At the RAF Benevolent Fund, we respect your privacy and take great care with personal information we hold about you. This privacy notice sets out how we collect and handle information about you. The terms of this policy may change, so please check it from time to time. This version published on 9 February 2021, supersedes all previous versions.
Please read this notice carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights and how to contact us or our supervisory authority, the Information Commissioner's Office, in the event you have any concerns we are unable to address.
Our use of personal information is governed by law. The RAF Benevolent Fund is committed to complying with the principles set out in the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR).
The Royal Air Force Benevolent Fund is the leading welfare charity supporting current and former members of the RAF, their partners and families, providing practical, emotional and financial support. We are a registered charity in England and Wales (1081009) and in Scotland (SC038109) and registered with the Information Commissioner's Office (ZA111002). The following wholly owned subsidiaries also process personal information and are therefore registered with the Information Commissioner's Office:
|Name||Description||ICO Registration Number|
|RAF Disabled Holiday Trust||Providing holidays to disabled serving and former members of the RAF and their dependants||ZA234348|
|RAF Benevolent Fund Housing Trust||Provides and manages properties for beneficiaries of the RAF Benevolent Fund||Z6071914|
|RAF Dependants Fund||Promotes the efficiency of the RAF through relieving dependants of deceased serving personnel from financial distress||Z943187X|
|RAF Dependants Income Trust||For subscribers of the RAF Dependants Fund to make further financial provision for their dependants in the event of death in service||Z9431897|
a) When you give it to us directly:
For example, personal information that you submit through our website by making a donation, signing up for newsletters, challenge events or personal information that you give to us when you communicate with us by email, phone, letter or complete an application form.
b) When we obtain it indirectly:
For example, your personal information may be shared with us by third parties including other military or military-related charities; RAF Stations; family or friends who have suggested that you might require our services; websites offering fundraising services; an employee of ours that has given your details as an emergency contact or referee; sub-contractors in delivery of our services; or employment agencies.
c) When it is available publicly:
Your personal information may be published on publicly available sources including where you have made your contact information available on your organisation's website and we use this to contact you. Our use of publicly available personal data complies with the principles set out in the UK GDPR.
d) When you visit our website:
There are many different data processing activities across the RAF Benevolent Fund. We will only ever capture the minimum amount of information that we need for the particular reason we are processing your data. The most commonly collected personal information are your name and contact details including postal address, telephone number and email address. We may also process the following:
- Your date of birth and gender
- Your financial information, such as bank details and/ or credit/ debit card details
- National identifiers such as an RAF service number or National Insurance number
- Social relationship data relating to family or social relationships
- Health data and other special category data
- Details of work history and qualifications
- And in some, but fewer cases, information about:
- Life history – brief or detailed descriptions of significant life events that could identify you
- Socio-demographic data – for example, information about your role in society
- Preference data – for example, your likes and dislikes
- Photographic and CCTV data
To be within the scope of UK GDPR, this personal data must be recorded in an RAF Benevolent Fund filing system, or we have an intention of recording it in a filing system. Any personal information you tell us that we do not file, or do not intend to file, for example personal information you may tell us during a telephone conversation that we do not record in any way, is outside the material scope of UK GDPR.
Your personal data is required to enable the RAF Benevolent Fund to achieve its aims and objectives as a charity. Your personal information, however provided to us, will be used for specific, explicit and legitimate purposes which include:
- to provide you with support or information you have requested;
- to provide services to our beneficiaries;
- to provide further information about our work, services, activities or products (where you have provided your consent to receive such information; or you would have a reasonable expectation to receive such information)
- to process your donations;
- to answer your questions/ requests and communicate with you in general;
- to manage relationships with our supporters and beneficiaries;
- to enable eligible guests to stay at our cottages
- to ensure your safety when you visit RAF Benevolent Fund sites
- to further our charitable aims in general, including for fundraising activities;
- to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
- to report on the impact and effectiveness of our work;
- to run/ administer our website, keep it safe and secure and ensure that content is presented in the most effective manner for you and for your device;
- to administer your participation in fundraising events and challenges;
- to process your application for a job or volunteer role with us
- to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
- for the prevention of fraud or misuse of services; and/or
- for the establishment, defence and/ or enforcement of legal claims.
The UK GDPR requires us to rely on a lawful basis for each data processing activity undertaken with your personal data including those set out in the previous section. These legal bases are:
- Consent - Where you have provided your consent for our use of your personal information in a certain way (for example, where you have provided your consent for us to use your personal information to send you fundraising material by email, or to send you our newsletter).
- Contractual obligation - Where it is necessary for us to process your personal information in order to perform a contract to which you are a party, or to take steps prior to you entering a contract, for example where you apply for a role at the RAF Benevolent Fund.
- Legal obligation - Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject. For example, this might be where we have a legal obligation to share personal information with HMRC for Gift Aid claims or tax calculations; or process your data when you have exercised your data protection rights.
- Vital interests - Where it is in your, or someone else's vital interests. For example, in the case of a medical emergency suffered by an individual that needs to be reported by us to the emergency services.
- Public Interest – Where it is necessary to perform a task carried out in the public interest
- Legitimate interests - Where applicable law allows us to collect and use personal information on the condition that to do so is necessary for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. In broad terms, our "legitimate interests" means the interests of running the Charity as a charitable entity, and pursuing our aims and ideals; for example
- the administrative activities of providing support to our beneficiaries,
- taking donations,
- acknowledging your kind donations and sending you pin badges,
- administering events,
- receiving applications forms,
- passing data between our wholly owned subsidiaries,
- producing anonymous statistical reporting
- administrative activities related booking a break at our cottages
- ensuring the contact details we have for you remain accurate.
In addition, where we process special categories of data an additional condition of processing is established and documented as required by Article 9 of the GDPR.
We commit to building open and honest relationships with supporters of the RAF Benevolent Fund. Transparency and privacy are key to our approach. To help us understand our existing donors better we undertake in-house research which may involve gathering information about you from publicly available sources, for example, Companies House, property registers, 192 directory, The Times Online and Who's Who; and segment donor information based on characteristics such as location, or number and value of donations. We may from time to time engage specialist agencies to gather information about you from similar publicly available sources and create a profile about you and your interests.
This is often called "wealth profiling". This analysis and research helps us to understand the background of our supporters so that we can make appropriate requests to those who may be willing and able to give more than they already do, enabling us to raise funds and help beneficiaries sooner and more cost-effectively. You will always have the right of opting out of this processing (see below). We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. We also use publicly available sources to carry out due diligence on donors, to meet money laundering regulations, and ensure gifts to the Fund are in line with the charity's Anti-Fraud, Anti-Bribery & Anti-Corruption Policy.
This research helps us to understand more about you as an individual so 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.
If you would prefer us not to use your personal information for supporter research, please let us know by contacting us at email@example.com.
We may use your contact details to provide you with information about our work, events, or services which we consider may be of interest to you (for example, about services you have used, or are available to you; or updates about fundraising appeals and/or volunteering opportunities via our newsletter). Where we do this via email, SMS or telephone, we will not do so without your prior consent. We may also ask for your consent to send you information by post. You can opt out of receiving emails from the Fund at any time by clicking the "unsubscribe" link at the bottom of our emails or you can tell us by contacting us at firstname.lastname@example.org. In some circumstances, we may send you information in the post under the legal basis of legitimate interests. Again, if you wish to opt out of receiving postal mail from us you can tell us by contacting us at email@example.com.
We do sometimes need to share your personal information with other third parties in order to effectively provide our services, however we will never sell your personal information for marketing purposes. Non-exhaustively, parties we share data with include:
- Independent occupational therapy and mobility equipment organisations (only with your consent – see section entitled 'Lawful Processing')
- counselling and related support organisations (only with your consent – see section entitled 'Lawful Processing')
- Organisations providing beneficiary holidays and hotel booking systems
- RAF stations
- Professional services including solicitors
- Parties who assist the Fund in the administration of beneficiary enquiries
- Fundraising event organisations
- IT providers and cloud storage providers
- Regulatory authorities, such as tax authorities.
- Order and postal donation fulfilment organisations
- Mailing house providers
- Payroll Giving providers
- Content management system providers
- Organisations specialising in processing financial transactions and direct debits
- Organisations specialising in administering fundraising lotteries and online tribute pages
- Organisations specialising in advertisements to appear in social media newsfeeds
In rare circumstances, where we identify an individual as being at risk of harm to either themselves or others, or has other safeguarding needs, we may need to pass personal data to local authorities, medical professionals or emergency services.
The RAF Benevolent Fund has an online presence through the following third-party social media platforms.
We may provide Facebook with email addresses of those who have signed up to receive newsletters or other fundraising information in order to allow our fundraising advertisements to appear in your newsfeed and the newsfeed of others.Facebook only uses your email address for this purpose. This should not disrupt your experience of using Facebook, but if you would like to opt out of this activity you can do so by emailing our website manager – firstname.lastname@example.org.
We want our blog and social media presence to be a healthy environment for discussion.Our communications team moderate comments on the blog and social media accounts to protect those who view them. We will challenge, rather than delete, inaccurate comments or data, and remove anything that is discriminatory or unlawful.
If you have a complaint or comment about how we moderate social media, please contact our communications team at email@example.com.
When you use our secure online donation function you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.
When we process children's personal information, where required we will not do so without their consent and use our best endeavours to determine their competency to give consent by assessing the age range of children we will be interacting with and the context and nature of the data to be processed, and their understanding of the process and their rights. Where required, the consent of a parent/ guardian will be sought. We will always have in place appropriate safeguards to ensure that children's personal information is handled with due care.
In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records as shown below:
Personal data connected to Fundraising and Finance
Personal data connected to Welfare (Beneficiaries)
All other personal data
Varies dependant on purpose but kept for no longer than necessary
There are circumstances whereby data may be deleted before the maximum retention period. These are:
- your personal information is no longer required in connection with the purpose for which it was collected for.
- we are no longer lawfully entitled to process it, or
- you validly exercise your right of erasure (see see section entitled "Exercising your rights") and we delete / fully anonymise the data.
We may need to keep your data for statutory purposes, for example, gift aid declarations.
If you request to receive no further contact from us we have a legal obligation to maintain a small amount of data on our suppression list. This will comprise of your name and contact details in order to comply with your request and ensure we avoid sending you unwanted materials in the future.
The RAF Benevolent Fund is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers with features enacted to prevent unauthorised access.
We conduct supplier audits with our main data processors to ensure their information security system is robust and UK GDPR compliance is in place to ensure the safety and security of personal data we share with them.
From time to time, the RAF Benevolent Fund may need to transfer personal data outside of the United Kingdom to effectively provide our services and further our aims and objectives. This may be suppliers or agencies; or users who access our website in non-UK countries. Some non-UK countries have been approved by the UK Government as having adequate data protection law so that the transfer of personal data to these countries does not need additional protection. For any non-UK countries that have not been approved by the UK Government, the Fund takes necessary steps to safeguard personal data that is being internationally transferred. This includes entering into agreements with the international party by way of 'standard contractual clauses' which have been approved by the UK Government or by gaining explicit consent from individuals whose personal data appears on our website. Please note that some countries outside of the UK have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals.
Where we rely on your consent to use your personal information, you have the right to withdraw your consent. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time.
When we use your personal information, you have the right to:
- Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we can confirm your identity, we will provide you with this personal information.
- Request that we delete the personal information we hold about you, as far as we are legally required to do so.
- Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
- Object to the processing of your personal information where we:
- process on the basis of legitimate interests;
- use the personal information for direct marketing; or
- use the personal information for statistical purposes.
- Ask for the provision of your personal information in a machine-readable format to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us:
- in reliance on your consent; or
- because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means
- Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage. If you decide you do not want to receive any further emails from us, please tell us and we will remove you from the mailing list. At any point you can request to unsubscribe from our mailing by contacting us using the details listed in the section entitled "How to contact us".
You also have the right to lodge a complaint with the Information Commissioner's Office at www.ico.org.uk/concerns.
We may update this Policy from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an updated Policy on our website. This Policy was last updated on 9 February 2021.
Our Data Protection Officer can be contacted directly at firstname.lastname@example.org.
This website contains links to third party websites that may collect your personal data. This policy does not cover external websites and we encourage you to read the privacy policies of any external websites you visit via links from this website, or links embedded in any email originating from us. We are not responsible for their privacy practices or website content.
For any enquiries about this privacy notice or our treatment of your personal data, please contact:
Post: Royal Air Force Benevolent Fund, 67 Portland Place, London, W1B 1AR
Candidate privacy notice
At the RAF Benevolent Fund, we respect your privacy and take great care with personal information we hold about you. This privacy notice sets out how we collect and handle your personal data. It also explains your rights and how to contact us or the Information Commissioner's Office, in the event you have any concerns we are unable to address.
If you have any questions about this privacy notice, please speak to a member of the RAF Benevolent Fund's HR Team or Information Compliance Officer. Their contact details can be found at the end of this notice.
Who we are
The RAF Benevolent Fund is the leading welfare charity supporting current and former members of the RAF, their partners and families, providing practical, emotional and financial support.
What personal data do we use
The RAF Benevolent Fund only stores the minimum data required for the purpose of assessing your suitability for the role you have applied for or are interested in.
When you apply for a job or inform us you are interested in applying for a vacancy, we ask for:
- Your name and contact details ( address, phone number and email address)
- The type of work you are looking for
- Relevant work history and professional qualifications (typically in your CV)
- Your right to work in the UK
- Driving licence details (if the role requires you to use a company car)
If we invite you for an interview, we collect the following information:
- Details of any specific needs you want to inform us about, so we can make any reasonable adjustments for your interview
- Responses you give at an interview , plus any observations we make through interviews, that are relevant for your application
- Your current notice period (if applicable)
- Details about former managers, colleagues or other people you may want us to contact to act as referees
We will sometimes collect further information as necessary for specific roles as follows:
- Results of tasks or tests we set as part of the application process for particular roles
We'll also ask for the following data for equal opportunities monitoring separately from the interview process but it is your decision whether to provide it to us:
- Ethnicity (which is a type of 'special category' data)
- Disability status (which is a type of 'special category' data)
- Age demographic
- Gender identity (where gender reassignment is disclosed, this is 'special category' data)
- Your age group
We also get information from outside of the RAF Benevolent Fund, including:
- Recruitment and executive search agencies
- Job boards
- Your referees to ask for information in relation to the position you have applied for (if you are invited for interview or offered a position at the RAF Benevolent Fund)
- Results from background checking agencies. This will include information about criminal convictions if you have a record, and immigration status, if you are not from the UK
Our legal basis for using your personal data
The RAF Benevolent Fund adheres to UK data protection law and this means we need to meet certain conditions before we are allowed to use your personal data in the manner described in this Privacy Notice. To use your personal data, we will rely on one or more of the following legal grounds:
- Performance of a contract: This is when we need the data to process your application to enter into an employment contract (or other contract) with you.
- Compliance with a legal obligation: This is when a law or regulation says we must collect the information to decide if we can enter into an employment contract (or other contract) with you.
- Legitimate Interests: This is when we need to use your data for our legitimate interests, or those of a third party. It means using data in a way that you expect us to, for a reason which is in your and/or our (or a third party's) interest and which doesn't override your interests, rights and freedoms.
- Public interest: This is when we need the information to perform a specific task in the public interest that is set out in law.
- Vital interests: Where we may need to use your personal data to protect your life, or the lives of others, and have no way of asking your permission.
- Consent: We have your consent.
In this section we explain which of the above legal grounds we rely on to use your data in a certain way.
- Contact you during the hiring process;
- Consider your suitability for a role you are applying for; and,
- Gain references and check any relevant information you give us in your CV
We need to use your data to comply with the law, so we can:
- Make sure you have the right to work within the UK.
- Run DBS checks (criminal background checks) if you are applying for a role working with vulnerable people in the Welfare Directorate, Legacy and 'In Memory' Fundraising, Major Donor Fundraising and Legacy Administration Management, or any other role working with vulnerable people; or the role you are applying for is based at, or requires regular visiting to a Ministry of Defence site; or you are applying for a senior role.
We need to use your data when it’s in our legitimate interest, so we can:
- Complete our recruitment and promotion processes.
- Keep a copy of your application data if you let us know you want to be considered for other roles.
We need your consent to use your data, so we may ask:
- If you want to share details about yourself on a voluntary basis to help us with our equal opportunities monitoring.
How we use your 'special category' data:
We may need to process sensitive information about job applicants that data protection laws call 'special category' data. This is information that can reveal a person's racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as genetic or biometric data (if used for identification purposes) and data concerning a person's health, sex life or sexual orientation.
Data protection laws say we need a second lawful basis to process ‘special category’ data in addition to the bases above. This second lawful bases we use are explicit consent, exercising legal rights in the field of employment, reasons of substantial public interest and to establish, exercise or defend a legal claim.
For equal opportunities monitoring, we collect ethnicity, disability status, age demographic and sometimes health data (for example, if you inform us of gender reassignment) with your explicit consent and for reasons of substantial public interest. We need to use this information to make sure we give job applicants equal opportunity and treatment regardless of their demographic. Providing this information is voluntary and won’t affect your application in any way.
We store this data in an anonymised format separately to your application.
Who we share your data with
Companies that help us recruit, and need to process your details:
- Companies which specialise in aptitude testing and IT related testing, if these tests are required for the role you are applying for.
- Our IT managed services provider, ITRM and cloud services provider, Microsoft Azure
References if your application is successful:
- We contact the referees using the contact details you have given us to learn more about you. We only tell them your name and where we are calling from.
- We ask the Disclosure and Barring Service to check your criminal record, if this is necessary for the role
- In some circumstances, we may share your details with other parties. This is to comply with the law or to protect our rights, property or safety.
How long do we keep your data
If your application is unsuccessful, we delete some of your information, for example, the results of criminal record checks, immediately. If you're unsuccessful and agree that we can keep your information for other job openings, we keep relevant information for up to 6- months after we close the hiring process. We need to keep a copy of all applications for at least 6 months in case we face a legal challenge about our decision.
Who has access to your data at the RAF Benevolent Fund
Aside from the external organisations and people who we share your data (as defined in this notice) , your data will only be available to RAF Benevolent Fund staff who are authorised to process your data for the purpose of your application or role you are interested in. Typically, this means HR staff, the hiring manager, and in some circumstances, a Director and the Controller of the RAF Benevolent Fund. Data collected for the purpose of equal opportunity monitoring is available to HR staff only.
Data transfer outside of the UK
The RAF Benevolent Fund does not routinely share candidate’s personal data outside of the UK. However, if it is necessary to share data in this way, we make sure your data is protected by ensuring the country is listed as having adequate data protection laws according to the European Commission, or is listed as having adequate data protection laws according to the United Kingdom. For countries that do not have adequate data protection laws, we use specific clauses in contracts which are approved by the European Commission, to provide the necessary safeguards.
You have a right to:
- Access the personal data we hold about you (make a data subject access request)
- Ask for a copy of your personal data in a portable (machine-readable) format or request the Fund to send it to someone else
- Ensure any inaccurate data is corrected
- Ask us to delete, block or suppress your data. For legal reasons, we might not always be able to do so. There may be times when we continue to use your data when we say it's in our 'legitimate interest'
- Withdraw any consent you have given us, or object to us processing your data
- Ask a member of staff to review an automated decision
To exercise your rights, please speak to the HR department or the Information Compliance Officer.
For any questions or queries in relation to this privacy notice, please contact either HR or the Information Compliance Officer.