Introduction and general terms
Who we are
- a) Personal data is information about a living individual which is capable of identifying that individual. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession.
- b) Processing is anything done with/to personal data, including storing it.
- c) The data subject is the person about whom personal data are processed.
- d) The data controller is the person or organisation who determines the how and what of data processing.
- e) The GDPR is the General Data Protection Regulation 2016/679 which governs the processing of personal data.
SMEF’s purpose is defined in its trust deed as “The education of the poor people of Santa Maria de Fe, Misiones, Paraguay and elsewhere in Paraguay, especially, but not exclusively, in formal education at tertiary level.”
We take active steps to make sure that our supporters are aware of the ways in which they can help us achieve our overall purpose. They help us in a variety of ways, primarily by:
*fundraising and donating money
*volunteering, either as teachers in Paraguay, or in administrative work in the UK
*welcoming our Paraguayan students to their homes during visits to the UK
*offering moral or spiritual support through prayer and promotion among friends and fellow parishioners, workmates or school contacts.
Why we hold and process supporters’ personal data
We hold and process supporters’ personal data for a number of reasons:
*to keep a record of donations made and actions taken by our supporters and our communications with them
*to send our supporters information about how the money they have donated is being spent, through the newsletter or individual reports
*to send our supporters information about our projects, principally through the newsletter
*to let our supporters know when and why we are looking for further donations and for fundraising activities
*to record and communicate campaigning actions by supporters
*to claim gift aid on donations
*to respond to orders for Christmas cards and to manage our records of sales
*to support and manage our volunteer programme
*to ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted.
Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for organisations to collect and process your personal data. SMEF relies on the following legal bases for collecting and processing your data:
We may ask you for your consent to be put on our data base for mailings – for instance where you have expressed a wish to know about our activities.
In limited situations processing may be necessary for a contract we have with an individual, or because they have asked us to take specific steps before entering into a contract.
If the law requires us to, we may need to collect and process your data. For example, where you sign up to the Gift Aid scheme, we will process your data for the purposes of submitting a Gift Aid claim to HMRC.
In very rare situations it could occur that we would need to use data in the event of someone’s life being threatened by illness or accident, eg: in the case of a volunteer in Paraguay or a Paraguayan student in the UK, to protect their vital interests.
In limited situations it could occur that we may use data in the public interest, eg: to prevent crime or dishonesty, or safeguard the wellbeing of people with whom we work.
Processing is necessary for the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject. In many situations we need data in order to carry out a task in our legitimate interest, such as
*to send thank you emails or letters in response to donations made to us
*to send thank you emails or letters upon termination of regular giving arrangements
*to record donation details on our database
*to make Gift Aid claims
*to organise educational and fundraising events in schools or other campaigning activities
*to organise a visit of a Paraguayan student invited to a private home
*to enrol volunteers
*to communicate with volunteers in respect of the activities for which they are volunteering
*to give former volunteers news about friends they have made in Paraguay and the progress of their former students.
*to continue to communicate with data subjects already on our database, from whom we have not yet received an answer, to give those data subjects the opportunity to complete a consent form if they would like to do so
*to keep a record of correspondence and any associated documents, eg: when supporters contact us with a question, comment, compliment or complaint, so that we have the information available in the event of a follow-up.
If you would prefer we do not use your personal information in this way, or want to change the way you hear from us, please contact us:
*by email to email@example.com
*by post to SMEF, 20 Oakcroft Road, London SE13 7ED
What information might SMEF collect about you?
We only collect personal data relevant to the type of transactions or interaction you have with SMEF, or information that you have wished to share with us. We are likely to process details such as your name, email address, postal address, telephone or mobile number, and if you are a UK tax payer so that we can claim Gift Aid.
For example, when you contact SMEF to make a donation or respond to something you have read in our newsletter, or you email or write to SMEF, or you speak to one of our volunteer staff, we may receive and retain personal information. You may give us your information indirectly when you sign up to events, contribute to SMEF via fundraising sites like BT MyDonate, or participate in a campaigning action with a partner. In most circumstances we will ask you to put your consent in writing or email reply, to ensure there is no doubt that you wish to remain on our data base.
We do not normally collect “sensitive personal data” about our supporters, e.g. health status or criminal record, and would only do so where there is a clear and specific reason for doing so, such as volunteering in Paraguay and working with children and young people, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this we will do it carefully, in accordance with applicable laws, and will store it on a secure database, to which only a limited number of relevant staff have access.
How will SMEF use your personal data?
SMEF will use your personal information for the following purposes:
*to send you newsletters from time to time detailing our activity
*for specific fundraising reasons
*for “service administration”, which means that SMEF may contact you for reasons related to administering any donations you have made, your tax status with regard to Gift Aid if claimed, or an activity you have signed up for
*to confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used
*in relation to correspondence you have entered into with us whether by letter, email, text, or any other means, and to contact you about any content you provide
*for internal record keeping so as to keep a record of your relationship with us
*for highly limited marketing purposes, particularly to keep a record of those who have ordered Christmas cards and to record their preferences and feedback
*to communicate with SMEF volunteers – to support them in their designated role or administer that role
*to implement any instructions you give us to with regard to withdrawing consent
*to protect our staff and those with whom we work, or to prevent crime and dishonesty
SMEF does not exclude inviting you in the future to participate in surveys or research about SMEF or our work, but participation would always be voluntary.
Will SMEF share your personal information with anyone else?
We will only use your information within SMEF for the purposes for which it was obtained. SMEF will not, under any circumstances, share or sell your personal data with any third party, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
Only authorised staff and key volunteers have access to your personal information, and only if necessary. They understand the policies, processes and protocol for keeping it safe.
We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies, statutory bodies, or law enforcement agencies for tax purposes, where it is in the public interest, or the prevention and detection of crime, subject to appropriate protection in law).
How long will SMEF keep your personal information?
We will retain the personal data of a data subject on our database whilst the data subject remains an active supporter of SMEF as demonstrated by any of the following:
*making a donation
*making contact by email or letter
*making verbal enquiries about SMEF
*volunteering for SMEF
*showing appreciation of the newsletter
*in any other way demonstrating their active support for SMEF and its projects.
In general, we will endeavour to keep personal data only for as long as we need it. We will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules. We will not automatically delete your record if an email bounces or a newsletter is returned “addressee moved away”, but keep it dormant in case you contact us again. If you request that we stop sending you fundraising materials we will keep a record of the appropriate information to enable us to comply with your request not to be contacted by us, and we will delete your record completely if you ask us.
The accuracy of your information is important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest. If you wish to change how we communicate with you, or update the information we hold, then please contact us by one of these methods:
*email to firstname.lastname@example.org
*post to SMEF, 20 Oakcroft Road, London SE13 7ED
How SMEF keeps your data safe
We undertake regular reviews of who has access to which information, and ensure that there are appropriate technical controls in place to protect your personal details, including passwords and up-to-date anti-virus software on the strictly limited number of computers that have database material on them. We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by trustees and appropriately trained staff and volunteers.
Your rights over your personal data
Unless subject to an exemption under the GDPR, you have rights with respect to your personal data, including:
*the right to request a copy of your personal data which SMEF holds about you (which is known as “subject access request”)
*the right to request that SMEF corrects any personal data if it is found to be inaccurate or out of date
*the right to request your personal data is erased where it is no longer necessary for SMEF to retain such data (this is known as the “right to be forgotten”) and to the extent that we are permitted to by law or regulatory guidelines (but note that under HMRC rules we are required to retain financial data for seven years for audit purposes, and so will not be able to delete donation details until this time period has elapsed)
*the right to withdraw your consent to the processing at any time
*the right to object to the processing of personal data (where applicable)
*the right to lodge a complaint with the Information Commissioners Office.
How to ask us to access, amend or delete your information
If you would like to:
*tell us that your contact details have changed
*advise us that we have incorrect, out-of-date or inaccurate details for you
*ask us to stop sending you information or communications
*have your details removed from our database
please contact us in one of the following ways:
*by email to email@example.com
*by post to SMEF , 20 Oakcroft Road, London SE13 7ED
How to find out more, or make a complaint about SMEF’s approach to data protection
To make a formal complaint about SMEF’s approach to data protection or raise privacy concerns directly with our data protection team, please contact us at firstname.lastname@example.org. If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by going online to www.ico.org.uk/concerns, or by calling 0303 123 1113.
We keep this Privacy Notice under regular review and we will place any updates on our website. If we make a significant change, we will notify you.
Q Does SMEF obtain personal data from other organisations?
A SMEF does not obtain personal data from any other organisations.
Q Does SMEF use profiling as part of its fundraising campaigns?
A SMEF does not use profiling as part of its fundraising campaigns.
This Notice was last updated in July 2018.