Privacy Policy
Last Updated On 24-May-2023
Effective Date 24-May-2023
This Privacy Policy sets out how Calibre Audio (“Calibre Audio”, “we,” “our,” “us,”) collects, uses, and shares the information that you provide to us through our website located at https://calibreaudio.org.uk/ (our “Site”) or through our charitable activities and services (collectively, our “Services”).
Calibre Audio is a company limited by guarantee incorporated under the laws of England and Wales and a charity registered at the Charity Commission with charity number 286614. Our registered office is at New Road, Weston Turville, Aylesbury, Bucks, HP22 5XQ. We provide a socially inclusive audiobook service that seeks to extend and enrich the lives of members by providing a high-quality personalised service.
At Calibre Audio we are committed to protecting your personal information and being transparent about what we do with it. The privacy and security of your personal information is extremely important to us.
We do: use your personal data to help us provide a great experience for you as a member or supporter. This includes tailoring the information we share to ensure you find it relevant, useful and timely.
We do: respect your privacy and work hard to ensure we meet strict legal and regulatory requirements.
We don’t: sell your personal data to third parties.
If you have any questions relating to this Privacy Policy or how we use your personal data, please send them to enquiries@calibre.org.uk or post them to Calibre Audio, Aylesbury, Bucks. HP22 5XQ.
CONTENTS
1. Personal information we process
2. Sensitive personal information
3. Why we process your personal information
4. Our Lawful Basis for processing personal information
5. How we share your personal information
6. International data transfers
7. How long your personal information is stored for
8. Use of “Cookies”
9. Your rights
10. Other websites
11. Updates to this Notice
12. Contact us
1. Personal information we process
1.1 Personal information is any information that relates to an individual.
1.2 We collect personal information about our members, donors, supporters, volunteers or anyone else that accesses our Services. This includes the following information:
• Name
• Address and contact information e.g. telephone number and e-mail address
• Date of birth
• Gender
• Membership number and details
• Donation history
• Legacy information
• Disability or health condition
• Demographic information
• Experiences of print disability, if you share these with us
• Your reasons for supporting Calibre Audio
It may also include:
• Details of any opt-in and opt-out preferences you have communicated to us
• Whether or not you are a UK tax-payer (so that we know whether or not we can claim Gift Aid)
• Details of any gifts you have given to Calibre Audio
• Notes relating to our relationship with you. Examples of this could be:
Correspondence between you and Calibre Audio
Connections between you and other individuals or organisations known to Calibre Audio
Data gathered through prospect research (see section 3.8, below)
1.3 If you contact us, we may keep a record of that correspondence, including your contact details, name, interests, and related information. This includes any email correspondence with us.
1.4 If you are invited to or attend a Calibre Audio event, we may collect and store information such as your name and email address and keep a record of your interest in that event and topic.
1.5 We also collect and store information about your device and your visits to the Site such as your IP address, geographical location, browser type, referral source, length of visit, and number of page views. See more in the “Cookies” section below.
1.6 We collect an IP address from all visitors to our Site. An IP address is a number that is automatically assigned to your computer when you use the Internet. We use IP addresses to help diagnose problems with our server, administer our Site, analyse trends, and gather broad demographic information for aggregate use in order for us to improve the site, and deliver customised, personalised content.
These lists are not exhaustive, but are intended to give an indication of the sort of information we collect.
If you use your credit or debit card to donate to us, buy something or pay online or over the phone, we will ensure that we manage this securely and in accordance with the Payment Card Industry Data Security Standard (PCI DSS).
We do not store your financial information for longer than we need to.
2. Sensitive personal information
We will only collect and use sensitive personal information (also known as special category data under the UK GDPR) if there is a valid reason for doing so and where the law allows us to. Sensitive personal information includes personal information about health, ethnicity, religion, political opinions or sexuality.
2.1 We ask for information about health conditions as part of our membership sign-up process so that we can check eligibility and better provide our Services. We may also ask for information about your religion or ethnicity as part of our equality and diversity monitoring. There is no obligation to provide this information.
2.2 If you provide us with any ‘sensitive personal information’ by any means of communication, we will treat that information with extra care in accordance with our Data Protection Policy.
2.3 We will only use sensitive personal information to:
(a) Help you with your enquiry/membership subscription/request/donation;
(b) For internal training; and
(c) For monitoring or evaluating the Services we provide.
If you share your story with us to use in publicity which may include sensitive health information, we will ask for consent in advance.
3. Why we process your personal information
3.1 We may process your personal information for various purposes, including:
(a) to contact you, including to respond to your inquiries;
(b) process and administer your membership;
(c) to send fundraising requests and communications;
(d) to send you our newsletters, topic updates, and event invites, at your request;
(e) to run and operate our lottery and raffle;
(f) for business purposes, such as analytics, research, advertising and marketing, and operational purposes;
(g) for supporter profiling, research and screening exercises;
(h) to consider your application for employment;
(i) to administer our volunteering programme;
(j) to comply with a specific legal requirement, law enforcement and maintain our security; or
(k) as otherwise disclosed at the time of collection or use.
3.2 If a situation arises where we intend to use your personal information for any reason beyond its original purpose, we will notify you and provide additional information ahead of time.
3.3 Membership
If you are a Calibre Audio member, we will use your personal information to administer your membership. This includes posting you your audiobooks, sending resources such as catalogues, providing information about our services and products and sending you information about your membership by post and e-mail. It is also used to check who you are when you contact our Membership Services Team. For members who are under 16 (‘Young Calibre’ members), we communicate with, and send membership information and products to their parent or guardian.
3.4 Online Sales and Events Management
We process personal information to fulfil any orders taken online or through Membership Services. Your data will be used to communicate with you throughout the process, including confirming we’ve received your order and payment, to confirm dispatch, to clarify where we might need more detail to fulfil an order, or to resolve issues that might arise with your order. We also use member data if we are attending an event in your area and would wish to invite you.
3.5 Volunteering and recruitment
When you volunteer with us we will collect your contact details and the other information set out in our application form (e.g. your previous experience). We may also need to collect additional information about you (such as references, criminal reference checks, details of emergency contacts or medical conditions). We will process this information for legal and safeguarding purposes. In order to administer our volunteer programme we will contact you about volunteering opportunities and record your shifts/ any expenses claims made.
If you apply for a job with us, we will process your personal data, including sensitive personal data, to comply with our contractual, statutory and management obligations and responsibilities. This data can include, but isn’t limited to, your contact details, information contained in your application form and information relating to your health, racial or ethnic origin, and criminal convictions.
3.6 Research
We carry out research with our supporters, customers, staff and volunteers to get feedback on their experience with us. We use this feedback to improve the experience we offer and ensure we know what you find relevant and interesting.
If you choose to take part in research, we’ll tell you when you start what data we will collect, why and how we’ll use it. All the research we conduct is optional and you can choose not to take part. For some of our research we may ask you to provide sensitive personal data (for example, ethnicity). You don’t have to provide this data and we also provide a ‘prefer not to say’ option. We only use it at an aggregate rather than individual level (for example, for reporting on equal opportunities).
We may give some of your personal data (for example, contact information) to a research agency so that they can carry out research on our behalf.
3.7 Fundraising
Marketing Communications
Where you have agreed to receive communications from us, or where it is in our legitimate interests to do so, we may send you communications about our work, news about the charity, reading suggestions, fundraising opportunities and our lottery and raffle by e-mail, text message and phone.
We’ll never share your information with companies outside Calibre Audio who want to use it for their own marketing purposes.
We won’t send any marketing communications requesting donations to young people under 16, but we will send them information on how to fundraise on our behalf if they specifically request this.
You can change your communication preferences or opt-out of receiving communications from us at any time. Please contact us at enquiries@calibre.org.uk.
Donations
Where we have your permission, or where it is in our legitimate interests to do so, we may invite you to support our vital work by making a donation, getting involved in fundraising activities or leaving a gift in your will.
If you make a donation, we’ll use any personal information you give us to record the nature and amount of your gift, claim Gift Aid where you’ve told us you’re eligible, thank you for your gift. If you interact by mail, email or have a conversation with us, we’ll note anything relevant and store this securely on our systems.
If you tell us you want to fundraise to support our cause, we’ll use the personal information you give us to record your plans and contact you to support your fundraising efforts.
Charity Commission rules require us to know where funds have come from, as well as any conditions attached to them. We follow a due diligence process which involves researching the financial soundness, credibility, reputation and ethical principles of donors who’ve made, or are likely to make, a significant donation to Calibre Audio.
Gifts in wills
If you’ve told us that you have left a gift in your will, or are thinking about doing so, we will keep details of this. The data we will hold will enable us to keep in contact with you, name, address, membership number and contact details. If we have a conversation or interaction with you (or with someone who contacts us in relation to your will, such as your solicitor), we’ll make a note of these throughout your relationship with us, as this helps to ensure we direct your gift as you wanted.
Where a donor has passed away and we are in the process of receiving their legacy gift, we will process personal data of individuals involved in the estate administration for the purpose of ensuring our compliance with legal obligations in receiving and using the legacy gift for our charitable purposes. Access to this personal data is restricted and stored for as long as necessary to administer our legacy. More detailed information about use of personal data for this purpose is provided to the estate Executors, Trustees or their professional advisors during the legacy administration process.
We rely on legitimate interests to process personal data of individuals involved with the supporter and their estate. Where we would like to process data that is not for the direct purpose of the legacy administration process, we will seek specific consent from an individual - for example, if we would like to remain in contact with a donor’s relative to update them on how the legacy has been used to benefit a specific area of Calibre’s work.
3.8 Profiling, screening and major donor research
Profiling
We know it’s important to our supporters that we use our resources in a responsible and cost-effective way. This is why we undertake profiling and targeting to help us understand our supporters and make sure that:
• our communications (for example, emails) and services (for example, our website) are relevant, personalised and interesting to you
• our services meet the needs of our supporters
• we only ask for further support and help from you if it’s appropriate
• we use our resources responsibly and keep our costs down.
To do this we’ll analyse how you interact with us (for example, on our website or by direct contact) and use both geographic and demographic information to let you know what’s happening in your local area and better understand your interests. The personal information we collect includes transactional information, for example, in relation to memberships, donations, and online shop purchases.
Much of the information we collect is aggregated, which means we look at it as a whole rather than at an individual level. Data Aggregation is any process in which information is gathered and expressed in a summary form, for purposes such as statistical analysis. A common aggregation purpose is to get more information about particular groups based on specific variables such as age, profession, or disability.
However, we may also collect some personal data to create profiles which help us to personalise your experience and target our marketing campaigns to you and to other people. For example, we may use your membership data to ensure you don’t see adverts about membership online. Or we may use your personal data to find online users with a similar profile to you who may also be interested in our products or services, for example, by using Facebook (and other social media platform) ‘custom’ and ‘lookalike’ audience tools.
In some cases we will augment the information we already have about you by obtaining information from publicly available sources (as outlined in the Major Donor section below).
We may sometimes use third parties to capture some of the above data on our behalf, but only where we are confident that the third party will treat your data securely, in accordance with our terms and in line with the requirements set out in the UK GDPR.
We won’t profile anyone under the age of 16.
Wealth-screening
On occasion, we also engage with specialist agencies such as Prospecting for Gold to screen our supporter database against the agency’s database of publicly available information in order to better assess (based on estimated levels of wealth), whether our existing members and supporters may have the capacity and propensity to provide greater financial or other support to Calibre Audio. This enables us to communicate and engage with supporters in the most appropriate and cost efficient ways. We have robust contracts in place with these agencies to ensure that the personal data is used safely and correctly.
The wealth-screening agency’s database typically includes and screens against the following information:
• Public Registers: Companies House, The Electoral Commission (Political Donations), The Electoral Roll (Open Register), The FCA (Financial Services Register), The Law Society, The Land Registry.
• Trade and Industry References, Professional directories, Charity Commission.
• UK Reference volumes: Who’s Who, Debrett’s People of Today, Debrett’s Peerage and Baronetage, City of London Livery Company information, Trustfunding.org.uk.
• Reliable print and broadcast media: newspapers (The Telegraph, The Times and Sunday Times, City AM), magazines.
• Information that individuals put into the public domain such as on company websites or biographies on professional networking sites.
If you would like any further information on this process, or would like to opt-out of your data being used in this way, please contact us at enquiries@calibre.org.uk.
Major Donors
As a national charity reliant upon fundraised income, it is in our legitimate interests to use personal information in the ways described below, to help us understand our supporters and potential supporters, tailor our communications and use our resources effectively.
If we invite you to an event or to meet with one of our fundraisers, or if we are in discussions with you about how you can support us now or in the future, we will use your personal information to conduct some research to ensure that we can have a more informed conversation with you. If you are a Calibre member this typically includes: contact and membership details; the amount and purpose of any previous donations; a record of communications we have sent or received from you. We may note conversations and interactions we have with you where it is relevant to your relationship with us.
We may augment our membership data with additional publicly available information about you such as professional profiles (for example, corporate biographies and/or LinkedIn profiles); search engine and public social media results; resources such as Companies House and the Charity Commission; and third-party publications such as Debretts, Who’s Who and the Sunday Times Rich List. We may also use third-party aggregators of publicly available information to review financial, philanthropic and professional information.
If you would prefer we did not do this, please just let us know and we will, of course, respect your wishes.
4. Our Lawful Basis for processing personal information
4.1 Organisations that collect and use personal information must have a lawful basis for doing so under data protection law. The UK General Data Protection Regulation (“UK GDPR”) sets out six ‘lawful bases’ upon which personal information (and additional conditions for sensitive personal data) can legitimately be used. The UK GDPR requires us to tell you the legal basis which we rely on when processing your personal information.
These include:
• Obtaining your (explicit) consent to use your personal information for a particular purpose (for example to send you direct marketing by e-mail or SMS or to collect sensitive personal data);
• Where the use of the personal information is in our “legitimate interests” (see below for more information);
• Where we need to process your personal information in order to perform our obligations under a contract that we have entered into with you (for example to provide you with goods or services); and
• To process personal information where we are under a legal obligation to do so (for example to process your gift aid declaration).
4.2 Personal information may be legally collected and used if it is necessary for a legitimate interest of the organisation or a third party using the personal information, as long as its use is fair and does not adversely impact the rights of the individual concerned. When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair. Our legitimate interests include:
• Charity Governance, including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance;
• Administration and operational management, including responding to solicited enquires, providing information that you have requested, research, events management, checking your preferences so we can communicate with you according to your wishes, the administration of volunteers and employment and recruitment requirements.
• Fundraising and Profiling, including administering campaigns and donations, and sending direct marketing by post and via social media platforms, sending thank you letters, analysis, profiling (including major donor research, supporter profiling and wealth-screening as set out in section 5 above), targeting and segmentation to develop communication strategies and maintaining communication suppressions.
5. How we share your personal information
5.1 We may share your personal information with third parties, including the following:
(a) with contractors, suppliers, or other third parties that provide services on our behalf;
(b) with our professional advisors (e.g. solicitors and accountants);
(c) as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of an insolvency proceeding;
(d) pursuant to a court order, or other legal or regulatory process or as otherwise required or requested by law, regulation, or government authority programs, or to protect our rights or the rights or safety of third parties; or
(e) with your consent or as otherwise disclosed at the time of data collection or sharing.
5.2 On the rare occasion that Calibre Audio merges with or transfers all or part of its Services to another organisation you will be given the opportunity to opt-out before any personal information is transferred.
5.3 Calibre Audio will not trade or sell personal information with anyone else, nor send mailings on behalf of other organisations. However, we may share information that has been de-identified or aggregated without restriction.
5.4 We require any third parties that we share personal data with to respect the security of your personal information and to treat it in accordance with the law.
6. International data transfers
6.1 We generally do not transfer any of your personal data outside the United Kingdom. However, please be aware that the personal information we collect may on occasion be transferred to and maintained on servers or databases located outside of the United Kingdom, where the privacy laws may not be as protective as those in your location. This may be the case where we engage with a supplier based outside of the UK or EU. Where this is the case, we comply with the UK GDPR in respect of any international data transfers and will put extra steps in place to safeguard the data where required.
7. How long your personal information is stored for
7.1 The personal information you provide will be kept in accordance with our Data Retention Policy.
7.2 The criteria used to determine the period of storage of personal information is: (i) the respective statutory retention period; (ii) our contractual and/or business relationships with you; (iii) (potential) disputes; and (iv) any guidelines issued by relevant supervisory authorities. After expiration of that period, the corresponding information is routinely deleted, as long as it is no longer necessary for the fulfilment of a contract, the initiation of a contract or to protect or defend our position or that of a third party. If you have any questions about retention periods, please contact us using the details in section 12 below.
7.3 If you apply for a job with Calibre Audio we will keep your application materials on file, including any voluntary demographic data you may include with your submission, for up to one year.
8. Use of “Cookies”
8.1 We use cookies to personalise content, ads and to analyse our traffic. We also share information about your use of our site with our advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. For example, when you give consent to cookies, we share information with Google who detail how they use your data on the Google Privacy and Terms site: How Google uses information from sites or apps that use our services – Privacy & Terms – Google. You can find more information about our use of Cookies in our Cookies Policy
9. Your rights
9.1 Under privacy laws, you have rights relating to your personal information. You have a right to the following:
(a) to request access to the personal information we hold about you;
(b) to request that we rectify or erase your personal information;
(c) to request that we restrict or block the processing of your personal information;
(d) under certain circumstances, to ask us to port personal information about you that you have provided to us to you or a third party; and
(e) where we previously obtained your consent, to withdraw consent to processing your personal information.
9.2 To exercise these rights, contact us via the “Contact Us” section below. Please be aware that Calibre Audio may be unable to provide these rights to you under certain circumstances, such as if we are legally prevented from doing so or can rely on exemptions.
9.3 Additionally, you have the right to lodge a complaint against us. To do so, contact the supervisory authority in your country of residence. In the UK, this is the Information Commissioner’s Office at www.ico.org.uk/concerns.
10. Other Websites
10.1 Our Site contains links to other websites. Please note that when you click on one of these links, you are entering another website for which Calibre Audio has no responsibility. We encourage you to read the privacy policies on all such sites as their policies may be different than ours.
10.2 The Site may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share information or you otherwise interact with social media features on the Site, those social media companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party social media companies and the use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to read the privacy policies for any social media accounts you create and use.
11. Updates to this Notice
11.1 We may change this Privacy Notice at any time in our discretion. If we decide to make significant changes to our Privacy Notice, we aim to notify you of these changes. We will also post these changes on this page.
12. Contact us
12.1 If you have any questions about this Privacy Notice, the practices of this Site, or our Services, you can contact us by phone at 01296 432339 or email us at enquiries@calibre.org.uk or by post at Calibre Audio, Aylesbury, Bucks. HP22 5XQ.