Justice and Care does all it can to protect the privacy and protect the personal data of everyone who engages with us, by whatever means. This policy aims to explain how we use the information people give us, how we store it and what it means for you. This policy should be read in conjunction with our terms and conditions which are available on our website.
If you have any questions about how your information is handled, or have any feedback, do get in touch. Here’s our contact details:
Phone: 0203 959 2580
Post: Data Protection Officer, Suite 139, 210 Upper Richmond Road, London, SW15 6NP
Who are we?
Justice and Care is a charity committed to helping to bring an end to modern day slavery. We are a charity registered in England and Wales (1133829) and Scotland (SC042389). Our company number is 6990037 and our registered office address is 10 Queen Street Place, London, EC4R 1AG.
We also have separate charity/non-profit entities in the US, the Netherlands and India. However, this policy refers to Justice and Care in the UK – and likewise when we talk about ‘us’, ‘we’, ‘our’ we are referring to Justice and Care in the UK.
Justice and Care holds and processes personal information in accordance with the European General Data Protection Regulations (GDPR) and other applicable laws.
How do we collect data?
Directly with us
We primarily collect personal information each time you deal with us – that could be through making a donation, asking to be kept up to date with our work, requesting information, providing comments, applying for a job, via social media or perhaps interacting with one of our campaigns.
From website interaction
We collect non-personal data such as IP addresses, details of website pages downloaded and file downloaded using Cookies. More information about Cookies can be found below.
Indirectly from 3rd parties
Through social media and other sites
We may collect information that you have made publicly available from social media and other sites such as Twitter, Facebook and Linkedin. Each will have their own privacy policies.
From publicly available data
We may also collect information from publicly available sources such as newspapers, blogs, articles, websites, Companies House and the Charities Commission.
What information do we collect
We collect and hold varied information which may include but not limited to your name, address, telephone number, birthday, your bank details, the company you work for, your personal and business connections, family details, your ip address and information about your work.
Why do we collect information?
Broadly speaking this information is held to allow us to collect donations, to stay in touch and connect well with supporters and to help develop and grow the work of Justice and Care.
How do we use your information?
We use the information to:
- Keep supporters up to date with our work, sometimes with real time updates
- Ask for financial and non-financial support
- Process donations and Gift Aid contributions
- Provide information that you have requested
- Keep records of our relationship – including conversations we’ve had, events you’ve attended, issues you’ve raised, emails we’ve exchanged
- Conduct market research to aid our understanding of supporters
- Provide a personalised service
- Customise the content of the Justice and Care website to visitors current and future needs
- To enable certain groups to access restricted content on our site
- Analyse the information to aid our understanding of our supporters and potential donors – this includes developing profiles to help us provide the right information at the right time and also target our fundraising activities
We may use publicly available data (for definition see above) to identify potential supporters who we understand have an interest in giving major gifts or having a public profile with charities such as Justice and Care. Where you do not want to pursue a relationship with us, we will not retain any publicly sourced personal data about you that we have collected for this purpose.
For very specific situations
We will also collect and store data from time to time for other purposes, such as to organise a trip for supporters to see our work. This will be agreed with the individual at the time and might include sensitive information such as personal health and also holding such things as passport information. This information will only be held as long as necessary.
Use of digital information
Other information relating to website activity may be used by us to offer and improve our services, to diagnose problems with our server or services, to provide you with requested information or technical support, to administer our site and to communicate with you and to assist us with providing a more personalised experience to you on our site. We may also aggregate and anonymise information received to produce reports on trends and statistics such as the number of visitors that have visited/clicked on our site and email open rates.
We collect IP addresses to obtain aggregate information on the use of this website. An IP address is a number assigned to your computer by a web server when you’re on the web. When you are on our site, we have a server that logs your computer’s IP address which we generally only use to track IP addresses in the aggregate to show us how many users entered a specific area of our site. However, we may use such information to identify a user if we feel that there are or may be safety and/or security issues or to comply with legal requirements.
Basis of processing your data
If you are a new supporter of Justice and Care, providing us with your information for the first time in December 2017, we will process your personal data on the basis of the consent you provided us. You are free to change your preferences by contacting us at any time (see changing your preferences below).
For those that have joined our mailing list historically, we’re taking a different approach. Here’s how:
- For those that haven’t given financially – we’ll be contacting you to ask your preferences moving forward. We’ll give you a number of times to respond, but if we don’t hear from you we’ll be taking you off our mailing lists in 2018.
- For those who are currently giving or have given to Justice and Care in the last 24 months, we’ll try to seek your communication preferences – but we’ll assume if we don’t get hold of you, that you want to stay in touch with our work
- For those that have given more significant amounts to Justice and Care beyond these time frames (£1000 in the last last three years, or more than £10,000 since we began) on the basis you’ve invested sacrificially into the work we’ll again seek out your communication preferences but again assume if we don’t get hold of you, that you want to stay in touch with our work
We use three different types of Cookies – those that help the website remember information from page to page (such as the details you filled in on a donation form), analytics Cookies which help us understand how many people are visiting our site and the pages they are looking at (no personal information is stored, but information may be kept for up to two years) and embedded functionality Cookies that allow users to do such things as share one of our stories on social media such as Facebook.
How we share your data
We do not share, rent or sell your data with any other charities or organisations. However, we may share relevant parts of your data with partners or affiliates of Justice and Care subject to this policy, including those who assist us to perform our services (such as the wider family of Justice and Care in India, the Netherlands, the US and Bangladesh) – this will be in very specific circumstances for example to facilitate a trip to see our front end work, to help answer a question you may have or to provide an update on an area of work you’ve supported.
We may need to pass on information if required by law or by a regulatory body. For example, a Gift Aid audit by the HRMC or if asked for if required by a law enforcement agency.
We may provide third parties with overall information about visitors and users to our site, but this information, other than as explained above, is both aggregate and anonymous.
Our service providers and third parties
We employ some agents to help us carry out tasks on our behalf, for example processing online donations and then passing on information to us. These agents are bound by contract to protect your data and we remain responsible for them.
How and where we store your information
We use cloud based systems to process and store data (primarily the Salesforce platform). Data therefore may be processed outside of the European Economic Area (EEA). We adopt the Information Commissioners approved measures and therefore ensure that personal data is held in compliance with European data protection regulations. We take all reasonable steps to ensure that your data is stored and processed securely in accordance with this policy. By submitting your personal data you agree to this transfer, storing and processing of your information.
For how long do we keep data?
We will keep your personal information only for as long as we consider it necessary to carry out each activity. We take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned.
For example we will retain details of donations for 7 years to meet tax and accounting requirements, but we will only hold sensitive medical personal information provided to participate in an overseas trip until the trip is completed.
Legacy income is an important source of income for our beneficiaries. We may keep data you provide indefinitely to carry out the administration of legacies and to communicate with the families of those leaving us legacies.
Our intention is to use Secure Socket Layer (SSL) software, which encrypts information given over the internet to protect all personal data as soon as it is possible. We also seek to ensure our network is protected and routinely monitored and ensure that access to personal data is restricted to those staff and volunteers whose job role requires such access and that suitable training is provided.
Whilst we make every reasonable effort to ensure that information sent to us is done so securely, we cannot warrant the security of information transmitted to us through the internet. When you transmit information to us via the internet, you do so at your own risk.
If you use your debit or credit to donate to us, or pay for a trip, whether online, over the phone or by mail, we will process your information securely in accordance with the Payment Card Industry Data Standard. We do not store your debit or credit card details once your transaction has completed. All card details are securely destroyed once your donation or payment has completed.
Bank account details for the purpose of collecting direct debits or standing orders. We or our partner organisations will always work in accordance with direct debit mandate rules.
Changing your preferences
We want to make sure you receive the information from Justice and Care that you want in the way you want. You can change therefore your preferences on what you receive from us and how we contact you (mail, phone or email) at any time.
You can do so by:
Visiting our website – www.justiceandcare.org
Calling us: 0203 959 2580
Email us: firstname.lastname@example.org
Write to us: Suite 139, 210 Upper Richmond Road, London, SW15 6NP
You have the right to ask us not to process your personal data for marketing purposes such as by email or text. We will inform you (before collecting your data) if we would like to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
If you provide us with sensitive personal data, including but not limited to your racial or ethnic origin, political opinions, religious or spiritual beliefs or your physical or mental health or condition, you hereby explicitly consent to our use of such data in accordance with this policy.
You also have the right to request details of the information we hold about you. To exercise that right you should contact the Data Protection Officer at the address given above. We will respond within 30 days of receiving your letter or as otherwise required by law.
Changes to policy
From time to time, we will make changes to this statement to keep it up to date and relevant. You should therefore ensure that you check regularly to see what’s changed.