Please read this policy carefully, along with any other documents referred to in this policy, to understand how we collect, use and store your personal information.
Privacy policy
Orbis UK is committed to protecting the privacy of your data. This policy (together with any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
What information do we collect and how do we process this information?
- Who we are
- Why we collect information
- How do we collect information
- What information do we collect and how do we process this information
- How do we use your information
- Updating us on how you would like us to use your information
- Will we disclose the information we have collected to outside parties?
- How do we keep your data safe?
- Your rights
- Updating your information
- Children’s data
- Applications to work or volunteer for Orbis UK
- Confidentiality
- Notification of change of privacy policy
- Making a complaint
- Cookies
Who we are
Orbis UK is the operating name of Orbis Charitable Trust, a charity registered with the Charity Commission (No 1061352) and a company limited by guarantee (No 03303689).
Whenever we refer to 'we', 'us' or 'our', we are referring to Orbis UK.
The processing of your personal data is carried out by Orbis UK, we are registered with the Information Commissioner’s Office as a Data Controller.
Orbis UK complies with the following legal requirements:
- The Data Protection Act 2018
- General Data Protection Regulation 2016
- Privacy and Electronic Communication Regulations 2003
If you have any questions regarding our privacy policy, please contact:
Orbis UK, 41-42 Craven Street, London, WC2N 5NG, UK , EC3R 6AF Tel: 44 (0)20 7608 7260 Email: [email protected]
Why do we collect information?
Collecting information from the people that we interact with allows us to operate and provide our services more efficiently, for the benefit of the charity and our beneficiaries. For example, collecting information and understanding more about how people use the information we provide, means we can improve how we communicate with you and keep you up-to-date on relevant matters.
How do we collect information?
We collect information when you interact with us. When you contact Orbis UK regarding our activities, register as a supporter, send or receive information, engage with social media, make a donation to us, volunteer with us, apply to work for us or make contact with us in any other way, you provide us with personal information. We may also collect information through our use of cookies (please see the Cookies section below).
What information do we collect and how do we process this information?
Financial information
In order to process donations and other financial transactions, we may ask you for your bank, debit or credit card details.
Personal information
When you interact with us, we may collect information such as your name, address, email address, other contact details and gift aid declarations.
Other information
We may also collect the following information from you:
- Records of your donation history and any correspondence with us;
- Any images, photographs or videos if you take part in any events with us;
- Details of your visits to the website including your IP address (see below section on Cookies for more information in relation to this);
- Other details relevant to your communications with us
If you provide consent, we may collect personal data from you such as health or religion.
Publicly available information
In addition to the information you give us directly, we may also, where the law allows us to do so, collect information about you from publicly available sources or third parties (please see the Research section below for more information on this).
How do we use your information?
When you provide us with personal data, such as your name and email address we may use your information in a number of ways and for a number of purposes including:
- To provide you with information that you have requested from us or that we feel may be of interest to you where you have consented to being contacted
- To provide you with information about our work or our activities
- To process donations we may receive from you
- To fundraise in accordance with our internal policies and procedures
- For administrative purposes (e.g. to follow up on a donation query, to make travel arrangements if you are visiting a project, to invite you to an event)
- To contact you in the most appropriate way and so that you do not receive unwanted communications
- For internal record keeping
- To contact you where you are the named person for an organisation (e.g. a church)
- Where it is required or authorised by law
Fundraising and marketing
We may contact you by email or text for fundraising and marketing purposes if you have provided consent to be contacted in this manner.
If you have given us your address or phone number, we may also send you information about our work by post or phone unless you have told us that you would prefer not to receive information in this way. This is on the basis of it being within Orbis UK’s legitimate interests to do so. Please read the 'Our legal basis for processing' section below for more information on this.
The types of fundraising and marketing materials that you can expect to receive from us include appeals, newsletters and updates on our work, event invites, information about volunteering opportunities and other ways that you can support us.
Research and analysis
We may use research, profiling and screening techniques to analyse your personal information to create a profile or your interests and preferences, so that we can contact you with information relevant to you. This allows us to ensure our communications are relevant and timely.
We might also make use of additional information about you, including geo-demographic information and measures of affluence, when it is available from third party sources. For instance, addresses, directorships, newspaper articles and typical earnings in a given industry from sources such as Companies House, the electoral register, the Charity Commission’s Register of Charities, Who’s Who, LinkedIn, company annual reports, and articles in newspapers and magazines.
We do this because it helps us to understand the background of the people who do or may support us and to make appropriate requests. This helps us to provide a more targeted and relevant donor experience, and to raise funds more efficiently. Please contact us using the details above if you would prefer that we did not use your data in these ways.
Updating us on how you would like us to use your information
If you wish to update the way you would like to be communicated with in future or wish to opt out of ways we use your information, please contact us at [email protected] or call us on 020 7608 7260. Please be aware it may take up to 28 days for any changes to be activated.
If we are processing your data on the basis that your consent has been given, you have the right to withdraw this consent at any time.
Our marketing communications to you will include information on how to opt out of receiving future marketing communications from us.
Our legal bases for processing data
We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:
a. Consent: where you have provided your consent for our use of your personal information in a certain way, for example, where we ask for your consent to send you information about the charity via email and SMS.
b. Legal obligation: where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject, for example where we have to share your personal information with regulatory bodies which govern our work, or where we claim Gift Aid on donations.
c. Contractual relationship: where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract), for example, we might do this where you attend a paid for event.
d. Legitimate interests: where applicable law allows us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights.
We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For instance, we rely on the legitimate interest ground to process your personal data in order to send you fundraising materials by post or phone.
Will we disclose the information we have collected to outside parties?
We may pass personal details to suppliers who are instructed to act on our behalf in the following circumstances only:
- To help us process your financial transactions, such as our direct debit or online credit card donations
- To help us undertake and manage fundraising campaigns for the four reasons detailed below: - Print companies and mailing houses that are printing and sending newsletters and fundraising appeals to our supporters - If we have your consent to contact you by phone then we may share relevant information with a Professional Fundraising Organisation (PFO) which is carrying out fundraising campaigns on our behalf to our supporters - We may disclose anonymous information to a third party marketing or research company to carry out analysis of our fundraising and awareness campaigns - We may disclose your information to a research company to identify any relevant publicly available data that will allow us to communicate with you more effectively and with the most relevant information
In both these situations we ensure we send data securely and have signed agreements that cover the third party's data protection responsibilities. As part of the agreements we request that the service providers delete all supporter information once the campaign/analysis has taken place.
We may also disclose your information if required to do so by law, or if we believe in good faith that this is necessary to protect the rights, property and safety of Orbis UK, or others.
We will never share or sell your data to a third party organisation for them to contact you for their marketing purposes.
We aim to ensure that there are appropriate physical, technical and managerial controls in place to protect your personal details.
For example, when we collect personal information from you, this information is stored on our secure servers which also stores our database, Raiser’s Edge.
In relation to financial data, we process debit and credit card transactions in compliance with the Payment Card Industry Data Security Standard (PCI DSS) which defines the requirements for the storage, processing and transmission of payment card data.
This means that this financial data, whether online donations or written or telephone debit or credit card responses to fundraising appeals are processed and stored securely and that your financial data is not stored by us for any period longer than necessary to process your donation.
We use secure server layer software (SSL) to protect information transferred over the Internet, for example when processing recurring direct debit payments.
Third party suppliers who provide services to Orbis UK are compliant with UK data protection regulations. The main suppliers are:
- Rapidata – who provide our online payment system and direct debit processing
- Cymba – who process donations by premium short messaging service (PSMS)
When we work with external companies who collect or process data on our behalf, we do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our requirements in relation to how data is processed and kept secure.
We may need to transfer your personal data to organisations based in countries outside of the EEA to allow them to perform services on our behalf. In doing so, your data may be stored or otherwise processed outside of the EEA.
Where your personal information is transferred, stored, and/or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information.
We share a limited amount of personal data with our sister charity Orbis International, who are based in New York, USA. If you require further information around the types of safeguards in place, please do get in touch with us.
Our website may from time to time contain links to third party websites. If you follow a link to any of these websites, please note that these websites will have their own privacy policies in place, and we do not accept liability for any such policies.
Despite the precautions set out in this policy, no data transmission over the internet is guaranteed to be secure. As such, whilst we do endeavour to protect your personal information as set out in this policy, we cannot guarantee the security of any information which you provide us with.
Your rights
You have a number of rights regarding the personal information we hold about you
- Right to be informed
You have the right to be told how your personal information will be used. This privacy policy is intended to be a transparent description of how your data may be used.
- Right of access
You have the right to obtain confirmation from us that we are processing your personal data and a copy of the personal data we hold about you. You can make this request free of charge by emailing us at [email protected]. Please include ‘Subject Access Request’ in the subject line of your email which will help us to identify and respond to your request as quickly as possible.
- Right to object
You have the right to object to the processing of personal data in certain circumstances. For instance, you have the absolute right to object to the processing of your data for direct marketing purposes and in some cases, a right to object where we are relying on legitimate interest.
- Right to rectification
You have the right to have inaccurate personal data we hold about you rectified or completed if it is incomplete. Please contact us if you think any of the personal data we hold about you is inaccurate or out of date.
- Right to erasure
You have the right to have the personal data we hold erased if it is no longer necessary for the purpose we originally collected or processed it for, you withdraw consent or where there is no lawful basis for us to keep it. However, depending upon the purposes for which the data is held, it may be necessary to hold a very limited amount of data to ensure that you are not contacted in error in the future.
- Right to data portability
You have the right to receive a copy of the personal data you have provided in a structured and commonly used format to manage and reuse for your own purpose or to have this data transmitted to a third party where technically feasible.
- Right to restrict processing
You have the right to restrict the processing of your personal data where you have contested its accuracy or have requested it to be erased.
- Rights related to automated decision making including profiling
Individuals have the right not to be subject to a decision when it is based on automated processing with no human intervention which produces a legal effect or similar significant impact.
We do not currently carry out any automated decision making.
Please be aware that some of the above rights only apply in certain circumstances and we may not be able to grant every request. You can visit the Information Commissioner’s Office for further information about this regulation at ico.org.uk.
Please contact Orbis UK if you wish to exercise any of these rights, at: 6th floor, 10 Lower Thames Street, London, EC3R 6AF, call 44 (0)20 7608 7260 or email [email protected].
Data retention
We will store your personal data in a form which permits us to identify you, for no longer than is necessary for the purpose for which the personal data is processed. We may retain and use your personal data as necessary to comply with legal and statutory obligations.
Unless still required in connection with the purpose for which it was collected and/or processed, we will generally remove your personal information from our records 7 years after the end of the financial year that it was collected.
Children's data
When you donate or otherwise engage with us, you are stating that you are over 18 years of age or are a minor acting with parental consent. You agree that any information you provide to us about yourself upon registration or at any time is true.
Applications to work or volunteer for Orbis UK
If you apply for an employment vacancy at Orbis UK we will use the information you supply as part of the recruitment process (see job applicant privacy notice). If we need to take up references for example, we will inform you beforehand, unless we are required to disclose this information by law.
If you have been interviewed but are unsuccessful in your job application, we will hold your information for six months after the recruitment campaign and then destroy or delete these records.
If you are successful in your application, a personnel file will be created which will contain relevant personal information. This is covered more fully in the staff handbook, which you will receive once you commence work with Orbis UK.
Once you leave Orbis UK your information will be held for a relevant period. Please contact us for further details.
If you apply to become a medical volunteer for Orbis globally, your data will be collected and shared with Orbis International in New York, USA to follow up on your application.
As a global organisation, we may on occasion, need to share information with a provider outside the European Economic Area (EEA). However, we require them to process your information in compliance with European data protection regulations. We will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this privacy policy.
Notification of change of privacy policy
We reserve the right to amend this privacy statement. You are advised to visit this website section periodically in order to keep up-to-date with the changes in our privacy policy.
Making a complaint
If you wish to make a complaint in relation to how we have used your data, you can contact us at [email protected], call us on 020 7608 7260 or contact the Information Commissioner’s Office.
Cookies
What are cookies?
Cookies are pieces of information that are sent to your computer (or other device) by a website when you visit. They are stored on your device allowing a website to recognise you when you visit.
Do we use cookies?
Yes. Orbis UK uses this data to analyse trends and statistics to help us provide a better service. If you do not want cookies to be used there are various options to disable or opt-out without affecting your navigation around our site, however this may restrict functionality in some areas.
We may use 'essential cookies' which are required for the operation of our website; analytical cookies to allow us to recognise and count visitors; functionality cookies which recognise you and remember your preferences; and targeting cookies which record your visit to our webpage and links you have followed and then targets our content more specifically to you.
What cookies do we use?
Third-party cookies
By using the Orbis UK website or by performing certain actions (such as using a social sharing button) certain other sites may also set cookies.
Making a donation
Cookies are used in order to take a donation online, if you want to donate without the use of cookies, please donate via an alternative route such as over the phone or by post.
Analytics
Orbis uses Google Analytics to produce anonymous data which we use to measure trends and statistics helping us provide a better service. This is a common performance cookie which many websites use. You can opt-out of Google Analytics here. (Note this opt-out will extend to all sites using Google Analytics, not just Orbis UK).
Embedded content:
Orbis UK sometimes embeds photos and video content from websites such as YouTube and Flickr. As a result, when you visit a page with content embedded from these sites you may be presented with cookies from them. Orbis UK does not control the dissemination of these cookies. You should check the relevant third party website for more information.
Social media sharing icons, buttons and widgets:
The Orbis UK website uses embedded ‘share’ buttons to enable users of the site to easily share pages with their friends through a number of popular social networks. These sites may also set cookies. Orbis UK does not control the dissemination of these cookies and you should check the relevant third party website for more information about these.
Advertising
Like many websites, we may make use of cookies to identify if you have visited our website, or visited a specific page on our website. These cookies may then be used to display related advertising from Orbis UK on third party websites such as Facebook or on online adverting networks such as the Google Display Network (GDN). These cookies do not provide us with personally identifiable information.
Find out about your options to opt out of ‘interest-based advertising’ served by Google
Find out more about ‘online behavioural advertising’ in the UK
How do you disable cookies?
If you wish to restrict or block the cookies which are set by Orbis UK, or any other website, you can do this through your browser settings. The Help function within your browser should tell you how.
You can find detailed information on cookies and how to disable them at www.allaboutcookies.org.
November 2018