This Policy describes how and why The Lullaby Trust uses your personal information, how we protect your privacy when doing so and your rights and choices regarding this information. We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it.
We use personal information on a day-to-day basis in order to operate. Our use of personal information allows us to provide you with a product or service you may have requested, make better decisions, communicate more efficiently and ultimately helps us in achieving our goal – to stop all unexpected deaths of babies and young children.
This Policy explains:
- Who we are
- How we collect information about you
- Why we use your information
- How we use your information to fulfil your requests and support you
- How we use your information to tell you about our work
- What we do if you choose to tell us about your experience of sudden and unexpected death of a baby or young child
- Sharing your information with other organisations
- How long we keep your information
- How we keep your information safe
- Your rights
- Updates to this Policy
London, SW1E 5HX
The processing of your personal data is carried out by or on behalf of The Lullaby Trust and The Lullaby Trust Sales Limited.
The Lullaby Trust (registered charity number 262191in England and Wales) and a company limited by guarantee in England (number 01000824); and The Lullaby Trust Sales Limited (company number 01731141 in England).
We refer to both organisations throughout this Policy collectively as “The Lullaby Trust”, “we”, “our” or “us”.
We collect information in the below ways:
2.1 Information you provide to us directly
You may give us your information in order to sign up for one of our events, make a donation, purchase our products, register as a volunteer or ambassador for us, apply for research funding, use our helpline, information service or otherwise communicate with us.
When you use our website, we collect your personal information using “cookies” and other tracking methods. There are more details on the cookies and tracking methods we use in our Cookies Policy outlined below.
In addition, in accordance with common website practice, we will receive information about the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device, including what type of device it is, what specific device you have, what operating system you’re using, what your device settings are, and why a crash has happened. Your device manufacturer or operating system provider will have more details about what information your device makes available to us.
2.2 Information you provide to us indirectly
2.3 Information from other sources
We also use information from the following sources:
Social Media – Depending on your settings or the privacy policies for social media and messaging services like Facebook, WhatsApp or Twitter, you might give us permission to access information from those services, for example when you publicly tag us in an event photo.
Information available publicly – We supplement information on our supporters with information from publicly available sources such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of someone’s interests and support of The Lullaby Trust.
We will only use your information where we have a legal basis to do so and will always respect your rights.
Where we use your information, it may be because you have consented to us doing so or because we consider we have a legitimate interest to do so. Where we do rely on a legitimate interest to use your information, we will always ensure that this is done in a fair way that respects your rights. Other reasons may include using information because we have a legal obligation to do so or because we have to fulfil contractual obligations.
We only use your information:
- If you have given us your consent to use the information for a specified purpose, such as sending marketing communications to you by email
- If you have given us your consent to provide a service to you, such as our Care of Next Infant (CONI) scheme
- Where it is necessary for us to comply with a legal obligation, for example to claim Gift Aid on a donation
- Where it is necessary to enter into, or perform, a contract with you, such as when you apply for a job with us
- For our own (or a third party’s) legitimate interests, provided your rights don’t override these interests, for example fundraising, internal record keeping, research and reporting.
4.1 To respond to or fulfil any requests, complaints or queries you make to us
If you contact us directly, we will use the information you give to us to handle your enquiry or request. This may include sharing your details with other The Lullaby Trust personnel in order to process your enquiry, responding to your query or feedback, or sending you relevant information such as fundraising materials or information on safer sleep advice or our bereavement services. We may also keep a record of conversations we have with you, feedback you provide and any marketing materials we send out to you. We use this information to compile internal reports to help us improve our services and to handle queries more efficiently.
4.2 To process any donations you make, claim any relevant Gift Aid and maintain a record of your past or potential future financial contributions
This includes keeping a record of any pledges, gift agreements or any other indications that you are planning to donate to The Lullaby Trust. We keep a record of any donations we receive for audit or legal purposes, for example we are legally required to keep information related to Gift Aid for six years. We may need to use your information to prevent fraud.
4.3 To provide you with information and support for any services, events, fundraising and campaigning activities or volunteering opportunities you sign up to
If you have completed a form to register or enquire about an event or activity, or to sign up to one of our campaigns, we will send you details about the event, activity or campaign and provide with support throughout. You can contact us at any time if you want to update your communication preferences or if you choose not to receive this information.
We will send information and support to you by post, phone, mobile messaging, email, social media, or any other channels for which you have provided your details. When you have asked for details of an event, we will send you information including, where relevant, ideas for fundraising and reminders on key information about the activity.
Where appropriate, we will use the information you provide to identify any help we can offer, specific to the activity you have signed up for and to provide necessary information to event organisers. Where this includes information about your health or other sensitive information, we will only use this information if you have consented to us doing so.
We may also receive information through event organisers or through third party websites such as JustGiving or Virgin Money Giving so we know you are fundraising for us.
4.4 To manage our recruitment
When applying for a role with The Lullaby Trust via our online recruitment portal and/or through a recruitment agency the personal data you provide as part of the recruitment process will only be held and processed for the purpose of the selection processes and in connection with any subsequent employment unless otherwise indicated. You will be asked to provide certain information including your name, contact details, employment history and qualifications. This information is mandatory in order to consider your application, communicate with you about your application and where successful, follow up with references or meet our statutory and internal monitoring and reporting responsibilities. We may also view social media profiles of applicants, such as LinkedIn, to the extent that it is relevant to your application. Unsuccessful applicant data will be held confidentially within the recruitment system for a period of 6 months before it is deleted in order that you can access and re-use data in future applications and we can respond to statutory reporting requests.
5.1 To send you marketing communications by email, mobile messaging, or direct message on social media, where you have agreed to receive this
Where you have provided an email, mobile phone number, or details of your social media profiles and consented to being contacted in this way, we will send you information by those channels – including by direct message through social media – covering ways to give or raise money for us, to campaign for us and to volunteer for us.
5.2 To contact you by phone and post
Where it is appropriate and relevant, and you have provided us with a telephone number or a postal address, we will occasionally call or write to you to tell you about ways to give or raise money for us, to campaign for us and to volunteer for us. We do this as we consider it is a legitimate interest to promote our charitable cause and communicate with you about ways you can support us. We will not contact you by phone for marketing purposes if your number is registered with the Telephone Preference Service, unless you have agreed to receive calls from us.
5.3 To manage your contact preferences
You can tell us to stop contacting you, or change the way in which we do so, by getting in touch with us – call 020 7802 3200 or email email@example.com. We will keep a record of any requests to stop receiving marketing from us to ensure that we do not communicate with you in the future, unless you tell us you want to hear from us again.
5.4 To make sure we speak to you in way that is relevant to you, and to understand our supporters more broadly
We try to ensure that our communications are as effective as possible so that we make the best use of the money we spend on them. This means communicating with people in different ways, appropriate to them.
On occasion, we will use information about how you have interacted with us previously, for example the record of your previous donations to us and the type of activity you have been involved with, to tailor our communications with you about future activities. We will also use information about how you use our website or interact with our emails so we can make them more effective. For example, we use the third party provider Google Analytics to gather this information.
In certain circumstances we will use information about you from publicly available sources such as online registries, websites, media or social media, or personal introductions in order to understand more about your interests and preferences so that we can better tailor our communications – telling you about the things you are likely to be interested in or letting you know of ways to fundraise with us which is relevant to you. We may do this by looking up such information as your career information, peer networks, listed directorships, demographic information, ability to donate, interests or other information.
External data sources include publicly available information such as Companies House, Charity Commission and other charity registers, Electoral Roll, reputable newspaper articles, publications, company websites and biographies on professional networking sites as well as geographic and demographic information based on your postcode. This allows us to segment our database and gives us a better understanding of our supporters.
It also helps us to make appropriate requests to supporters who may be able and willing to give more than they already do. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would.
We will analyse data from our database so that we can understand our supporters. We may also use broad demographic information such as statistics and analysis from third parties to better understand how our own supporter base compares to the general population. This helps us to decide who to send our communications to and is useful to ensure the communications you receive are relevant to you.
If you would prefer we didn’t use your information in the ways listed above, then you have the right to tell us to stop by getting in touch with us call 020 7802 3200 or email firstname.lastname@example.org
5.5 To target our digital and social media marketing
On occasion, we will use the information you provide us to target our digital and social media advertising effectively. This could include securely providing contact details such as your name and email address to digital advertising networks or social media companies such as LinkedIn, Instagram, Facebook, Google, SnapChat and Twitter. For example, we may use your information to enable us to display adverts to you, or to potential supporters who have similar characteristics to you
Any information we share with social media companies will be shared in an encrypted format and will not be used for their own purposes. You can stop your information being used for this by contacting us.
Where you have asked us not to use your information for targeted digital advertising, you may still see adverts related to The Lullaby Trust. This is because the social media site or advertising network may select you based on information they hold, such as your age and location, or websites you have visited, without using information that has been provided by us.
You can control the kind of advertising which you see through the relevant social media site:
5.6 Use any images, videos of, or other information you tell us about something you have done for The Lullaby Trust
If you share information about the fundraising or campaigning activities you have done for us, or your personal experiences, by post, email or over social media, we may want to use this to help us promote our events and activities in the future. We will obtain the necessary consent to use this information.
6. What we do if you choose to tell us about your experience of sudden and unexpected death of a baby or young child
Where you have provided information about your experience of sudden and unexpected death of a baby or young child, including through a survey, focus group, questionnaire, or when we are talking to you by phone or email, we will, if it is appropriate for you for us to do so, explain what the information will be used for and whether it will be held anonymously or not. If the information will be held in a way that could be connected to you personally, we will ask your consent to store and use what you tell us.
We will use this information for the purposes explained to you at the time of collection. For example, to better understand the issues that are important to our supporters which helps shape our communications and activities. We may compare statistics related to our supporters to information about the general population, to help our understanding.
Where you provide more detailed information we may want to use this in our communications including PR and media activity, digital and social media, campaigning, fundraising materials and internal communications, to help us raise awareness of sudden and unexpected death in infancy or childhood. We would never use your story without obtaining your consent first.
We will never share your information with third parties for their own purposes, unless this is explained to you at the time we collect your information and:
- You give us your consent to
- We have a legitimate interest to do so, for example sharing information with regulators to protect our rights, property and safety, or the rights, property and safety of you or others; or
- We are legally required to do so. For example, we receive a court order requiring us to share information.
We may share your personal information with other entities in our group if we are satisfied that we have a legitimate business interest to do so or if you have given your consent to the sharing.
We also use suppliers known as ‘data processors’ to process your personal information on our behalf, for example, to send out mailings or process payments. When enlisting the services of such suppliers we ensure that they are under a contractual obligation to only use your information in accordance with our instructions and for no other purposes.
When you are using our secure online donation / shopping pages you are going through to a partner company and the information you give to such partner company, such as your credit card number and contact information, is provided to them so that the transaction can take place.
The data that we collect from you may be transferred to, stored at and processed at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff, operating outside the EEA who work for us. In those circumstances, we will make sure that adequate levels of privacy protection, in line with UK data protection law, are in place. These safeguards will usually be contractual and/or the result of a European Union decision which allows the transfer (such as a US organization that is certified under the EU-US Privacy Shield Framework).
We will hold your information for only as long as is necessary from the end of your relationship with the charity in accordance with our Data Retention Policy. In some circumstances, this will be shorter. For example, information related to unsuccessful job applications who we interview are destroyed after 6 months. In some circumstances, this will be longer, for example, pension information of former employees. If you would like to know how long we will hold any specific information, then please contact us and we can provide further details.
We ensure that there are appropriate technical and organisational controls (including physical, electronic and managerial measures) in place to protect your personal details. For example our online forms are always encrypted and our network is protected and routinely monitored.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). If you want to access your information, send a description of the information you want to see and proof of your identity by post to The Lullaby Trust, Audley House, 13 Palace Street London, SW1E 5HX. We do not accept these requests by email so we can ensure that we only provide personal data to the right person. We will endeavour to respond fully to all requests within one month of receipt of your request, however if we are unable to do so we will contact you with reasons for the delay.
- Ask us to correct personal information that we hold about you which is incorrect, incomplete or inaccurate.
- Ask us to erase your personal information from our files and systems where there is no good reason for us continuing to hold it.
- Object to us using your personal information to further our legitimate interests (or those of a third party) or where we are using your personal information for direct marketing purposes.
- Ask us to restrict or suspend the use of your personal information, for example, if you want us to establish its accuracy or our reasons for using it.
- Ask us to transfer your personal information to another person or organisation.
Contact us on 020 7802 3200 or email email@example.com if you have any concerns.
If you have given your consent to us processing your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our Data Retention Policy, we will dispose of your data securely.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
We may update this Policy to reflect changes in how we use your information. You may wish to check this Policy each time you provide The Lullaby Trust with your information. Where appropriate, we will provide you with notice of any significant changes to how we use your information. This Policy was last updated in May 2018.
Our Cookies Policy
This Policy explains:
- What is a cookie?
- Types of cookies
- Categories of cookies we use
- What information do we collect using cookies?
- Cookies set by third parties
- How do I manage my cookie settings?
- Updates to this Policy
If you have any questions about our Cookies Policy, please call 020 7802 3200, email firstname.lastname@example.org or write to The Lullaby Trust, Audley House, 13 Palace Street
London, SW1E 5HX or email.
Cookies are small text files that are automatically placed onto your device via the browser (e.g. Microsoft Internet Explorer, Apple Safari, Google Chrome or Firefox) that you use to access a website that you visit. They are widely used to improve the performance of websites, for saving different options and to provide website owners with information on how their website is being used.
There are broadly four reasons why a cookie might be stored on your device when visiting The Lullaby Trust’s website:
- Cookies that make the website work properly for you and enable you to make use of the secure online services that we provide
- Cookies that collect data about your use of the website which are then anonymised and used to help us improve our online services
- Cookies that remember your preferences and make the website easier for you to use
- Cookies that are placed by third party services we make use of to enhance the information we present online. We have no control over these third party cookies.
There are two broad types of cookies – ‘first party cookies’ and ‘third party cookies’:
First party cookies are cookies that are served directly by the website operator to your computer, and are often used to recognise your computer when it revisits that site and to remember your preferences as you browse the site. Basically, these are our cookies.
Third party cookies are served by a service provider on behalf of the website operator, and can be used by the service provider to recognise your computer when you visit other web sites. Third party cookies are most commonly used for web site analytics or advertising purposes.
In addition, cookies may be either ‘session cookies’ or ‘persistent cookies’. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached. We use both session and persistent cookies.
- Strictly Necessary Cookies – These cookies are essential for you to be able to use and move around website or for you to use certain features: e.g. adding items to a shopping basket or remembering items in a shopping basket if you revisit the website.
- Performance Cookies – These cookies collect information about how you as the viewer makes use of the website: e.g. which pages you visit most. These cookies do not collect information that personally identify you as a viewer.
- Functionality Cookies – These cookies remember choices made by you or aspects of your interaction with our website to enhance your experience during your visit to our website. These cookies are also used to remember a user’s preferences for a font size, or customisable parts of a web page: e.g. language, appeals visited or user’s location.
- Targeting cookies i.e. Third Party Cookies and Cookies used for Advertising – These cookies collect information if you decide to share a page from the website or if you use social media sites: e.g. Facebook, etc., These may track how you interact with our website which then shows you relevant content elsewhere on the internet. These may also be used to choose the advertisements that are displayed to you on our website and other websites
We may collect some, or all, of the information available from cookies when you visit our website, depending on how you use it. We monitor how people use our website so we can improve it. We collect this information anonymously.
However, you can choose to use our website anonymously without giving us any information. Please see ‘Changing your cookie preferences’ below.
- the areas of the website you visit;
- the amount of time you spend on the site;
- whether you are new to the site, or have visited it before;
- the country, region, city and/or borough associated with your IP address or device;
- how you came to our website – for example, through an email link or a search engine;
- the type of device and browser you use;
- how you use the website and the quality of your experience – for example we may track your bandwidth when viewing videos;
- how you interact with our donation and sign up forms – for example what you select as your communication preferences; and
- any error messages that you receive on the site
Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously; we don’t share this information.
If you go on to a page on our website that contains embedded content, for example YouTube, you may be sent cookies from these websites.
Our website also contains embedded “share” buttons to enable users of the site to easily share articles with their friends through a number of popular networks, for example, Facebook and Twitter. These sites may set a cookie when you are also logged in to their service.
We do not control the setting of these cookies, so we suggest you check the third party website for more information about their cookies and how to manage them.
The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie, and how to disable cookies altogether. Below is some helpful guidance about how to make these changes.
Please find below links describing how to do this on some popular browsers.
You can find out more about cookies and how to delete and control them on www.aboutcookies.org or click help in your browser menu.