Prisoners of Conscience Appeal Fund is a registered charity in England and Wales, registered charity number 213766. The charity is governed by a Corporate Trustee, Prisoners of Conscience Appeal Fund Trustee (Limited), company number 07690599.

Prisoners of Conscience Appeal Fund regards the lawful and correct treatment of personal information as crucial to the successful, secure and efficient performance of its functions, and to maintain confidence between those with whom it deals.

To this end, Prisoners of Conscience Appeal Fund fully endorses and adheres to the rules and principles set out in the UK General Data Protection Regulation and UK Data Protection Act (2018).

Prisoners of Conscience Appeal Fund as a body is a Data Controller and the Corporate Trustee is ultimately responsible for the implementation of the charity’s data protection policies.

This Privacy Statement explains:
1. How we collect and use your personal data
2. The lawful basis for processing your personal data
3. How your personal data may be shared with any third parties
4. How we keep your personal data secure
5. How long we keep your personal data for
6. Your rights
7. How to make a complaint
8. Our use of cookies
9. Children’s data

1. How we collect & use your personal data
We may collect information about you whenever you interact with us, for example, when you enquire about our activities or services, submit a grant application, visit our website, donate to us, sign up to receive e-news messages, attend an event, fundraise on our behalf or contact us through the following channels: online, email, phone, SMS, social media or post. In some instances, we may also receive information about you from third parties, where we believe you’ve given them permission to share your information.

We use personal data in order to provide grants to beneficiaries, to raise funds to support our work and to process donations and submit claims such as Gift Aid.

Supporters

We may process the following categories of personal data of individuals who contact us in relation to actual or possible support for the charity and representatives of organisations and Trusts that may also support us:

  • Full name
  • Contact details
  • Donations – amounts, dates, methods of payment
  • Gift Aid information – amounts claimes, Gift Aid declarations
  • Communications – correspondence between supporters and the charity
  • Event information – whether a supporter has been invited to or attended events
  • Mailing preferences – preferred methods of contact
  • Photographs (see “Use of Photographs” below)

Research and analysis of data

We may undertake in-house research and may engage other organisations to create a fuller understanding of your interests and support of Prisoners of Conscience Appeal Fund to help us identify people who may be able to support us with a larger gift, but only where those organisations:

(a) agree to keep your personal data confidential and to hold it separately from other data held by the contractor;

(b) only use personal data we allow a contractor to access for the purposes of its work for the charity; and

(c) delete all personal data held by the contractor relating to the charity after the completion of their work, unless otherwise required by law.

We may also use existing data you have given us from our own database and combine this with information from publicly available sources and records such as the electoral roll, land records, charity websites and annuals reviews and Companies House records. We may also collect information on your interests, for example board memberships, career, hobbies, or from articles about you in newspapers or magazines. We only use sources of data we consider to be (a) reputable and (b) where someone would expect their information may be read by the public.

This allows us to be more efficient and cost-effective with our resources, and reduces the risk of someone receiving information that they might find irrelevant, intrusive or that wastes their time as it’s an uninformed approach. Lastly, research helps reduce the risk of us aligning ourselves with someone that would damage our reputation.

We are committed to putting you in control of your data and you’re free at any time to opt out of this activity.  Please contact us on 02074076644 or email Info@prisonersofconscience.org.

Grant Applicants

We may process the following categories of personal data of individuals who contact us in relation to actual or possible support from us:

  • Full name
  • Contact details
  • Eligibility criteria
  • Information on status of grant
  • Communications – correspondence between applicants and the charity
  • Event information – whether an applicant has been invited to or attended events
  • Photographs (please see “Use of Photographs” below)

Referral Agencies

We may process the following categories of personal data of individuals associated with the referral agencies who assist the grant applicants who contact us in relation to actual or possible support from the Prisoners of Conscience:

  • Full name
  • Job title
  • Contact details
  • Communications – correspondence between caseworkers and the charity
  • Photographs (please see “Use of Photographs” below)

2. The lawful basis for processing data

Where required, we will seek consent to process your personal data, for example, by requesting specific opt-in consent in electronic marketing communications such as our e-newsletters, in other instances we may process your personal data on other grounds when we are legally allowed to do so.

This includes:
(a) legitimate interest, for example, to fulfil the purposes of the charity and to manage our relationship with you, where we are confident that such processing is necessary and would not be against your individual interests, rights and freedoms. For example, this could include sending letters in the post updating you about our activities, supporter analysis and research, administering your grant application or inviting you to our events by post.
(b) legal obligation, in order to comply with common law or statutory requirements, such as submitting Gift Aid claims to the Inland Revenue or reporting to the Charity Commission.

Processing of Grant Applications

There are specific check-boxes on our secure, encrypted online grant application system for referral agencies and applicants to give consent to their data being used in order to process their application and for further fundraising purposes.

Use of photographs
Where practicable, we will seek consent of individuals before displaying photographs in which they appear. If this is not possible (for example, a large group photo), we will remove any photograph if a complaint is received. This policy also applies to photographs published on our website or in our printed materials.

3. How your personal data may be shared with third parties
We will only share data with third parties when necessary to fulfil the purposes of the charity. For example, administering donations via our card processing provider and submitting Gift Aid claims to HMRC, or undertaking supporter research to help identify people who may be able to support us with a larger gift, so we can be efficient and cost-effective with our resources.
We require all third parties to comply with relevant data protection legislation.
In the case of grant applications, personal data will not be passed on to anyone outside the organisation without explicit consent from the grant applicant or the referral agency authorised to act on their behalf, unless there is a legal duty of disclosure.

4. How we keep your personal data secure
Only authorised personnel will have access to personal data.
All personnel are made aware of the charity’s Privacy Statement and data protection policies.
All data is kept in secure filing, paper, password protected and encrypted electronic systems.
All confidential post is opened by the addressee only.
We operate a clear desk policy.
Any paper records containing personal data, which are to be destroyed, are confidentially shredded using the services of a professional confidential shredding company.

5. How long we keep your personal data for
We will take reasonable steps to keep your personal data up to date and accurate and we recognise that ensuring your personal data is disposed of when no longer needed reduces the risk that it will become inaccurate, out of date or irrelevant.
Your personal data will therefore not be kept for any longer than is necessary for the purposes for which we process it.

6. Your rights
You may have the right to access the personal data we hold about you, to have that personal data rectified or erased or to opt out of receiving communications from us. You may also have the right to object to our processing of your personal data relating to a particular purpose. 
If you wish to exercise any of these rights or have any questions about this policy, our contact details can be found in in clause 7 below. There is no cost for this service. We will action any requests as soon as possible and no later than 30 days from the request.

7. How to make a complaint
Should you ever wish to make a complaint or think that there is a problem with the way we are handling your personal data, you can contact us directly at:
Prisoners of Conscience Appeal Fund, PO Box 61044, London, SE1 1UP. Tel: +44 (0)20 7407 6644. Fax: +44 (0)20 7404 6655.
Email: info@prisonersofconscience.org

We will always do our best to resolve any queries or problems raised directly with you in as efficient manner as possible.  That said, you also have the right to contact the UK’s data protection authority, the Information Commissioner’s Office (ICO) at https://ico.org.uk/global/contact-us

8. Our use of cookies
Cookies are small files that are downloaded onto your computer (or other electronic device) from websites that you visit. Cookies contain information that allows websites to collect statistical information about our user’s browsing actions and patterns while on our website.

How we use cookies
We use cookies to help us provide you with the best experience when you visit our site. Some cookies are crucial to the smooth running of our website – for example our donation pages rely on them. Other cookies allow us to understand how visitors are interacting with our website so that we can improve it. Cookies also make it easy for you to share the content on our site with your contacts on Facebook or other social networks. These cookies, as with all others we use, do not contain information that can personally identify you.

Managing cookies
All browsers allow you to refuse to accept cookies stored on your advice, should you choose to do so. These settings are usually found under the ‘Preferences’ or ‘Tools’ menu of your browser. For more information about cookies, please see www.allaboutcookies.org

9. Children’s data
While we do not actively collect personal data from children (under 18s), we do, in some cases, receive personal data (names and ages) of children within grant applications. We only collect and process this data with consent of those with parental responsibility.

Changes to this Privacy Statement
Please note that this privacy statement may be updated from time to time. Any changes will be published on our website.