“Personal information” means any information relating to an identifiable person who can be directly or indirectly identified by it. This includes a person’s contact details, date of birth and their IP address.
In other words, personal information is anything which can be used to identify you (either by itself or when combined with other information).
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
In other words, processing refers to all stages of collecting, storing and using your personal information.
WHO WE ARE
United World Schools (UWS) is committed to providing a free basic education for children in remote and marginalized communities. UWS consists of a head office and in-country teams, governed by a board of trustees.
UWS-USA office address is 1300 Pennsylvania Avenue, NW, Suite 700 Washington, DC 20004
This policy refers to the personal information processed by UWS-USA, UWS UK and in-country teams, including all information processed by the official UWS website.
WHY WE COLLECT PERSONAL INFORMATION AND WHAT WE DO WITH IT
We collect information purely for the purpose of helping our work towards our mission. Specifically, UWS processes personal information in order to:
- administer donations (including keeping records of our supporters’ relationships with us)
- administer enquiries including volunteering and job applications
- contact people if we need to
- contact people with updates on our work and our impact
- contact people about opportunities to support our work
- help us make our website work better
- show us how people are using our website, so that we can keep improving it
- understand why people support our work, so we can better meet their needs and find more people like them
- analyze it alongside publicly available information to carry out due diligence on our donors and to help tailor our communications and products
- monitor and evaluate the progress of our schools
In any case, we will only process personal information when at least one of the following conditions applies (as defined by the General Data Protection Regulation):
- You have given your express permission for us to do so (in that way and for that reason)
- It is necessary in order to deliver contracted goods and services
- We have a legal obligation
- There is a legitimate interest (when it is not obviously annoying or intrusive and would reasonably be expected based on your interaction with us in the past)
We may contact you by post, telephone, email or SMS, in line with how you have agreed to be contacted. You can change how you hear from us at any time simply by contacting us.
If you would prefer us not to analyze your information or combine it with publicly available information, no problem, please just let us know by contacting us.
WHAT PERSONAL INFORMATION WE PROCESS
We process any personal information you actively provide to us, including from donation and payment transactions, enquiries and surveys and forms. Website usage information is collected using cookies.
Personal information we process includes:
- postal addresses
- email addresses
- telephone/mobile numbers
- contact preferences
- bank details
- taxpayer status (to understand if we can claim Gift Aid)
- dates/years of birth
- gender (where this is appropriate)
- information about how you support us
- correspondence and details from interactions with our staff
- information that is publicly available
- IP addresses and web browsers (and versions) used
- information on how people use our website, using cookies and page tagging, to help us improve the website and our services
- any other personal information provided to us
HOW WE COLLECT PERSONAL INFORMATION
We collect information in the following ways:
- When you interact with us
such as when you make a donation, complete a form or attend an event. Sometimes you might be interacting with an organization working on our behalf, but we are still responsible for your information.
- When you interact with third parties
such as when you make a donation through a third party website e.g. JustGiving, and give your permission for your information to be shared with us (we won’t have access to your information otherwise).
- Social media
Similarly, if you engage with us on social media and messaging services like Facebook or Twitter, you might give us permission to process information from those accounts. The data we are given access to by social media services will vary but will always be in line with the Terms of that particular service. We will not be able to access your private messages, photos, etc. It will just be anything you specifically send to us and possibly information about you as a person, e.g. your age, where you live, etc. which might be pooled with other information to draw a general profile of our audience on that service.
- When you visit our website
- From other information that is available to the public
to help us tailor our communications, we may use information from publicly available sources such as Companies House or information published in the media.
WHO WE SHARE YOUR INFORMATION WITH
We will always keep your details safe and will not sell or swap your information with any other organization. We may share your information with trusted partners, agents or service providers to help us with our work or to help us better understand our supporters. These partners will only use your information under our instruction and will not use it for their own purposes.
We always have contracts in place with our suppliers, which require them to comply with UK’s law on data protection and to have systems and processes to protect the security of your information.
We may disclose personal information if required to do so by law or if we believe that such action is lawful and necessary to protect and defend the rights, property or personal safety of UWS and our stakeholders and for other lawful purposes.
Examples of organizations we may share your data with include:
- Our website and social media partners:
Facebook, Twitter, Instagram, YouTube, LinkedIn, Raising IT (website provider)
- To process donations and claim gift aid:
BACS, Her Majesty’s Revenue and Customs (HMRC), PayPal, Xero (industry-recognized online accounting software), HubSpot (industry-recognized online donor database software)
- To store data internally:
Dropbox (secure file storage platform), Google (secure file storage and email platform)
HOW WE KEEP YOUR INFORMATION SAFE
We have physical, technical and human controls in place to keep your information secure.
We ensure that extra controls are in place for financial, sensitive and special categories of information, meeting regulatory and legal requirements for managing these types of information.
The transmission of information over the internet is never completely secure and UWS cannot guarantee the security of any information you transmit to us, and you do so at your own risk. We advise against sending personal information using unsecure wifi (e.g. free public wifi).
Once we receive your data, we make every effort to ensure its security both on our systems and while in transit between our systems and any partners working on our behalf.
Access to your personal information is restricted to those who require it to do our work and all staff with access to your personal data are trained in how to keep it safe.
We cannot be responsible for the privacy policies and practices of other websites, even if you access them using links from our websites and we recommend that you check the policy of each site you visit.
Sometimes we may transfer information submitted by you to our other offices or we may need to use a service provider or partner outside the European Economic Area (EEA) – which may include a country that does not have the same level of data protection as the UK.
HOW LONG WE KEEP YOUR INFORMATION
We will hold your personal information on our systems for as long as it is lawful and necessary to do so. This is so that we can provide the services, products or information you have requested, administer your relationship with us, ensure we don’t communicate with you if you’ve asked us not to and comply with the law.
We may keep information relating to gifts in wills indefinitely so that we can administer these gifts and communicate appropriately with the families of those leaving UWS a legacy.
We will review and assess our approach to data protection every two years.
Under data protection law, you have the following rights regarding our processing your personal information. For more information on your full rights, please visit see the Information Commissioner’s Office website, currently at this address: https://ico.org.uk/
- Your right to information/to be informed
it is our responsibility to ensure you are clearly informed of when, how and why we are collecting your information and what we will do with it. We do this through this Policy and privacy notices which explain these points any time we collect your data.
- Your right to object
you can object to us contacting you. We provide the opportunity for you to say how we can contact you and what for on our website and you can change these preferences at any time.
- Your right to restrict processing
you can ask us not to process your personal information (though this still permits us to store it).
- Your right to rectification
you can ask for any inaccurate personal information we hold about you to be corrected
- Your right to erasure (your right to be forgotten)
you can ask us to erase the personal information we hold about you
- Your right to data portability
making it easy for you to obtain a copy of any personal information you have provided to organizations in a machine-readable format so you can easily transfer it to other organizations providing similar services. Any copies of personal information we provide upon request will be provided in plain text format.
- Your right not be evaluated on the basis of automated processing
you can ask that we do not include your personal information in any automated profiling exercises that might make assumptions about you in order to get insight into our supporter audience (in order to tailor communications and reach more people that might be interested in supporting us)
- Your right of access
you have a right to see what information we hold about you and can request to see it.
You can also lodge a complaint about the way we manage your data with the Information Commissioner’s Office (ICO). More information is available on the ICO website, currently at this address: https://ico.org.uk/
For more information or to exercise your rights, please contact us.
If you would like to request a copy of the personal information we hold about you, please send a description of the information you would like as well as proof of your identity to United World Schools, Unit 138, China Works, Black Prince Road, Lambeth, London, SE1 7SJ. Once your identity is confirmed, we will send you a copy of your personal information, in line with what we are legally required to disclose, within one month. We accept no liability for the security of your personal information, as contained in your request, until it has been received by us.
HOW TO CHANGE THE WAY WE CONTACT YOU
It is easy for you to change or withdraw your communication preferences with us at any time.
You can update your preferences by contacting us at any time to request changes to how we contact you and what for – or to tell us not to contact you at all. We will always respect your wishes, though please note there may be some information we have to keep or reasons we must contact you that are required by law.
In the event that you change or withdraw consent for your information to be shared publicly, we will not share anything else publicly but will be unable to retract anything already shared outside of UWS’ own website.
Like most websites, our site uses small data files stored on your computer called cookies. Cookies give us insight into how people use our website to help us keep improving it. Cookies do lots of different things, such as helping us to:
- avoid asking you to register or complete details twice
- estimate the number of visitors to our site, including the source and patterns relating to this traffic
- understand how visitors use the site, and how we can enhance this experience
You are able to set your devices to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time, although of course please be aware this means that you’ll miss out on some personalized services. You can delete your cookies through your device settings at any time.
You can find out more about cookies at www.allaboutcookies.org
WHAT IF I’M UNDER 18?
If you are under 18, please get your parent or guardian’s permission before you send us any information about yourself, this includes photos and messages.
Also, if you do use our sites to find out about fundraising, campaigning or supporting the work of UWS, please let an adult know.
Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behavior of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us.