Privacy Notice

Who we are

We are a Data Controller responsible for the fair and lawful processing of personal information for the purposes of the Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679 ("Data Protection Law") as amended by the UK General Data Protection Act 2021 and all associated laws and regulations.

How and when we collect personal information

We collect personal information in the following ways:

• When directly given to us by a person: this could be if a question is asked about our activities, registration for an event, making a donation, asking a question about sponsoring a child or children’s rights, purchasing something, applying for a job or volunteering opportunity, giving feedback or making a complaint, from participating in a programme or research project or the monitoring of one. Communication may be by telephone, via the website, by post, email or direct message on social media channels.
• Indirectly: interaction with us on social media platforms such as Facebook, WhatsApp, Twitter, Instagram, YouTube or LinkedIn includes some personal information such as IP address. The amount of information we receive will depend on the privacy preferences set on each platform.
• Through partners or third parties working on our behalf: this could be speaking to one of our fundraisers on the street or doorstep, or one of the other third parties that we work with (for example JustGiving or Virgin Money Giving).

Facebook Marketing

We participate in Facebook’s ‘Custom Audience’ program, which enables us to display adverts to existing supporters when they visit Facebook. We may provide personal information i e email address, mobile number and address to Facebook, so they can determine whether the person is a registered account holder with them. Our adverts may then appear when that person accesses Facebook.

The data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account.

For more information please see Facebook Business and Facebook’s Data Policy.

Collection of Data through ‘Cookies’

Cookies are widely used text files containing small amounts of information which are downloaded to a computer or mobile device when visiting a certain webpage to make a website work efficiently, as well as to provide information to the owners of a website. Cookies are sent back to the originating webpage on each subsequent visit or to another webpage that recognises that cookie.

When you have consented we use cookies to:

• track traffic flow and browsing patterns in connection with our website
• understand the total number of visitors to our website on an ongoing basis and the types of internet browsers (e.g. Firefox, Chrome, Internet Explorer, Safari or Opera) and operating systems (e.g. Windows or Mac OS) used by our visitors
• monitor the overall performance of the website and continually improve it
• help to identify and resolve errors that visitors encounter on the website
• customise and enhance your online experience
• enable Plan International UK and third parties to advertise both on and off the website.

For more detail on our cookie policy and a description of the cookies we use please see our cookie policy.

Information we collect and why we use it

When people engage with us we collect information about them. This may include name, address, email address, telephone number, date of birth, job title, bank or credit/debit card details (if making a donation or purchase), and details of education and career.

Special Category Information

Special category information is more sensitive personal information and includes information relating to racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, health or a person's sex life or sexual orientation.

Special category information is treated that with additional care and confidentiality.

Personal information of those 18 or under

For a person aged 18 or under, they must get their parent/guardian’s permission before they provide any personal information to us and in some circumstances we will ask for parent/guardian to provide consent to us in addition to your permission.

View our Children and Young People Privacy Notice. 

How we use your information

We mainly use personal information for:

• Donation processing or transactional purposes: to process donations or other payments, to claim Gift Aid on donations and verify any financial transactions. We need to use personal information in order to carry out our obligations arising from any contracts entered into for goods or services, for example, processing an order and payment for a product from our Christmas Card shop.
• Responding to a request: to provide the services or information requested, for example in response to a query or complaint.
• Administration: to update supporters  with important administrative messages about donations, a campaign or services, or to record and deal with a complaint, record a request not to receive further marking information, record what our volunteers have done and for other essential internal record keeping.
• Developing, monitoring and evaluating our services: we may use personal information to improve current and future delivery of our services. For example we may create profiles to test advertising campaigns on social media or to evaluate the effectiveness of our programmes.
• Processing an application to work with us: we need to process information if we are sent an application form or CV or details in order to evaluate suitability and respond or to administer the working arrangement.
• Employment: we need to ensure that we meet our obligations as an employer and manage people effectively in the organisation.
• 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 campaigns or events.
• Fundraising, direct marketing or campaigning: we will only send marketing information by email, SMS, or telephone if we have been given your consent. If consent is withdrawn and opt in to receive marketing information is received subsequently, then the most recent preference will supersede an earlier one.
• Providing and developing our website: we use personal information to help provide with access to our website, personalise experiences, and improve and develop it further.
• Prevention of crime: we record images on CCTV which we use to prevent crime and keep our staff, visitors and other users of our office safe.
• Market research and surveys: we use surveys or market research to help improve our website, fundraising, services and strategic development. Participation is voluntary and no individuals will be identified as a result of this research, unless we have consent to publish feedback.
• Legal, regulatory and tax compliance: we may process personal information to fulfil obligations we are subject to.
• Profiling and analysis: we want to improve the information we provide through our website, services, products and information. For the purposes of our legitimate interests we may use personal information to conduct profiling of supporters or potential supporters so that we can better understand our supporter’s preferences. This helps us communication in a more focused, efficient and cost-effective way. Our profiling and analysis activities can be broken into five categories:

i) Data matching

We may combine the personal information we hold with data obtained from external sources, such as the Office for National Statistics or social media, to infer social, demographic and financial characteristics, so we can tailor communications and services to better meet supporters’ needs or the needs of others based on the insight we gain from the profile we build. We will not use the results of this data matching activity in a way that intrudes on anyone’s privacy or previously expressed privacy preferences.

ii) Segmenting

We conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that campaigns or mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who fall within a certain segment of supporters.

iii) Major donor analysis

We carry out research to determine whether an individual could be a potential major donor. We use publicly available information from third party sources such as Google; Companies House; published biographies and publicly available LinkedIn profiles.

The type of information we collect can include:

• career overview
• gift capacity
• areas of interest
• history of giving to us and others
• how the individual is connected with us and others
• publicly available information on any philanthropic activities.

iv) High value event planning

We use publicly available information to produce short biographies of people who are due to meet with our leadership or attend an event we are hosting.

v) Ethical screening and minimising risk

Plan International UK is a member of the Institute of Fundraising and registered with the Fundraising Regulator. We ensure all our fundraising is compliant with the Code of Fundraising Practice. We carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering and/or terrorist financing before we accept a donation.

We screen supporters to minimise risk of creating an association with an individual or group that conflicts with the standards set out in our ethical policy.

Lawful Basis

Data protection legislation identifies a number of lawful basis on which personal data may be processed. We need to identify the purpose for processing the data and the most appropriate lawful basis for doing so.

Most of our processing of personal data is carried out on the basis of consent. Consent must be informed, freely given, specific and unambiguous. The information provided in this Privacy Notice is the information needed for informed consent to be given.

Consent maybe withdrawn. If you want to stop or change our use of your personal data for marketing and fundraising activities, you can do so at any time by contacting our supporter engagement team.

Legitimate interests

We rely on this lawful basis when it is necessary for a legitimate business interest of the organisation or a third party to use personal data as long as its use does not unduly impact the rights of the individual concerned. For example

• where we contact you via post about the various ways you can help Plan International UK
• sending information or updates about sponsorship or donations
• organising visits or trips to see Plan International UK work in action
• using personal information for data analysis or profiling
• conducting research to better understand who our supporters are and improve the way we communicate
• to improve our services or for our legal purposes, for example, dealing with complaints and claims.

Before processing on this basis we carry out a Legitimate Interest Test.

Sharing personal information

We will only use personal information for the purposes for which it was obtained. This may include sharing within the organisations that make up Plan International Limited. We will not sell or share personal information with any third party for their purposes and no one will receive marketing from any other companies, charities or other organisations as a result of giving your details to us.

We share personal data for the following purposes:

• Third party suppliers: we share information with data hosting providers or service providers who help us to deliver our services, projects, or fundraising activities and appeals. These providers act under our instruction and are subject to pre-contract scrutiny and contractual obligations.
• Where legally required: where disclosure is required by law, for example, to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share personal information with the emergency services if we reasonably think there is a risk of serious harm or abuse to a person.

Keeping your details up to date

We will use publicly available sources to ensure that the information we hold is accurate and up to date. For example, where a redirection service is signed up to, we use the Post Office’s National Change of Address database to keep in touch. We may use other services to cross-check the accuracy of the contact details we hold.

Changes of address or other details can be notified by contacting us at the address given below.

Keeping your information safe

We implement 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.

Any debit or credit card details which we receive on our website are passed securely to our payment processing partner, in accordance with  the Payment Card Industry Security Standards.

International transfers of information

If a transfer of personal data outside England, to the European Economic Area (EEA) or other countries, is necessary eg for administering child sponsorship, monitoring and evaluating our programmes work, travel administration or due to safeguarding and security purposes. we take steps to put in place suitable safeguards to protect personal information by conducting transfer impact assessments and taking appropriate measures such as entering into approved standard contractual clauses or International Data Transfer Agreements.

How long we hold your information for

We only keep your information if it is reasonable and necessary for the relevant activity and in line with our Data Retention Policy.

Data Subject Rights

There is a right to request the following

• Access to Personal Data Access–to know that we are processing an individual’s personal data and, in most circumstances, to have a copy of the personal data of that we hold
• Data Correction – that we correct inaccurate data or complete incomplete data that we hold
• Data Erasure Right – known as the right to be forgotten
• Data Restriction Right –to restrict the way we process personal data in certain circumstances
• Data Processing Objection Right –to object to us processing 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 –to receive a copy of certain personal data or to have it transferred to another organisation

Notification of changes to this Privacy Notice

Please visit this page to keep up-to-date with the changes to our Privacy Notice. This version was last updated on 7/11/2022.

Concerned about our use of personal data?

Please talk to us directly so we can help resolve any problem or query. Our Supporter Engagement Team will be happy to help resolve any issues, queries or concerns.

Supporter Engagement Team
Telephone: 0300 777 9779
Email: [email protected]
Post: Supporter Engagement Team, Plan International UK, Finsgate, 5-7 Cranwood Street, London, EC1V 9LH

The fundraising preference service (FPS) service is run by the Fundraising Regulator and allows a person to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service or by calling 0300 303 3517. Once a request is made through the FPS, we will ensure that your new preferences take effect within 28 days.

Alternatively, contact our Data Protection Officer at

The Data Protection Officer
Plan International UK
Finsgate
5-7 Cranwood Street
London
EC1V 9LH

Email: [email protected]

Any concerns can also be addressed to Information Commissioner’s Office (ICO) using their help line 0303 123 1113 or visit their website.