Privacy Policy
INTRODUCTION
Rwanda Action is a charity and a company limited by guarantee registered in England and Wales with charity number 1124634 and company number 06610865.
Rwanda Action (referred to as “we”, “us” or “our” in this privacy policy) is the data controller for the purposes of the Data Protection Act 2018 and the General Data Protection Regulation (together referred to as ‘Data Protection Regulations’). References to the processing of personal data or information includes the collection, use, storage and protection of such data.
We take the privacy and security of our supporters, volunteers, beneficiaries and staff very seriously, making every reasonable effort to ensure that your personal data is kept secure and intact. This policy has been put in place to protect your rights under the Data Protection Regulations, and it is important that you understand what we will do with your data and are happy with this. It describes how Rwanda Action collects, stores and uses your personal data, together with our obligations, your rights, and how individual personal preferences can be amended.
If you want to discuss any matter relating to how your data is used, including amending your personal preferences, please email us at info@rwandaaction.org or write to us at Rwanda Action, Bugsell Farm, Bugsell Lane, Robertsbridge, East Sussex, TN32 5EN. We may be required in certain instances to ask that your request for information be submitted in writing.
We may change this policy from time to time and any such changes will be published online at www.rwanda-action.org. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.
This policy is effective from 17th September 2023.
WHAT DATA DO WE COLLECT ABOUT YOU, WHY AND HOW DO WE USE IT?
Organisations are permitted to process data if they have one or more legal bases for doing so. Personal data means any information capable of identifying an individual. It does not include anonymised data.
Please note that by providing us with your data, you warrant to us that you are over 13 years of age.
We may collect and use the following personal data about you:
- Communication Data – this includes any communication that you send to us whether that be through the contact or newsletter sign up forms on our website, through post, email, text, social media messaging or posting. Our lawful ground for this is either your consent or our legitimate interests, which in this case are:
- to promote the aims and charitable objectives of Rwanda Action
- to provide and personalise our services to beneficiaries, to communicate with our supporters and volunteers, dealing with enquiries and requests and recording any contact with you
- to provide you with information that you have indicated an interest in, for example information about our campaigns, volunteering, fundraising and how you can donate to us.
- Contractual data – this includes data pertaining to any kind of contractual agreement, including employment contracts and data collected in anticipation of entering into such agreements or where such agreements have terminated but there is a continuing need to retain data for the protection of one or both parties to an agreement. Our lawful ground for this processing is our legitimate interests and/or because is necessary in relation to a contract, agreement or ongoing arrangement for the provision of goods or services which someone has entered into with us or because someone has asked for something to be done so they can enter into a contract, agreement or arrangement with us.
- User Data – this includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website.
- Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We collect and use this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and to inform our marketing strategy.
- We may use Communication Data, User Data and Technical Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests, which in this case is to personalise the way our website is presented when users visit it, to make improvements to our website and to ensure we provide the best service for our supporters.
- Sensitive Data We do not collect any Sensitive Data about you without your consent. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
Where appropriate and with your knowledge and consent, we will collect data necessary to ensure the safeguarding of children and vulnerable persons, such as that required to undertake a Disclosure and Barring Service criminal records check.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver craft items you) but we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing, including requesting your consent if necessary.
We may process your personal data without your knowledge or consent where this is required or permitted by law but will only do so in accordance with this policy.
We do not carry out automated decision making or any type of automated profiling.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect data about you either when you provide it directly to us (by phone, post or email), including when you enquire about our activities such as fundraising or volunteering, or when you subscribe to our newsletter via the website, send or receive an email or make a donation or purchase products to or from us.
We may also automatically collect certain data (such as which pages you visit) from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this at www.rwanda-action.org.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
We will only ever collect the information that we need, including data that will be useful to help fulfil our charitable objectives or 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.
NEWSLETTERS AND OTHER MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you our newsletter and other marketing communications is legitimate interest, but certain forms of communication (specifically email and texts, but not post or non-automated phone calls) require consent which we will collect where necessary. You can update your preferences at any time either by contacting us directly at info@rwandaaction.org or by using the unsubscribe option in every newsletter.
Opting out of receiving our newsletter/marketing communications whether by email, text or other means does not remove you from our database and will not affect the data we hold relating to other forms of engagement that you have had with us, including purchases, volunteering or donations. You may request deletion of your data at any time in writing, subject to any overriding legal requirement for its retention, such as the need, where appropriate, to comply with the requirements of Her Majesty’s Revenue and Customs or other regulatory authorities, or to prevent the commission of or assist in the investigation of an actual or suspected criminal offence. We may keep certain data on a ‘suppression list’ so we know, if requested, not to contact you or process your data in future until further notice.
DISCLOSURES OF YOUR PERSONAL DATA
We may in certain sometimes share your personal data with trusted third parties, including with and in the circumstances set out below
- Service providers who provide payment, data storage, communications, IT and system administration services, such as Mailchimp, JustGiving and others.
- Professional advisers including lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. Except as stated above, or as otherwise permitted or required by law, we will not share your data with other third parties and will never sell it to anyone.
INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Our third parties service provider (Mailchimp) is based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Mailchimp are a US-based provider that is part of EU-US Privacy Shield: this means we may transfer data to them, as they have equivalent safeguards in place.
We may use other extra-territorial service providers for Cloud storage or the secure storage of data, but only if they too have in place stringent safeguards that meet the standards required by UK law.
Data may be shared with our trusted colleagues and partners in Rwanda, such as that relating to visiting staff or volunteers. Such data is limited to that which is strictly necessary for the purposes for which it is being shared and is deleted or destroyed when no longer required for that purpose. We take appropriate all technical and organisational measures necessary to protect the privacy and security of the individuals and to prevent the unauthorised or unlawful processing, accidental loss or destruction of, or damage to personal data.
DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees, volunteers and trusted partners and third parties who have a legitimate need to process such data. They will only process your personal data on our instructions and, where appropriate, formal agreements will be put in place to ensure its privacy and security.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to do so.
The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. Please note that, unless encrypted, email messages sent via the internet may not be secure and could be intercepted and read by someone else. Please bear this in mind when deciding whether to include personal or sensitive information in any email messages you send to us.
DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected or being processed, bearing in mind your wishes and any legal, accounting, or reporting requirements. For example, for tax purposes the law requires us to keep basic information about our beneficiaries, supporters and volunteers (including Contact, Identity, Financial and Transaction Data) for six years after they stop supporting us.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
As stated, we may keep certain data on a ‘suppression list’ so we know, if requested, not to contact you or process your data in future until further notice.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can read more about these rights at:
If you wish to exercise any of the rights set out above, please email us at: info@rwandaaction.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a small fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Where a data request relates to another person, including a child under the age of 16, we will require proof that the person requesting the data has a legal right to receive it on behalf of that other person.
We will respond to all legitimate requests within 30 days, once we have established the identity of the person submitting the request.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
LINKS TO OTHER WEBSITES
Rwanda Action’s website and other communications that you receive from us may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they process your data and so visit them at your own risk. When you leave our website or follow a link, we encourage you to read the privacy policy of every website you visit.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see www.rwanda-action.org.
Approved: September 2023
Review date: September 2024