Under the General Data Protection Regulations we must have a ‘legal basis’ for any processing of personal information. This section outlines the legal bases on which we process information about our supporters and volunteers.

Legal Obligation

We have a legal obligation to collect, process and store information about our supporters for the purposes of processing Gift Aid claims, and we must keep this information for six years after a Gift Aid claim has been made to HMRC.

We have a legal obligation to collect and process information about any criminal convictions or pending investigations of anyone interested in volunteering for us to allow us to safeguard the people we support, and ensure that any risks identified are appropriately managed.

Under GDPR, we also have a legal obligation to keep your personal information up to date by checking against third party sources. For example we may check your details against the Post Office National Change of Address register to check if you have moved.


Legitimate Interest

We have a legitimate interest to process personal information about our supporters in the following circumstances:

  • For providing you with information, products or services you have requested or information relating to the product or service to which you have signed up. For example, if you have signed up to take part in Sleep Out we will use your information to send you communications about Sleep Out
  • For processing your donation or supporting your fundraising, including sending you a communication to wish you luck with your fundraising event
  • For keeping a record of your relationship with us, so we don’t forget what support you’ve previously given us
  • For dealing with and responding to any requests, complaints or queries you make to us
  • For understanding how we can improve our communications, products and services through data analysis or market research
  • For managing our fundraising events
  • For analysing the success of our fundraising activities and identifying ways to improve our fundraising activities
  • For analysis and profiling of our supporters, using information we already hold
  • For administering and improving our website by analysing statistics and data from our website analytics tools
  • For displaying our online content to you in a format that suits the device you are using, for example if you are using a mobile device to access our website
  • For contacting you if you enter your details into one of our online forms and you don’t submit or complete the form to see if you are having problems completing the form and whether we can provide any help
  • For conducting training and quality assurance processes

We only rely on legitimate interests where we have taken your rights into account, considered how intrusive the processing is and conducted a balancing test to ensure that your rights do not outweigh our rights to process the data.


We operate an ‘opt-in’ policy for our communications which means that we will only send you marketing communications where we have explicit consent to send them to you, except where we have a legitimate interest to communicate with you about a specific activity.

Outside of any legitimate interests, we will seek explicit consent from you to send you communications by email, post, SMS and phone. You can withdraw your consent at any time by emailing [email protected] or calling 029 2023 9585 and asking for the fundraising team. You will also be given the opportunity to withdraw your consent whenever we send you marketing communications.