This website is owned by Independent Age, which is the data controller. In some circumstances, partners collaborating with us may also be data controllers and, where this occurs, we will ensure we are transparent about how your personal data is being managed.

Independent Age is the operating name of the Royal United Kingdom Beneficent Association – a charity registered in England and Wales (charity registration number 210729) and in Scotland (charity registration number SC047184) and incorporated by Royal Charter.

Independent Age Enterprises Ltd (registered company number 04735201 in England and Wales) is the wholly owned subsidiary of Royal United Kingdom Beneficent Association, which trades on our behalf – for example, to sell merchandise.

Counsel and Care for the Elderly (charity registration number 203429, company registration number 645708) merged with Independent Age in October 2011, but continues to operate as a separate charitable company to collect donations and legacies. Independent Age is the managing trustee and continues to provide the services previously offered by Counsel and Care for the Elderly.

Our registered address is:

Independent Age 
18 Avonmore Road
London
W14 8RR

Our information governance team is responsible for answering any questions about this Privacy Notice and related data protection matters, including making a data subject access request (SAR). To contact the team, please write to us at the address above, marked ‘Private and confidential’, or email our data protection address at dp@independentage.org.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the United Kingdom’s (UK’s) supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with any concerns you may have before you approach the ICO, so we would encourage you to contact us first.

We aim to make getting in touch with us as easy as possible, so we can be contacted:

• in writing, marked ‘Private and confidential’ to Independent Age, 18 Avonmore Road, London, W14 8RR
  through our website at independentage.org
  through our social media channels – Facebook, X (formerly Twitter), Instagram and YouTube 
  on our free Helpline on 0800 319 6789
  by email at charity@independentage.org. 

If you are not satisfied with our reply and/or the outcome, or with how we handled your complaint, you have the right to make a complaint to the ICO. You can find out more information about reporting a concern on the ICO website or by calling its helpline on 0303 123 1113. 

For correspondence, comments and feedback, or complaints about specific subjects, we invite you to contact the team that can best help directly:

We may update this Privacy Notice from time to time. If we make significant changes, we will let you know on our website.

Data protection law requires us to rely on one or more lawful grounds to process your personal information. We consider the following grounds to be relevant:

• specific consent, where you have provided specific consent to us using your personal information in a certain way, such as to send you email, text and/or telephone marketing
• performance of a contract, where we are entering into a contract with you or performing our obligations under it
• legal obligation, where necessary so that we can comply with a legal or regulatory obligation to which we are subject, for example, where we are ordered by a court or regulatory authority like the Charity Commission or Fundraising Regulator
• vital interests, where it is necessary to protect life or health – for example, in the case of a medical emergency suffered by an individual at one of our events – or a safeguarding issue that requires us to share your information with the emergency services
• legitimate interests, where it is reasonably necessary to achieve our or others’ legitimate interests, as long as what the information is used for is fair and does not unduly effect your rights. We consider our legitimate interests to be running Independent Age (and its subsidiaries) as a charitable organisation in pursuit of our aims and ideals, so we might:
  • send communications by post that we think will interest you
  • conduct research to understand better who our supporters are so we can better target our fundraising
  • monitor who we deal with to protect Independent Age against fraud, money laundering and other risks
  • enhance, modify, personalise or otherwise improve our services/communications for the benefit of our stakeholders
  • work to understand better how people interact with our website.

When we legitimately process your personal information in this way, we consider and balance any potential effect on you (both positive and negative), and your rights under data protection laws. We will not use your personal information where the effect on you overrides our interests – for example, where its use would be excessively intrusive – unless, for instance, we are otherwise required or permitted to by law.

When we use special category information – such as ethnicity, sex/gender, religion or health information – we require an additional legal basis to do so under data protection laws. That means we will either do so on the basis of your explicit consent or by another route available to us by law – for example, if we need to process it for employment, social protection, safeguarding or vital interests.

When you give it to us directly

You may give us your details when you:

• sign up for one of our events
• receive support from our Helpline or another service
• volunteer with us
• order an advice guide or factsheet
• sign up for a newsletter
• apply for a grant
• tell us your story
• make a donation
• communicate with us. 

Sometimes your data is collected by an organisation working for us – for example, a professional fundraising agency – but we are responsible for your data at all times.

For certain events, we may collect your image, audio and likeness – as captured on a webinar or in photographs, or through streaming or film recordings made of the event. We would always seek your consent in advance to do this.

You may give us your data when applying for a job vacancy, volunteer or trustee role – for example, you may have filled in an application form, submitted a CV or resume, and provided your passport details or other identification documents.

When you give it to us indirectly

You may give data to us indirectly when you sign up to events such as the London Marathon or contribute to Independent Age through fundraising sites like JustGiving or Virgin Money Giving. These independent third parties will only share your data with us when you have chosen to support Independent Age and with your consent. You should check their privacy policy when you provide your data to understand fully how they will process it.

When you use our website

Like most websites, we use ‘cookies’ to help us make our site, and the way you use it, better. Cookies mean that a website will remember you. They are small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example, by automatically filling in your name and address in text fields. This data helps us understand how people are using our website and shows us how to make it better.

When you access our social media
We might also obtain your personal data through your use of social media such as Facebook/Instagram (Meta) and X, depending on your settings or the privacy policies of these social media messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this:

• linkedin.com/legal/privacy-policy 
• youtube.com/howyoutubeworks/our-commitments/protecting-user-data
• facebook.com/privacy/policy 
• privacycenter.instagram.com/policy
• twitter.com/en/privacy (now called X).

When the data is publicly available
We might also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like Independent Age. In this scenario, Independent Age may seek to find out more about these individuals, their interests and motivations for giving through publicly available data. This data may include newspaper or other media coverage, open postings on social media such as LinkedIn and data from Companies House.

The Independent Age Helpline provides older people and their families with clear, free and impartial information on the issues that matter: money, housing and care. It also offers signposting and refers callers to an advice team for in-depth advice. All calls to the Helpline are recorded.

We may collect, store and process a variety of data about you on our database, some of which will be personal and special category (sensitive) data, such as:

• basic contact details, such as your name and telephone number
• other data related to the advice being sought or issues discussed, including age, health, disabilities and mobility issues
• equalities-monitoring data, including data about your ethnic origin, sexual orientation, sex/gender, health, caring responsibilities and any 
• religion/non-religion or belief – although we will only collect this sensitive data with your explicit consent, which you can withdraw at any time
• marketing preferences with respect to services provided and supporter opportunities you’d like to hear about.

How do we use your personal data?
We collect your personal data to provide services to you and to offer opportunities that may be of value and interest to you, as well as to ensure the safety and accessibility requirements of our staff, volunteers and the people who support us.

Our Helpline also makes use of third-party tools to help us provide the best advice possible to our users, such as an online benefits checker or a signposting service. When used, an internal copy of the results may be stored on a user’s record on our database.

We will sometimes call users of our Helpline service to make sure we have dealt with their requests and concerns in an effective and diligent manner – so we can evaluate the quality of our services – but also to seek specific consent to use their experiences where we feel they could benefit others.

We may want to share your story with fellow service users as a case study. We will always seek your consent in advance, and you have the right to object or stop any processing (see Sharing your data).

We will always inform users if we are recording or capturing audio or visual personal data and be transparent about how we are going to use it. You have the right to refuse to be recorded or have your image captured.

Who do we share your personal data with?

We share your personal data with third parties that work with us to provide a service and with external agencies that inspect our work – and where we are required to share data for legal reasons or if we believe that you are at risk of harm or may harm someone else. The public interest in safeguarding may override confidentiality interests in this regard. However, all data will be shared on a need-to-know basis only, this being decided by a qualified, designated person at the time.

We may also occasionally review live calls with potential partners, where there is a legitimate interest to do so. However, this supervised activity is subject to strict confidentiality safeguards being in place to ensure compliance with data protection legislation.

Our digital and phone services are a vital resource that allow us to work with the many older people we support who are facing financial hardship. We work with older people to signpost them to local and tailored support, as well as to provide telephone and web-based Good to Know Groups, which cover a variety of useful topics and are available to all older people.

We may collect, store and process a variety of data about you, some of which will be personal and special category (sensitive) data. The types of data we may collect include:

• basic contact details, such as your name, address, date of birth, telephone number and email address
• other data related to the advice being sought or issues discussed, including age, health, disabilities and mobility issues, because these will affect the types of services we can signpost to
• any interests and hobbies you may have so we can provide a more valuable service to you
• equalities-monitoring data, including data about your ethnic origin, sexual orientation, sex/gender, health, caring responsibilities and any religion/non-religion or belief – although we will only collect this sensitive data with your explicit consent, which you can withdraw at any time
• marketing preferences with respect to services provided and supporter opportunities you’d like to hear about.

How do we use your personal data?

We collect your personal data to provide relevant services to you and to signpost you to opportunities that may be of value and interest.

We will sometimes call users of our digital and phone services to make sure we have dealt with their requests and concerns in an effective and diligent manner – so we can evaluate the quality of our services – but also to seek specific consent to use their experiences where we feel they could benefit others.

We may want to share your story with fellow service users as a case study. We will always seek your consent in advance, and you have the right to object or stop any processing (see Sharing your data).

Any contact will be recorded so we can monitor and evaluate the quality of the services we provide. We may use third parties to evaluate the services we provide, but we will only share the minimum amount of data that they need to do that – and appropriate data processing agreements will be in place for this purpose.

Who do we share your personal data with? 

Our digital and phone services team may use third-party services for our Good to Know Groups for example, and we may share your contact data to enable you to participate. We also use third-party tools to enable us to provide the best information possible to our users, such as the STEP signposting service. We may also directly refer individuals to third-party services once explicit consent is given, with any results being held on a user’s record on our database.

We may use third parties to evaluate the services we provide, but we will only share the minimum amount of data that they need to do that – and appropriate data processing agreements will be in place for this purpose.

If you wish to engage with Independent Age and support the work we do – for example, by making a donation, registering to fundraise or campaign, signing up for an event, taking part in the Independent Age lottery, or expressing an interest in or informing us of your intention to leave a gift in your Will – we will collect: 

• basic contact details, such as your name, address, date of birth, telephone number, email address and social media handles
• your bank or credit/debit card details (only for confirmed supporters*)
• your current interests and donor activities 
• your employment situation
• equalities-monitoring data, including data about your ethnic origin, sexual orientation, sex/gender, health, caring responsibilities and any religion/non-religion or belief – although we will only collect this sensitive data with your explicit consent, which you can withdraw at any time
• consented third-party information that supports your gift, such as about your solicitor, executor, legal power of attorney or next of kin.

Where it is appropriate, we may also ask:

• for data relating to your health – for example, if you are taking part in an event
• why you have decided to support us – although we will never make this question mandatory, and only want to know the answer if you are comfortable telling us.

*We only use this data for processing payment. We do not store credit/debit card details. 

How do we use your personal data?

We will use your data to:

• administer your donation or support your fundraising and participation in our activities, including processing Gift Aid claims
• keep a record of your relationship with us
• ensure we know how you prefer to be contacted
• manage feedback or complaints we receive from you
• work with third parties to send you relevant marketing materials based on your preferences and our analysis of your interests (see Direct marketing and Building profiles)
• share your story with fellow supporters, with your consent (see Sharing your data).

We process your personal data for these purposes in line with our legitimate interests in conducting fundraising, processing payments, promoting our charitable activities, customising our social media communications and responding to you when you make an enquiry. We also process your data when required under law or with your consent, such as when you consent to receive marketing from us.

Some of our supporters choose to give higher donations, and this enables Independent Age to have a greater impact on the lives of older people in financial hardship. To help us identify individuals, trusts or companies that may have a philanthropic interest in our work, we undertake in-house research and may also work with reputable external organisations. This research is based on data provided to us by our supporters, along with publicly available sources, such as the electoral roll, Companies House records, newspaper articles, company websites and internet searches. 

Knowing more about our supporters and their interests enables us to tailor our communications in the most appropriate way, and to better engage those who have an interest in helping older people and becoming more involved with Independent Age.

If you campaign on our behalf – by signing one of our petitions or sending an email to an MP, for example – we will collect:
•    your name
•    your contact details including your address, when necessary
•    a record of the action you have taken
•    a record of who your MP is, where applicable

We may also ask for:
•    your story, which may include information about your health and other circumstances
•    equalities-monitoring data, including data about your ethnic origin, sexual orientation, sex/gender, health, caring responsibilities and any religion/non-religion or belief – although we will only collect this sensitive data with your explicit consent, which you can withdraw at any time.

How do we use your personal data?

We will use your data to:

• keep a record of your relationship with us
• ensure we know how you prefer to be contacted
• share your story with fellow campaigners, with your consent (see Sharing your data)
• work with third parties to send you relevant campaign materials based on your preferences and our analysis of your interests. 

However you support us, we will not: 

• sell any of your data to anyone and we never will
• swap or share your data without strict restrictions on how our partners can use and disclose the data we provide.

Our annuitants benefit from financial support from us in the form of regular payments. Annuitants also have access to our range of Helpline advice and information services.

For us to carry out these services and provide financial assistance, we need to collect, store and process a variety of data, in addition to that collected for our Helpline services. Some of this data will be personal and special category (sensitive) data. The additional types of data we may collect include:

• detailed financial data, including financial assets and benefits that annuitants may be receiving, which is collected periodically to assess their financial needs
• bank account data so we can make payments
• detailed health, mobility and disability data, which allows us to assess annuitants’ needs more thoroughly
• information about any lasting powers of attorney that may be set up, which allows us to communicate with other individuals or agencies
• information referencing any religious beliefs, interests or hobbies
• information about any safeguarding concerns and action taken as a result of a safeguarding issue
• information for additional contacts that annuitants may have given us for reference purposes, or contacts who can be contacted in the event of any emergencies – and we assume annuitants will already have informed these contacts in these circumstances.

How do we use your personal data?

We will use your data to:
•    keep a record of your relationship with us and services provided
•    ensure we know how you prefer to be contacted.

We may want to share your story with fellow service users as a case study. We will always seek your consent in advance, and you have the right to object or stop any processing (see Sharing your data).

When you apply for a job or volunteer role, we collect your data to allow us to assess your suitability, to correspond with you about your chosen role and to provide you with additional information about Independent Age and its various activities.

We will collect a range of data about you, which may include:

• your name, address and contact details, such as your email address and telephone number
• your contact preferences
• referee information
• details of your qualifications, skills, experience, education, volunteering and employment history, and any other information you choose to share in your application
• any reasonable adjustments we need to make during the recruitment process, including for any disabilities you wish to make us aware of
• information about your entitlement to work/volunteer in the UK
• equalities-monitoring data, including data about your age, ethnic origin, sexual orientation, sex/gender, health, caring responsibilities and any religion/non-religion or belief – although we will only collect this sensitive data with your explicit consent, which you can withdraw at any time
• for volunteer roles, at application stage, your emergency contact details, languages and your age where this relates directly to the role 
• for job roles, where an offer is made, your date of birth, sex/gender, emergency contact details and your bank details so that we can pay you.

We may also collect information about you from third parties, such as references supplied by former employers or for a DBS/SVG check. For job applicants, Independent Age will only seek information about you from third parties once we have made you an offer of employment. In all cases, the application process will make clear at what point we will be contacting third parties. For volunteer applicants, Independent Age will seek information from third parties during the volunteer recruitment process.

How do we use your personal data?

We process your personal data to administer your job or volunteer application and to monitor recruitment statistics. In some cases, we need to process your data to ensure we are complying with our legal obligations – for example, checking an individual’s right to work in the UK.

We have a legitimate interest in processing your personal data so we can manage our recruitment process, assess and confirm your suitability for the position and decide who to offer a role to. We may also need to process data from job and volunteer applicants in line with our legitimate interest in responding to, and defending against, legal claims.

We process health data if we need to make a reasonable adjustment to the recruitment process for applicants who have a disability. This is to carry out our obligations and exercise specific rights in relation to employment.
For some roles, Independent Age is obliged to seek information about criminal convictions and offences. This is necessary to carry out our obligations and exercise specific rights in relation to employment and volunteering.

If an applicant is unable to fulfil these requirements, they will not be able to progress any further with their application.

Who do we share your personal data with?

As part of the recruitment process, we may need to share your data with third parties to conduct any necessary background checks and vetting processes, such as contacting previous employers/referees to obtain a reference. As part of the recruitment process, we will make clear to you which checks will be required and at what stage of the process.
Your data is stored securely on Independent Age systems and, where relevant, the systems of third parties that we have a working relationship with. In these circumstances, appropriate data-sharing agreements will be in place with any third-party organisation, so safeguarding any data they may have access to. Sensitive data is only available internally to those staff who need to view it as part of their role.

Independent Age collects and processes a range of data about you that is appropriate to the role that you perform or performed with us. This will vary depending on whether you are an employee, volunteer or trustee. Full details can be found in the relevant privacy policy, which you can request from our people team (see Who we are and how to contact us).

We will store contact and financial details of suppliers, potential suppliers, and grant applicants and grantees so we can procure services, manage and process contracts and grant applications and agreements, and make payments.

Whether you are, or want to become, one of our suppliers or grantees: 

• we will not sell any of your data to anyone and we never will
• we will not swap or share your data without restrictions on how our partners can use and disclose the data we provide
• you can opt out of any updates to our procurement or grant programme activity by updating your consent preferences. 
   

Where possible we use publicly available sources to keep your records up to date – for example, the Post Office’s National Change of Address database and data provided to us by other organisations as described in How we use your data.

Where we use external sources of data to help us provide more accurate communications to you, we will seek assurances from these third parties that any data provided has been collected lawfully and appropriate consents have been sought to share that data with other organisations like us.

We keep your personal data only for as long as we need to use it for the purposes set out in this Privacy Notice.

Our data retention policy and schedule set out the different periods we keep personal data for in respect of the relevant purposes. We may also hold data as required to comply with: 

• legal/legislative requirements
• a legitimate reason for continuing to store it, such as dealing with legal disputes
• a requirement of relevant regulatory authorities, including, but not limited to, the ICO.

Personal data we no longer need is securely disposed of and/or anonymised, so you can no longer be identified from it. We may keep some personal data in archives for statistical or historical purposes, although we will do this in a manner that complies with applicable data protection laws.

We continually review what personal data and records we hold and delete what is no longer required. We never store payment card data.

We will only email or phone you where we have your consent to deliver marketing or other communications to you. You can indicate your marketing preferences when you make a donation, take part in our lottery or register your interest in our work. Our forms have clear marketing preference questions, and we include information about how to opt out when we send you marketing communications. If you no longer wish to receive marketing communications, engage in our campaigns, support our appeals asking for a donation or find out about our grant-funding opportunities, just let us know when you provide your details or click the ‘unsubscribe’ link in any email we send or update your communication preferences on our website.

We do not sell or share personal details to third parties for the purposes of marketing. But, if we run an event in partnership with another named organisation, we may need to share your details. We will be very clear on what will happen to your data when you register.

Independent Age has a legitimate interest in keeping lists of people who no longer wish to be contacted (known as a suppression list) to ensure that we do not unintentionally contact them in the future. The suppression list also collects emails that bounce or are blocked or invalid. We also keep suppression lists of supporters and prospects who have asked us to remove them from our postal mailing or marketing lists for the same reason.

We use profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience for our supporters. This means we can better understand your interests and preferences and so contact you with the most relevant communications.

Prospect research 

We may carry out research using publicly available information, to identify individuals who may have an affinity with our cause but with whom we are not already in touch. This may include people connected with our current major supporters, trustees or other lead volunteers.

We also undertake in-house research and, from time to time, engage specialist agencies to gather information about you from publicly available sources – for example, Companies House, the electoral register, company websites, ‘rich lists’, social networks such as LinkedIn, political and property registers, and news archives. We may also carry out wealth screening to fast-track this research by using trusted third-party partners. You will always have the right to opt out of this processing.

This research helps us to understand more about you as an individual, which means we can focus any conversations we have with you about fundraising in the most effective way. It also means we can provide you with an experience as a donor or potential donor that is appropriate for you.

If you would prefer us not to use your personal data for building profiles or screening, please contact us.

Independent Age stores all the data held about you on its own systems, which are within the UK and the European Economic Area and which are protected by UK data protection laws and other associated legislation.

We do not trade names with other organisations, 'list swap' or rent out contact information or other personal data provided to us. We will never pass your details to a third party to use in their own business activities.

Independent Age uses third parties to process data on its behalf, which may include your personal data. Only data that is necessary for a particular purpose is provided to any third party, with a clear expectation that all data, used and stored, is subsequently destroyed when any processing has been completed.

We may share your personal data:

• with members of our group, which means the registered charity and subsidiaries as defined in section 1159 of the UK Companies Act 2006
• with business partners, suppliers and subcontractors, including:
  • providers of our fundraising and campaigning materials , email marketing and events
  • our customer relationship management systems
  • providers of signposting systems 
  • archive and storage systems
  • printers, fulfilment houses, photographers, videographers, creative designers, creative agencies and online survey providers
  • insurers, solicitors, brokers, loss adjusters, managing agents and landlords
  • analytics and search engine providers that assist us in improving and optimising our site
  • where we are under a duty to disclose or share your personal information to comply with any legal obligations, or to protect the rights, property or safety of Independent Age staff, volunteers, donors, beneficiaries or others – this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction
• with a prospective seller or buyer of our business or assets in the event we sell or buy any such business or assets, including where Independent Age or substantially all of its assets are acquired by a third party, in which case the necessary personal data will be one of the transferred assets
• where required to do so by law, or where the disclosure is ‘necessary’ for purposes of national security, taxation and criminal investigation
• for employees, with payroll agencies, HMRC, pension, insurance companies and statutory bodies
• where we have your written/verified verbal consent.

Independent Age may ask if you would like to share your story as a case study. If you agree to become a case study, we can, at your request, make your case study anonymous, which will not identify you in any way. We use case studies in Independent Age promotional activities, guides and campaigns. We will always seek your consent in advance of using your data for a case study and inform you of how and where we are going to use a case study.

Where possible, data that we collect from you will be stored and accessed in the UK. Some of our partners may run their operations outside the UK and these countries may not provide the same standard of data protection as the UK. Your data may also be processed by staff operating in these locations who work for us or for our service providers. In these instances, we will take the necessary steps to make sure appropriate protections are in place (in accordance with UK data protection laws) and that information is safeguarded. These safeguards include ensuring that Independent Age and the relevant recipient enter into standard contractual clauses.

Independent Age takes the security of your data very seriously. We have internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by our employees as part of their duties. This includes strict access controls and security of our network and databases, and the information within them, and rigorous change controls to ensure only those people who have a need to view, amend or process your information can do so.

In all cases, you have the:

• right to be informed whether or not we process your information and how that information is stored and used by us
• right to access your informationat any time by submitting a SAR to our data protection lead – we will provide information to you within a month of receiving your request
• right to correct the information we hold about you if it is incorrect or incomplete
• right to delete the information we hold about you, which is termed the ‘right to be forgotten’ – it is not always possible to delete all information because of legal reasons or processing requirements but, where this is the case, we will explain this to you in more detail
• right to restrict processing of your information at any time by contacting the relevant department (see Who we are and how to contact us) or our data protection lead – for example, this may be to change how you support us and how we contact you in future
• right to port (move) the information you have provided to us to another organisation – we will give this information to you in a common data format that is accessible to another organisation
• right to object to any processing where you feel we have not sought appropriate consents – in these circumstances we will investigate your concerns and the decisions we have made accordingly
• right to object to automated decision-making where your data is processed by machines and decisions made without human intervention – this also applies to profiling, where decisions may be made automatically to evaluate certain things about you
• right to withdraw consent if we have obtained your consent to process your data – you can withdraw this consent at any time by contacting our data protection lead, and this will not affect the lawfulness of processing based on consent before its withdrawal.

For more information about your rights, or to request a change in line with your rights set out in this Privacy Notice, please contact our data protection lead at dp@independentage.org.