Charity Walk for Peace (‘CWFP’) is strongly committed to protecting personal data. This privacy statement describes why or how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others.
Personal data is any information relating to an identified or identifiable living person. CWFP processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure and retention periods for each purpose may differ.
This Privacy Notice tells you how we look after your personal data when you visit our website and at other points at which we collect your personal data. It tells you about your privacy rights and how the law protects you.
We may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection. This document may also be described as a Fair Processing Notice.
CWFP is the data controller for your data. Our registered office is at 33 Gressenhall Road London SW18 5QH. You can contact us there or by email at email@example.com or by ‘phone on 020-8874 6630
DEFINITION OF KEY TERMS
- Data Controller
The person or organisation who decides why personal data is required and directs how it will be processed accordingly
- Data Subject
Any living individual in the EU
Data Protection Officer
General Data Protection Regulation
- Personal Data
Any information from which a particular living individual can be identified
A person or organisation which processes personal data on the instruction of a controller
Any operation which is performed on / use made of personal data from collection through to deletion
- Sensitive personal data / Special category data
Information relating to a person’s racial/ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, health, sex life and/or sexual orientation, genetic data and/or biometric data for the purpose of uniquely identifying a living individual.
IMPORTANT INFORMATION ABOUT US
Charity Walk for Peace (‘CWFP’) is a company registered in England and Wales under number 09538103 and also as a charity with registered number in England and Wale of 1161567.
The charity’s key aims are:
- alleviation of poverty;
- the relief and assistance of people;
- to relieve financial hardship, sickness and poor health amongst elderly people;
- the promotion of religious harmony for the benefits of the public.
CWFP acts as a controller of personal data and is responsible for your personal data in connection with its activities (collectively referred to as “CWFP “, “we”, “us” or “our” in this privacy statement). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Statement. If you have any questions about this Privacy Statement, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
- Name of DPO:
- Email address:
- Postal address:
33 Gressenhall Road London SW18 5QH
- Telephone number:
- 020-8874 6630 / 07547870197
Changes to this privacy statement
We recognise that transparency is an ongoing responsibility, so we will keep this privacy notice under regular review. This privacy notice was last updated on 24th May 2018.
Making a complaint
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please Contact us in the first instance.
A REQUEST WE WOULD LIKE TO MAKE OF YOU
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you. We will notify you if this is the case at the time.
LETTING YOU KNOW ABOUT OUR EVENTS
CWFP holds a large number of events throughout the year, such as:-
- Annual Charity Walk for Peace
- Charity Walk for Peace at regional and local branch levels
- National and regional meetings for donating funds to local charities
CWFP may invite its members on such events. You may receive such invitations by post unless you have asked us not to contact you in this way (‘opted out’) or by email if you have consented to receive such invitations in this way.
Newsletters & Contact by Social Media
In addition, CWFP may contact you using the preferences you have expressed when you provide us with your Profile Data or otherwise have stated these in your consent form.
THE TYPE OF PERSONAL DATA WE COLLECT ABOUT YOU
When we refer to collecting or using personal data, or personal information, we are referring to any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and share different kinds of personal data about you which we have grouped together as below:
Types of personal data that we collect, store, use and transfer
- Identity Data
This includes: Name, username or similar identifier, title, and, membership details (if applicable), title or office held within CWFP (if applicable) and title and office held within other charities.
- Contact Data
This includes billing address, delivery address, email address and telephone numbers.
- Financial Data
This includes bank account and payment card details if given by you
- Transaction Data
This includes details about payments from and to you, and in some cases details of services you have obtained from us.
- Technical Data
This includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Profile Data
This includes your username and password, preferences, feedback and survey responses.
- Events Data
This includes your preferences in receiving information about (or invites to) events and your communication preferences.
- Human Resources Data (‘HR Data’)
This includes Identity Data, Contact Data and Special Category Data for staff and volunteers. With regard to staff members this may also include Financial Data and Transaction Data.
We may also collect, use and share Aggregated Data (i.e. Anonymous Data) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
WHERE DO WE GET YOUR PERSONAL DATA FROM?
We use different methods to collect data from and about you. We have set this out in the list below.
- How we collect personal data
Direct Interactions You may give us your Identity Data or Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
– Request that details of events be sent to you
– Apply for products and services
– Give us some feedback
- Automated technologies or interactions
- Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
– Membership data from Majlis Ansarullah UK Ltd, a registered charity that organizes the CWFP events.
– Contact Data and Financial Data from other charities participating in our events.Technical Data from the following parties:
– Analytics providers such as Google based outside the EU;
– Search information providers such as Google, based inside OR outside the EU.
Further information about cookies
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we have your consent to do so.
- Where we need to perform a contract which we are about to enter, or have entered into, with you.
- Where we need to comply with a legal or regulatory obligation.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We use your personal data when undertaking the following activities:
Type of activities which we engage in, and corresponding purposes
- CWFP member registration
Administration, governance and maintenance of membership records for CWFP.
- Financial Information Entry
1. Donations Entry into System
2. Getting Gift Aid Consent
3. Payroll Data Entry into System
4. Accounts Payable
5. Payments to other charities
- HR Employee, Payroll, Pension processing
1. To maintain employee records
2. For processing the payroll
3. For sponsored employees, records required by Home office.
LEGAL BASIS FOR USING YOUR PERSONAL DATA
We have set out below, in a table format, a description of particular activities in which we engage, and according to which we process personal data. Further, we have set out the legal basis which we rely on in order to do so. We have also identified our legitimate interests for processing personal data, where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need any further details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
|Specific purpose or activity||Type of data used||Lawful basis for processing (Article 6 GDPR)||Lawful basis for processing (Article 9 GDPR)|
|For administrative purposes to register non- members interested in CWFP activities||Identity Data
|1. Donations Entry into System
2. Getting Gift Aid Consent
3. Payroll Data Entry into System
4. Accounts Payable
5. Payment to charities
|1. To maintain employee records
2. For processing the payroll every month
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose. This new purpose must be compatible with the original purpose for which we collected your data. If you have any questions concerning this matter, please Contact us .
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or seek your consent to do so
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where we are required, or permitted to do so by law.
SHARING YOUR PERSONAL DATA
CWFP may need to share your personal data with the parties set out below. Our purposes for doing so are set out in the table above marked Type of activities which we engage in, and corresponding purposes.
|External third parties|
|Type of professional advisers acting as processors or joint controllers||Country in which company is based||Service provided / need for sharing|
|HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers||United Kingdom||Require reporting of processing activities in certain circumstances|
|Majlis Ansarullah (UK) Ltd||United Kingdom||Sharing Identity data|
We require all third parties to respect the security of your personal data and to treat it in accordance with the law and our own specific and stringent security requirements. We only permit the above third-party service providers to process your personal data in accordance with our instructions and we put in place legal agreements to ensure this accordingly.
INTERNATIONAL DATA TRANSFERS
We do not currently share your data outside the European Economic Area (EEA). We may however at times have to transfer your personal data out of the EEA, at that time we will ensure a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: ‘Adequacy of the protection of personal data in non-EU countries’.
- Where we use service providers in countries that have not been deemed to provide an adequate level of protection, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: ‘Model contracts for the transfer of personal data to third countries’.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
- We have obtained your explicit consent
Please Contact us if you wish to receive further information on the specific mechanism which we use when transferring your personal data out of the EEA or if you have any concerns.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed and/or processed in an unauthorised manner. These measures include:
- Hard copies of personal data are securely managed and not left unattended.
- CWFP maintains a clear desk policy (meaning that confidential information is not left unattended e.g. papers containing confidential information is not left on desktops, laptops are not left unsecured and any confidential information is locked away when not in use).
- Personal data is always out of view of anyone who has not been granted access to it and it should be locked away outside core operating hours.
- Paper-based documentation containing personal data is disposed of in a secure manner when no longer required (i.e. via confidential waste bins or cross shredders).
- Systems holding personal data have controls and measures in place to keep the data secure, provide protection from malware infection and data backup in case of equipment failure.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have an operational ‘need to know’. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the following criterion:
- the amount, nature, and sensitivity of the personal data;
- the potential risk of harm from unauthorised use or disclosure of your personal data;
- the purposes for which we process your personal data; whether we can achieve those purposes through other means; and
- the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available on request Please contact us using link here on section 17, contact us. In some circumstances, you can ask us to delete your data: see your right to Request Erasure below for further information.
In some circumstances, we may anonymise your personal data (so that you can no longer be identified through the data) for research or statistical purposes. According to the law, anonymous data is not classed as personal data, as the data cannot be used identify any given individual. As such, we are permitted by law to use anonymous data indefinitely without further notice to any data subject.
DESCRIPTION OF YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that your data is being lawfully processed.
- Request correction of the personal data that we hold about you. This enables you to request that any incomplete or inaccurate data which we hold about you is corrected, though we may need to verify the accuracy of the new data which you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data in the following circumstances: where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully; or where we are legally required to erase your personal data. Please note, however, that we may not always be able to comply with your request of erasure due to specific legal reasons. If such circumstances arise, you will be notified at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) if our legitimate interest is overridden by your own interests and/or fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where you consider our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to yourself or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note, this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you at the time if this is the case.
EXERCISING YOUR LEGAL RIGHTS
Data Subject Access Requests:
- No fee usually required
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 reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
- What we may need from you
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.
- Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of your other rights please contact us using the link here firstname.lastname@example.org by email or use link in section 17 Contact us below.
As mentioned above, we have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy statement. If you have any questions about this privacy statement or how we handle your personal information, please contact our DPO using the contact details provided above.