As someone who interacts with Twins Trust you have the right to be informed of what we do with your data.  We’re committed to protecting and respecting your privacy.  This privacy notice tells you what to expect when Twins Trust collects personal information.  It also explains when and why we collect this information, how we use it, the conditions under which we may disclose it to others, how we keep it secure and what rights you have in relation to the data we hold about you.

Please read the following carefully to understand our practices regarding your personal data.  By visiting https://www.twinstrust.org you are accepting the practices described in this policy.

Twins Trust is a registered charity number (Eng & Wales ) 1076478, (Scotland) SC041055, and a registered company number 3688825.

How can you contact us? 
Notification of Change of Privacy Notice 
Use of cookies 
How to control or delete cookies 
How do we collect your information? 
What information do we collect? 
What is the purpose of the processing that Twins Trust does of the data it collects? 
Your choices 
Do we process sensitive personal information (special category data)? 
How do we protect your personal information? 
How can you update your Contact Preferences or Update the Information we hold about you? 
What other Data Protection rights do you have? 
Making a Complaint 
Right of Access / ‘Subject Access Request’ 
Right of Rectification 
Right of Erasure / Right to be forgotten 
Right to Restrict Processing 
Right to Object 
Why are we allowed to process your personal information? 
How will we disclose the information we have collected to outside parties?
Children’s Data 
Other Websites 
Emails Terms of Use 
Your Credit or Debit Card Information 

How can you contact us? 
If you have any questions or concerns regarding our Privacy Notice or our processing of your personal information, please contact: 

Twins Trust Data Protection Officer
Manor House
Church Hill
Aldershot, Hampshire
GU12 4JU

Email: data@twinstrust.org or contact our enquiries team by email at enquiries@twinstrust.org, or by telephone at 01252 332 344 (or 00 44 252 332 344 if you are calling from outside the UK). 

Notification of Change of Privacy Notice 
We may modify this privacy notice at any time, but if we do so, we will notify you by publishing the changes on this website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or via our magazine that is sent to members. If, after being informed of these changes, you do not end your association with Twins Trust, you will be considered as having expressly consented to the changes in our privacy notice. If you disagree with the terms of this notice, or any updated version of this notice, you may exercise your rights to end your association with Twins Trust at any time. This notice was last updated on 30 July 2019. 

Use of cookies 
A cookie is a very small text file that is placed on your hard drive by the server of a web page you visit. It is an individual label, which identifies you as a visitor. Twins Trust does not use cookies to collect personally identifiable information. Twins Trust does, however, use session cookies to: 

• Collect statistical data on visitor movement and use of our websites in order to help us optimise them
• Remember things like information you've entered on forms when you navigate away to other pages in a single web browser session
• Remember the order details that have been placed within a shopping basket
• Recognise that you are logged in to areas such as the Members only area
• Improve the user experience by integrating third-party social media tools and services

When someone visits www.twinstrust.org we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is processed in a way that does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. 

How to control or delete cookies 
You can delete cookies already on your computer or device at any time. If you choose not to accept cookies at all, you can still visit our website, however, when cookies are disabled, we cannot guarantee an optimum experience and there will possibly be content or functionality that is no longer available. Visiting the Help section within your browser should provide information on how to do this. For mobile devices you may need to refer to the product manual. 

For more information about controlling and deleting cookies please visit http://www.aboutcookies.org.uk/ and/or see the Twins Trust Cookie Policy.

How do we collect your information? 
We obtain information about you when you use our website, for example, when you contact us about Twins Trust services and courses, to donate, take out a membership, or if you register on the website to access free resources and/or receive one of our monthly newsletters. 

We may also receive information about you when you interact with third parties with whom we work. For example, if you’ve donated to us through a third-party website (such as JustGiving or Virgin Money Giving) and given them permission to share your information with us. 

What information do we collect? 
When we do collect information from you, either directly or from third parties we work with, this information may include: 

• name
• address
• email address
• telephone number
• contact preferences
• bank account details for setting up a regular direct debit
• credit card details for processing credit card payments
• employer details for processing a matching gift
• taxpayer status for claiming Gift Aid, and
• babies’ dates of birth
• website username and password (the password is stored in an encrypted format so we cannot access it) 

We may also collect and process information about your interactions with us, including details about our contact with you through email, post and telephone, and details of donations you make to us. In addition, we may collect and record any other relevant information you share with us about yourself, including your interests or your affiliations with other charities, community groups, or your employer, and pages that you have visited on our website. 

What is the purpose of the processing that Twins Trust does of the data it collects?

Click here for details of how data is processed. 

We may contact you for marketing purposes by email if you have agreed to be contacted in this manner. We will also send you service communications via email when you book a place on a course on our website, have donated, or taken out a membership. We may also use your information to analyse and improve the content and operation of our website, and where we are required by law to disclose or otherwise use your information.

If you have provided us with your postal address or telephone number, we may send you information about our work or other communications of the kinds described above by direct mail or contact you by telephone unless you have told us that you would prefer not to hear from us in this way. We provide information about how you can change your marketing preferences below. 

When we process your personal data, it will only be used for the purpose for which it was collected. If we wish to use that information for another purpose (for example, for a media call), Twins Trust will contact you with information about the further purpose and to gain consent and/or approval to do so. 

Your choices 
You have a choice about whether you wish to receive information from us. If you do not want to receive direct marketing communications from us about the vital work we do for families of multiples or the services Twins Trust offers, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information. 

We will not contact you for marketing purposes by email or phone unless you have given your prior consent. We will not contact you for marketing purposes by post if you have indicated that you do not wish to be contacted in that way. Please note that new registrants to the website will receive a copy of the (normally Member only) Multiple Matters magazine in the quarter after they have registered, unless it is indicated that you do not wish to receive anything by post. 

You can change your contact preferences at any time by: 

• visiting the website and clicking here after logging in
• emailing the Enquiries team at enquiries@twinstrust.org
• calling the Twins Trust Head Office on 01252 332 344

On the occasions that you have paid for a course or a membership, we will contact you by email, phone or post with information that is relevant to that service. Examples of this may include a phone call with late changes to a course, or renewal information for your membership that is due to expire. One of the membership benefits is to receive a monthly email about the season specific discounts that are a benefit of having a Twins Trust membership. While you have the option to choose not to receive these emails, you will still receive information about your Twins Trust renewal because this is necessary as part of the contractual agreement you have with Twins Trust. 

When you join the Twins Trust Membership scheme this has benefits for the individual joining, and the monies paid are viewed as a donation to Twins Trust that allows us as a charity to continue doing the work we do. We believe that it is not unreasonable as a charity for us to contact you about further donation opportunities via case studies, raffle and challenge events after you have committed to becoming a member, to help us secure further funds from our supporters. At any point, as a member, if you wish to update your contact preferences so that you only receive Membership notifications relevant to your membership subscription, you can do so by following the steps outlined above. 

To ensure that our communication with you is relevant and tailored to your background and interests, we may supplement what we know about you with information that is available to the public. This allows us to better understand your interests, preferences, and level of potential engagement and/or donation, so that we can contact you in the most appropriate way. The information we collect and process about you from publicly-available sources may include demographic information associated with your postcode or your address and an estimate of your age. We collect this information ourselves and may use third-party service providers from time to time. 

We process personal information for certain legitimate business purposes where the processing enables us to enhance, modify, personalise or otherwise improve our services / communications for the benefit of our customers. As a fundraising charity, we may gather information about you from publicly available sources – for example, Companies House, the Electoral Register and the media – to help us to understand more about you as an individual and your ability to support us. We may carry out wealth screening, a process which uses trusted third-party partners to automate some of this work. By doing this, we can focus conversations we have with you about fundraising and volunteering in the most effective way and ensure that we provide you with an experience as a donor or potential donor which is appropriate for you. You have the right to object to this, by contacting us at data@twinstrust.org

You are not required to provide personal data to us. Please note, however, that if you choose not to share your personal information with us, this will affect our ability to provide a service you may request. For example, we are unable to receive a donation from you if you do not provide your payment information. 

Do we process sensitive personal information (special category data)? 
Under data protection law, certain categories of personal information are recognised as sensitive, including health information and information regarding race, religious beliefs, and political opinions (‘special category data’). In limited cases, we may collect special category data about you. We would only collect special category data if there were a clear reason for doing so, such as where we need this information to ensure that we provide appropriate support when you participate in Twins Trust courses, or information needed to support and give understanding to a Helping Hands application. 

When special category data is collected, it is held securely and is only available to the specific people that need to access that information. Those specific people may be Twins Trust employees, or they may be selected third parties that we work with. 

For example, 

• When someone makes a Helping Hands application for support in the home, we will sometimes collect special category data and will need to share this information with the support practitioner that will be working with the family. This support practitioner is contracted by the Norland Agency, and there is a partnership agreement in place between Twins Trust and the Norland Agency for this support to take place. 
• When someone books on to an antenatal or parenting course, we may collect special category data about your pregnancy (such as fertility treatment that was received). This information may be passed on to a support practitioner who has a third-party contract with Twins Trust, and who will be running the course. All information that is given is stored securely within the Twins Trust network, and if any information is shared outside of this, there is an agreement in place for the data to be destroyed when no longer required. 
• When a family suffers from a bereavement, they may contact Twins Trust’s Bereavement Support Group (BSG). Due to the nature of the contact, potentially sensitive information will be shared with the BSG. This information is stored securely within the Twins Trust network and is not shared outside of this small network. 

How do we protect your personal information? 
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it if is reasonable and necessary to fulfil the need for which it was collected. As noted above, due to the nature of the Twins Trust charity, it is often necessary to keep information for an indeterminate period. This is because the circumstances under which you contact Twins Trust may recur later, and historical information is always beneficial. 

Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk. However, any payment card details (such as credit or debit cards) we receive on our website are passed securely to our payment processing provider according to the Payment Card Industry Security Standards. 

Internally at Twins Trust, we have restrictions in place that ensure that only people that need to access data can do so. As well having managerial and technological security of your data as described above, we also use encryption on financial data, and run staff awareness and training programs to ensure that all staff understands how to best protect your data. 

Some of our service providers and affiliated organisations lie outside of the European Economic Area (EEA). Therefore, sometimes we transfer your data outside the EEA. If we do, we ensure your data is processed only in countries that provide an adequate level of protection for your data or where the recipient provides safeguards, such as model contract clauses, binding corporate rules, or mechanisms like the EU-U.S. Privacy Shield framework. For a copy of such safeguards, please contact us at data@twinstrust.org

How can you update your Contact Preferences or Update the Information we hold about you? 
If you do not wish us to use your personal data for marketing purposes as outlined above, you can follow the 'Update your Email Preferences' section on the user profile update page on the website after logging in, or click on the 'Update Preferences' link in any email that you receive from Twins Trust. 

You can also change any of your contact preferences at any time (including telling us that you don’t want us to contact you for marketing purposes) by: 

• Indicating that you do not wish to receive our marketing emails by clicking the ‘unsubscribe’ link in at the end of our marketing emails; 
• Contacting us through our Enquiries team by email at enquiries@twinstrust.org, or by telephone at 01252 332 344 (or 00 44 1252 332 344 if you are calling from outside the UK), or by writing to us at: 

Data Protection Officer
Twins Trust
Manor House
Church Hill
Aldershot, Hampshire
GU12 4JU

• Entering your details on the Fundraising Preference Service (FPS) website and choosing ‘Twins Trust’ (Charity Number 1076478). This service is run by the Fundraising Regulator and allows you to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at https://public.fundraisingpreference.org.uk/ or by calling the telephone helpline on 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days of your request. 
If you have indicated that you do not wish to be contacted for marketing purposes, we will maintain your details on the database but mark your record in such a way to help ensure that we do not continue to contact you specifically for marketing. However, we may still need to contact you for administrative purposes, including (but not limited to): 
• Processing a donation you have made and any related Gift Aid; 
• Joining or Renewing Membership information; or
• Explaining and apologising where we have made a mistake. 

If your contact details have changed or you think any information we have about you is incorrect or incomplete, you can always update or correct the information we hold about you by contacting us through our Data Protection Officer at data@twinstrust.org, or by updating your details on our website after logging in, by clicking here.

What other Data Protection rights do you have? 
The following outlines the rights that you have, and how they can be exercised. 

Making a Complaint 
You can make a complaint or raise a concern about how we process your personal data by contacting our Data Protection Officer at data@twinstrust.org. If you are not happy with how we have handled your complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in the UK, or the Fundraising Regulator, which is responsible for overseeing fundraising activities carried out by charities in the UK. 

Alternatively, you may choose to contact either the Information Commissioner or the Fundraising Regulator directly about your complaint, regardless of whether you have raised it with us first. 

Right of Access / ‘Subject Access Request’ 
You have a legal right to have confirmation that your data is being processed, and to have a copy of the personal and supplementary information we hold about you. This is known as a 'Subject Access Request'. We will provide a copy of this information free of charge, in a commonly used electronic format such as a PDF file. 

Please note that if a request comes in that is manifestly unfounded or excessive or repetitive, we will charge a fee based on the administrative cost for providing this information. We will also charge a fee to comply with requests for further copies of the same information. All information will be provided within one month of being requested, unless the request(s) are complex and/or numerous. In this case, the period of compliance will be extended by a further two months, but you will be informed within one month of making the request that this extension has been applied, including explanation as to why. 

To submit a Subject Access Request, please contact the Data Protection Officer data@twinstrust.org to request a copy of the Subject Access Request application form. We will take steps to verify the identity of the person making the request prior to releasing the information. 

Right of Rectification 
You have a right to correct any errors in the information that we hold about you if it is incomplete or inaccurate. If we have disclosed the personal data in question to third parties, we will inform them of the rectification where possible. We will also inform you about the third parties to whom the data has been disclosed where appropriate. 

Any request for rectification will be responded to within one month and will be free of charge. To contact us to exercise your Right of Rectification, please email the Data Protection Officer data@twinstrust.org with the details that you require to be updated. No changes will be made until reasonable steps are taken to verify the identity of the person making the request. 

Alternatively, as outlined above, you can update your information yourself by logging in to the website and clicking here
 
Right of Erasure / Right to be forgotten 
You have a right to request that Twins Trust delete or remove the personal data we hold about you when there is no compelling reason for its continued processing. Please note that the right to erasure does not provide an absolute ‘right to be forgotten’. You have a right to have personal data erased and to prevent processing in specific circumstances: 

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed 
• When the individual withdraws consent 
• When the individual objects to the processing and there is no overriding legitimate interest for continuing the processing
• The personal data was unlawfully processed
• The personal data has to be erased in order to comply with a legal obligation

If we have disclosed your personal data to third parties, we will inform them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so. In regards to exercising a right to be forgotten with regard to photographs, individuals have the right to request photos be removed from websites and future versions of printed materials, but we cannot guarantee that we can remove from social media. 

Any request for erasure will be responded to within one month, and will be free of charge. To contact us to exercise your Right of Erasure please email the Data Protection Officer data@twinstrust.org with the details that you require to be erased. No changes will be made until reasonable steps are taken to verify the identity of the person making the request. 

Right to Restrict Processing 
You have the right to ‘block’ or suppress the processing of your personal data. This means that Twins Trust will continue to store the personal data, but not process it any further. We will retain just enough information about you to ensure that the restriction is respected in future. 

Any request for restriction of processing will be responded to within one month and will be free of charge. To contact us to exercise your Right of Restricted Processing, please email the Data Protection Officer data@twinstrust.org with the details that you require to be restricted. No changes will be made until reasonable steps are taken to verify the identity of the person making the request. 

Right to Object 
You have the right to object to: 

• direct marketing (including profiling); and
• processing for purposes of scientific research and statistics

We will stop processing your personal data for direct marketing purposes as soon as we receive an objection, and this is free of charge. To update your preferences for Direct Marketing, please see the section on 'How can you update your Contact Preferences or Update the Information we hold about you?'

Why are we allowed to process your personal information? 
Our Privacy Notice considers several laws, including: 

• the Data Protection Act 1998 (also known as DPA98) 
• the Data Protection Act 2018 (also known as DPA18) which brings into force in the UK. This will come into force in the UK on 25th May 2018 and will replace DPA98
• the Privacy and Electronic Communications (EC Directive) Regulations 2003 (also known as PECR) 

Generally, our processing of your personal information as described in this notice is allowed by these laws because we have a legitimate need to carry out the processing for the purposes described above. Some processing may also be necessary so that we can perform a contract with you or because it is required by law. We only use your information to send you marketing communications by email with your consent, and you can always opt out of receipt of marketing communications by email, post or telephone as explained in the section on 'How can you update your Contact Preferences or Update the Information we hold about you?'

Sometimes it is necessary to process your data for us to comply with our legal obligations, for example, when we submit gift aid submissions to the HMRC. On this occasion, we provide the HMRC with your full name and your postcode. 

How will we disclose the information we have collected to outside parties? 
We will never sell, rent or trade your personal data. We may disclose your data to our service providers (such as outlined below) who render services to us or you on our behalf (all of which are contractually obligated to act only on our instructions and in accordance with applicable laws, including the GDPR). 

For example, 

• We securely send your name and address information to a print house that delivers the direct mailing for the quarterly magazine that Twins Trust sends out to members, and prospective members. 
• For families that have successfully applied to our Helping Hands programme, your details will be securely passed to the Norland Agency for a support practitioner to them work with the family. 
• For families that agree to speak to the media to help publicise our work, we will ask for your consent. Once this has been granted, Twins Trust will send out a media release to various different media outlets. No contact details will be on the press release. If a journalist wishes to interview you, again consent from you will be obtained. Once consent is granted Twins Trust will send your name and your contact details to the journalist. 
• We may send your information to companies that offer wealth screening services. You can opt out of profiling by contacting us at data@twinstrust.org and asking us to opt you out. 

For all outside parties that we securely share information with, this is in accordance with a contract held with these parties, including the contractual obligation to destroy the data when it is no longer required. 

We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement, or to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect Twins Trust, for example, in cases of suspected fraud or defamation, or to comply with any other applicable legal obligation. 

Children’s Data 
Twins Trust does not offer an online service for children. We do, however, collect data about children when we collect information for case studies, or for applications to our Helping Hands service. The basis for processing this information is consent, and if the child is under the age of 13, the consent will be sought from the parent. The child cannot give the consent themselves. 

Other Websites 
Our website may contain links to other websites run by other organisations. This privacy notice applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website. 

In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site. 

Emails Terms of Use 
Emails aren’t always secure, and they may be intercepted or changed after they’ve been sent. Twins Trust doesn’t accept liability if this happens. The contents of emails reflect their author's views and not necessarily those of Twins Trust. 

Please do not send Twins Trust any financial data through email. 

The information in emails is confidential, so if you’ve received one by mistake, please delete it without copying, using, or telling anyone about its contents. 

Your Credit or Debit Card Information 
If you use your credit or debit card to donate to us, take out a membership or make a booking online, we pass your card details securely to our payment processing partner as part of the payment process. We do this in accordance with the Payment Card Industry Security Standard, and don’t store the details on our website or databases. 

If you call us and give us your details over the phone, we process your payment via a WorldPay secure connection that meets PCI DSS Standards. PCI DSS is the worldwide Payment Card Industry Data Security Standard that was set up to help businesses process card payments securely and reduce card fraud. This is achieved through enforcing tight controls surrounding the storage, transmission and processing of cardholder data that businesses handle. PCI DSS is intended to protect sensitive cardholder data. The card financial information is then destroyed, so that any paper copies of transactions that have taken place cannot be used by another person to process an inappropriate payment. For further information about PCI DSS standards, please contact data@twinstrust.org with your query. 

End of Twins Trust Privacy Policy