Privacy policy

This page outlines our privacy policy to explain what personal information we hold, how we may use it and what your rights are.

At Tommy’s we are committed to protecting your personal data and helping you understand what we are doing with it. We will use your personal data in compliance with all data protection laws, keeping it safe and using it in ways that you would reasonably expect.

1. Who are we and what do we do?

Tommy's is the leading charity in the UK working to improve maternity care and save babies' lives. We fund research into the causes and prevention of pregnancy complications that lead to miscarriage, stillbirth and premature birth. We also provide health information to support parents throughout their pregnancy journey.

Tommy’s is registered as a charity in England and Wales (registered charity number 1060508), and in Scotland (registered charity number SC039280). We are also registered as a company limited by guarantee (company number 3266897).

There are 2 wholly owned subsidiary companies of Tommy’s:

The Baby Fund Trading Limited (registered company in England and Wales number 2557706), to record our activity classed as trading, including the selling of sponsorship rights, and
LLHM Limited (registered company in England and Wales number 10584979), to manage our event-driven activity, specifically the London Landmarks Half-Marathon.

Within the context of this policy, ‘we’ means the charity Tommy’s, and The Baby Fund Trading Limited. LLHM Limited has its own Privacy Policy.

We are located at:

Nicholas House,
3 Laurence Pountney Hill,
London EC4R 0BB

Telephone: 0207 398 3400

Email: [email protected]

2. Where does Tommy’s collect your personal data from?

Tommy’s collects your personal data from the following places:

When you give it to us

This is the main way that we collect personal data about you. You give us information when:

You fundraise for Tommy’s by organising or taking part in an event
You donate money directly to Tommy’s
You contact Tommy’s to provide you with support or information
You contact Tommy’s to share your personal experiences
You order goods or services from Tommy’s
You complain to us about something that we have done
You apply to work for us
You sign up to charity and fundraising activities and appeals
You sign up to receive information and service communications
You register on the My Prem Baby app or other support tools we provide

When you give permission to other organisations to provide Tommy’s with your personal data

We receive personal data about you from an event organiser e.g. London Landmarks Half Marathon when you have asked them to share your personal data with Tommy’s, perhaps because you are running and raising money for Tommy’s.

We also receive personal data about you from an online fundraising site such as Just Giving. These organisations will only provide us with your personal data if you have given your consent to do so.

We also receive personal data about you if you make a donation via social media e.g. Facebook.

When your personal data is available publicly

In order to grow our income and meet the charitable objectives of Tommy’s we undertake prospect research to supplement the information we hold about potential donors. This is explained fully in 6. Prospect research and helps us build a better picture of our potential supporters.

We receive information about you from social media accounts, for instance if you tag Tommy’s in one of your posts.

3. What personal data does Tommy’s collect?

Personal data is information that can be used to identify you.

Tommy’s collects and stores the following personal data where it is relevant and needed in your contact with us:

Personal information about you such as your name, gender, marital status, date of birth, contact details (including postal address, telephone number, email address, social media identity)
Financial information such as your bank account or credit card details where you provide these to make a payment, or your tax status to enable us to claim gift aid
Your marketing preferences such as whether you wish to receive our e-newsletters
Donation information such as details of any gifts you have given to Tommy’s
Event information such as details of any Tommy’s events you have registered for or participated in
Information which helps us understand our relationship with you and your reasons for supporting Tommy’s
Employment information such as your job title and your employer
Publicly available information such as data gathered through prospect research
Visual information about you such as photographs and, in the case of certain events, film
Medical and pregnancy information (physical or mental health conditions) about employees, race participants and users of pregnancy tools
Personal experiences of Tommy’s support, from people who share this information with us
Information about your activities on our website and about the device you use to access these, such as your IP address and geographical location.

4. How do we use your personal data?

How we use your personal information will depend on how you interact with us.

The details below set out how you could interact with Tommy’s, what we are doing with your personal data, our lawful basis for processing your data, and our legitimate interest (if we are relying on this).

We will only keep your information for as long as we need it. The maximum period will be 7 years since our last interaction with you.

The lawful bases we use to process your personal data are: -

⦁ Consent

This is where we have asked you if we can use your personal data in a certain way and you have clearly agreed to this. If we are relying on consent as our lawful basis to process your personal data, you have the right to withdraw your consent at any time.

⦁ Legal obligations

If we are relying on this as our legal basis to process your personal data we are complying with a common law or statutory obligation.

⦁ Fulfilling contracts

This is where we need to process your personal data in order to fulfil a contractual service to you.

⦁ Our legitimate interest

This is where we are processing your personal data in ways that you would reasonably expect. If we are using this basis, we have conducted a legitimate interest assessment to make sure that we have a legitimate interest, that the processing is necessary to achieve that interest and that we have balanced our interests against your interests, rights and freedoms.

Where we are relying on this basis, we have outlined a summary of our legitimate interest.

If you are in contact with us or use our services, we may ask you if you would like to hear from us about our charitable and fundraising activities. You can unsubscribe from hearing from us at any time. This will not impact the service you receive from us.

5. Who do we share your personal data with?

At Tommy’s we will only share your data when we have a need to do so. The main reasons will be to provide you with the service you require eg processing payments from you via BACS or because we are using the services of a specialist company where we do not have the necessary expertise.

We will never sell your information to a third party for marketing purposes. We ensure that all organisations that are processing your personal data on our behalf have the highest standards of security and will not use your personal data for anything other than our agreed purposes that we have set out in this policy.

We may share anonymised data relating to specific health conditions or lifestyle issues with non-profit health research organisations with the aim of improving public health, and it may be used in research publications. This will only be done in an anonymised manner.

We will share your information with third parties in the following circumstances: -

When we share your personal data	The organisations we share your personal data with	Why we share your personal data
If you sign up to attend an event which promotes Tommy’s and helps us fundraise	Companies that develop and manage online booking tools	To facilitate your booking process
If you sign you or your child up to participate in or attend a fundraising event for Tommy’s	The organiser of the event	To ensure the organiser of the event knows who is taking part and can manage the event
If you participate in an event and consent to us using your images and/or those of your child	Social media organisers, PR companies and local media	To publicise Tommy’s work and to maximise fundraising
If you consent to receive emails or SMS from us	Companies that have the necessary technological and administrative skills to send mass communications on our behalf	To update you on our work, your fundraising and donations, to track your actions and to prompt you to complete an order/donation in the most cost effective and efficient manner
If you order fundraising materials or event clothing from us	A specialist warehouse and logistics company to fulfil your orders	To fulfil your orders in the most cost effective and efficient manner
If you receive a letter thanking you for your support or to advise you of your direct debit schedule	A specialist fulfillment company to prepare and dispatch your letters	To write to you in the most cost effective and efficient manner
If you make or receive payments to or from us	BACS clearing houses, our bank and card payment providers	To process your payments and receipts
If you access our website	A specialist company that develops and maintains the Tommy’s website	To ensure that our website functions correctly, is easy to navigate and is secure
If you have indicated that you wish to gift aid your donations	HMRC	To ensure that we can reclaim UK tax and maximise your donation
If you have contacted us to provide you with general or personal support and information	A specialist company that develops and maintains the Tommy’s website if that is the way you have contacted us; A specialist company that has the necessary technological and administrative skills to send out mass emails on our behalf if this is what you have requested to receive	To provide you with the appropriate support that you have requested through the most appropriate communication channel
If you use our support services or tools such as the My Premature Baby App	Specialist companies that have the necessary technological skills to provide these services	To provide you with the appropriate support you have requested
If you subscribe to e-learning modules and/or make use of Tommy’s online services for pregnancy and parenting at work support	Companies that develop and manage online systems providing pregnancy and parenting at work support	To enable us to provide you with the pregnancy and parenting at work support you have requested
If you consent to share your personal story with us	Current and potential donors;	So that people can understand the work that Tommy’s does
If you complete a survey for us on an event or about a service, we have provided	Specialist organisations that develop and maintain online survey tools A specialist company that develops and maintains the Tommy’s website	To continually assess and improve our services
If you have participated in an event supporting Tommy’s	A specialist agency that uses your anonymised data to identify and market Tommy’s events to potential entrants	To maximise fundraising
If you apply for a job at Tommy’s, you may be asked to complete a psychometric assessment	A firm of occupational psychologists	To help us match the right people for the right jobs
If we have a regulatory or legal obligation	The police, regulatory bodies, legal advisors or auditors	To ensure we meet our regulatory and legal obligations
If you place an order from our online shops or Dance with Peppa shop	A specialist ecommerce website when you place an order. A specialist warehouse and logistics company to fulfil your orders.	To receive and fulfil your orders in the most cost effective and efficient manner

6. Prospect research

Identifying prospective donors is necessary to securing donations from trusts and major gifts from individuals, so that we can grow our income and meet Tommy’s charitable objectives.

Our approach to prospect research complies with current law; we will update our approach should the legal position change.

Prospect research helps us to:

Identify if a potential donor may have the capacity and propensity to give major gifts to Tommy’s; and
Identify how best to approach them.

Prospect research includes manually gathering public and freely given information from the Internet, from Tommy’s contacts and from Tommy’s own donor records, and creating profiles to help us identify individuals, trusts, foundations and corporations able to give at this level. This means that we:

Create short profiles of potential donors, using public and freely given sources of data to identify people who may be able and predisposed to give major gifts. The type of information we may collect in profiles includes:
- Career history, areas of interest, connection to Tommy’s
- Gift capacity based on visible assets and previous charitable giving.

The data sources we use include:

- Charity Commission data (which identifies trustees of grant-giving trusts, and charitable aims)
- Other sources of information about charitable trusts’ giving, for example trustfunding.org.uk, trust websites, charity trade press
- Companies House data (which identifies company directors)
- Mint UK (a comprehensive database of UK companies)
- Company and charity websites which profile, for example owners, senior partners, or Trustees
- News articles about business, financial or philanthropic decisions
- Public media where individuals have volunteered information about their interest or experience with pregnancy complications, for example interviews where individuals have spoken publicly about miscarriage
- Public social media accounts, e.g. a company’s Facebook or LinkedIn page, or an individual’s public Twitter account which has a primarily professional function.

Create queries on our database to identify past donors who may have given at major-gift level in the past, and therefore could do so again
Database postcode reviews of current donors
Review lists of individuals signing up to Tommy’s fundraising events (and have opted into communications) to look at the reasons that people give, their job titles, their family name (if they are well-known/in the public eye) and postcodes. We use this information to target personalised invitations to engage further with Tommy’s at those who are most likely to be interested.
Identify where our Trustees, Fundraising Board or staff may be able to help with an introduction, for example because they move in the same professional social circles as a potential donor.

We do not seek consent to our prospect-research activities as defined above, because we believe we have legitimate interest which is not over-ridden by the individual’s fundamental rights.

For prospect-research purposes we gather sensitive data only in the form of information about experience of pregnancy complications which the subject has willingly put in the public domain or shared with Tommy’s. We do not:

Gather data from personal sources such as personal Facebook and Twitter accounts
Conduct automated wealth-screening using external agencies.

We want all individuals who come into contact with Tommy’s to have a positive experience, whether or not they are donors. We believe that the way we carry out prospect research will help us to identify potential donors efficiently, and to avoid making inappropriate or excessive approaches.

7. Automated decision-making

Tommy’s does not carry out profiling or take significant decisions about individuals by wholly automated means. The only exception to this is where Tommy’s collates email addresses of previous years’ participants in sporting events who have fundraised for Tommy’s. This data is used to target potential participants to fundraise for Tommy’s at future sporting events.

8. Storing your information outside the EEA

In very limited circumstances, Tommy’s may transfer your personal data outside the European Economic Area (EEA). Tommy’s will ensure that the country to which your personal data is transferred ensures an adequate level of protection for your rights and freedoms.

9. EU representative

Tommy’s does not have an office in the EU but if you reside in the EU and Tommy’s processes your personal data or you are an EU supervisory authority, you can contact our EU representative who is based in the Republic of Ireland with any queries or concerns you may have. Please email [email protected].

10. Your rights

You have the following rights:

The right to be informed of how your personal data is used – we do this in the Privacy Policy and providing links to this Privacy Policy when we are collecting personal data from you.
The right to access your personal data – you can submit a request to find out about the information we hold about you.
The right to object to the processing of your personal data – if we are processing your personal data under the legitimate interest lawful basis.
The right to have your personal data rectified – you can request that we correct your personal data if it is incorrect or incomplete.
The right of portability of your personal data – you can request that some of your personal data is transferred to you or to another organisation.
The right to be forgotten – you can request that we delete your personal data.
The right to have your personal data restricted – you can request that we stop processing your personal data and only store it.
The right to object to direct marketing – you can object to direct marketing at any point and we will not send you any further marketing communications unless you change your mind.
The right to request that any automated decisions are reviewed by a human
The right to withdraw consent – if we are relying on your consent as our lawful basis for processing your personal data, you can withdraw your consent for processing at any time.
The right to complain about our processing of your personal data – please contact [email protected] so that we can help you. If you wish you can contact the Information Commissioner’s Office on 0303 123 1113 or via their website.

11. Queries

If you have any questions or queries about this Privacy Policy, or if you would like to exercise any of your rights, please contact the Data Protection Officer at the address and contact details below:

In writing: Data Protection Officer, Tommy’s, Nicholas House, 3 Laurence Pountney Hill, London, EC4R 0BB
Tel: 0207 398 3400
Email: [email protected]

Data Protection Officer:

Amy Thomas
Chief Operating Officer

[email protected]

We may at our discretion amend this Privacy Policy from time to time. Please check here to ensure you understand the version of our Privacy Policy which will apply at that time.

This Privacy Policy was last updated in October 2021