Twinning Project takes the privacy and security of your personal information very seriously.
This privacy policy sets out how Twinning Project processes personal data (that is, information by which an individual can be identified) collected by us in the course of our lawful activities, in accordance with the General Data Protection Regulation and any subsequent legislation (‘Data Protections laws’). This policy has been put in place to protect your rights under the Data Protection laws, and it is important that you understand what we will do with your data and are happy with this. If you want to discuss any matter relating to how your data is used, please email us at info@twinningproject.org.
References to the processing of information includes the collection, use, storage and protection of data.
Twinning Project is the ‘data controller’ for the purposes of this policy, and the policy extends to its staff, trustees, volunteers and anyone else processing data on our behalf from time to time.
Twinning Project is committed to ensuring that your privacy is protected. Any personal data collected by Twinning Project will only be processed in accordance with this privacy policy.
Organisations are permitted to process data if they have a legal basis for doing so. Twinning Project processes data on the basis that:
• Express and informed consent has been given by the person whose data is being processed; and/or
• Twinning Project has a legitimate interest in processing the data; and/or
• It is necessary in relation to a contract or agreement which the person has entered into or because the person has asked for something to be done so they can enter into a contract or agreement; and/or
• There is a legal obligation on Twinning Project to process data.
Where Twinning Project is relying on solely consent as the basis for processing data, we are required to obtain your explicit consent and you can modify or withdraw this consent at any time by notifying us in writing, although this may affect the extent to which Twinning Project is able to provide services to or interact with you in future.
Twinning Project may change this policy from time to time and any such changes will be published on our website. Notwithstanding any change to this policy, we will continue to process your personal data in accordance with your rights and our obligations in law.
This policy is effective from 1st October 2019.
What data do we collect?
We collect the data necessary for Twinning Project to pursue its charitable objectives. Accordingly, data will be processed for operational purposes, fundraising and marketing, running events, keeping our supporters informed of our activities and the effective running of Twinning Project through its professional staff, trustees and volunteers. Data collected and processed may include, but not be limited to:
• Names and contact information such as telephone numbers, email and postal addresses
• Donor and volunteer records and preferences, including, where necessary, bank or payment details in order to process payments from you
• Such other information that is relevant and necessary for Twinning Project to carry out its activities, charitable purposes and legal obligations.
What we do with the data we process
Twinning Project uses the data collected to maintain accurate internal records of our engagement with supporters, volunteers, staff and others. These records facilitate our activities run in accordance with our charitable objects, communicating with our supporters and raising funds and awareness about our work through activities and events. Data may be processed and viewed by the relevant staff, trustees and volunteers in the course of Twinning Project’s activities (all of whom work in accordance with this privacy policy) and will be retained only for as long as is reasonable, necessary and permissible in law.
You, as the data subject, may request deletion of your data at any time in writing, subject to any overriding legal requirement for its retention, such as the need, where appropriate, to retain Gift Aid records for Her Majesty’s Revenue and Customs. We may keep such data on a ‘suppression list’ so we know not to contact you or process your data in future until further notice.
Your rights in relation to your personal data
You may request details of personal information which we hold about you. Any such request must be submitted in writing. A small fee may be payable if an information request is particularly onerous.
You may choose to restrict the collection or use of your personal information, but this may inhibit or limit the way in which Twinning Project is able to interact with you. You may, at any time, change your mind about what information we hold about you, or if we continue to hold it at all, subject to any legal obligation on Twinning Project to retain data.
You are responsible for the accuracy of data you have provided to Twinning Project. If you believe that any information we are holding on you is incorrect or incomplete, please write to us as soon as possible. We will promptly correct any information found to be incorrect.
We may use your personal information to send you information about Twinning Project and matters relating to Twinning Project’s activities which we think may be of interest to you. We will only share data with trusted third parties where necessary for us to communicate with you (such as mailing companies for postal communications or through email campaigns or newsletters), for event management or as stated above, and only once we are satisfied that any such use of data will accord with our privacy policy. We will not sell or share your personal information with any other charities, businesses or marketing companies without your explicit consent.
You can obtain further information about Data Protection and privacy laws by visiting the Information Commissioner’s website at: https://ico.org.uk.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the data we process. Persons processing data on behalf of Twinning Project do so in accordance with this policy and on the basis that Twinning Project is satisfied that they can and will adhere to our high standards for data protection and security.
The transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. You are responsible for keeping the password you use for accessing our website (if applicable) confidential; we will not ask you for your password (except when you log in to our website).
Web Browsing and Cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We may also collect and store information about your browsing device, including, where available, your IP address, operating system and browser type. This is anonymous statistical data about your browsing activities and patterns, and does not contain any personal data.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy policy applicable to the website in question.
Your consent
This policy exists to inform you of your rights and our obligations in relation to your personal data. In order for us to be able to continue to communicate with you fully in future (using both electronic and non-electronic means) we would like to record your consent by asking you to tick the box below. If you do not, we may not be able to tell you about the wonderful work of Twinning Project as efficiently as we would like.
