Privacy Policy
Introduction
At SWAN, we are committed to respecting your data privacy. The Data Protection Act 2018 (“DPA”) and Regulation (EU) 2016/679 of the European Parliament (the General Data Protection Regulation (“GDPR”)) require that we provide you with information about how and why we use personal data. We aim to process information about you fairly, lawfully, and in a transparent manner and the aim of this document is to provide you with sufficient information for you to understand what we are doing with your personal data. This policy also explains our commitment to protecting your personal data and your rights towards those data. Please read it carefully to understand our views and practices regarding your personal data and how we will use it.
The controller of your data is Southern Women’s Aid Network (SWAN), 31 Whitehorse Road, Croydon CR0 2JH. References to we, our or us in this policy are to the controller, SWAN.
Our Data Protection Advisor oversees our compliance with this policy. They can be contacted using the contact details below.
Personal information we may collect about you
WE COLLECT INFORMATION ABOUT YOU IN THE FOLLOWING WAYS:
Personal data you provide to SWAN directly
You may provide us with information about you when you submit an enquiry form on our website, write to us, call us, or when you make or enquire about making a donation or to access support This may include your name, address, email address, telephone number, payment details, appeal you wish to support, gift aid status etc. and information you provide in any correspondence with us. You may also provide us with marketing and communications preferences and in some cases an indication of your consent for us to perform certain processing activities on your personal data.
Information collected by your involvement with SWAN
Your activities and involvement with SWAN will result in personal data being collected. This could include details of how you’ve helped us by being involved with our campaigns activities. When you use our website we will collect personal information about you using cookies and other digital media technologies details of which are contained in our Cookies Policy. We will receive and store information about the type of device you use to access our website, what operating system you have, some of your device settings and your IP address.
Social Media
Depending on your settings or the privacy policies of the social media platforms and messaging services you use (e.g. Facebook, YouTube, Twitter, Instagram, WhatsApp etc.) you may allow us to access information from those services for example if you publicly “like” or “follow” us we may be able to collect information from your social media profile. We strongly advise you to check the privacy settings on your social media accounts to ensure that you know what information is shared with us and others.
Lawful basis for processing
DATA PROTECTION LAWS REQUIRE THAT A CONTROLLER THAT PROCESSES PERSONAL DATA MUST DO SO BASED ON ONE OF THE FOLLOWING LAWFUL LEGAL BASIS:
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Contractual obligation: the processing is necessary for the performance of a contract or taking steps to enter into a contract between the controller and the data subject.
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Legal obligation: the processing is necessary for the controller to comply with the law or a legal requirement (not including contractual obligations).
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Vital interests: the processing is necessary to protect someone’s life.
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Legitimate interests: the processing is necessary for the controller’s legitimate interests, or the legitimate interests of a third party however, such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires protection of the personal data.
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Consent: the data subject has given consent for the processing for one or more specific reasons.
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Public task: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
How we use your personal information
The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for doing so.
| Personal Data | Our Purpose | Lawful Basis |
|---|---|---|
| Name; address; cheques, card, bank or other payment details | Necessary to fulfil the wishes of our donors making a donation and to enable the use of the funds for the purpose it was donated for | Legitimate interest of SWAN and the donor |
| Personal contact information collected from donors | Our donor information is used to create and maintain a database of donors and potential donors, their relationship with us, respond to complaints, queries, etc. | Legitimate interest of SWAN and the donor |
| Name, address, email, phone number and other contact details | To contact you as a follow-up on your enquiry regarding accessing SWAN food or other aid; | Legitimate interest; Consent |
| Name and house address | We use our donor database to contact our former, current and prospective donors from time to time, through direct postal mail, to ask if they would like to make a donation to an appeal. | Legitimate interest of SWAN and the donor |
| Name, email, phone number and other electronic contact details | We use our donor database to contact our former, current and prospective donors from time to time, through a range of digital methods such as email, SMS or social media to ask if they would like to make a donation to an appeal. | Consent of the donor |
| Name, address, email, phone number and other contact details | Where you have donated towards a particular project/appeal, we may contact you from time to time to update you on how your donations was/is being used, the success of our appeals, our activities on the field, developments of new products and services, and new campaigns | Legitimate interest; |
| Name, address, email, phone number and other contact details | To respond to queries, questions or questions we may receive from our donors, in a time and professional manner. | Legitimate interest of SWAN |
| Personal identification numbers, IP addresses, user names and other IT system identifying information | We use cookies and other digital technologies on our website, in our emails, and in other digital interactions with you to allow us to understand traffic to our website, and how well our website and outbound digital communications perform. | Legitimate interest of SWAN |
If for any reason we would like to process your personal data for any other purpose different from the purposes listed above, we will provide you with appropriate additional privacy information at the point where you come across those additional purposes.
Withdrawing consent
Where you have given consent to use your data in a particular manner, you have the right to withdraw that consent at any time. You may do this by contacting us using the contact details below. Please note however that the withdrawal of your consent will not affect the lawfulness of any processing that had commenced before the consent was withdrawn. When we contact you by electronic means, we will always provide you with the option to opt out of receiving further communication of that nature from us.
Sharing your data
SWAN sometimes uses third parties to help us keep you informed with whom we may need to share your data for these specific purposes only. Services used may include mailing houses, email and text marketing services. We will share your personal data with other organisations to enable us process your donation, send you communication materials, and to undertake other activities in line with the information provided in the above table.
Please note that we may need to disclose your personal information where we:
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are under a legal duty to comply with any legal obligation or in order to enforce or apply our terms and conditions; or
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need to disclose it to protect our rights, property or safety of our customers or others, including the exchange of information with other companies, organisation and/or governmental bodies for the purposes of fraud protection and credit risk reduction
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HMRC (for Gift Aid processing), our regulators and other government agencies where we are required to do so by law or to assist with any investigation or enquiry
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Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.
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Other organisations as we may determine from time to time such as payment processors (Worldpay, KeyIVR, SmartDebit, PayPal), email and text messaging providers (Text Marketer, MailChimp, Mailing House) and for publicity (media channels carrying appeals).
If you provide us with any personal information other than your own you, are responsible for ensuring they know that you have done this and for providing them with access to this privacy policy. We reserve the right to contact any such individual and inform them when, where and how we obtained their personal data including citing you as the source.
How long we keep your personal information
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and we will review this from time to time. How long information will be stored for depends on the information in question and what it is being used for. For example, we will retain information about donors and donations for no longer than 7 years from the date of donation for taxation and financial record-keeping. We retain information about queries and/or contact from individuals for as long that it is needed for us to respond to the query and/or maintain records of queries for our internal management purposes. We retain records of donors and potential donors for as long as we feel you may be interested in making donations. Records of our marketing activities are kept in accordance with our donor records as above. If you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (though we’ll keep a record of your preference not to be emailed). We continually review what information we hold and delete what is no longer required. We never store payment card information.
It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you move home, change your phone number or email address. If you want to update your personal data, please contact us at [email protected].
Your rights in relation to personal information
YOU HAVE THE FOLLOWING RIGHTS CONCERNING YOUR PERSONAL DATA:
| Rights | Brief Explanation |
|---|---|
| Right to be informed | This is known as ‘privacy information’. We are required to provide you with information regarding the purposes for processing your personal information, the retention period and who it will be shared with. This Privacy Policy serves that purpose. |
| Right of access | Commonly known as “subject access request”(SAR). You have the right to obtain confirmation from us as to whether we are processing your personal data, and where that is the case, access to that personal data. If you are seeking to obtain specific information (e.g. about a particular matter from a particular time period), it helps if you clarify the details of what you would like to receive in your written request. |
| Right to rectification | This enables you to have any incomplete or inaccurate information we hold about you to be corrected. If you feel that any data that we hold about you is inaccurate you have the right to ask us to correct or rectify it. |
| Right to erasure | Also known as “right to be forgotten”. You have the right (under certain circumstances, but not all) to ask us to erase personal data concerning you. |
| Right to restriction of processing | You have the right (under certain circumstances, but not all) to ask us to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of your personal data that we hold. |
| Right to data portability | You have the right (under certain circumstances, but not all) to ask us to provide you with the personal data about you which you have provided to us in a structured, commonly used and machine-readable format. You also have the right to ask us to transmit those data to another controller. |
| Right to withdraw consent | Where we are relying on consent as the lawful basis for our processing of your data, you have the right to withdraw that consent at any time. Please note that this will not affect the lawfulness of processing based on consent before it is withdrawn. |
| Right to object to direct marketing | Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing. |
| Rights in relation to automated decision making and profiling | We do not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you. |
Please note that some of these rights are not absolute and can only apply in certain circumstances. For more information on your rights, visit the ICO website on https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
You should note that some of these rights, for example the right to require us to transfer your data to another service provider, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details below.
Your right to lodge a complaint with the ICO
If you wish to complain about the way SWAN is managing your personal information (including a complaint about fundraising activity), we would like you to give us the opportunity in the first instance, to address your concerns. Please contact us using the details below:
Email: [email protected]
Phone: 02034900690
Post: Data Protection Advisor, SWAN, 31 Whitehorse Road, Croydon, CR0 2JH
If you remain unhappy with the outcome of your complaint, you have the right to complain to the UK Information Commissioner’s Office (ICO). Their contact details are below:
Information Commissioner’s Office
Post: Wycliffe House, Water Lane, Wilmslow. Cheshire. SK9 5AF
Phone: 03031231113
Email: [email protected]
Website: Make a Complaint
Changes to this policy
We may update this privacy policy from time to time. When we change this policy in a material way, we will update the version date at the bottom of this page. For significant changes to this policy we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.