Privacy Policy

Frontiers is committed to respecting and protecting your privacy.  For the purposes of the General Data Protection Regulation (GDPR) and any subsequent UK legislation covering data protection the Data Controller is Frontiers.  The person responsible for data protection in the organisation is the Data Protection Co-ordinator.  If you have any questions about this Policy or concerning your personal information held by Frontiers please:-

Call us on: 0303 333 5051

Email us: data-requests@frontiers.org.uk

Write to us: Frontiers, PO Box 1445, High Wycombe, HP12 9BU

This Policy sets out why we collect personal information about individuals and how we use that information.  It describes the legal basis for this and explains the rights you have over the way your information is used.

WHAT INFORMATION WE COLLECT

We collect information:

• When you give it to us directly

We collect personal information, including your name and contact details, each time you deal with us.  For example, when you make a donation, request materials or information, sign up for an event, complete an application form to work with us, volunteer or contact us for any other reason.

• When you use our website

We collect non-personal data such as IP addresses, details of pages visited and files downloaded.  Website information is collected using cookies, see the section on Cookies below.

• When it is available on social media

We may collect information you make available on, for example, Facebook, LinkedIn or Twitter.  You may wish to check their privacy policies to find out more information about how they process your data.

• From publicly available data

We may collect information from Companies House, the Charities Commission and information published in articles, newspapers or blogs.

• Indirectly from third parties

We may collect information from third parties, such as event organisers or referees for applications, where you have given your consent.  You may wish to check their privacy policies to find out more information about how they process your data.

HOW WE USE YOUR INFORMATION

We may use your personal information to:

• Provide information or services you have requested
• Keep you up to date on news and stories about our mission and events
• Process donations you give us, including gift aid
• Keep records of your relationship with us, e.g. questions you have asked or complaints you have made
• Organise volunteering activities you have told us you would like to be involved with
• Seek your views on services or activities we provide so we can make improvements
• Maintain our organisational records and ensure we know how you prefer to be contacted
• Process applications for work or ministry, either in the UK or overseas.

OUR LEGAL BASIS FOR PROCESSING YOUR INFORMATION

The use of your information for the purposes set out above is lawful because one or more of the following applies:

• Consent

Where you have provided information to us for the purposes of requesting information, working with us, or that we carry out a service for you, we will proceed on the basis that you have given consent to us using the information for that purpose.  You may withdraw consent at any time by emailing us at the email address above.  This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.

• Legitimate interest

Where you have previously requested information, services or events, we may contact you again if similar new information, services or events become available that might be of interest to you.  Where you have previously made a donation, we may continue to send you information about the work your donation has made possible or other work we wish to undertake.  Where you have previously asked us not to contact you in a particular way we will continue to respect your preferences.  You can change your contact preferences at any time or object to us processing your data by contacting us by telephone, post or email as shown above

• Legal obligations

We may need to process or retain certain information from you to fulfil our duties under UK law, for example for audit, tax and gift aid purposes.

HOW WE KEEP YOUR INFORMATION SAFE

We have controls in place to protect any personal data you provide.  For example, online forms are encrypted and our network is protected and routinely security checked.

Access to personal data is restricted only to those staff members whose job-roles require such access.  Suitable training is provided for all our staff.

However, no data transmission over the internet can be guaranteed to be 100% secure.  While we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.

We use cloud-based systems to process data and therefore data may be processed outside of the European Economic Area (EEA).  We adopt the Information Commissioners approved measures and therefore ensure that personal data is held in compliance with European data protection regulations.  We take all reasonable steps to ensure that your data is stored and processed securely in accordance with this policy.  By submitting your personal data you agree to this transfer, storing and processing of your information.

HOW LONG WE KEEP YOUR INFORMATION

We will keep your personal information only as long as it is necessary for the relevant activity.  We have a Records Retention Policy to implement this, which takes account of our legal, accounting and tax obligations, as well as considering what would be reasonable for each activity.  For example, we may retain details of donations for seven years to meet tax and accounting requirements, but keep sensitive medical personal information provided for a short-term overseas trip only until that trip is completed.  If you have any questions about our Records Retention Policy, please contact our Data Protection Co-ordinator as above

WHEN WE SHARE YOUR INFORMATION

• A few third parties provide services for us, for example sending mail and processing donations.  We select these service providers with care, share only the information necessary to provide the relevant service and have agreements in place requiring them to operate with the same care over data protection as ourselves.

• We occasionally share information with third parties when running joint events with them.  We will let you know if any data might be shared when you register for an event.

• Should you apply to travel overseas with us, we may share personal information with partners in overseas locations.  This may include sensitive personal data such as medical information.  We will obtain your consent before any data is transferred.

• We may also disclose your personal information if required to do so by a legal obligation, or for the purposes of fraud prevention, or where doing so would not infringe your rights, but is necessary and in the public interest.  Otherwise we will not share your information with other organisations without your consent.

COOKIES

What are Cookies?
A cookie is a text file sent from our website as soon as you visit the site.  It is stored on your computer's hard drive and helps us to identify your computer (not you) and collects information in an aggregate, anonymous way.

Cookies may be used to collect information about your visit to our website, for example, traffic data, location data, device information, date and time, and pages you visit.

The use of cookies is an industry standard for most major websites.  You can find more information about cookies by follow these two links - http://www.allaboutcookies.org/ or https://www.aboutcookies.org/

Our use of cookies on our website
To enjoy our website to the full, we recommend that you leave cookies turned on.  If you turn off cookies then you may not be able to access parts of the site.

The cookie data we collect may be used to:

• Customise our website's content and help our visitors' current and future needs
• Process any requests, applications or transactions you may make
• Aid our internal administration and analysis

Managing cookies
 Most browsers allow you to turn off the cookie function.  To do this you can look at the help function on your browser.

Third party cookies
We work with several third party suppliers who set cookies on our website to enable them to provide us with services.  These are mainly used for reporting and to help improve the way we communicate.

We use websites such as YouTube to embed videos and you may be sent cookies from these websites.  We do not control the setting of these cookies, so we suggest you check third party websites for more information about their cookies and how to manage them.

We also use third party suppliers such as Google Analytics who may also use cookies.  They may also use tracking pixels, which are commonly found in advertising to track the effectiveness of adverts.

As some of these services may be based outside of the UK and the European Union, they may not fall under UK legislation.  If you are concerned about this, you can change your cookie settings (see above) and can find more information about this here - https://ico.org.uk/

YOUR CHOICES AND TELLING US WHEN THINGS CHANGE

 Preferences
You can change your preferences on what you receive from us or how we contact you, by contacting our Data Protection Co-ordinator as above.

Updating your details
We do appreciate it if you keep your details up to date.  You can do so in the same way as updating your preferences (above).

We may use Post Office address search, postcode lists or other sources to confirm data that you provide us with if, for example, we are unsure of what you have completed on a form.

We will not use these sources to create data that you have chosen not to provide, for example, if you have left a telephone number blank; nor will we automatically update changes of address, we will normally only update your address when you tell us it's changed.  However, if you are a regular giver and mail is returned to us, we may use external sources to update your address details to enable us to inform you on how your money is being spent.

YOUR RIGHTS

You have the right to request details of the processing activities that we carry out with your personal information through making a Subject Access Request.  Such requests have to be made in writing and exceptionally may be subject to a charge.  More details about how to make a request, and the procedure to be followed, can be found in our Data Protection Policy.  To make a request contact us at data-requests@frontiers.org.uk

You also have the following rights:

• the right to request rectification of information that is inaccurate or out of date;
• the right to erasure of your information (known as the "right to be forgotten");
• the right to restrict the way in which we are using your information; and
• the right to request that your information be provided to you in a format that is secure and suitable for re-use (known as the "right to portability");

All of these rights are subject to certain safeguards and limits or exemptions, further details of which can be found in our Data Protection Policy.  To exercise any of these rights, you should contact our Data Protection Co-ordinator as above.

If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Information Commissioner's Office.  Further details about how to complain can be found at https://www.dataprotection.ie/docs/Making-a-Complaint-to-the-Data-Protection-Commissioner/r/18.htm

CHANGES TO THIS PRIVACY POLICY

This policy was last updated in March 2018.  We may amend this policy from time to time to take account of changes to our processes or changes to data protection or other legislation.  If we make any significant changes to this policy we will show this clearly on our website, in our publications such as Connected or by writing to you directly.  By continuing to use our website you will be deemed to have accepted these changes.