When we talk about 'personal information' here, what we mean is any data which could directly or indirectly be used to identify you – for example your name, email, telephone number or your computer's IP address.
War on Want never sells or exchanges our supporters' information with other organisations.
We take responsibility for the personal information we collect about you, and we aim to be transparent about how we handle it, and give you control over it.
Who are War on Want?
The full legal information for War on Want is as follows:
War on Want, 44-48 Shepherdess Walk, London, N1 7JP, UK
Registered Charity no. 208724. Company Limited by Guarantee Reg. no. 629916
War on Want is registered to collect people’s information, with the Information Commissioner.
If you have any questions, comments or concerns about any part of this policy or how War on Want handles your information please contact our Data Protection Officer: email@example.com.
- We will only ask for or collect the personal information that we need to talk to you about our work – such as membership, fundraising, donating, campaigning and volunteering.
- We give you control over the personal information we hold about you to make sure it is accurate.
- We make sure your personal information is always secure and protected.
- We are fair and transparent about how we use the personal information we hold.
- We only ever use your personal information for the purpose that you trusted us to use it for.
- We respect your choices and will tell you if there are important changes that affect your personal information or how we use it.
- We take responsibility for the personal information that we hold about you.
What personal information does War on Want collect?
War on Want defines personal information as any information that could be used to identify an individual.
We will only ever collect the information we need – including data that will be used to help improve our services. We collect two kinds of information:
- Non-personal information such as IP addresses (the location of the computer on the internet), pages accessed and files downloaded. This helps us to determine how many people use our website, the frequency of visits and how popular our pages are. This information doesn’t tell us anything about who you are or your address, it simply allows us to monitor and improve our service.
- Personal information such as an individual’s name, postal address, email address and phone numbers. We will also hold details of any donations, campaign actions or transactional services you may make with us, together with your marketing communications preferences. We will hold a record of our communications with you and any communications with us.
We may use your name and address information to contact you by telephone, and use other sources of publicly available information to ensure we hold relevant information about you.
As a supporter, if you use a credit or debit card to make a donation to us, your card details are processed through our payment-processing partner – Stripe – as part of the payment process. We do this in accordance with the Payment Card Industry Security Standards.
As a volunteer we ask for your personal contact information, and we ask for some (optional) information which we use to provide some equality and diversity information to make sure our Diversity and Inclusion Policy is working.
We do not store any credit card information from either digital or paper donations.
Where does the information War on Want holds come from?
Most of the information we hold is given to us directly by you during your interaction with our website, our services, or supporter activities such as fundraising. We may also receive your information when you donate to us through third party services such as Virgin Money Giving and Payroll Giving Agencies.
In some situations, we may update your information through other agencies; for example to check that we have a valid postal address, or to check whether you are registered on the telephone preference service or fundraising preference service.
What legal basis does War on Want use to collect personal information?
War on Want needs a lawful reason to collect and use personal information. The law names six legitimate ways that we can process personal data. Of those six, we consider that three of them can be applied to War on Want’s operations:
- Information is processed on the basis of someone’s consent
- Information is processed for a legal obligation
- Information is processed on the basis of the ‘legitimate interests’ of War on Want.
As a supporter of War on Want we will always ask for explicit consent to send marketing and fundraising emails, and text messages. We will also ask if you want to be contacted by phone. All our telemarketing campaigns are checked with the Telephone Preference Service and Fundraising Preference Service to make sure that we do not make contact if you do not want to receive marketing communications from us.
You can of course withdraw consent at any time by contacting our supporter care team on 020 7324 5040 or email firstname.lastname@example.org.
If you volunteer with War on Want we will always ask for permission to process personal information.
If you become a member War on Want is required to provide you with information relevant to your membership including notifying you about general meetings and voting rights.
War on Want has a legal obligation to process health and safety information for members, staff and volunteers, which may include personal information in relation to incidents on War on Want premises.
If you have kindly added Gift Aid to a donation we must also process some minimal information for HMRC and hold this for seven years.
The law allows War on Want to legally collect and use (process) personal information if it is necessary for a legitimate business interest of the organisation. However it must be used in a fair and balanced way that does not impact on your rights. This includes using direct marketing for charitable purposes if there is a wider benefit to society. For War on Want this means that for our campaigns and appeals we can lawfully write to you to encourage your support of our work.
In line with best practice War on Want has carried out a balancing test to reflect how we consider we may process information under this lawful basis. You can request a copy of our Legitimate Interest Assessment from our Data Protection Officer: email@example.com.
You have the right to object to our lawful processing of your information and can withdraw consent to marketing communications at any time by contacting our supporter care team on 020 7324 5040 or email firstname.lastname@example.org.
When we use your information we will always consider if it is fair and balanced to do so and if it is within a supporter's reasonable expectations. We will balance your rights and our legitimate interests to make sure that we use your personal information in ways which are not unfair or unduly intrusive.
How your information is used
War on Want uses your personal information to:
- Administer your donations, applications for membership and participation in campaigns
- Process sales transactions, donations or other payments and verify financial transactions
- Handle orders, deliver products or campaign materials and communicate with you about orders
- Contact you with information and updates about issues we work on, our campaigns and events
- Record any contact we have with you
- Communicate with our members, supporters and customers and conduct surveys
- Administer volunteer, supporter and member records
- Carry out research on the demographics, interests and behaviours of our supporters to help us gain a better understanding of them and to enable us to improve our service
- Carry out analysis of the personal information we collect about you and add publicly available information to create a profile of your interests, preferences and level of potential donations
- Prevent and detect fraud or other illegal activity
- Other reasonable purposes, directly connected to your relationship with War on Want.
Sharing your information
War on Want never sells or exchanges our supporter's information with other organisations.
We will only share your information if:
- We are legally required to do so, for example by a law enforcement agency legitimately exercising a power or if compelled by an order of the Court
- We believe it is necessary to protect or defend our rights, property or the personal safety of our people, visitors to our premises or websites
- We are working with a trusted service provider that is carrying out work on our behalf. These partners may include mailing houses, marketing agencies, IT specialists and research firms. Where this service is undertaken on behalf of War on Want, this is done under contract, in compliance with strict Data Protection requirements and security measures are taken.
Transfer of personal information overseas
Information is stored by War on Want on computers located in the UK, we may also store information in paper files. We may transfer the information to other offices and third party organisations as explained above – these may be situated inside or outside the EU. Under data protection law organisations that want to transfer personal data outside of the EU must assess whether the country the data would go to has an adequate level of protection for individuals. The European Commission decides whether countries are considered adequate, either partially or fully. Several of the contracted suppliers that War on Want works with store information outside of the EU. These are usually where we have embedded a data capture form in our website, and the data you enter is transferred securely to our overseas contractor for processing. Data is stored in Canada through our key supplier Engaging Networks, and in the USA through Action Network. The EU has published a 'finding of adequacy of the protection of personal data in non-EU countries' for Canada and the USA, and War on Want also ensures that information is secure both in transit and at rest with the supplier.
How long War on Want will keep your data
Some specific examples of how long we keep certain types of data include:
- Where someone has left War on Want a gift in their Will. In these cases we will maintain our records of that pledge to carry out legacy administration and communicate effectively with the families of people leaving us a legacy.
- If you have kindly added Gift Aid to a donation we must record the fact that you are a UK taxpayer. HMRC requires that we maintain a record of that Gift Aid for seven years after your last donation to us.
- If you apply for a job with us, and share sensitive information as part of the application process, the information will be stored in a personnel record if you are successful, or for six months after the closure of the recruitment campaign if your application has been unsuccessful.
- For volunteers we keep information for four years after your last interaction with us.
How do we protect and secure your personal information?
We are committed to protecting your personal information. We use appropriate technical and organisational measures, including encryption, to protect personal information and privacy, and we review them regularly. We protect your information using a combination of physical and IT security controls, including access controls that restrict and manage the way that information and data is processed, managed and handled. We also make sure that our staff are adequately trained in protecting personal information.
Our procedures mean that we may sometimes ask for proof of identity before we share your personal information with supporters or members – for example when we contact you we will want to check that we are speaking to the owner of that personal information.
In the unlikely event of a security breach which compromises our protection of personal information, and we need to let you know about it, we will do so.
What are my rights when it comes to my personal data?
Data Protection Rights
Where War on Want is using your information with consent you can withdraw that consent at any time. You also have the right to ask War on Want to stop using your information for direct marketing purposes. If we contact you by email every message we send will include a link to opt out of receiving future messages. If we contact you by other means and you want to change how, or if, you receive our communications please our supporter care team on 020 7324 5040 or email email@example.com
Your rights are clearly laid out in data protection law, see below for a summary or the Information Commissioner’s Office for more detail.
The Right to be Informed
The Right of Access
You can write to the Data Protection Officer asking for what information we hold about you and can request a copy of that information, this is called a Subject Access Request. Once we are sure you have the right to see the requested records (for example: We have confirmed that you are who you say you are) we will have one calendar month to comply.
The Right of Erasure (also known as the right to be forgotten)
You have the right to request that your information be deleted from our systems and databases but only in certain circumstances e.g. HMRC requires that we keep Gift Aid information for seven years.
In many cases we would recommend that we suppress rather than delete your information completely, otherwise you may be contacted in error if your details are then given to us from a third party lead generation company.
The Right of Rectification
You have the right to ask that we correct and update factually inaccurate information that we may hold about you.
The Right to Restrict Processing
You have the right to request that we restrict the processing of your personal data in certain circumstances:
- When you are contesting the accuracy of the data we hold, and we are verifying the accuracy of that data.
- When you have objected to having your information processed under the lawful basis of legitimate interest, and we are considering whether our organisation’s legitimate grounds override yours.
- When the processing is unlawful and you oppose erasure and request restriction instead.
- Where we no longer need the information, but you have requested your data from us to establish, exercise or defend a legal claim.
The Right to Data Portability
You have the right to data portability. This means that you can ask for and reuse your personal information for your own purposes across different services. It has been designed to allow you to copy or transfer your information from one IT environment to another – for example from one banking service to another, or one utility provider to another.
The Right to Object
You have the absolute right to stop the processing of your personal information for direct marketing purposes, even in circumstances where we may be processing your information under the legitimate interest lawful basis.
The Right to Object to Automated Decisions
You have the right to object to automated decisions where a someone is using your personal information in a computerised model or algorithm to make decisions “that have a legal effect on you”. This is more likely to be applicable to scenarios such as if you have applied for a mortgage or credit card and the decision is made automatically based upon your credit profile. War on Want does not do this kind of modelling.
Exercising your rights
If you wish to exercise any of these rights please contact the Data Protection Officer: firstname.lastname@example.org or on 020 7324 5040.
Lodging a complaint
If your complaint is not dealt with to your satisfaction you can raise this with our supervisory authority the Information Commissioner's Office via their website or on 0303 123 1113.
Marketing and communication preferences, cookies and third-party websites
To help ensure our communications with you are relevant, we analyse geographic, demographic and other key characteristics and behaviours relating to you; as well as your previous responses to our marketing communications. This helps us to personalise and improve your supporter experience with War on Want and minimise wastage. Some of this analysis is based on data provided by you and some of this is provided by external organisations.
We only want to send communications that are of genuine interest and relevant to you. You are in control of how we use your personal information for marketing and fundraising purposes. If we contact you by email every message we send will include a link to opt out of receiving future messages. If we contact you by other means and you want to change how, or if, you receive our communications please our supporter care team on 020 7324 5040 or email email@example.com.
We will still need to contact you to fulfil our legal obligations which include notifying you about general meetings if you are a War on Want member.
You may come across War on Want naturally on Facebook through your own networks, or you might be presented with a promoted advert from us. We use targeting advertising on Facebook which allows people who are interested in our work to connect with us and become a supporter. We do this to inform, educate and engage new potential supporters.
We may provide your email address, mobile number and address to Facebook, so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. Facebook deletes that data that we provide them in an encrypted format if it does not match with an account however we want to remind our supporters and users that information shared by you or your contacts on timelines, on our page or in private messages may be used and sold by Facebook for commercial purposes.
Social media sites
By using our website you agree that, unless you have set your computer's browser to reject them, we can place temporary session cookies on that device and use that data in accordance with this policy. For more information, visit our full cookies statement.
Links to third party websites