Please read this policy carefully to understand how we collect, use and store your personal data.
HART (Humanitarian Aid Relief Trust) is a small charity making a genuine difference to the lives of those in war-torn and forgotten lands. Here are the following principles in order to protect your privacy:
• we do not collect more information than is necessary;
• we do not use your data for purposes other than those specified;
• we do not keep your data if it is no longer needed;
• we do not spread your data to third parties without your consent.
HART (Humanitarian Aid Relief Trust) is registered with the Information Commissioners Office (ICO) and holds a current Data Protection License.
What this policy takes into account
• the Data Protection Act 1998
• the Privacy and Electronic Communications(EC Directive) Regulations 2003 as amended by The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011
• Directive 2009/136/EC of 25 November 2009 (“The European Union Cookie Directive”)
• Possible new GDPR (General Data Protection Regulations) due in May 2018!
Who We Are
(HART) Humanitarian Aid Relief Trust: UK Registered Charity 1107341. Registered office address: Unit 1, Jubilee Business Centre, 213 Kingsbury Road, Kingsbury, LONDON, NW9 8AQ
At HART we take your privacy very seriously and are committed to protecting your personal information.
The Data Protection Officer HART Unit 1, Jubilee Business Centre, 213 Kingsbury Road, Kingsbury, LONDON, NW9 8AQ.
This policy includes:
i) How we collect information
We may collect information about you whenever you interact with us, for example when you:
• Enquire about our activities or visit our website or donate to us
• Sign up to receive updates on a campaign or our activities or newsletters
• Post content to our website/social media sites (including Facebook)
• Volunteer for us
• Attend a meeting or fundraising event with us and provide us with information about you
• Contact us through the following ways: online, email, phone, SMS, social media or post
• We may also receive information about you from third parties – but only if you’ve given them permission to share your information.
ii) Where we collect information from
HART may collect information in the following ways:
When you give us information directly: You may provide your details to us when you request specific information, make a donation, campaign for us or participate in one of our events.
When you have given other organisations or persons permission to share it: You may have provided your details to another person or organisation that works with or knows HART. For example, in order to sign up to a third-party event, or if you have given permission for a person to give us your contact details via a business card.
Social media: Depending on your settings or the privacy policies for social media and messaging services like Facebook and Twitter, you might give us permission to access information from those accounts or services.
When your information is available from other public sources: We may collect personal details about you from the public domain and other open sources, such as from social networks, company websites, political and property registers, and news archives. We may use data services agencies to collect this information. Please see the section below for more details.
iii) What categories of personal information we collect
The type and quantity of information we collect and how we use it depends on why you are providing it and always with your permission. If you support us, for example by making a donation, volunteering, registering to fundraise, signing up for an event or campaigning for us, we may collect where relevant:
• Your name
• Your contact details (full address, email address and phone number)
• Your date of birth
• Your bank or credit card details (only if you are making a donation)
• Where it is appropriate, we may ask for your reason for giving and your specific interests relating to HART’s work
We may in the future carry out targeted fundraising activity to ensure that our communication with you is as relevant and timely as possible and provides the best experience of supporting HART. In doing so, we may supplement what we know about you with information from third party sources to help us better understand your background and ensure any requests for additional support are tailored to you and how you might support us. This also helps us not to send irrelevant or inappropriate communications to our supporters, so that we can operate as cost-effectively as possible. These third party sources may provide us with the following information:
• Your parliamentary constituency
• An estimate of your age based on publicly available sources
• An estimate of the size and composition of your household
• Information about your interests, including shopping preferences, TV subscriptions and hobbies
iv) How we will use your personal information
We will use your personal information in a number of ways, including for the following purposes:
• To provide you with the information you have requested
• To update you about any changes to our services
• To administer your donation, including Gift Aid processing
• To maintain our organisational records and ensure we have your most up-to-date communication preferences
• To help us improve our services, campaigns or information-offering
• To invite you to participate in a HART event or visit our website
• To analyse and improve the operation of our website
• To analyse your website behaviour
• To tailor advertising that is presented to you on the internet according to your interests, preferences and other characteristics
• If we choose to work with third parties to ensure that we send you targeted communications (see ‘What categories of personal information we collect’ above)
• To contact you where you have been identified as a contact person for an organisation, such as a school or church (if we obtain your contact details in this way, we will only use them to contact you in the ways in which you have agreed to be contacted)
If you have any questions or would like to contact us about your marketing preferences, please contact us.
We always want you to get the most out of our website, so if you do experience any issues with our online forms we may follow up with you to find out how our team can best support you with any problems experienced.
We may in the future analyse more your personal information to create a profile about you, your interests and preferences. In doing this, we may combine information that you have given us with other information about you when it is available (for example, from public records or social media). This may include any of the information listed above (for example, an estimate of your age). This provides background information about our supporters and helps us to tailor appropriate communications to them, as well as helping us to improve the quality of our supporters’ experience with us. We may use third-party suppliers to undertake these activities on our behalf and share your data with them only to the extent required (usually only your full name and postcode). Please rest assured that our suppliers will not share this information with any other organisation and it will only be used for the purposes set out above. Additionally, we may use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
You can opt out of your data being used in this way by contacting us.
We may in the future participate in Facebook’s ‘Custom Audience’ programme which enables us to display ads to our existing supporters when they visit Facebook. We provide your email address, mobile number and address to Facebook so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account.
For more information please see https://www.facebook.com and Facebook’s Data Policy at https://engb.facebook.com/policy.php.
v) Children’s data
While we do not actively collect information from children (under 18s), we appreciate that our supporters are of all ages. Where appropriate, we will always ask for consent from a parent or guardian to collect information about children.
‘Cookies’ are small pieces of information sent by a web server to a web browser, which enable the server to collect information from the browser. Essentially, a cookie takes the form of a small text file deposited on your computer’s hard drive.
vii) How we keep your data safe and who has access to it
As per our data principle promise we place great importance on the security of your personal information and will always try to take appropriate precautions to protect it. We ensure that there are appropriate technical controls in place to protect your personal details. For example, we use encryption technology on our websites and carry out regular security reviews on our network. We have security protocols on how we handle hardware and soft data especially how this is accessed by staff or vetted volunteers.
We always ensure only authorised personnel (for example, HART staff, volunteers or vetted contractors) have access to your information, and that they are appropriately trained to manage your data.
Despite all of our precautions, no data transmission over the internet can be guaranteed to be 100% secure. So, while we strive to protect your personal information, we cannot guarantee the security of any information you disclose to us online, and you must understand that you do so at your own risk. However, any payment card details (such as credit or debit cards) we receive through our website are passed securely to our payment processing providers who meet the required Payment Card Industry (PCI) Security Standards.
Who we share your personal data with including third-party service providers
We do use external organisations that collect and/or process personal data on our behalf. We call these providers Third Party Providers. Before working with these companies, we perform rigorous checks to ensure they meet all relevant regulations and legislation. We always implement a contract with our suppliers, which imposes robust data protection requirements, including the provisions of this policy, and seeks to provide maximum protection of your personal details.
Third Party Providers we mostly use
We use third-party providers especially for services such as credit card payments and database storage and here are examples of some of those providers we use;
• PayPal for donations
• Stewardship which includes Give.net for donation appeals
• MailChimp which provides tools for subscription to our HART news
• SalesForce is a database tool so we can best utilise administration
We regularly check our providers to ensure your information is protected and if you would like any further information about our third-party providers please just contact us.
Financial or technical considerations may occasionally lead us to use the services of a supplier based outside the European Economic Area (EEA), which in turn might lead to your personal information being transferred, processed and stored outside the EEA. For example, SalesForce are based in the United States and we ensure they carry stringent assurances on our HART data. If these suppliers are based in countries that European Union authorities do not consider provide adequate levels of protection for personal data, we take steps to provide suitable safeguards to protect your personal information, such as entering into the European Commission approved standard contractual clauses. If you would like to receive further information about our safeguards, please contact us.
We may legally be required to disclose your details if required to by the police or for regulatory reasons. We will only ever share your data in other circumstances if we have your consent to do so.
viii) How we keep your information up to date
Where possible, we try to keep your records up to date; for example, we may contact you by phone or other means to ensure our data is correct.
How long we keep your information for
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 any donations you have made for at least six years. There may be other regulatory reasons that we need by law to keep hold of your information.
If you ask us to stop sending you our newsletters or other 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.
Legacy Income Data
Should you decide to leave HART legacy income which is vital to sustaining HART’s work. We may keep data you provide to us indefinitely, both to administer legacy gifts and to communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyze the source of legacy income we receive but also because we would always wish to acknowledge your kind gift and ensure you as a person will be remembered.
Where you contribute material to us, for example through user-generated content or in response to a particular campaign, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted, unless otherwise stated at the point of generation.
Our legal basis for processing your information and HART promise to you
Although in many cases we will seek consent to process your personal data, in some instances we may process your information without consent when we are legally allowed to do so. This will only be where it is in our legitimate interests to do so and where we are confident that such processing is not likely to prejudice your legitimate interests or rights and freedoms.
Where we are processing your personal data on the basis of consent that you have given us, you are entitled to withdraw that consent at any time such that we can no longer rely on it as a basis for continuing to process your personal information. HART has always offered to personalise how we communicate with you and use your data where permission has been freely granted to process your information we have offered to individually tailor how we use your data so that you are in control especially how we communicate with you, this has always been our promise to do so.
ix) Your rights by law in the United Kingdom
You retain control of how we use your data and you have the right to ask us to stop processing your personal information, which we will do. In some circumstances, we may legally be required to retain your personal information for audit purposes. However, this will be discussed with you depending on your requirements. Please contact us if you have any concerns.
You also have the right to request a copy of the information we hold about you. If you want to access your information, please contact: The Data Protection Officer, Humanitarian Aid Relief Trust: UK Registered office address: Unit 1, Jubilee Business Centre, 213 Kingsbury Road, Kingsbury, LONDON, NW9 8AQ.
We believe that we exceeded the new data protection rules due to come into force under the General Data Protection Regulation (GDPR), as we have always given our supporters control over how we use their data. Here is a list of the new rights due to come into force and which is expected to become law in the UK in May 2018, under these rules you are also granted a number of additional rights. These include:
• The right to rectification
• The right to erasure
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling
For more information on these rights please read the relevant guidance issued by the ICO.
If you would like to make a complaint about how we process your personal data, please contact our Data Protection Officer.
If you are not happy with how your complaint is dealt with, you should contact the Information Commissioner’s Office. Alternatively, you are entitled to make a complaint to the Information Commissioner’s Office without first referring your complaint to us.
This policy may change from time to time. Especially if the data protection laws keep changing. If we make any significant changes to this policy, we will publicise these changes clearly on our website or contact you directly with more information.
Please do revisit this policy each time you consider giving your personal information to HART. Please remember you can contact us at any time and we are more than happy to discuss your personal data preferences.