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A UK-based charity supporting the Evangelical Fellowship of Sierra Leone
Privacy Notice
Respecting you and the data you share with us is really important to us. This Privacy Notice sets out the ways in which we use your personal information, your rights and the options available to you.
Contents:
2. When does Support EFSL collect information about you?
3. What personal information does Support EFSL use?
4. Why does Support EFSL need your personal Information?
5. Who might Support EFSL share your information with?
6. How long will Support EFSL hold a record of your information?
8. Other important information
1. Introduction
Support Evangelical Fellowship of Sierra Leone (Support EFSL), registered charity number 1141005 is committed to protecting your privacy. At all times we aim to respect any personal information you share with us, or that we receive from others, and keep it safe.
Certain personal information will be required by us in order to fulfil our contractual obligations when providing certain professional services. Otherwise the provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services may be impaired. For example, you will be unable to make a donation.
2. When does Support EFSL collect information about you?
A. When You Give It to Us DirectlyFor example, personal information that you submit when making a donation; or that you give to us when you communicate with us by email, phone, letter, social media or through our website.
B. When We Obtain It IndirectlyFor example, your personal information may be shared with us by third parties (e.g. Ripe for Harvest, Charities Aid Foundation CAF or Stewardship). Where we have not already done so, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.
C. When We Obtain It from Our Client CharitiesIn the course of supplying independent examination of accounts and other similar professional services, we may receive personal data provided by client charities, in cases where you have undertaken transactions or otherwise been connected with them. For example, information on your giving to that charity, amounts received by you from the charity, minutes from trustee meetings, or other records.
D. When It Is Available PubliclyYour personal information may be available to us from external, publicly available sources.
E. When You Visit Our WebsiteWhen you visit our website, we automatically collect the following types of personal information:
- Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
- Information about your visit to our website, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
- We also collect and use your personal information by using cookies on our website. Please see our Cookie Notice. In general, we may combine your personal information from these different sources for the purposes set out in this Notice.
3. What personal information does Support EFSL use?
We may collect, store and otherwise use the following categories of personal information:
- Your name and contact details, including postal address, telephone number and email address;
- Your position in an organisation, and information related to the work that you do there;
- Your date of birth (when we need to verify your identity and for security);
- Your nationality (when we are helping you set up a charitable company, or if you are applying to receive funds from us as an individual);
- Your financial information, such as bank details, credit and debit card details, account holder name, sort code and account number;
- Information about your computer or mobile device and your visits to and use of our website, including, for example, your IP address and geographical location;
Do You Collect or Use Special Categories of Personal Information?
The EU General Data Protection Regulation (GDPR) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and religious beliefs.
In certain situations, Support EFSL may collect and use these special categories of personal information, for example information about your religious beliefs which you may communicate to us when corresponding with us. We will only collect and use these special categories of personal information if there is a valid reason for doing so and the GDPR allows us to do so.
4. Why does Support EFSL need your personal information ?
We collect and use your personal information in the following ways:
A. To provide information about the work of Support EFSL and enable donations to be made to EFSL
When you request us to provide you with one of our products or services, we use information about you:
- To provide you with information about the work of Support EFSL (e.g. through the distribution of prayerletters by post and email);
- To process financial information (e.g. donations to Support EFSL, submitting applications for Gift Aid);
- To run/administer our website, keep it safe and secure and ensure that content is presented in the most effective manner for you and for your device;
- To fulfil our contractual obligations when providing certain professional services including accounts examination and book keeping; and
- To fulfil regulatory responsibilities required of us when carrying out the functions of the charity.
Sometimes we are required by law to use information about you:
- To help prevent and detect crime (including, for example, the prevention or detection of fraud); and
- To comply with a legal or regulatory obligation.
- To audit and/or administer our accounts.
- For the establishment, defence and/or enforcement of legal claims.
We can use your personal information in this way because we are required to do so by law.
5. Who might Support EFSL share your information with?
We will disclose some of your information to agents, statutory bodies and suppliers in order to provide our services to you. Those parties may include (but are not limited to):
- Statutory bodies (for example, HMRC or the Charity Commission)
- Payment processors (for example, Banks or Card Payment Intermediaries)
- IT Software and Security contractors: to maintain, develop and secure the software that we use to provide our web services to you.
- Email marketing provider - TTmail: to send, track and report your interest in messages from us, if you give us consent to do so.
- Any additional people you may have authorised to act on your behalf or to receive your personal information during the provision of our products or services.
- Your chosen recipients of your donation(s) (please note that you can donate anonymously if you prefer);
- Analytics and search engine providers;
- Professional service providers such as accountants and lawyers;
- Parties assisting us with research to monitor the impact/effectiveness of our work and services; and/or
- Regulatory authorities who oversee the work we do.
We do not sell your personal data or information to any third party organisations.
When you use our secure online donation function you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.
6. How long will Support EFSL hold your information
We keep your data for as long as it is necessary to provide the services that you have asked for, and to meet our legal obligations to HMRC and other accounting regulations. As a general rule, we will keep your data for seven years from the end of your relationship with us. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it, or (iii) you validly exercise your right of erasure (see section 7), we will remove it from our records at the relevant time.
If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.
When you give permission to receive emails from us about Support EFSL activities, your information will be kept with us until you notify us that you no longer wish to receive these messages, or:
- If your inbox rejects our messages more than 20 times consecutively, your email address will be added to our suppression list which means you’ll no longer receive communications from us.
- After 12 months of inactivity we will contact you to see if you still wish to receive communications from us. If you do not respond to this communication we will remove you from our list and you will be unsubscribed.
7. What are your rights?
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing purposes, or to unsubscribe from our email list at any time.
You also have the following rights:
- Right of access: You can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
- Right of erasure: You can request that we delete your personal information from our records as far as we are required to do so. In some cases we may suppress your personal information in order to stop further communications with you, rather than delete all of your personal information.
- Right of rectification: If you believe our records of your personal information are inaccurate, you have the right to ask or those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate.
- Right to restrict processing: You have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
- Right to object: You have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests basis (see section 4 above), (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
- Right to data portability: Where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering in a contract, and in either case we are processing your personal information using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.
- Rights related to automated decision-making: You have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation, (ii) is authorised by EU or Member State law to which Support EFSL is subject (as long as that law offers you sufficient protection), or (iii) is based on your explicit consent.
Please note that some of these rights only apply in certain circumstances. At all times you have the right to make a complaint to the Information Commissioner’s Office www.ico.org.uk if you think that any of your rights have been infringed by us.
If you have any concerns or complaints about the way we use your personal information, please contact us using details below:
Support EFSL Data Protection Trustee
Rev K Wiebe
9 St Andrews Road
Didcot
OX11 8EW
8. Other important information
8.1 Security and Storage of Personal Information
Support EFSL is committed to keeping your personal information safe and secure. We have appropriate and proportionate security policies and organisational and technical measures in place to help protect your personal information.
Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on dveices which have features to prevent unauthorised access.
8.2 International Transfers of Your Personal Information
Given that we are a UK-based organisation and many of our recipients are based in the UK, we will normally only transfer your personal information within the European Economic Area (EEA), where all countries have the same level of data protection law under the GDPR.
Although Support EFSL is a UK-based organisation, the main recipient (EFSL) to whom your donations are transferred is based and operates overseas (in Sierra Leone). To do this, Support EFSL may provide EFSL with your personal information, thus it will be stored outside a location in the EEA. Before we do this we will seek your explicit consent to proceed.
Please note that some countries outside the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient of data implements appropriate safeguards (such as by entering into standard contractual clauses which are approved by the European Commission) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Notice; If you have any questions about the transfer of your personal information, please contact the Support EFSL Data Protection Trustee using the details contained in section 9 below.
Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.
8.3 Lawful Basis for Processing Your Personal Information
The GDPR requires us to rely on one or more “lawful basis” to use your personal information. We consider the basis listed below to be relevant:
- Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you monthly email updates).
- Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
- Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
- Where there is a legitimate interest in us doing so. The GDPR allows us to collect and use your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that use is fair, balanced and does not unduly impact your rights). In broad terms, our “legitimate interests” means the interests of running Support EFSL as a charitable entity and pursuing our aims and ideals, for example to provide supporters with information about the work of Support EFSL. When we use your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted by law).
8.4 Links and Third Parties
We link our website directly to other sites. This Notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.
Paypal & JustGiving are secure 3rd party payment sites; so we never receive your debit card, credit card or banking details from those sites.
8.5 Children’s Personal Information
If we are required to process children’s personal information, we will not do so without their consent or, where required, the consent of a parent/guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care.
9. Who can you contact about data at Support EFSL?
If you have questions about privacy or have a concern or complaint about our handling of personal data, you can contact our Data Protection Trustee, who will investigate the matter:
Support EFSL Data Protection Trustee
Rev K Wiebe
9 St Andrews Road
Didcot
OX11 8EW
10. Change to this notice
We may update this Notice from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an updated notice on our website. This Notice was last updated on 12 July 2020.
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