GDPR and Privacy Policy

Moray Food Plus is a data controller registered with the UK Information Commissioner’s Office registration number ZA465913. Keeping your personal information safe is very important to us.  We are committed to complying with privacy and data protection laws and being transparent about how we use personal data.

We have policies, procedures, and training in place to help our team understand their data protection responsibilities and follow the principles of data protection.

We have a nominated member of staff who serves as our Data Protection Officer. If you have any questions regarding our Privacy Policy, please email admin@morayfoodplus.org.uk. This privacy policy relates to personal information that Moray Food Plus collects and uses.

How and when we collect personal information

We may collect your personal information from you directly when you:

  • Communicate with us for any reason, by post, telephone, text, email, social media, or via our website
  • Fundraise for, or donate to Moray Food Plus
  • Donate food to Moray Food Plus or are referred to Moray Food Plus for support.
  • Participate in a survey or research.
  • Work or make an application to work or volunteer with us.
  • Take part in our participation work as an expert by experience to advocate for change
  • Interact with us as a supplier, contractor, consultant, or in any other capacity.

We may also collect personal information about you from other organisations. For example, this might be from an out of area food bank, a referral agency like a doctor’s surgery, occupational health, or from your current or past employer.

The personal information that we collect

We only collect personal information that we genuinely need.

This may include:

  • Contact details such as name, address, email address, and phone numbers.
  • Date of birth
  • Gender
  • Nationality
  • Any information that you give us or a third-party agency relating to your circumstances and why you used Moray Food Plus.
  • Information that you provide when you donate food at a food bank.
  • Information you provide when you correspond with us.
  • Financial information that you provide to us as part of our Money Advice Service.
  • Media including photos and videos

      • For job and volunteer applicants:

    • your bank account details and tax and residency status
    • references from previous employers or educational institutions
    • contact details for you, and any next of kin
    • qualifications
    • information concerning your health and medical conditions
    • details of unspent criminal convictions.

Our legal basis for processing personal information

Our legal basis for processing personal information is usually for our legitimate interests, if we have your consent, for the performance of a contract or to meet our legal obligations. We may collect and use your personal data if it is necessary for our legitimate interest and so long as its use is fair, balanced, and does not unduly impact your rights.

We will ask for your consent to send you marketing emails and text messages. You can withdraw consent for this at any time.

Usually, we will only process sensitive personal data if we have your explicit consent. In extreme situations, we may share your personal details if we believe someone’s life is at risk.

We may process personal information because it is necessary for the performance of a contract to which you are a party (or to take steps at your request prior to entering a contract), or because we are legally obliged to do so (for example to meet employment or charity laws).

Why we collect personal information

We collect and use personal information about people who Moray Food Plus services, people who support Moray Food Plus, job applicants, and volunteers for a number of reasons.

Assisting people that use food banks

We collect personal information about you if you use a Moray Food Plus service, or via an organisation that refers you to Moray Food Plus. Our legal basis for using this information is our legitimate interest, and where appropriate your explicit consent. We use this information to respond to your need for help, and ensure that we are providing help when and where it is most needed. We work with the Independent Food Aid Network (IFAN) and The Moray Council to use anonymised statistical data (information that cannot be used to identify you) to campaign at a regional and national level to challenge the structural issues that lock people into poverty.

Processing donations

If you kindly make a food donation to Moray Food Plus, a financial donation to us, we may use your personal information to collect your donation and maintain a record of our supporters. Our legal basis for using your personal information for this purpose is to fulfil our legal obligations, and our legitimate interest in meeting our fundraising objectives. We are legally required by HMRC to collect some personal information if you choose to gift aid your donation.

Donations using PayPal

Moray Food Plus is a Scottish Charitable Incorporated Organisation (SCIO) SC042997 Page 3 of 4 Moray Food Plus uses PayPal to accept donations via the Moray Food Plus website. PayPal (Europe) S.a.r.l. et Cie, S.C.A. and PayPal Inc. are the data controllers for the Personal Data collected and processed in connection with Personal Data obtained when you visit their website, during the registration and application process, and throughout your continued use of the services in the European Economic Area (EEA), the United Kingdom (UK), and Switzerland. Their full Privacy Policy can be found here.

Dealing with complaints and appeals

If a complaint is raised with us, we will process any personal information provided to manage and resolve the complaint or appeal. This may include sharing relevant information (including contact information) within Moray Food Plus, third-party agency, or person that the complaint has been made about. Our legal basis for using personal information for this purpose is legitimate interest.

If you make a complaint about an individual and this forms part of their personal data and the individual requests access to it, we will seek to remove personal information identifying you first. In some situations, we may be obliged to provide your personal data. We will seek your consent before providing the information but may be required to provide this even if you do not consent.

Promoting our cause

We work alongside people who have lived experience of poverty and destitution to raise the profile of our cause. We will use personal information that you share with us if you agree to help us promote our cause. This might include photographs and videos. For example, we may use your information in case studies and stories that we publish or share with the media. We will seek to anonymise your information wherever possible and will only use your information for this purpose if you have given your consent for us to do so.

Campaigning for change

If you choose to take part in one of our projects and share personal information with us, we may use that information to support the project and make our collective voices heard. We may invite you to take part in future activities based upon your location and previous actions that you have taken. Our legal basis for using your personal information for this purpose is for our legitimate interests and where appropriate your consent.

Carrying out surveys and consultation work

If you choose to take part in one of our surveys, we will use the personal information that you provide to process the results of the survey and undertake analysis. We may use a university or other academic institution or organisation to undertake an analysis of survey responses. Survey results are anonymised before being shared or published. Our legal basis for using your personal information for this purpose is for our legitimate interests, or where appropriate your consent.

Employee administration and development

We will process personal information of our employees to fulfil our contract with them and to meet our legal obligations as an employer. This includes payroll processing and the provision of training. We are required by law to share some financial information with the HMRC. We may also need to share some personal information with other organisations (for example solicitors or pension providers). A full privacy statement for employees is available from Moray Food Plus on request by emailing admin@morayfoodplus.org.uk.

Employee recruitment

We may collect your information in a variety of ways. For example, data might be contained in application forms, CVs or résumés, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment, including online assessments. The organisation may also collect personal data about you from third parties, such as recruitment services, references supplied by former employers, information from employment background check providers and information from criminal records checks when applicable to the role.

We need to process your data prior to entering into a contract with you, to meet our legal obligations, or for our legitimate interests. We will not use your data for any purpose other than recruitment. 

Volunteer Management

If you apply to be a volunteer with Moray Food Plus your personal information will be used to process your volunteering application. Our legal basis for using your personal information in this way is our legitimate interest, where appropriate your consent, or because we have a legal responsibility to keep it. Moray Food Plus uses statistical and aggregate information about volunteers to help develop and improve people’s experiences of volunteering, for equalities monitoring purposes, and to evidence the impact of volunteering.

Undertaking safeguarding activities including PVG checks

When necessary, we process relevant personal information about employees and volunteers for safeguarding purposes. This might include undertaking PVG and other checks to identify any criminal and other activity we need to be aware of. It may be necessary to share some personal information with relevant authorities such as the police. Our legal basis for this processing is to meet our legal obligations.

Processing expenses

We will use your personal information including your bank account details to process expense claims. Our legal basis for using your information for this is for the performance of a contract.

Governance

We process relevant personal information about existing and potential trustee members for governance purposes. This might include checks to identify any criminal and other activity we need to be aware of to ensure that we select appropriate trustees. Our legal basis for this processing is to meet our legal obligations with the Office of the Scottish Charities Register (OSCR).

Sharing personal information

We will only share your personal information where we need to, where someone’s life is at risk or we are required to do so by law. We may share your information with our bank to process a payment; our professional advisers (such as our legal advisers) where it is necessary to obtain their advice; and our IT service providers and data storage providers. Where required, we will process personal information to comply with our legal obligations. In this respect we may share your personal data to comply with subject access requests; tax legislation; for the prevention and detection of crime; and to assist the police and other competent authorities with investigations including criminal and safeguarding investigations.

International transfers of personal data

We may need to transfer some personal data to the third parties described above who are located outside of the UK. In such cases, we will take appropriate measures to ensure your personal data remains protected. If the organisation is based outside of the UK and in a country that is not protected by an adequacy decision (providing an adequate level of data protection) we will take appropriate safeguards such as implementing the ICOs International Data Transfer Agreement (IDTA). If you have any questions or need more information regarding international transfers of your personal data, please contact us at admin@morayfoodplus.org.uk.

Your rights

If you no longer wish to receive communications about Moray Food Plus, the work that we do and how you can help us, please contact admin@morayfoodplus.org.uk. You also have the right to:

  • Ask us for a copy of your personal information. There are some exemptions, which mean you may not always receive all the information we process.
  • Tell us to change or correct your personal information if it is incomplete or inaccurate.
  • Ask us to restrict our processing of your personal data or to delete your personal data if there is no compelling reason for us to continue using or holding this information.
  • Receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you, so that you can send it to another organisation.
  • Object, on grounds relating to your specific situation, to any of our processing activities where you feel this has a negative and disproportionate impact on you.

    • For all requests please contact us at admin@morayfoodplus.org.uk. We will respond to any request within 28 days. Please note that we may be entitled to refuse requests where exceptions apply; for example, if we have reason to believe that the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Privacy Policy.

    How long we keep your personal information

    We will hold your personal information only for as long as is necessary. We will not retain your personal information if it is no longer required. In some circumstances, we may legally be required to retain your personal information, for example for finance, employment, or audit purposes.

    A summary of our retention periods is available below:

    People who need help from Moray Food Plus Your personal information is stored in a secure database for 12 months after which point data will be anonymised.
    People who donate food to Moray Food Plus Where you provide personal information alongside your food donation, your personal information is stored in a secure database for three years.
    Financial donors Your personal information is stored in a secure database for seven years.
    Volunteers (inc. people engaged in our participation projects) If your application is unsuccessful, or if you stop volunteering, your information will be held for twelve months unless we’re obliged to keep it longer. In which case, we only keep necessary information.
    Clients supported by Resilience Team Your personal information is stored in a secure database for six years from the date you last accessed support.
    Clients supported by Money Advice Team Your personal information is stored in a secure database for six years from the date you last accessed support.
    Promoting our work through sharing your story, photographic images and videos Five years after consent was obtained.
    Representatives of referral agency partners Two years after the date of the last referral made.
    Complainants Six years if the complaint is upheld, three years if the complaint is not upheld.
    Employees Seven years after employment ceases.

    Changes to this policy

    This Privacy Policy may change from time to time. We recommend that you visit this webpage periodically to keep up to date with the changes in our Privacy Policy.

    This policy was last updated 05 June 2023.

    Making a complaint to the Information Commissioner’s Office

    If you are not satisfied with our response to any query you raise with us, or you believe we are processing your personal data in a way that is inconsistent with the law, you can complain to the Information Commissioner’s Office whose helpline number is: 0303 123 1113.