Policy and programmes: privacy notice
We want all of our beneficiaries and everyone who participates in our research to feel confident and comfortable that any personal or sensitive information you share with us will be looked after and used appropriately.
Please read the following to understand our practices regarding your personal and sensitive information and sensitive data and how we will treat it. We are committed to treating you with respect and openness.
Who we are
Plan International UK is a leading children’s charity. We strive to advance children’s rights and equality for girls all over the world. We are committed to protecting your personal information and making every effort to ensure that your personal information is processed in a fair, open and transparent manner. We won’t do anything with your information you wouldn’t reasonably expect.
We are a "data controller" for the purposes of the EU General Data Protection Regulation 2016/679 ("Data Protection Law"). This means that we are responsible for, and control the processing of, your personal information.
The Data Protection Officer
Plan International UK
5-7 Cranwood Street
How and when we collect information about you
We always strive to provide a clear, honest and transparent approach regarding how and when we may collect and use your personal and sensitive information and sensitive data. We collect information from you in the following way:
- When you directly give us information: this could be if you are participating in one of our programmes or research projects, or included in programme monitoring activities.
Information we collect and why we use it
When you engage with us as a beneficiary or participant in one of our programmes, or research projects, we may collect information about you (referred to in this Privacy Notice as 'personal information').
This may include your name, address, email address, telephone number, date of birth, job title, and details of your education and career, and other information relating to you personally which you may choose to provide to us. You will have given us this information whilst participating in one of our programmes or research projects.
- Sensitive Personal Information: data protection law recognises that certain types of personal information are more sensitive. This is known as 'sensitive' or 'special category' personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person's sex life or sexual orientation. If you provide us with any sensitive personal information we will treat that information with extra care and confidentiality and always in accordance with this Privacy Notice.
- If you're 18 or under: if you're aged 18 or under, you must get your parent/guardian’s permission before you provide any personal information to us and in some circumstances we will ask for your parent/guardian to provide consent to us in addition to your permission.
How we use your information
We will mainly use your information:
- Responding to a request: to respond to any questions or concerns you raise in any of our programmes or research projects.
- Programme design: we may use your information in order to ensure we have well designed projects.
- Monitoring and evaluating our programmes: we may use your information in order to assess whether our projects have achieved their intended impact.
- High quality research: we may use your information on a research to influence decision makers and improve programme design.
- Working with children and young people: we collect essential information to enable us to safeguard the children and young people we work with, for example, in programmes and research.
- Protecting your vital interests: we may process your personal and sensitive information where we reasonably think that there is a risk of serious harm or abuse to you or someone else.
- Prevention of crime: if you visit our office, we may record your image on CCTV which we use to prevent crime and keep our staff, visitors and other users of our office safe.
Our profiling and analysis activities can be broken into five categories:
The law allows personal and sensitive information to be collected and used if it is necessary for a legitimate business interest of the organisation - as long as its use is fair and balanced and does not unduly impact the rights of the individual concerned.
When we use your personal and sensitive information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal and sensitive information in ways that are not unduly intrusive or unfair.
Some examples of where we have a legitimate interest to process your personal information are:
- Sending you information or updates about a programme or research project you participated in.
- Organising visits or trips as part of a programme or research project.
- Using your personal and/ or sensitive information for data analysis.
- Conducting research to better understand the contexts in which our programmes are implemented.
- To improve our services or for our legal purposes, for example, dealing with complaints and claims.
Sharing your information
We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal and/ or sensitive information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
We will only share your data for the following purposes:
- Third party suppliers: we may need to share your information with data hosting providers or service providers who help us to deliver our services. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.
- Where legally required: we will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk of serious harm or abuse to you or someone else.
Keeping your information safe
We take looking after your information very seriously. We've implemented appropriate physical, technical and employee measures to help us protect the personal information we have, both on and off-line, from improper access, use, alteration, destruction and loss.
International transfers of information
We may wish to transfer personal data outside the European Economic Area (EEA), for certain purposes including administering child sponsorship, monitoring and evaluating our programmes work, travel administration or due to safeguarding and security purposes. We may also on rare occasions decide to use the services of a supplier outside the European Economic Area (EEA). This means that your personal and/ or sensitive information is transferred, processed and stored outside the EEA.
In those circumstances, we take steps to put in place suitable safeguards to protect your personal information when processed by the supplier such as such as entering into the European Commission approved standard contractual clauses (required by article 13(1)(f)), and specific International Data Transfer Agreements. If you would like a copy of the standard contractual clauses, please contact our Data Protection Officer.
How long we hold your information for
We only keep your information if it’s reasonable and necessary for the purposes set out in this notice.
You have various rights in respect of the personal information we hold about you – these are set out in more detail below.
- Information Right – the right to receive the information contained in this policy and our data collection forms about the way we process your personal data.
- Personal Data Access Right – the right to know that we are processing your personal data and, in most circumstances, to have a copy of the personal data of yours that we hold. You can also ask for certain other details such as what purpose we process your data for and how long we hold it.
- Personal Data Correction Right – you have the right to request that we correct inaccurate data or complete incomplete data that we hold on you.
- Personal Data Erasure Right – known as the Right to be forgotten. In certain circumstances you may request that we erase your personal data held by us.
- Personal Data Restriction Right – you have the right to restrict the way we process your personal data in certain circumstances, for example if: you contest the accuracy of the data, if our processing is unlawful, to pursue legal claims, where we are relying on legitimate interests to process data.
- Data Processing Objection Right – you have the right to object to us processing your data for (i) direct marketing purposes (ii) scientific or historical research or statistical purposes and (iii) purposes of profiling related to direct marketing or based on our legitimate interests or on the performance of a task in the public interest.
- Data Portability Right – you have the right to receive a copy of certain personal data or to have it transferred to another organisation in some circumstances.
Notification of changes to this Privacy Notice
This Privacy Notice may change from time-to-time. For example, we will continue to update it to reflect new legal requirements. Please visit this website page to keep up-to-date with the changes to our Privacy Notice. This version was last updated on 25/05/2018.
What to do if you are not happy?
In the first instance, please talk to us directly so we can help resolve any problem or query. Our Evidence, Learning & Impact Team will be happy to help resolve any issues, queries or concerns you may have.
Telephone: 0300 777 9777
Post: Evidence, Learning & Impact Team, Plan International UK, Finsgate, 5-7 Cranwood Street, London, EC1V 9LH
Alternatively, you can contact our Data Protection Officer using the contact details given above.
If you continue to have outstanding concerns about the matter raised or the way in which we have handled it, the case can be handed on to an external Ombudsperson for review.
Information Commissioner’s Office
You also have the right to contact the Information Commissioner’s Office (ICO) if you have any concerns about Data Protection using their help line 0303 123 1113 or visit their website.