This privacy notice explains how St Raphael’s Hospice (“we”, “us”, “our”) collects, uses, and protects your personal data when you take part in our society lottery.
We are the data controller, responsible for ensuring that your information is processed in accordance with data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Our contact details are:
St Raphael’s Hospice
Registered charity number: 1182636
Address: London Road, Cheam, Sutton, SM3 9DX
Email: supportercare@straphaels.org.uk
1. What information we collect
We may collect and process the following types of personal data when you subscribe to or take part in our lottery:
- Name, address, email address, and telephone number
- Date of birth (to confirm eligibility to play)
- Payment details (e.g. debit card, Direct Debit, cheque, or bank transfer)
- Lottery play records (entries, wins, and communications)
- Contact preferences and correspondence historyWe will only collect information that is necessary to operate and administer the lottery.
2. How we use your information
We process your personal data to:
- Administer your lottery membership and process payments
- Run draws and notify winners
- Manage prize payments and financial records
- Comply with our legal and regulatory obligations (e.g. Gambling Commission requirements)
- Respond to your enquiries and provide supportWhere you have given consent, we may also use your information to send you updates or marketing about our charitable work and lotteries.
3. Lawful basis for processing
We rely on one or more of the following lawful bases under the UK GDPR:
- Contract: To enter you into the lottery and fulfil our agreement with you.
- Legal obligation: To meet requirements under gambling, financial, and data protection law.
- Consent: Where you have agreed to receive marketing communications.
- Legitimate interests: To manage and improve our lottery operations in a way that does not override your rights.
4. Who we share your information with
We will only share your personal data where necessary and under a written agreement ensuring it is protected.
(a) External Lottery Manager (ELM)
We appoint an External Lottery Manager (ELM) to run certain aspects of the lottery on our behalf, such as processing payments, running draws, and managing player communications.
Our current ELM is Sterling Management Centre Limited, Suite 8, Second floor, Furness Gate, Furness Business Park, Peter Green Way, Barrow- in- Furness LA14 2PE.
They act as a data processor, and only process your data under our instructions.
(b) Canvassing or Marketing Agencies
Where we use canvassing agencies to recruit new supporters or promote the lottery, they process your information strictly for this purpose under our written direction.
We ensure all agencies comply with UK GDPR and data protection best practice.
(c) Other Third Parties
We may share limited information with:
- Our professional advisers (e.g. accountants, auditors)
- Payment service providers and banks
- Regulatory bodies such as the Gambling Commission or the Information Commissioner’s Office (if legally required)
We do not sell or rent your data to anyone.
5. Data storage and security
Your personal data is stored securely on protected systems within the UK or in other locations within the UK GDPR “adequacy” framework.
We apply appropriate technical and organisational measures, including encryption, access control, and regular security reviews, to keep your data safe.
6. Data retention
We retain your personal data only for as long as necessary to meet our purposes and legal obligations:
| Data Type | Typical Retention Period | Legal/Operational Basis |
| Lottery membership and play records | 6 years after your last lottery entry | Limitation Act 1980 / financial recordkeeping |
| Payment and financial records | 6 years | HMRC/statutory accounting requirements |
| Marketing consent and contact preferences | Until withdrawn or 2 years after last interaction | UK GDPR legitimate interest/consent basis |
| Enquiry or correspondence data | 2 years from resolution | Legitimate interest |
7. Your data protection rights
You have the right to:
- Access the personal data we hold about you
- Request correction or erasure of your data
- Restrict or object to processing
- Withdraw consent (where applicable)
- Request transfer of your data (data portability)
To exercise any of these rights, please contact us at lottery@straphaels.org.uk
If you are not satisfied with our response, you can complain to the Information Commissioner’s Office (ICO): www.ico.org.uk | Tel: 0303 123 1113.
8. Changes to this notice
We may update this privacy notice from time to time. The most recent version will always be available on our website, and we will notify you of any significant changes.