This document sets out our full Data Protection and Privacy Policy to explain what personal information we hold, how we may use it and what your rights are.  If you don’t have time to read the whole policy now, the introductory Privacy Notice is a brief summary of the policy.

PRIVACY NOTICE

This Privacy Notice summarises, and forms part of, our Data Protection and Privacy Policy which immediately follows it.  At LLHM we protect your rights and we provide you with a clear route to contact us about the data we process that relates to you personally.

In carrying out our day-to-day activities we process and store personal information relating to our entrants and participants and we adhere to the requirements of the UK Data Protection Act (DPA) 1998 and, on implementation, the General Data Protection Regulations (GDPR) 2018.

For the purposes of this Privacy Notice and our full Data Protection and Privacy Policy:

• ‘Processing data’ means obtaining, recording or holding information, or carrying out an action such as organising, disclosing or destroying the information.

• ‘Direct marketing’ means the communication of any advertising or marketing material which is directed to particular individuals.

• ‘Administration’ means the processing of data which excludes any element of direct marketing.  Examples include: sending race packs to race participants; sending you your iTAB (please see Paragraph 11 Information Sharing and Disclosure) through the post if you have ordered one.

If you do not participate in a race you can exercise choice over the types of communication and information you receive from LLHM Ltd. You can change your mind at any time, or ask to see the information we hold about you, by contacting the Data Controller: LLHM Ltd, Nicholas House, 3 Laurence Pountney Hill, London, EC4R 0BB, or by phone on 0207 398 3422 or via email at [email protected]

However, if you participate in an LLHM event, there are some communications and information  that are a condition of entry, such as:

• We must send you communications in advance of, and after, the race, including your start time and wave colour; and

• You will be photographed and filmed during the race.  Photography and video footage will be broadcast through social media and/or television, and may be used by LLHM for marketing purposes.

• Your start times and your results will be published on LLHM’s website.

You cannot exercise a choice about these conditions of entry.  Please see Paragraph 9 Consent and legitimate interest.

We collect information about:

• Visitors to our websites and owned social-media channels (eg LLHM’s Facebook page, Twitter and Instagram), including race participants.

• People who contact us to complain, or make an enquiry or request about data protection or freedom of information.

• Volunteers who provide support at LLHM events.

We collect:

Personal data.  Examples are names, dates of birth, email addresses and postal addresses.  For more examples please see Paragraph 5 of the full policy.  We also collect Internet Protocol (IP) addresses: this is information a computer uses to identify a networked computer to which it transmits.

Non-personal data.  An example is the web pages accessed on a computer: we collect this information so that we can show users the articles they have recently read, and improve their user experience.

 We collect information that we need to, or that we believe would be useful to provide our services, products and information (see Paragraph 8).  These purposes comprise:

• Fulfilling LLHM’s legal obligations

• Administration

• Marketing.

We seek your consent if consent is necessary.  To assess whether consent is necessary we carry out a balancing exercise between your rights and expectations, and our legitimate interests to carry out the data processing activity, consistent with the law.

We will never sell your data to any individual or organisation.

We will only pass on your information:

• If we are legally required to do so

• To a third party which is acting on our behalf to fulfil a service that we provide, or (see Paragraph 11 Information sharing and disclosure).

• You opt-in to us doing so

We keep the information we hold about you accurate and up-to-date so far as we are able.

We follow the Code of Fundraising Practice for the UK, issued by the Fundraising Regulator, to ensure that we treat all donors, including vulnerable donors, fairly.

If you ask us to remove your personal information from our records, we will make efforts to ensure we have identified the correct record on our system, and we will review the data to ensure that we are not required to hold it for legal or financial reasons. If, once these actions have been taken, we determine that we have no legal or financial obligation to keep your data, we will delete the information we hold about you from our records.

• We use a secure server for all areas of our website which collect personal information.

• We use cookies and third party pixels to help us track the success of our online advertising and to monitor the use of our website.

• We review and update our application of this policy at least every four years.

 
DATA PROTECTION AND PRIVACY POLICY

1. Who we are and what we do

The LLHM is a closed-road central-London run and is the only half-marathon to go through both the City of London and City of Westminster. It is organised by baby charity Tommy’s to benefit themselves and many other good causes.

Tommy's exists to save babies' lives. It funds research into the causes and prevention of pregnancy complications that lead to miscarriage, stillbirth and premature birth.  It also provides pregnancy health information for parents-to-be.

LLHM Limited (registered company in England and Wales number 10584979) was established in January 2017 and is a wholly owned subsidiary company of Tommy’s.  Tommy’s is registered as a charity in England and Wales (registered charity number 1060508), and in Scotland (registered charity number SC039280). Tommy’s is also registered as a company limited by guarantee (company number 3266897).

Within the context of this policy ‘we’ means LLHM Limited.


2.  Data protection regulations

In carrying out our day-to-day activities we process and store personal information relating to our participants and we adhere to the requirements of the UK Data Protection Act (DPA) 1998 and, on implementation, the General Data Protection Regulation (GDPR) 2018.

We take our responsibilities under data protection regulation seriously and we ensure the personal information we obtain is held, used, transferred and otherwise processed in accordance with those regulations and all other applicable data protection laws and regulations including, but not limited to, the Privacy and Electronic Communication Regulations.

3.  Definitions

Ballot Place: A ballot place is a place that LLHM Ltd sells in the event to enable entrants to participate. There are only a limited amount of ballot places available and in order to secure a ballot place, participants need to enter the LLHM Ballot and runners are selected at random.  If a participant is successful in obtaining a ballot place through the LLHM Ballot, they can choose to fundraise if they wish, but it is not compulsory.  If a participant is unsuccessful in obtaining a ballot place through the LLHM Ballot, the only way they can get a place is through a charity.  A ballot place is sometimes referred to as a ‘Public Place’ or ‘Own Place’

Ballot Place Runner: A participant who has been successful in securing a Ballot Place

Charity Ballot Place Runner: A Ballot Place Runner who has chosen to fundraise for another charity

Charity Place:  A Charity Place is a place that a charity will buy in the event from LLHM Ltd. The charity will then market their Charity Places to their supporters and request a minimum fundraising commitment in return

Charity Place Runner: A participant who has taken one of our charity partners’ Charity Places.


4. What is personal data?

Personal data is information that can be used to identify an individual, such as name, address, phone number or email address.


5. What personal information do we collect, and why?

Personal information is information that can be used to identify you. It may include your:

• Name

• Date of birth (we collect this to ensure you are over 17 years old on race day)

• Email address

• Postal address

• Bank account details

• Job title and employer

• Mobile and landline telephone numbers

• Gender

• Marital status (we ask for the title by which data subjects prefer to be known).

It may also include:

• Details of any opt-in and opt-out preferences you have communicated to us

• Details of any payments you have made to LLHM

• Details of any LLHM events you have participated in

• Notes relating to our relationship with you.  Examples of this could be:

• Correspondence between you and LLHM

• Connections between you and other individuals or organisations known to LLHM.

 

These lists are not comprehensive, but they are intended to give an indication of the sort of information we collect.

We collect this personal information about you when you enter our ballot, register your details with us as a charity place runner and engage with our social media.  (In respect of social media we collect information about gender, age and location only.)  If you do nothing other than read pages or download information from our website, we may gather information about this use, such as which pages are most visited and which events or activities are of most interest.  This information can be used to help us improve our website and services and ensure we provide you with the best service.  The information we use for this purpose is aggregated or anonymised, ie it will not identify you as an individual visitor to our website.  More information can be found in Paragraph 15 Our website and social media.

In recording this information, we apply all the usual data protection principles outlined in this policy, so people sharing this information can feel confident that this information will not be used or stored inappropriately, and they retain the right to access this information or to request its removal at any time.

If you use your credit or debit card to pay for your place, buy something or pay online or over the phone, we will ensure that we manage this securely and in accordance with the Payment Card Industry Data Security Standard.

We do not store your financial information for longer than we need to.


6. Sensitive personal data

Sensitive data, as defined by the GDPR, comprises:

• Physical or mental health or condition

• Sexual life

• Racial or ethnic origin

• Political opinions

• Religious or similar beliefs

• Trade union membership

• The commission or alleged commission by the data subject of any offence, or any proceedings for any offence that are ongoing.

We collect sensitive personal data about our participants only if there is a clear reason for doing so.  For example:

• LLHM acts as a Race Organiser, and to do this we collect information about any disability or medical condition you may have if you are planning to participate.  We pass this information on to our Event Management Company and the Event Medical Director, to ensure we provide appropriate support to enable you to participate and to make provision, where possible, for any medical emergency at the event.


7.  Our data-administration platforms

Our current data-administration platforms are listed below, but we reserve the right to change our platforms from time to time.

Active Network email tool: This is the email tool we use within Active Network to communicate about the event (including information about charity partners and sponsors) as LLHM Ltd, to LLHM participants

Ballot registration platform: This is the Active Network system which LLHM Ltd uses to allow people to enter the LLHM ballot, and make payment for their place if they are successful

LLHM Event Portal: The is a password-protected portal within Active Network which allows LLHM Ltd to have a full overview of all LLHM participant data

Charity Event Console: Each of our charity partners is given access to a private, password-protected section within Active Network. This allows our charity partners to register their charity place runners with LLHM Ltd, so we have their runners’ details

LLHM Dropbox: This is the secure digital file-sharing solution we use to share data with our partner organisations

Raiser’s Edge: This is the database which LLHM Ltd uses to store the data of any ballot place runners who have made a payment LLHM Ltd

Fat Beehive: This is the partner organisation that LLHM uses to manage our website and our pre-registration.


8. How do we use the information we process?

We may collect and use your personal information for a number of reasons, including:

•    In the provision of services, products or information you have requested

 

Here are some examples of how we use your information at different stages of our event management:

Pre-register examples

LLHM may allow people to pre-register.  Our pre-register system captures an interested participant’s first name, surname and email address.  This data is stored in the LLHM website which is password-protected and only accessible by the LLHM and Fat Beehive teams (please see Paragraph 11 Information Sharing and Disclosure).  As the form is very simple and contains no opt-ins, we only use this data to communicate with people by email specifically with information about entry into the event.  To communicate with anyone who has pre-registered we download a data list from the LLHM website, which we save on the LLHM shared drive.  We then upload this data into the Active Network email tool (please see Paragraph 7 Our data-administration platforms) to email the interested participants.  After the email has been sent, we delete the data file from our shared drive.  After pre-register is closed, we delete all data from the LLHM website.

LLHM ballot process examples

When a person enters the LLHM ballot, what happens with their data differs depending on whether they are unsuccessful or successful in the ballot.  During the ballot process applicants are asked a number of questions, and the table below sets out what happens with the data in the response that they give.

Question

What happens to the data?

 

Enter the general ballot

If a person enters the LLHM ballot their data will be saved in Active Network. The ballot form contains numerous opt-in questions and the person’s data will only be passed on to partner organisations should the entrant opt in to it being shared. The opt-in questions and how the data is shared are set out below.

Personal details including name, address, date of birth, email address and contact number

The data of all successful ballot applicants is shared with Human Race and Race Ahead, through a password-protected document through the LLHM Dropbox.

If a successful participant has ordered an iTAB, this data is also sent from Race Ahead to i-TAB, together with the individual’s finish time, via a password-protected document so i-TAB can fulfil the i-TAB order.

 

If an entrant has opted in to hearing from a charity partner or event partner or sponsor this data is also shared as set out below

Emergency contact details

This data is shared with Human Race in a password-protected document through the LLHM Dropbox in case of an on-the-day emergency situation.

Estimated finish time

This data is shared with Human Race in a password-protected document through the LLHM Dropbox to help assign wave times

Medical information

This data is shared with Human Race in a password-protected document through the LLHM Dropbox in case of an on-the-day medical incident

Are you happy to be contacted by LLHM Ltd in relation to entry into future events?  If yes, how are you happy to be contacted?

If a participant ticks ‘yes’ the entrant’s information along with their contact preference is uploaded on to Raiser’s Edge to enable LLHM Ltd to get in touch with them in the future whilst they remain ‘opted-in’

Would you like to run for Tommy’s in the London Landmarks Half Marathon?

If yes, how are you happy to be contacted?

If a participant ticks ‘yes’, the entrant’s information along with their contact preference  is uploaded on to Raiser’s Edge and Tommy’s will contact the person by the preferred means they have specified

Would you like to hear more about Tommy’s work?  If yes, how are you happy to be contacted?

If a participant ticks ‘yes’, the participant’s information along with their contact preference is uploaded on to Raiser’s Edge and Tommy’s will contact the person by the preferred means they have specified

Would you like to hear from event sponsors in relation to special promotions and offers?

If yes, how are you happy to be contacted?

If a participant ticks ‘yes’, the participant’s information will be passed on to the event sponsors, together with their preferred means of communication.  We share this information via a password-protected Dropbox to ensure secure file-sharing.

Would you like to hear from any of our other partner charities in relation to fundraising for the London Landmarks Half Marathon?  If yes, how are you happy to be contacted?

If a participant ticks ‘yes’, the participant’ information will be passed on to the partner charity (via a password-protected report created by the Race Organiser and hosted by the Active Network console), together with their preferred means of communication.

Would you like to hear from any of our other partner charities in relation to their work?  If yes, how are you happy to be contacted?

If a participant ticks ‘yes’, the participant’ information will be passed on to the partner charity (via a password-protected report created by the Race Organiser and hosted by the Active Network console), together with their preferred means of communication.

 

For administration purposes.  For example:

• For internal record-keeping, such as the management of feedback or complaints

• To record website traffic or to personalise the way our information is presented to you.

 

For legal purposes.  For example:

• Where the processing is required or authorised by law

• For the purposes of credit risk reduction or fraud prevention (regrettably some people target charities for illegal purposes such as money laundering, and we are therefore required to monitor financial activity and report suspected fraud to the appropriate authorities).

 

For marketing and PR purposes.  For example:

• We may contact you by mail, email, phone, text or social messaging; in some cases, this will require getting your consent.

• If you share a personal story with us when you complete your registration we may invite you to consent to future communications from us and to sharing your story more widely. 

We do not need your consent to process your data for legal purposes or for many administrative purposes, but in some cases we do need your consent to process your data, including for direct-marketing purposes (see Paragraph 9 Consent and legitimate interest).

If you have asked us not to use your information for marketing purposes we will retain your name, home address and email address on a suppression list to ensure we do not continue to contact you.

9.Consent and legitimate interest

For some data processing activities we may need your consent before we can contact you.  We carry out a balancing exercise to assess whether or not we need your expressed consent to conduct our activities.  To do this, we consider both the content of the personal data that we collect and the way in which we wish to use that data.

In some cases our balancing exercise concludes that opt-in consent is required, for example for some direct-marketing activities.  Where consent is required we ensure that no direct marketing takes place unless you have ‘opted in’.

For example we may wish to email LLHM participants, post the event, in relation to entering a future year’s ballot.  But our balancing exercise shows that the donor’s right to privacy and reasonable expectations over-ride LLHM’s interest in continuing contact with them, and therefore we need to obtain explicit consent for communication into future years’ events.

In other cases our balancing exercise concludes that opt-in consent is not required for us to process the data, because we have a legitimate interest in processing the data that is not overridden by the individual’s rights and interests.

Here are all our balancing exercises.

Conditions of entry into the race

Having taken the advice of the Information Commissioner’s Office, we require your agreement to the following activities as a condition of your entry into the race:

Condition of entry 1: Photograph and filming

During the LLHM runners will be photographed. Photos will be uploaded into the results section of the LLHM website and app and will be searchable by bib number or participant name.

During the LLHM runners will be filmed. This video footage will be broadcast through social media and/or television

LLHM Ltd reserves the right to use photos and videos of runners for marketing and promotion purposes and this is a condition of entry into the event

Condition of entry 2: Start times

Start times for the LLHM will be published on the LLHM website in advance of race day. This document will contain the participant’s first name, surname, wave colour and start time and is a condition of entry into the event

Condition of entry 3: Results

LLHM results will be published through the LLHM website and app and are searchable by bib number or participant name.

These are all conditions of entry into LLHM Ltd’s events. 

If you do not agree with these conditions of entry, you must not participate in the event.

10.      Your rights and preferences

We use the following statement to invite you to express your preference for how you would like to us to retain contact with you.

Are you happy to be contacted by us in relation to  LLHM Ltd organised events?

• Yes
• No

If yes, how are you happy to be contacted?

• Email
• SMS
• Telephone

In this way we give you the opportunity to opt in or opt out of further communications with us, and to express your preferred method of communication.  If you have opted in to further communications we will automatically invite you to update this option every four years; or at any appropriate earlier time that is required.

11.  Information-sharing and disclosure

LLHM Ltd will share your information with some of our partner organisations, who are our data processors.  Our partners are organisations which carry out activities for us such as managing our registration processes and our race pack fulfilment.

We may also disclose your personal information to third parties if we are required to do so by a legal obligation (for example to the Police or a Government body); or to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for example, in the case of suspected fraud or defamation.

Our current data processors and partner organisations are listed below, but we reserve the right to change our processors and partners from time to time.  We will not share your information for any other purposes.

Active Network: Active Network is the partner organisation that LLHM Ltd uses to:

• Manage the LLHM Ballot
• Take payment from the successful ballot applicants
• Hold the data of our ballot place applicants
• Hold the data of our Charity place runners (this includes Tommy’s charity place runners)
• Email all LLHM participants

Human Race: Human Race is the partner organisation that LLHM Ltd uses to:

• Manage the logistics of the race day delivery
• Assign participants their bib number
• Manage participant emergency contact and medical information in case of an on-the-day incident
• Produce the fulfilment files for our race packs.  This involves communicating personal data about participants to enable Race Ahead (see below) to produce packs of race information for participants which include our Race Guide and running vests

Race Ahead: Race Ahead is the partner organisation that LLHM uses to:

• Fulfil our race packs
• Manage our chip timing (to record runners’ individual times on event day)
• Manage our event photography
• Manage our results: for example publishing finish times on a website, or potentially sending an individual participant his or her finish time by text.

i-TAB: i-Tab is the partner organisation that LLHM uses to produce our medal inserts which are engraved with a runner’s time should a participant purchase an insert.

Fat Beehive: Fat Beehive is the partner organisation that LLHM uses to manage our website and our pre-registration.

We may also disclose your personal information to third parties if we are required to do so by a legal obligation (for example to the Police or a Government body); or to enable us to enforce or apply our terms and conditions or rights under an agreement; or to protect us, for example, in the case of suspected fraud or defamation.

12.      Vulnerable supporters

We recognise the importance of protecting our vulnerable supporters and we follow the Code of Fundraising Practice in the UK issued by the Fundraising Regulator on treating donors fairly. We believe this helps to support our staff and professional fundraisers (who may not be directly employed by LLHM) who come into contact with participants to provide high quality customer care.

13.  The accuracy of your information

Our aim is for all information that we hold about you to be accurate and, where necessary, kept up-to-date.  If any of the information we hold about you is inaccurate and either you advise us of this or we become aware in another way of its inaccuracy, we will ensure it is updated as soon as possible.

14. Storing your information

We may transfer your personal data to a country outside the European Economic Area (EEA), if one of the following conditions applies:

The country to which your personal data is transferred ensures an adequate level of protection for your rights and freedoms; or
• You have given us your consent; or
• The transfer is necessary for one of the reasons set out in the Act, including the performance of a contract between you (the data subject) and us, or to protect your vital interests;
• The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims; or
• The transfer is authorised by the relevant data protection authority where we have adequate safeguards with respect to the protection of your privacy, your fundamental rights and freedoms, and the exercise of your rights.

We currently use the services of a supplier (Active Network) which stores our data in the US.  Wherever your data is secured we seek to ensure that data storage standards are consistent with the standards of the Data Protection Act and the General Data Protection Regulation.

By submitting your personal information you agree to the transfer, storing or processing at a location outside the EEA.  We will take all reasonable steps to ensure that your data is kept secure and in accordance with this privacy policy.

It is a condition of entry when applying for a place in LLHM to accept Active Network’s terms and conditions.  Please view Active Network’s terms and conditions and privacy policy before agreeing.

Retention of data relating to own-place runners (and Tommy’s charity place runners)

Your record will be deleted if we have had no contact or interaction with you over a period of seven years, and you have opted out of communications.  This retention period has been determined with consideration for our legal obligations and tax and accounting rules, and we reserve the right to change it to reflect subsequent changes in those rules and obligations.  

Retention of data relating to other charity place runners

Unless you have opted in to receiving communications from LLHM Ltd, we do not hold your data if you are running for a charity other than Tommy’s.

15.      Our website and social media

By using our website, social media pages, entering a competition or providing your information, you consent to our collection and use of the information you provide in the ways set out in this policy.  If you do not agree to this policy please do not use our website, social media pages or services.

Our websites use cookies to help them work well and to track information about how people are using them. More information on cookies can be found in Paragraph 16.

For all areas of our website which collect personal information, we use a secure server. Although we cannot 100% guarantee the security of any information you transmit to us, we enforce strict procedures and security features to protect your information and prevent unauthorised access.

We use Fat Beehive to help us with our web design.

Our website contains links to other websites belonging to third parties and charity partners and we sometimes choose to participate in social networking sites including, but not limited to, YouTube and Facebook.  We may also include content from sites such as these on our website. However, we do not control the privacy practices of these other sites.  You should make sure when you leave our site that you have read and understood that site’s privacy policy in addition to our own.

16.Cookies

A cookie is a small file of letters and numbers that we may put on your computer or mobile device when you access our website.  Cookies allow us to distinguish you from other users of the website, helping us to provide you with a good experience when you browse our website and also allowing us to improve our site. For example, they will tell us whether you have visited our site before or whether you are a new visitor.  Another example is enabling us to show you articles that you have recently read, so that you can access them again more easily.

LLHM uses cookies and third party pixels to help track the success of our online advertising and monitor the usage of our website. We use Google Analytics for our web analytics. With cookies, the information we collect and share is anonymous and does not personally identify you. It does not contain your name, address, telephone number, or email address.

Cookies can be set by the website you are visiting (first-party cookies) or by other websites (third-party cookies) whose content we are hosting, eg YouTube.

Most web browsers allow at least a degree of control over cookies through their settings. You can opt to receive an alert whenever a cookie is set or to disallow the setting of cookies altogether. You can also delete all existing cookies.

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of LLHM’s website and many other websites that you visit. For information about how to manage or delete cookies for your particular browser, please refer to the browser’s help section. Alternatively you can visit www.aboutcookies.org, which has comprehensive information on how to manage cookies on a wide variety of desktop browsers.

17.      Policy changes

We may update the terms of this policy at any time, so please do check it from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us, or by placing a prominent notice on our website(s). By continuing to use our website you will be deemed to have accepted such changes.

18.Reporting data breaches

We will report any data breach within 72 hours (where feasible) of the breach having come to our attention.  Data breaches will be reported to the Information Commissioner’s Office, the data subject and, where relevant, the charity partner who has shared the data with us.

19. Review

We review our application of this policy in three ways:

• Every four years we review our approach to consent and the balancing of legitimate interest with the rights and interests of the individual.  If the balancing exercise indicates a different approach would be appropriate we change our approach accordingly.
• We monitor and regularly assess your feedback.  If the feedback assessment indicates a different approach would be appropriate we change our approach accordingly.
• We review this policy if there is a change in the law that requires us to do so.

20.      Responsibilities

All employees who process data are responsible for complying fully with this Data Protection and Privacy Policy.  Breach of this policy by an employee will normally result in the Disciplinary Procedure being implemented.

Self-employed contractors and volunteers are notified of their responsibilities when they begin delivering services to LLHM or volunteering with LLHM.  Breach of this policy by a contractor or volunteer will normally result in the termination of the Contract for Services or the Volunteering Agreement.

21.  Your rights

You have the right to:

    Request a copy of the information we hold about you

    Update or amend the information we hold about you if it is wrong

    Change your communication preferences at any time

    Ask us to remove your personal information from our records.

    Object to the processing of your information for marketing purposes, or

    Raise a concern or complaint about the way in which your information is being used.

 

22.  Queries

If you have any questions or queries about this Privacy and Data Protection Statement, or if you would like to request a copy of the information we hold about you, please contact the Data Controller at the address and contact details below.

Private Information Request:
Data Controller
LLHM Ltd
Nicholas House
3 Laurence Pountney Hill
London
EC4R 0BB

Tel: 0207 398 3422
Email: [email protected]

Data Protection Officer: 
Lia Bowman
Race Director 
([email protected])