TAKING CARE OF YOUR INFORMATION
ACTION AGAINST HUNGER’S MISSION AND PURPOSE IS TO A WORK FOR A WORLD FREE FROM HUNGER. WE CANNOT DO THIS WITHOUT YOU, WHICH IS WHY TAKING CARE OF THE INFORMATION YOU PROVIDE TO US IS SO IMPORTANT.
Action Against Hunger takes the privacy of the people we help across the world, our supporters and volunteers very seriously. We are strongly committed to protecting your privacy and every reasonable effort is taken to ensure that your information is kept secure and intact.
Please read this policy carefully. The terms of this Policy may change, so please check it from time to time. This version published on Tuesday 22 May 2018 supersedes all previous versions.
If you have any questions, please call our Supporter Care team on 020 8293 6190 or email email@example.com
WHO WE ARE
Action Against Hunger UK Limited (‘Action Against Hunger’) is a registered charity and our registration number is 1047501 in England and Wales and SC048317 in Scotland. We are also a company limited by guarantee incorporated in England (company number 03069468) and have a wholly owned trading subsidiary called Action Against Hunger Enterprises Limited (company number 06569439). Our registered address is Action Against Hunger UK, 6 Mitre Passage, Greenwich Peninsula, London SE10 0ER.
We are a “data controller” for the purposes of the EU General Data Protection Regulation (GDPR).This means that we are responsible for, and control the processing of, your personal information.
WHY WE HOLD AND PROCESS SUPPORTERS’ PERSONAL DATA
GDPR provides the legal framework that defines how personal information can be used. Action Against Hunger is fully committed to complying with the principles set out in GDPR and has a legal duty to protect any information we collect from you. In summary:
- Your personal information is only used for the purpose for which we collect it
- We will hold your personal information on our systems only for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules
- Your personal information is only seen by those who need it to do their jobs
- We will only disclose data when we have your consent, or where we are obliged to disclose personal data by law, or as expressly permitted under the GDPR (through contract; legal obligation, vital interests; public task; or legitimate interests)
- We will keep your information up to date. Inaccurate or misleading data will be corrected as soon as possible
- Your information will be protected from unauthorised or accidental disclosure and processed in an appropriate manner to maintain its integrity and confidentiality
- We will provide you with a copy of your personal information on request (please see below for information on access rights and requests)
These principles apply whether we hold your information on paper or in electronic form.
HOW WE COLLECT INFORMATION
- When you interact with us directly, for example by making a donation, enquiring about our work, attending an event or signing up to newsletters. Sometimes, you may be interacting with an organisation working on our behalf, but we are still responsible for your information.
- When you interact with third parties, for example when making donations to fundraising pages through a third-party website such as Everyday Hero, or sign up to our events via EventBrite, and give permission for your information to be shared with us. Similarly, if you engage with us on social media and messaging services like Facebook, Whatsapp or Twitter, or email services we use such as Mailchimp, you might give us permission to access information from those accounts. The data we are given access to by each third party may vary but will also be in line with the terms and conditions of that particular service
- When you visit our website we may gather information such as what pages you visit or how long you spend reading that particular page. This data helps us to improve your online experiences, such as our choice of words and images that appear on the site
- We may also receive information about you from third parties, for example from mailing list brokers and media companies.
We will only ever collect the information that we need, including data that will be useful to help improve our services. The information is either needed to fulfil your request or to enable us to provide you with a more personalised service. You don’t have to disclose any of this information to browse our sites.
WHAT INFORMATION WE COLLECT
We only collect personal data relevant to the type of interactions you have with Action Against Hunger.
The personal information we collect might include name, date of birth, email address, postal address, telephone number, taxpayer status (for Gift Aid eligibility) and credit/debit card details.
We may also collect information about the donations you make to us, events you register to attend, fundraising you do for us, and details from any interactions you have with our Supporter Care team.
Sensitive Personal Data
We do not collect “sensitive personal data” about our supporters, e.g. health status, unless there is a clear reason for doing so – such as participation in a marathon or similar fundraising event where we need this to ensure that we provide appropriate facilities or support to enable you to participate in the event. All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
WHY WE COLLECT THIS INFORMATION
We collect and hold supporters’ personal information so that we can promote our work. We will ask for your consent before we use your information for certain purposes, such as sending you emails about upcoming events. We may also use your information where we have a legitimate interest in order to carry out our activities. Examples of this include:
- To provide you with services, products or information you have requested, or that we feel would be of interest to you and reasonably expected by you
- To process donations, payments, gift aid, event registrations or other administrative activities
- To provide you with personalised updates on our work and the difference your support is making, and to provide you with other ways you can support us, where you have agreed to receive this
- To conduct market research or ask you to participate in surveys
- To analyse and improve our website, services, products and communications
- To understand our supporters better and keep a record of your relationship with us
WHO WE SHARE YOUR INFORMATION WITH
We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
We may need to share your personal information with partners, suppliers or agents to allow them to perform services on our behalf or help us to understand more about our supporters. In such cases, information is only shared for the purpose of providing services on our behalf relating to communications, or agreements between yourself and Action Against Hunger. Such processing is conducted under relevant Data Processing Agreements.
We also may need to disclose your information if required to do so by law or as expressly permitted under applicable data protection legislation.
Our website may include links to websites run by other organisations. Action Against Hunger is not responsible for the privacy practices of these other websites so you should read their privacy policies carefully before sharing any personal or financial data.
We have contracts in place with third party suppliers, partners and agents that we work with, and we require them to comply with the GDPR.
We may provide your email address or mobile phone number to digital advertising or social media companies who work on our behalf, such as Facebook, Instagram, Twitter, YouTube, Google or LinkedIn. This is so we can reach you and others like you with our latest news and information on how to support us. This data is always provided in an encrypted format and is deleted immediately after use.
If you don’t want to see targeted advertising from us on social media, please refer to the instructions provided by the relevant website or app.
Some of the examples of organisations with which we may share your data include:
- Our social media partners
- Our fundraising partners
- Our mailing houses or fulfilment partners
- Our media partners
- Companies that help us to process donations and transactions
- Analysis and research partners
- Database partners
STORING AND PROTECTING YOUR INFORMATION
We recognise the concerns that many people have about giving personal information online.
We place great importance on the security of all personally identifiable information associated with our beneficiaries and supporters, as well as prospective, current and previous staff, consultants and volunteers. We have security measures in place to protect against the loss, misuse and alteration or destruction of personal data under our control. Information is stored by us electronically and we may also store information on paper files. We also use a secure server when you make a donation or payment via our website.
However, no data transmission over the internet is 100% secure. As a result, whilst we cannot absolutely guarantee that loss, misuse or alteration of data will not occur while it is under our control, we use our best efforts to prevent this and protect your personal information. The Charity uses a set of controls to provide protection from the most prevalent cyber security threats and is applying for Cyber Essentials Plus certification.
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
When your information is no longer required, we will always dispose of it securely, in accordance with our Retention of Records Policy.
PAYMENT CARD INFORMATION
Action Against Hunger does not store any sensitive payment card data in our systems. The Charity has an active PCI-DSS compliance programme in place. This is the international standard for safe card payment processes.
TRANSFER OF INFORMATION OUTSIDE OF THE EU
Action Against Hunger supports the principle of “fair and transparent” processing of your personal information. We support your rights in relation to your personal information under the General Data Protection Regulation
You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’). You can also use this form if you are requesting information on behalf of somebody else. We will ask you for proof of your identity before we can act upon your request.
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information that is inaccurate or complete information which is incomplete (‘right to rectification’). If you inform us that your personal data is inaccurate, we will inform relevant third parties with whom we have shared your data so they may update their own records. If your personal details change, please help us to keep your information up to date by notifying us at the address below:
You have a right to object to Action Against Hunger processing your personal information (‘right to object’) at any time where we rely on our legitimate interests for doing so.
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’). This right does not apply where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example, where it is no longer necessary for us to continue holding or processing your personal data you may withdraw your consent. You should note that we are entitled to and reserve the right to retain your data for statistical purposes. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest.
You have a right to ask us to restrict our processing of your information (‘right to restriction’) if:
- You contest its accuracy and we need to verify whether it is accurate
- The processing is unlawful and you ask us to restrict use of it instead of erasing it
- We no longer need the information for the purpose of processing, but you need it to establish or defend legal claims
- You have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests
- You exercise your right to restrict processing; we would still need to process your information for the purpose of exercising or defending legal claims, protecting the rights of another person or for public interest reasons
If you would like to exercise any of your rights detailed above, please contact the Data Protection Officer at the address below. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
The Data Protection Officer
Action Against Hunger UK
First Floor Rear Premises
161-163 Greenwich High Road
Email: firstname.lastname@example.org (please state “Data Protection Right” in the subject line of your email)
You also have a right to object to our processing your data for the purposes of marketing. Action Against Hunger always acts upon your choices around what type of communications you want to receive and how you want to receive them. You have a choice about whether you want to receive information about the Charity’s work and fundraising areas.
We make it easy for you to tell us how you want us to communicate, in a way that suits you. Our forms have clear marketing preference questions; if you do not want to hear from us then you can update your preferences. We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted. You can change your marketing preferences for what you receive from us and how, at any time, by contacting:
Action Against Hunger UK
First Floor Rear Premises
161 – 163 Greenwich High Road
London, SE10 8JA
Tel: 0208 853 7571
If you have any concerns about our use of your data you may also report these to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113.
Most browsers will allow you to turn off cookies. Please note however, that turning off cookies will restrict your use of our website.
TRADEMARKS AND COPYRIGHT
Action Against Hunger’s websites contain material which is protected by copyright and/or other intellectual property rights. All copyright and intellectual property rights including the names, images and logos are owned by Action Against Hunger unless otherwise stated. All rights are reserved.
You are responsible for complying with all applicable copyright laws. We permit you to make copies of information on the Action Against Hunger website as necessary incidental acts during your viewing and you may take a print for your personal use of so much of the site as is reasonable for private purposes. All other uses are prohibited. Nothing in these terms shall be construed as conferring any right to use any trademark, logo, patent right or copyright of Action Against Hunger UK.
CHANGES TO THIS POLICY
By continuing to use our websites, it is considered that you have accepted such changes.
If you have any questions about this Policy, or how we use data please contact the Data Protection Officer at the above address.
Further information and advice about data protection is available from:
The Office of the Information Commissioner
Cheshire SK9 5AF
Tel: +44 (0) 01625 545 745
FUNDRAISING PREFERENCE SERVICES
Action Against Hunger is committed to empowering our supporters to manage their information. The Fundraising Preference Service (FPS) enables donors to take control of their charitable giving and conversations; and we want to help you use the service effectively.
Action Against Hunger supports the Fundraising Regulator and its efforts to develop the Fundraising Preference Service as a means of rebuilding trust between charities and the public. The Charity is committed to upholding fundraising best practice and being as transparent as possible with our donors.
LAST UPDATED: MAY 2018