Big Society Capital Limited respects your privacy and is committed to protecting your personal information. The EU General Data Protection Regulation and the Data Protection Act 2018 (the DP Legislation) enhance an individual’s rights in relation to personal information about them. This privacy notice will inform you how we collect and look after your personal information in accordance with the DP Legislation and tell you about your privacy rights and how the law protects you.
Important information and who we are
This privacy notice tells you what to expect when BSC collects and processes your personal information.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
BSC is the controller and responsible for your personal data (collectively referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).
Head of Legal
Big Society Capital
New Fetter Place
8-10 New Fetter Lane
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 13 March 2019 and historic versions can be obtained by contacting us.
Duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
If you contact us via social media, the personal information you provide will remain on that platform and that platform will be the data controller. We encourage you to read the privacy notice of the relevant platform.
Legal basis for processing personal information
Under the DP Legislation, we must have a legal basis for processing your personal information. In the situations described in the next section, we process your personal information for one of the legal bases set out below.
- Legitimate interests*. We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms. It is in our interests to ensure that our processes and systems operate effectively and to process information to help us achieve our mission to improve the lives of people in the UK by connecting investment to charities and social enterprises that are creating social change.
- Consent**. We may process your information where you give us your consent to do so. You have the right to withdraw this consent at any time by contacting us at firstname.lastname@example.org.
The situations where we collect data about you, what data we collect and why we collect it
- Visitors to Big Society Capital website
We use Google Analytics, to collect anonymised, aggregated data about visitors’ use of the website such as where the visitor came from, the browser types and versions, time zone setting and location and operating system used. We do this to find out things such as the number of visitors to the various parts of the site and to enable us to make the content useful. Further information about how Google uses this information and how you can control the information sent to Google can be found here. We do not collect any data on individuals via Google Analytics unless users have explicitly opted in to the collection of cookies. We do not make any attempt to find out the identities of the individuals visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
When Big Society Capital provides services, our aim is to make them easy, useful and reliable. Where services are delivered through the internet, this sometimes involves placing cookies on your device. A cookie is a small file of letters and numbers that is downloaded on to your computer, mobile phone or other internet enabled device when you visit a website. They are widely used in order to make websites work, or work more efficiently, remember your preferences, and to provide information to the owners of the site. Cookies cannot be used to identify you personally. Read more about the individual cookies we use by clicking here.
Mailing lists (consent**)
Open-source SITR Investment Deals database (consent**)
People who specify an interest in our Get Informed services (consent**)
If you have signed up to be a mentor, mentee or board facilitator using our Get Informed service, we will collect your contact details and personal information on your relevant experiences. As part of the matching process, we will share information you provide, as appropriate, with your corresponding mentee or mentor. Once a match is made, we will ask you to complete a survey related to your experience of the programme as well as your opinions and attitude on social investment at three months, six months and a year. This helps us to see whether Get Informed is fulfilling its purpose of improving access to, and understanding of, social investment.
If, when you sign up to the Get Informed mailing list, you indicate that you are a board member interested in learning about or taking on social investment, we will ask your opinion on matters related to social investment. This helps us see whether Get Informed is fulfilling its purpose in improving access to, and understanding of, social investment.
Recipients of BSC investment (legitimate interests*)
If we are in contact with you in relation to BSC investing into, or alongside, your organisation, we will use the information you give us for administration and analysis and possibly for research. The majority of the information will not include personal information. However we may collect certain categories of personal information. We will collect contact details and job titles for you and other staff members at your organisation in order to contact you about the application or for due diligence. We may also use these details in the future to contact you about initiatives which we think will be of interest to you, such as surveys related to BSC’s work, invitations to BSC events, invitations to partner with BSC on investment initiatives or fund management opportunities and to feature in our case studies. If we are in contact with you for an investment opportunity, as part of our due diligence on the investment, the personal information we may also collect includes CVs, biographies, salary information and references for key people in your organisation. The majority of this will be information which you, or someone at your organisation, give(s) us. In some cases it will come from third parties such as when we seek references. We may also collect some information from publicly available sources such as Companies House or your organisation’s website.
We may give copies of all or some of this information to individuals and organisations we consult when assessing applications, conducting due diligence, administering and monitoring investments and evaluating processes and impacts and our systems and controls. These organisations may include accountants, our shareholders, insurers, the Financial Conduct Authority and organisations or groups involved in delivering our investments. We will share your contact details and job title with third parties who want to get in touch with us about investing in or partnering with you. We may make public aggregated, anonymised data as part of our research, impact reporting and engagement work.
As a regulated firm, we are required to conduct due diligence on organisations in which we invest for the purposes of preventing financial crime. In order to fulfil our obligations, we are required to verify the organisation’s identity and conduct certain background screening. This may include verifying the identity of the organisation's shareholders, beneficial owners, management, directors or officers and/or other relevant information. To assist us with the verification and screening process, contact details you provide will be disclosed to credit reference and fraud prevention agencies which may keep a record of that information. If we need to conduct this due diligence using any of the personal information you have provided us with, you will be provided with further information prior to us doing so.
Job applicants (legitimate interests*)
If you apply for a job, we will ask for certain information in order to progress your application, assess your suitability for the role you have applied for and fulfil legal or regulatory requirements. The information will only be shared with our HR team and the relevant hiring manager(s).
We do not encourage speculative applications. If you send us a speculative application, we will direct you to our careers page and delete your speculative application.
We will ask for your contact details to contact you about your application. We will also ask for your CV and a covering letter to assess your suitability for the role. If you apply to us for a job through a recruitment agency, we will receive your contact details, CV and covering letter from them.
If you are shortlisted for a role, we will ask for you to provide proof of your identify so we can check that you have the right to work in the UK. As part of the assessment process you may be asked to attend an interview, where we might take interview notes, and to complete tests.
If we make a conditional offer of employment, we will ask you for information so that we can carry out pre-employment checks. We process this information to seek assurance as to your trustworthiness, integrity and reliability. You will therefore be asked to provide proof of your qualifications and referee contact details. In order to set up your employee record you will also be asked to provide bank details and emergency contact details. In order to comply with Financial Conduct Authority regulations, you will also be asked to declare any business or other interests you have.
You will be asked to provide equal opportunities information. This is not mandatory information – if you do not provide it, it will not affect your application. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
Given the nature of our business, for certain roles, we require a candidate who is made a conditional offer of employment to complete a fitness and propriety questionnaire and to disclose their criminal record history before starting employment and annually during employment. In some cases, we are required to carry out these checks (for example, for regulated roles); in all cases we carry out the checks in accordance with applicable law. If we need to conduct these checks, you will be provided with further information prior to us doing so.
- Interactions with BSC employees and registering for BSC events (legitimate interests*)
If you meet an employee of Big Society Capital, for example, at an event, and give them your contact details they will keep this information in order to contact you in the future about topics which might be of interest to you. They will also share this information with other staff members at Big Society Capital and occasionally, they will pass it on to third parties who they think you would be interested to hear from. Similarly, we will sometimes receive your contact details from a third party who thinks you would be interested in hearing from us.
When you register to attend seminars, training or other events that we organise or which relate to campaigns or other initiatives which we co-ordinate, we may ask you to provide contact information (such as name, email address and telephone number), biographical information (such as job title, employer and short credentials) and other relevant information (including communication preferences, meal preferences, guests’ names and feedback). We will use such information only where it is appropriate and relevant to our business relationship with you and where we have a lawful reason to do so.
Third party data processors
We use third party service providers for parts of our website, IT systems and when we communicate digitally with you. Sometimes they will process the personal information which you provide us with.
Transferring data to other countries
We, or our third-party providers, will transfer the personal information we collect about you to countries outside the EU, on the basis that anyone to whom we pass it protects it in accordance with applicable laws. We are in the process of ensuring that, in the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), your personal information receives an adequate level of protection in a way that is consistent with and which respects the EU and UK laws. Please contact us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at firstname.lastname@example.org.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints or queries
If you have any questions about this Privacy Notice, or want to submit a written complaint about how we handle your personal information, please contact us via firstname.lastname@example.org. You 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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.