This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal data. We may update this Policy from time to time without notice to you, so please check it regularly.
The provision of your personal data to us is voluntary. However, without providing us with your personal data, you will be unable to (as appropriate): contact us; subscribe to our mailing list; subscribe to any of our publications; or receive information about Pakistan Trade Union Solidarity.
- We collect information about you:
(1) When you give it to us DIRECTLY
You may give us your personal data in order to subscribe to a newsletter or publication, when you contact us by phone, email or post, when you sign a petition / statement, and/or when you donate money to us.
(2) When you give it to us INDIRECTLY
Your information will also be provided to us when you follow us or otherwise interact with on or via Twitter, when you like and/or join our page on Facebook or interact with us in other ways on or via Facebook.
(3) When you give permission to OTHER ORGANISATIONS to share it or it is AVAILABLE PUBLICLY
We may combine information you provide to us with information available from external publicly available sources. Depending on your privacy settings for social media services, we may also access information from those accounts or services. We use this information to gain a better understanding of you and to improve our communications and fundraising activities.
(4) When you visit our WEBSITE
- What information do we collect?
We may collect, store and use the following kinds of personal data:
(1) We will typically hold your name and contact details, including telephone number, location, and e-mail address. However, we may request other information where it is appropriate and relevant, for example:
- Your bank details or debit/credit card details (if making a donation).
(2) any communication preferences you give;
(3) information about your computer and about your visits to and use of this website including your IP address, geographical location, browser type, referral source, length of visit and number of page views; and/or
(4) any other information shared with us as per clause 1.
Do we process sensitive personal information?
Applicable law recognises certain categories of personal information as sensitive and therefore requiring more protection, including political opinions and trade union membership. In limited cases, we may collect sensitive personal data about you. We would only collect sensitive personal data if there is a clear reason for doing so; and will only do so with your explicit consent.
- How and why will we use your personal data?
Personal data, however provided to us, will be used for the purposes specified in this Policy or in relevant parts of the website.
We may use your personal information to:
(1) Enable you to subscribe to our hard copy publications;
(2) Send you information about our work, campaigns, organisations and any other information, products or services that we provide (this will not be done without your consent);
(3) Provide you with the services, products or information you have requested;
(4) If you request, put you in touch with other supporters in your area (who have also provided such consent);
(5) Handle the administration of any donation or other payment you make via credit/debit card, cheque, standing order or BACS transfer;
(6) Collect payments from you and send statements and/or receipts to you;
(7) Conduct research into the impact of our activity / campaigns;
(8) Deal with enquiries and complaints made by you relating to the website or us in general;
(9) Make petition submissions to third parties, where you have signed a petition and the third party is a target of the campaign to which the petition relates; and/or
(10) Audit and/or administer our accounts.
- Supporter Analysis
We may use some of your personal information to analyse our digital performance, for example to see how our website can be improved to help us achieve the purposes set out in section 9 below, to record how you are using our website or to assess the popularity of different articles / campaigns.
You can opt-out of the collection of information for such purposes here: http://www.aboutads.info/choices
- Communications, updates, fundraising
Where you have provided appropriate consent, we will contact you by telephone and e-mail, with targeted communications to let you know about our events and/or activities that we consider may be of particular interest; about the work of Pakistan Trade Union Solidarity; and to ask for donations or other support.
- Donations and other payments
All financial transactions carried out on our website are handled through either:
We will provide your personal data to PayPal / GoCardless only to the extent necessary for the purposes of processing payments for transactions you enter into with us. We do not store your financial details.
- Children’s data
We do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are 15 and under and we are holding your personal information, we will delete that information within a reasonable period and withhold our services accordingly.
- Security of and access to your personal data
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to your personal information.
Your information is only accessible by appropriately trained staff and volunteers.
We may also use agencies and/or suppliers to process data on our behalf. We may also merge or partner with other organisations and in so doing transfer and/or acquire personal data.
Please note that some countries outside of the EEA have a lower standard of protection for personal data, including lower security requirements and fewer rights for individuals. We may transfer and/or store personal data collected from you to and/or at a destination outside the European Economic Area (“EEA”). Such personal data may be processed by agencies and/or suppliers operating outside the EEA. If we transfer and/or store your personal data outside the EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your personal data.
- 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 direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following rights:
(1) Right to be informed – you have the right to be told how your personal information will be used. This Policy and any other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
(2) Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we have 30 days to comply.
(3) Right of erasure – as from 25 May 2018, you can ask us for your personal information to be deleted from our records.
(4) Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
(5) Right to restrict processing – you have the right to ask for processing of your personal data to be restricted if there is disagreement about its accuracy or legitimate usage.
(6) Right to data portability – to the extent required by the General Data Protection Regulations (“GDPR”) where we are processing your personal information (i) under your consent, (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 into a contact or (iii) by automated means, you may ask us to provide it to you – or another service provider – in a machine-readable format.
Where we consider that the information with which you have provided us does not enable us to identify the personal information in question, we reserve the right to ask for (i) personal identification and/or (ii) further information.
- Lawful processing
We are required to have one or more lawful grounds to process your personal information. Only 4 of these are relevant to us:
- Personal information is processed on the basis of a person’s consent
- Personal information is processed on the basis of a contractual relationship
- Personal information is processed on the basis of legal obligations
- Personal information is processed on the basis of legitimate interests
We will ask for your consent to use your information to send you electronic communications such as newsletters and and fundraising emails, and if you ever share sensitive personal information with us.
(2) Contractual relationships
Most of our interactions with supporters are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you subscribe to one of our publications, or purchase merchandise online.
(3) Legal obligations
Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
(4) Legitimate interests
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
We will rely on this ground to process your personal data when it is not practical or appropriate to ask for consent.
Achieving our purposes
These include (but are not limited to) promoting socialist policies
- Internal and external audit for financial or regulatory compliance purposes
- Statutory reporting
Publicity and income generation
- Conventional direct marketing and other forms of marketing, publicity or advertisement
- Unsolicited messages, including campaigns, newsletters, and fundraising appeals
- Analysis, targeting and segmentation to develop and promote or strategy and improve communication efficiency
- Personalisation used to tailor and enhance your experience of our communications
- Maintenance of suppression files
- Processing for historical, scientific or statistical purpose
Purely administrative purposes
- Responding to enquiries
- Delivery of requested products or information
- Communications designed to administer existing services including subscriptions, administration of petitions and financial transactions
- Thank you communications and receipts
- Maintaining a supporter database and suppression lists
Financial Management and control
- Processing financial transactions and maintaining financial controls
- Prevention of fraud, misuse of services, or money laundering
- Enforcement of legal claims
- Reporting criminal acts and compliance with law enforcement agencies
When we use your personal information, we will consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair in other ways.
- Data retention
The length of time each category of data will be retained will vary depending on how long we need to process it for, the reason it was collected, and in line with any statutory requirements. After this point the data will either be deleted, or we may retain a secure anonymised record for research and analytical purposes.
In the event that you ask us to stop sending you direct marketing/fundraising/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again.
- Policy amendments
- Third party websites
- Updating information
You can check the personal data we hold about you, and ask us to update it where necessary, by emailing us at email@example.com
We are not required by law to have a “Data Protection Officer” – however we have a Data Protection Manager.
Please let us know if you have any queries or concerns whatsoever about the way in which your data is being processed by emailing the Data Protection Manager at firstname.lastname@example.org