Privacy Policy

The Trussell Trust is a data controller registered with the UK Information Commissioner’s Office registration number Z279027X.

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 Lead. If you have any questions regarding our Privacy Policy, please email [email protected].

This privacy policy relates to personal information that the Trussell Trust, and its subsidiaries, collects and uses. In this policy ‘we’ means both the charity and its subsidiaries trading on its behalf who are: Trussell Trading Limited (ZB264431), a registered company in England and Wales: number: 13310114, Trussell Retail Limited (ZB558699) a registered company in England and Wales: number 14870045.

The charity and each of these subsidiaries may collect and decide for themselves how to use your personal information. The legal phrase that’s used to describe an organisation that makes these decisions is ‘data controller’.

The Trussell Trust is a data controller registered with the UK Information Commissioner’s Office registration number Z279027X.

The Trussell Trust supports a network of over 1,300 food bank centres throughout the UK which together make up the Foodbank Network. With the exception of Brent Foodbank, food banks within the Trussell Trust Foodbank Network are independent charitable organisations collecting personal information for their own use and therefore have their own privacy policies and are registered separately with the Information Commissioner’s Office.

→ How and when we collect personal information
→ The personal information that we collect
→ Our legal basis for processing personal information
→ Why we collect personal information
→ Sharing personal information
→ International transfers of personal data
→ Cookies and aggregate information collected from our website
→ Your rights
→ How long we keep your personal information
→ Changes to this policy
→ Making a complaint to the Information Commissioner’s Office

How and when we collect personal information

We may collect your personal information from you directly when you:
1. Communicate with us for any reason, by post, telephone, text, email, social media, or via our website
2. Fundraise for, or donate to the Trussell Trust or one of our shops
3. Donate food to a food bank or are referred to a food bank for support
4. Take campaign actions on our behalf
5. Participate in a survey or research
6. Work or make an application to work or volunteer with us
7. Agree to help us promote our cause
8. Take part in our participation work as an expert by experience to advocate for change
9. Interact with us as a supplier, contractor, consultant, or in any other capacity.
10. Visit our offices

We may also collect personal information about you from other organisations. For example, this might be from a food bank within the Foodbank Network, a referral agency like a doctor’s surgery, occupational health, or from your current or past employer. We carry out research on existing and potential supporters who we believe may have the interest and ability to support our work in a further capacity, (see section ‘Developing relationships with Supporters’ below).

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 food bank within the Foodbank Network relating to your circumstances and why you used a food bank
• Information that you provide when you donate food at a food bank
• Information you provide when you correspond with us
• Information you provide when interacting with our websites
• Financial information that you provide to us
• Other information about you from publicly available sources, like the electoral roll
• 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
  • information about your race, ethnicity, and sexual orientation
  • details of unspent criminal convictions.

For visitors to our office at Ashfield Trading Estate, SP2 7HL in Salisbury:

• your name
• your physical location (i.e. your attendance at the office)
• video recordings of your movement around some of areas of the premises

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 use food banks, people who support the Trussell Trust and/or food banks in the network, job applicants, and volunteers for a number of reasons.

Supporting the Foodbank Network

Food banks in our network operate as separate organisations under franchise. We collect personal information from staff, trustees, and volunteers at food banks to be able to support them in their day-to-day operations. Our legal basis for this is performance of a contract (meeting obligations under franchise), and legitimate interest.

Assisting people that use food banks

We collect personal information about you if you visit a food bank, or via an organisation that refers you to a food bank. 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 food banks within our network 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.

Developing relationships with supporters

The Trussell Trust’s work is made possible by the generosity of our supporters. We need a good understanding of our supporters so that we can communicate with them effectively and appropriately.

We may research our existing and prospective supporters to develop a better understanding of their interests and actions in support of our work. Sometimes we use specialist agencies who act on our behalf to enable us to tailor and target our events and communications effectively to people most likely to be interested. We may also use the research to profile our financial supporters in order to make appropriate requests to people who have the means and the desire to give more.

We may use third-party agencies to undertake research for us to identify companies and individuals within them with whom we might build corporate partnerships. We may obtain information about a person’s professional credentials, like their job title and email address in order to contact them.

We use the services of third parties to:

1. Cleanse and match data using databases (such as the Gone Away Suppression File, GAS Reactive and The Bereavement Register) to ensure our personal data is as accurate and up to date as possible
2. Analyse the personal data we hold in order to segment our supporters and enable us to communicate more effectively with them based on a person’s interests and previous interactions with us.
3. Undertake research of existing and prospective supporters using publicly available data sources (such as the Electoral Register, Companies House, public social media accounts such as LinkedIn, company websites, political and property registers, and news archives) to supplement the personal data we already have. This enables us to better understand areas of our work which existing or prospective supporters may be interested in supporting.

You have the right to opt-out from this activity at any time. If you would prefer us not to use your personal information in this way, please email us at [email protected].

Processing donations

If you kindly make a food donation to a food bank, a financial donation to us, or donate goods to one of our shops, we will 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.

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) with the food bank, 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 campaign actions and share personal information with us, we may use that information to support the campaign 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. If you sign up to a campaign which involves targeting MPs, we may forward your email, including your contact information to an MP. With your consent we will share your contact information with the nearest food bank in the Trussell Trust Network.

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 research

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.

Youth Participation

We work alongside other youth involving organisations to support young people with experience of poverty to influence decision makers and create a programme of youth engagement to increase understanding of the impact of poverty and why people are forced to use food banks.

Our work with young people involves collecting and using personal information from participants who act as ambassadors for change, influence decision makers, increase understanding about why people are forced to need food banks and the actions people can take to change this. Personal information may be collected directly from the young person participating in the project, or from schools, food banks, parents and guardians, or other professionals working with young people.

The type of personal information we may collect includes:

• Contact information
• Additional support needs
• Media including photos and videos

Our legal basis for processing personal information for this project is consent (including where appropriate explicit consent), our legitimate interest, or our legal obligation. A young person (over the age of 13) is considered able to provide their informed consent under UK law, but we will always seek consent from their parent or guardian wherever appropriate.
Please see our youth participation page for more information about how we collect and use personal data for our Youth Participation Project.

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 our Intranet or by contacting [email protected]

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. A full privacy statement for job applicants is included in the recruitment pack.

Volunteer Management

If you apply to be a volunteer with the Trussell Trust your personal information will be used to process your volunteering application. Where you apply to volunteer at a food bank in our network, for example via our website, your data will be passed to the appropriate food bank organisation within the network.

Your personal information is held by that food bank as a separate data controller in line with their own data protection and privacy policies. For more information about how the food bank you volunteer with looks after your information, or to exercise your rights, you should speak with your team leader or supervisor. You can also contact [email protected] and we will pass on your enquiry.

The Trussell Trust and some of the food bank organisations with our network use volunteer management systems provided by our third-party processors, Access Group (Assemble), and Workday (Peakon) who provide administration and technical support.

Where you access an account linked to your food bank within our volunteer management systems, the Trussell Trust will keep you up to date on opportunities across the Trussell Trust and the Network, as well as giving you chance to share your feedback and tell us more about your experience of volunteering. 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.

The Trussell Trust uses statistical and aggregate information about volunteers in the food banks to help develop and improve people’s experiences of volunteering, for equalities monitoring purposes, and to evidence the impact of volunteering across the network.

Undertaking safeguarding activities including DBS checks

When necessary, we process relevant personal information about employees and volunteers for safeguarding purposes. This might include undertaking DBS 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 Charity Commission and Companies House.

Health, safety and security

We will process limited personal data about attendees to our office in Salisbury whether those attendees are employees, contractors, volunteers, or members of the public. We do this to ensure the health and safety of people inside the building as well as the security of the building and its contents. Our legal basis for this processing is our legitimate interest.

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 personal information with third-party organisations who will process it on our behalf (for example a mailing house, our website administrator, or a printing supplier). We select these organisations carefully and put in place data processing agreements which require that they comply with data protection legislation.

We may also 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.

We may also share your personal data with other food banks in the Foodbank Network, who will use the personal data for the purposes described in this privacy notice.

In some situations, a charity in the Foodbank Network may transfer some or all its assets as part of a merger or acquisition. If another charity acquires the franchise, they will hold substantially all the same information and will assume the rights and obligations with respect to the personal information as described in this privacy policy.

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.

We might share your information across different parts of Trussell Trust for research, analysis and marketing.

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 [email protected]

Cookies, web beacons and other storage technologies used on our website

We use cookies and other tracking technologies to store information about how you use our sites. A cookie is a piece of data stored on a user’s computer to remember information about you and create a profile of your viewing preferences. Your profile is used to tailor your visit to our website, make navigation easier, and direct you to information that best corresponds to your interests. We require your consent to place non-essential cookies on your device. You can change your cookie preferences by selecting the button in the bottom left corner from any page on our website. View our cookies policy.

Analytics cookies

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a way so that it can not be used to identify you), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf and does not use your information for any other reasons. For further details, please see the about Hotjar section of Hotjar’s support site.

We use Google Analytics who act on our behalf as a processor to collect aggregate information from users. This information includes browser type, referring/exit pages, platform type, date/time of visit, number of clicks, error pages, and number of unique visits. This information is not linked to personally identifiable information provided by users. We use it to analyse visitor trends and use of our website, administer the website and to gather broad demographic information of our website users. For additional information about Google’s privacy practices, please see Google’s privacy policy.

We use Webtrends Optimise who act on our behalf as a processor to provide testing (including AB testing and multivariate testing) and personalisation to improve our website visitors’ digital experience. Webtrends Optimize uses cookies and other technologies to allow us to compare two or more versions of the website, conduct baseline analysis and test multiple variables on a page at the same time. We use it to analyse activity on a page and across the website and improve progression to the next step in a user’s journey. Information collected includes a device’s IP address and a randomly generated GUID (unique identifier). For additional information, please see Webtrend’s privacy policy.

You can opt in or out of using analytics cookies by selecting the button in the bottom left corner from any page on our website.

Marketing Cookies

We use the Meta Pixel and Conversion Application Programme Interface (CAPI) to help us identify when you have responded to one of our adverts on Meta products. This data is also used to assess the overall performance of our advertising campaigns.

If you consent to our use of marketing cookies, when provide your name or email address on our website we will securely share this information with Meta to match your profile, identify when you take an action on our site such as when you make a donation, optimise our campaigns, and target other users with similar profiles to yours. Meta process your data as a joint controller with us and we have entered into a UK Controller Addendum which sets out our responsibilities for compliance with the obligations under the UK GDPR with regard to the joint processing. For additional information about Meta’s privacy practices, or to exercise your rights, please see Meta’s privacy policy.

You can opt in or out of using marketing cookies by selecting the button in the bottom left corner from any page on our website.

Your rights

If you no longer wish to receive communications about the Trussell Trust, the work that we do and how you can help us, please contact [email protected] or click on the link within emails to unsubscribe to further emails .

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 [email protected]. 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 a food bank	Your personal information is stored in a secure database for six years from the date you last accessed support.
People who donate food at a food bank	Where you provide personal information alongside your food donation, your personal information is stored in a secure database for three years from the date you last donated.
People signing up to a campaign	Your personal information is stored in a secure database for up to two years from the date you last took an action.
Financial donors	Your personal information is stored in a secure database for seven years from the date you last donated.
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.
Survey and research participants	Twelve months after survey is completed. Then results are anonymised.
Promoting our work through sharing your story, photographic images and videos	Up to five years after consent was obtained.
Representatives of referral agency partners	Two years after the date of the last referral made.
Representatives of food banks in the network	Twelve months after a person ceases to be connected to a food bank.
Complainants	Six years if the complaint is upheld, three years if the complaint is not upheld.
Employees	Seven years after employment ceases.
Website users	See our cookie policy

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 on 23 November 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.