1. Introduction
1.1 We are New Ways (company registration number 02888488 and charity number 1035688). We operate as New Ways and we have our registered office at 47 Cumberland Street, London, SW1V 4LY (“we”, “us” or “our”). We are committed to protecting and respecting your privacy.
1.2 This Privacy Policy (and any other documents referred to in it) sets out the basis on which we will process and use any personal data about our supporters, potential supporters and visitors (“supporters”) to our website (www.newways.org.uk) (“website”) that we collect from them, that they provide to us, or that we collect from third parties. Please read this Privacy Policy carefully to understand our practices regarding these individuals’ personal data and how we will treat it.
1.3 For the purpose of the Data Protection Act 1998, (the “DPA”) and the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, (the “GDPR”), we are the data controllers and are located at 47 Cumberland Street, London, SW1V 4LY.
1.4 We comply with the DPA and with the GDPR which came into force on 25th May 2018 in respect of the collection, holding, storage, use, and processing of personal data about our supporters (such personal data is held in both manual and electronic records).
1.5 We may make changes to this Privacy Policy from time to time. If we do so, we will post the changes on this page and they will apply from the time we post them. Any updates will be advised and Individuals should check back frequently to see any updates or changes to this Policy. This Privacy Policy was last updated on 16th April 2019.
2. Grounds for data collection and what information we collect?
2.1 Personal data
(a) We collect and use the following types of personal data about our supporters:
(i) personal information such as name; postal address; phone numbers (home, work and mobiles as applicable); email address(es); contact preferences; information given when registering to use or completing forms on our website; information on donations made; information that our supporters give us – for example when making donations, such as bank account details for setting up regular direct debits, or taxpayer status for gift aid purposes; information given when using our website; and information given when taking part in New Ways social media functions or on our website.
(ii) the marketing preferences of our supporters and whether and when consent to receive marketing communications has been given or withdrawn.
(iii) correspondence between supporters and ourselves (whether by telephone, e-mail or otherwise).
(b) When visiting our website, certain technical information about our supporters is captured which may include for example, internet protocol (“IP”) addresses, login information, browser type and version, pages accessed, files downloaded, full Uniform Resource Locators, (“URLs”), clickstream to, through and from the website (including date and time), page response times, download errors, length of visits to certain pages and page interaction information (such as scrolling, clicks and mouse-overs). New Ways uses this information to improve the functionality and features of our website.
(c) We collect some of the personal information set out above directly from supporters and some from third parties (for example, we may receive personal information from supporters when they make a donation to us through a third-party website, such as Just Giving or Virgin Money Giving, and the supporter has given the third-party website permission to share information with us).
(d) Supporters don’t have to disclose personal data to us to browse the website or to use our social media sites, but supporters do need to provide us with certain personal data in order for us to provide them with certain services.
(e) The safety of children is very important to us. We do not knowingly collect the personal data of those who are under 16 years old without the consent of their parent or guardian. If you are under 16 please call us on 020 7976 5114 for further information.
3. Cookies
We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.
A « cookie » is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. ‘session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. ‘persistent cookies’ which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
c. ‘third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
4. How we use personal data
4.1 We obtain, collect, record, hold, store, organise, adapt, alter, retrieve, consult, disclose, destroy and otherwise use personal data of supporters, as set out in this Privacy Policy, for the following purposes:
(a) providing supporters with the products, services and information that they ask us for;
(b) corresponding with supporters and recording any relevant communications;
(c) sending marketing information to our supporters;
(d) keeping records of donations made and actions taken by our supporters;
(e) claiming gift aid on donations;
(f) supporting volunteers;
(g) recording campaigning activities by supporters;
(h) performing our obligations under any contracts that we enter into with supporters;
(i) telling supporters about changes to our services;
(j) ensuring that content from our website is presented effectively for supporters and for their computers;
(k) administering our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(l) improving our website to ensure that content is presented most effectively for supporters and their computers; and
(m) keeping our website safe and secure.
5. How we share personal data
5.1 We will only share supporters’ personal data if:
(a) we are working with partners or volunteers whom we have carefully selected to carry out work on our behalf, such as service providers and sub-contractors (for example, IT services providers and providers of technical, payment and delivery services) to perform any contract we enter into with them. The kind of work we may ask them to do includes processing, packaging, mailing and delivering purchases, answering questions about us and any services we provide and carrying out research or analysis to assist us in our mission. As well as organising events on behalf of New Ways and/or providing administration support. We only choose partners and volunteers we trust and only pass personal data to them where they have undertaken to keep your personal data secure. We do not allow these partners o volunteers to use your data for their own purposes or disclose it to other third parties and we will take all reasonable care to ensure that such partners/volunteers keep your data secure; or
(b) we are legally required to do so e.g. by law or by an order of a court of competent jurisdiction. We will not sell supporters’ information. We will not share supporters’ information with other organisations other than as stated above.
6. Legal basis for processing personal data
6.1 We rely on various legal bases to justify our processing of supporters’ personal data. Further details of these are set out below.
(a) The supporters have given their consent to the processing of their personal data for the specific purposes mentioned above. The supporters may withdraw their consent to this processing at any time by contacting us using the contact details set out in the “Contact and complaints” section of this Privacy Policy below, but this will not affect the lawfulness of any processing of their personal data which was carried out before they withdrew their consent.
(b) The processing is necessary for our legitimate interests. These legitimate interests include processing, packaging, mailing and delivering purchases, answering questions about us and any services we provide, carrying out research or analysis to assist us in our mission and processing credit card payments.
(c) The processing is necessary to perform a contract to which the relevant supporters are parties or to take steps that they have asked us to take before entering into a contract, such as buying a book or a DVD or requesting a free film screening pack about our work.
(d) The processing is necessary for us, as the data controller, to comply with our legal obligations, such as sharing personal data where we are legally required to do so e.g. by law or by an order of a court.
7. Where we transfer and store personal data
7.1 The personal data that we collect from supporters may be transferred to and/or stored at destinations outside the UK, but within the European Economic Area, (the “EEA”). As such, adequate protection for such personal and sensitive personal data will be ensured. However, it may also be processed by staff operating outside the EEA who work for one of our suppliers (e.g. IT service providers) – in these instances, we carefully select suppliers with whom we have appropriate contractual arrangements in place to ensure safeguarding of our supporters’ personal data. This includes staff involved in, among other things, providing support services and processing payment details. We will take all steps reasonably necessary to ensure that supporters’ personal data is treated securely and in accordance with this Privacy Policy and applicable law.
7.2 All information that supporters provide to us is stored on our secure servers and/or on the servers of our suppliers who we have engaged to host various IT systems for us.
7.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect supporters’ personal data, we cannot guarantee the security of data transmitted to our website; any transmission is at supporters’ own risk. Once we have received personal information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 Our mission is to enable people to offer their money, goods, skills or time, and through this involvement, provide the most effective help to those suffering the effects of extreme poverty in the world’s poorest communities. We will keep supporters’ information only for as long as they engage with us in any of the above ways, and only as long as we need it:
(a) to administer their relationship with us;
(b) to comply with the law; or
(c) to ensure we do not communicate with supporters who have asked us not to. To assist us in this process we will review on a regular basis the personal data of supporters that we collect and hold to ensure that such data is only kept for an appropriate length of time.
8. Individuals’ rights
8.1 Supporters have certain rights in respect of the personal data that we hold about them. To exercise any of the rights set out below, please contact us using the contact details set out in the “Contact and complaints” section of this Privacy Policy below:
(a) Access. We will confirm to supporters whether or not we are processing and using personal data about them, at their request and, if so, provide them with access to and a copy of such personal data and the other details to which they are entitled.
(b) Rectification. We will correct any inaccurate personal data and complete any incomplete personal data (including by providing a supplementary statement) that we hold about supporters without undue delay at their request.
(c) Prevention of processing likely to cause damage or distress. We will respect our supporters’ rights to require us to cease or not to begin processing their personal data for a specific purpose, or in a specific way, that is likely to cause unwarranted damage or distress, either to the relevant individual or a third party.
(d) Erasure. We will erase personal data concerning a supporter at their request without undue delay in certain circumstances, (for example, among other things, if their personal data is no longer needed for the purposes for which it was collected or otherwise used).
(e) Restriction. We will restrict the processing of supporters’ personal data in certain circumstances (for example, among other things, if they believe that their personal data held by us is inaccurate), if requested by them to do so.
(f) Data portability. We will respect the rights of supporters to receive personal data about them that they have provided to us in a structured, commonly used and machine-readable format and to transmit such personal data to another data controller without hindrance from us in certain circumstances.
(g) Right to object. We will respect the general rights of supporters to object to the processing of their personal data in certain circumstances.
(h) Right to object to marketing. We will respect supporters’ rights regarding use of their personal data for direct marketing purposes. In particular, we will not begin or we will cease processing any personal data of individuals for direct marketing purposes if at any time individuals ask us not to do so.
8.2 We will process all personal data in line with supporters’ rights in each case to the extent required by and in accordance with applicable law only (including, without limitation, in accordance with any applicable time limits and requirements regarding fees and charges).
8.3 We will respect supporters’ rights regarding use of their personal data for direct marketing purposes. In particular, we will not begin or we will cease processing any personal data of individuals for direct marketing purposes if at any time a supporter asks us to stop.
8.4 Supporters can exercise their rights by contacting us using the contact details set out below in the “Contacts and complaints” section of this Privacy Policy.
9. Contact and Complaints
9.1 Questions, comments, requests or complaints regarding this Privacy Policy and/or our use of supporters’ personal data should be addressed to info@newways.org.uk or New Ways, 47 Cumberland Street, London, SW1V 4LY
9.2 If supporters have any complaints regarding this Privacy Policy, they may also contact the UK Information Commissioner by telephone on 0303 123 1113 or at www.ico.org.uk/
9.3 We are not a ‘public authority’ as defined under the Freedom of Information Act 2000 and we will not therefore respond to requests for information made under that Act.
