1. Who We Are
JustPenny CIC is a UK-registered Community Interest Company (CIC) operating to support individuals and communities affected by marginalisation, poverty, trauma, and other social challenges.
Website Address: https://justpenny.org
Email: justpennyuk(at)gmail.com
Registered Office: 173 Withington Road – Whalley Range – Manchester – M16 8EF
2. What Personal Data We Collect and Why
We collect and process personal data for the following purposes:
a. Website Interaction
- When visitors leave comments, we collect the data in the comments form, IP address, and browser user agent string to aid spam detection.
- Visitor comments may be screened through an automated spam detection service.
b. Service and Programme Delivery
- We collect names, contact information, demographic details, and relevant personal circumstances to assess eligibility for support (e.g., food aid, counselling, mentoring, housing services).
- Sensitive data (e.g., health, ethnicity, safeguarding concerns) is collected only when necessary and with explicit consent or lawful basis.
- All data collected is limited to what is relevant, lawful, and necessary for the delivery of our services.
c. Images and Media
- If you upload images to our website or send images as part of participation in activities, we recommend avoiding images that include embedded location data (EXIF GPS).
- Images captured at events or during service delivery may be used in internal reports or for promotional purposes, with appropriate consent.
d. Cookies
Our website uses cookies for the following purposes:
- To recognise repeat visitors and enhance user experience.
- To store user preferences (e.g., login state, screen display options).
- Analytical cookies to help us understand traffic and usage patterns (e.g., via Google Analytics).
You may disable cookies in your browser settings. Some website features may not function properly if cookies are disabled.
3. Embedded Content and External Links
Articles and pages on this site may include embedded content (e.g., videos, forms, articles) or links to external services. These platforms may collect data, track your activity, or set cookies independently of JustPenny CIC. We are not responsible for the content or data policies of third-party sites.
4. Who We Share Your Data With
We do not sell your personal data.
However, we may share information:
- With safeguarding authorities, police, or social services where there is a risk of harm or a legal obligation to do so.
- With partner organisations or funders when delivering joint services (only with consent or anonymised where possible).
- With professional advisors or regulators when legally required.
All third parties we work with are contractually required to comply with data protection regulations.
5. How Long We Retain Your Data
We keep personal data only as long as necessary:
- Comments and associated metadata are retained indefinitely unless deleted by the user or administrator.
- Service user records are retained in accordance with our data retention schedule (typically 6 years after service completion).
- Donation records are retained for accounting purposes (typically 7 years).
6. Your Rights Over Your Data
You have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate or incomplete data.
- Request deletion of your data (except where legally required to retain it).
- Object to processing or request restriction in certain circumstances.
- Withdraw consent at any time (where processing is based on consent).
- Lodge a complaint with the Information Commissioner’s Office (ICO) if you believe your data has been mishandled.
To exercise any of these rights, please email us at: [justpennyuk(at)gmail.com].
7. How We Protect Your Data
We use a range of physical, digital, and organisational safeguards to protect your data, including:
- Secure, encrypted data storage systems
- Role-based access control for staff and volunteers
- Regular data protection and safeguarding training
- Clear breach reporting procedures in line with ICO guidance
8. Data Transfers
We store your data on servers located in the UK or EEA. If data is transferred outside of these areas (e.g., cloud-based platforms), we ensure it is protected by appropriate safeguards, such as Standard Contractual Clauses or UK IDTA.
9. Children’s Privacy
We do not knowingly collect data directly from children under 13 without the consent of a parent or legal guardian. When working with young people, we ensure their data is collected in line with safeguarding protocols and appropriate consent.
10. Changes to This Policy
We may update this Privacy Policy periodically. Any significant changes will be communicated on our website and, where appropriate, via direct contact.
11. Contact Us
If you have any questions about this policy or your data rights, contact:
JustPenny CIC
ICO Registration Number: [Awaited]