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Privacy Statement

Prisoners of Conscience Appeal Fund is a registered charity in England and Wales, registered charity number 213766. The Charity is governed by a Corporate Trustee, Prisoners of Conscience Appeal Fund Trustee (Limited), company number 07690599.

Prisoners of Conscience Appeal Fund regards the lawful and correct treatment of personal information as crucial to the successful, secure and efficient performance of its functions, and to maintain confidence between those with whom it deals.

To this end Prisoners of Conscience Appeal Fund fully endorses and adheres to the Principles of Data Protection, as set out in the new General Data Protection Regulation and Data Protection Act, which came into force on the 25th May 2018.

Prisoners of Conscience Appeal Fund as a body is a Data Controller and the Corporate Trustee is ultimately responsible for the implementation of the charity’s data protection policies.

This Privacy Statement explains:
1. How we collect and use data
2. The lawful basis for processing data
3. How data may be shared with any third parties
4. How we keep data secure
5. How long we keep data
6. How to access, rectify, erase data or opt out of receiving communications
7. The right to object to processing of personal data and direct marketing
8. How to make a complaint
9. Use of cookies
10. Children’s data

1. How we collect & use data
We may collect information about you whenever you interact with us, for example, when you enquire about our activities or services, submit a grant application, visit our website, donate to us, sign up to receive e-news messages, attend an event, fundraise on our behalf or contact us through the following channels: 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.
We may obtain the following personal data from:

Supporters
Full name
Contact details, including: postal address, electronic address, telephone number
Donations – amounts, dates, methods of payment
Gift Aid information – amounts claimed, Gift Aid declarations
Communications – correspondence between supporters and the charity
Event information – whether a supporter has been invited to or attended events
Mailing preferences – preferred methods of contact

Grant Applicants
Full name
Contact details, postal address, electronic address, telephone number
Eligibility criteria
Information on status of grant
Communications – correspondence between applicants and the charity
Event information – whether an applicant has been invited to or attended events

Referral Agencies
Full name and job title of caseworkers
Contact details, postal address, electronic address, telephone number of caseworker

We use personal data in order to provide grants to beneficiaries, to raise funds to support our work and to process donations and submit claims such as Gift Aid.

Use of photographs
Where practicable, we will seek consent of individuals before displaying photographs in which they appear. If this is not possible (for example, a large group photo), we will remove any photograph if a complaint is received. This policy also applies to photographs published on our website or in its printed materials.

2. The lawful basis for processing data
Although in many cases we will seek consent to process personal data, for example, by requesting specific opt-in consent in electronic communications such as our e-newsletters or automatic response emails from our online donation and grant applications forms, in other instances we may process data without consent when we are legally allowed to do so.

This includes:
(a) legitimate interest, for example, to fulfil the purposes of the charity and to manage our relationship with you, where we are confident that such processing is necessary and would not be against your individual interests, rights and freedoms. For example, this could include sending letters in the post updating you about our activities, administering your grant application or inviting you to our events.
(b) legal obligations, to comply with common law or statutory obligations, such as submitting Gift Aid claims to the Inland Revenue or reporting to the Charity Commission.

There are specific checkboxes on our secure, encrypted online grant application system for referral agencies and applicants to give consent to their data being used in order to process their application and for further fundraising purposes, with their specific consent.

3. How data may be shared with any third parties
We will only share data with third parties when necessary to fulfil the purposes of the charity. For example, administering donations via our card processing provider and submitting Gift Aid claims to HMRC.
We require all third parties to comply with relevant data protection legislation.
In the case of grant applications, personal data will not be passed on to anyone outside the organisation without explicit consent from the grant applicant or the referral agency authorised to act on their behalf, unless there is a legal duty of disclosure.

4. How we keep data secure
Only authorised personnel will have access to personal data.
All personnel are made aware of the charity’s Privacy Statement and data protection policies.
All data is kept in secure filing, paper, password protected and encrypted electronic systems.
All confidential post is opened by the addressee only.
We operate a clear desk policy.
Any paper records containing personal data, which are to be destroyed, are confidentially shredded using the services of a professional confidential shredding company.

5. How long we keep data
We will take reasonable steps to keep personal data up to date and accurate. Ensuring personal data is disposed of when no longer needed reduces the risk that it will become inaccurate, out of date or irrelevant.
Personal data processed for any purposes will not be kept for longer than is necessary for those purposes.

6. How to access, rectify, erase data or opt out of receiving communications
You have the right to access the personal information that we hold about you, to rectify that information, to erase your data or to opt out of receiving communications from us. There is no cost for this service. We will action any requests as soon as possible and no later than 30 days from the request.
If you wish to exercise any of these rights or have any questions about this policy, our contact details are in clause 8 below.
If a request is received from an individual to erase their data, we will securely remove their personal data from our records, in accordance with their legal rights.

7. The right to object to processing of personal data and direct marketing
You have the right to object to our processing of your personal data relating to your particular situation or to stop the processing of your personal data for direct marketing purposes.

8. How to make a complaint
If you wish to make a complaint or think that there is a problem with the way we are handling your information, you can contact us directly at:
The Data Protection Officer, Prisoners of Conscience Appeal Fund, PO Box 61044, London, SE1 1UP. Tel: +44 (0)20 7407 6644. Fax: +44 (0)20 7404 6655.
Email: info@prisonersofconscience.org

Or you can contact the UK’s data protection authority, the Information Commissioner’s Office (ICO) at: https://ico.org.uk/global/contact-us

9. Use of cookies
Cookies are small files that are downloaded onto your computer (or other electronic device) from websites that you visit. Cookies contain information that allows websites to collect statistical information about our user’s browsing actions and patterns while on our website.

How we use cookies
We use cookies to help us provide you with the best experience when you visit our site. Some cookies are crucial to the smooth running of our website – for example our donation pages rely on them. Other cookies allow us to understand how visitors are interacting with our website so that we can improve it. Cookies also make it easy for you to share the content on our site with your contacts on Facebook or other social networks. These cookies, as with all others we use, do not contain information that can personally identify you.

Managing cookies
All browsers allow you to refuse to accept cookies stored on your advice, should you choose to do so. These settings are usually found under the ‘Preferences’ or ‘Tools’ menu of your browser. For more information about cookies, please see www.allaboutcookies.org

10. Children’s data
While we do not actively collect data from children (under 18s), we do, in some cases, receive data (names and ages) of children within grant applications. We only collect and process this data with consent of those with parental responsibility.

Changes to this Privacy Statement
Please note that this privacy statement will be updated as required. Any changes will be published on our website.