.

9.2. When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed. Once processing has been completed, we may securely delete or anonymise your personal data.

9.3. Please, note that we can keep personal data for longer where we are keeping it for research or statistical purposes.

For more details about our retention periods, please contact us at admin@homelessnessimpact.org.

10. Your rights

Under the EU General Data Protection Regulation (GDPR), the UK GDPR and any other relevant rules in the UK as the Data Protection Act 2018, you are entitled to certain rights in relation to our handling of your personal data, as described below.

10.1. You may request details of the personal information that we hold about you under data protection laws. If you would like a copy of the information held about you please write to us at admin@homelessnessimpact.org.

10.2. If you think any information we have about you is incorrect or incomplete, please write to us or email us at admin@homelessnessimpact.org as soon as possible. We will correct or update any information as soon as we can.

10.3. You have the right to the erasure of your data. Should you want to exercise your right to erasure, please email us at admin@homelessnessimpact.org. Please, note that we are not required to delete the information important for the establishment, exercise or defence of legal claims, or that we need to retain in order to comply with the law.

10.4. You have the right of restriction of processing, where the data is wrongfully processed but should not be erased for a reason listed in Article 18 (1) of the GDPR and UK GDPR.

10.5. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies to information you have given us, if we are processing information based on your consent or in talks about entering into a contract and the processing is automated.

10.6. If you would like to exercise these rights, please write to us or email us at admin@homelessnessimpact.org. 

10.7. Please, note that GDPR and UK GDPR provisions on the right of access, the right to rectification, the right to restrict processing and the right to object may be limited based on the research and statistics exemption.

• to the extent that complying with the provisions would prevent or seriously impair the achievement of the purposes for processing;
• where processing is subject to appropriate safeguards for individuals’ rights and freedoms;
• if the processing is not likely to cause substantial damage or substantial distress to an individual;
• if the processing is not used for measures or decisions about particular individuals; and
• as regards the right of access, the research results are not made available in a way that identifies individuals.

11. Contact and complaints

Should you have any complaints about how we handle your personal information, please contact us at admin@homelessnessimpact.org. Should we be unable to resolve your complaint and you wish to take your complaint further, you may do so by contacting the UK Information Commissioner’s Office (ICO).The ICO can be reached at https://ico.org.uk/global/contact-us/

12. Data protection officer contact details

CHI has appointed a Data Protection Officer for you to contact if you have any questions or concerns about the CHI’s personal data policies or practices. CHI’s data protection officer’s name and contact information are as follows:

Aphaia Ltd
The Brew Eagle House
163 City Rd
London
EC1V 1NR
UK Contact email: dpo@aphaia.co.uk
‍Contact telephone: (+44) (0)20 3917 4158