Ending aid dependency in Malawi
The Capacity Foundation (the Foundation) is a charity registered in England and Wales, number 1171338. The Foundation’s postal address is Brooklands Cottage, Ffordd-y-Bont, Pontybodkin CH7 4TS. The lead Data Protection Authority for the Capacity Foundation is the Information Commissioner’s Office, Wycliffe House, Walter Lane, Wilmslow, Cheshire SK9 5AF
1 PERSONAL DATA THAT WE COLLECT
The type of personal information that we could collect about you includes:
Cookies are small text files on your computer, smart phone, tablet or other device. They are made by your web-browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website’s server. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience.
Cookies help the Foundation identify which bits of our website people are using, and help us to improve the user experience. Information supplied in cookies also allows us to measure the effectiveness of online marketing campaigns for the Foundation so that we can become more efficient.
A cookie, by itself, can’t be used to identify you; we cannot and do not link it with personal information we hold about you (e.g. your name, address, email address).
Following the UK’s departure from the European Union (EU), provisions contained in the EU General Data Protection Regulation (GDPR) are now covered by the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
3 HOW WE USE YOUR PERSONAL DATA
4 THE LEGAL BASES UPON WHICH WE USE YOUR PERSONAL DATA
Consent: We use consent to send you details on fundraising and campaigning by email and text. As is your right, you can withdraw your consent at any time. All our fundraising and campaigning emails include an unsubscribe link.
Where you sign a petition or otherwise take action, we also use consent to send your details on to the campaign target, or to send an email on your behalf, as indicated when you take action.
Performance of a Contract: We would need to process your information if you enter into a contract with us – for example, to provide your goods or services when you purchase greetings cards or raffle tickets.
Legal Obligation: We need to retain and use certain records to uphold the law, for tax purposes such as Gift Aid administration, to satisfy legal, regulatory and compliance obligations.
Legitimate Interest: We may collect and use data where this is reasonably necessary for our legitimate interests. Such processing will be fair, balanced and will not unduly impact on your rights as an individual. For example, there may be times when it is not practical or appropriate to ask for your consent and where we are confident this will not impact on your rights.
Our legitimate interests include campaigning and fundraising to support our charitable objectives. In support of these legitimate interests we may collect or process personal data in the following ways:
5 WHEN AND HOW WE COLLECT YOUR DATA
We collect your data when you contact us directly, or interact with us via a third party, to:
In certain circumstances, we will conduct our own research and gather information that is available within the public domain. There is a certain amount of publicly available information from sources such as social media, published articles and news channels. We would use this information to improve our communications and fundraising approaches.
6 MARKETING (CAMPAIGNING AND FUNDRAISING)
As a charity we communicate with individuals to encourage participation in our campaigns and to raise money to fund our work. We send campaigning and fundraising communications in a variety of ways:
BY EMAIL, SMS & PHONE: We will only communicate for campaigning and fundraising purposes via these channels if you have given us your consent for us to do so. As is your right you can withdraw your consent for any method of communication at any time.
BY POST: We send campaigning and fundraising information in the post on the basis of our legitimate interests. You will not receive mail from us if you have specifically requested not to. If you would prefer NOT to receive communications from us in the post, you can let us know via the form included with any of our letters, or by contacting us directly. Please note your preferences may not be updated immediately, but we will aim to process your request within 28 days.
BY SOCIAL MEDIAL ADVERTSING: If you are a social media user, we may use tools provided by the leading social media platforms, such as Facebook, to reach individuals likely to engage with and respond to our campaigns. If you have participated in our campaigns and have not opted out, we may contact you via social media advertising. We may also use your profile anonymously, and in conjunction with many other profiles, to identify audiences that are also likely to engage with our campaigns and thereby help us achieve our charitable mission and objectives.
In order to improve the performance of our campaigns, we use conversion tracking to measure the outcome and improve the return on investment of Facebook Ads, for example, by reporting on the actions that audiences take after viewing those ads. We add a tracking pixel or cookie to our website and then track these conversions back to ads we are running on Facebook. No personal information is contained in or collected as a result of using pixels. To opt out of remarketing pixels and technologies, visit Facebook’s ad preferences page here.
7 LENGTH OF TIME WE KEEP YOUR DATA
Your data is retained for as long as is necessary for the purpose that it was collected for. We are obliged to keep certain data to fulfil certain legal obligations and matters of record keeping e.g. financial records which we are required to keep for six years. Any data that is retained is minimised to ensure that we are keeping only that which is required. We will securely delete all data when it is no longer required.
8 SHARING YOUR DATA
We will not sell or swap your personal data; and it is the Foundation’s policy never to pass on your personal details to other organisations for their use, except when we have your express permission to do so or when the law requires it.
Your data will only be used under our explicit instructions and only for the purposes we specify, to carry out necessary operations for us, such as sending letters or processing financial transactions. All of our suppliers are trusted and will be required to sign agreements with us, each of them agreeing to respect the security of your personal data.
There may be a need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies.
9 CHILDREN AND VULNERABLE INDIVIDUALS
Supporters in vulnerable circumstances
The Foundation is committed to offering the very best standards of supporter care and protecting our supporters’ privacy, dignity and wellbeing. If we believe that a supporter may be in vulnerable circumstances that could affect their capacity to make a decision about supporting us financially, or in other ways, we will do all we can to protect that supporter.
You can request a copy of the information that we have on you. This will be free of charge in most cases. Please let us have details of the personal data you want to see and proof of your identity. You can send an email to firstname.lastname@example.org or write to us at Brooklands Cottage, Ffordd-y-Bont, Pontybodkin CH7 4TS.
Correcting the information we hold on you
If your personal information is out of date or is incorrect, we will correct it for you on request.
Erasing your personal data from our records
Simply let us know and we will delete your details from our database. This will mean that all records of you will be erased. Please note, for legal reasons we may be required to keep certain information e.g. in the case of financial details, where we are duty bound to keep these on file for six years.
Opting out of all marketing (campaigning and fundraising) communications
We will stop all campaigning and fundraising communications, or communications via a specific channel, on request. If you have given us consent you can withdraw your consent at any time. We aim to update your record within 28 days.
Restricting the processing that we do
If you do not wish your information to be used for the purposes of screening or profiling, let us know. We aim to update your record within 28 days.
Using your information elsewhere
On request, we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format.
Should you feel that your data is not being managed in an appropriate manner, you can raise a concern with the Information Commissioner’s Office. You can also find general information from the ICO here: https://ico.org.uk/for-the-public
The Foundation is committed to keeping your data safe. Your personal data is stored on a secure network and we regularly monitor our systems for vulnerabilities. Access to your data is closely monitored; it is only accessible by staff, volunteers and contractors who are bound by appropriate policies and procedures to protect your information.
We will review the policies and procedures of any third parties that we deal with, to ensure they are compliant with data protection laws.
By Post: The Data Manager, Capacity Foundation, Brooklands Cottage, Ffordd-y-Bont, Pontybodkin CH7 4TS.
By Phone: +44 (0)7779 338343
If you are requesting access to the personal data we hold about you, please provide details of the personal data you want to see and proof of your identity.
If you wish to contact the regulator (Information Commissioner’s Office) you can do so at: https://ico.org.uk/concerns