We want everyone who supports us to feel confident and comfortable that any personal information you share with us will be looked after and used appropriately.
This Notice (together with our Terms and Conditions and any other documents referred to on our site) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us - how we collect, use and store your personal information.
Please read the following to understand our practices regarding your personal 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 data.
We collect information from you in the following ways:
- When you directly give us information: this could be if you ask us about our activities, register with us for an event, make a donation to us, ask a question about sponsoring a child or children’s rights, purchase something, apply for a job or volunteering opportunity, give us feedback or make a complaint, or otherwise provide us with your personal information. This includes when you telephone us, visit our website, or get in touch through the post, by email or direct message on social media channels.
- When you contact us through partners or third parties working on our behalf: This could be if you speak to one of our fundraisers on the street or doorstep, or one of the other third parties that we work with (for example Just Giving or Virgin Money Giving), and provide your consent for your personal information to be shared with us.
- When you indirectly give us information: When you interact with us on social media platforms such as Facebook, WhatsApp, Twitter, Instagram, YouTube or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform and the privacy notices/policies of each platform. To see how to change your settings on these platforms, please refer to guidance from the platform provider.
We may participate in Facebook’s ‘Custom Audience’ program, which enables us to display adverts to our existing supporters when they visit Facebook. 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.
Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account.
Collection of Data through ‘Cookies’
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a certain webpage. Cookies are then sent back to the originating webpage on each subsequent visit, or to another webpage that recognises that cookie. Cookies are widely used in order to make a website work, or to work more efficiently, as well as to provide information to the owners of a website.
• 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 Plan International UK 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
If you use our website, our social media pages (such as Facebook, Twitter, YouTube, Google+ and Instagram), subscribe to our services, donate to us and/or shop online, we will assume that you are happy for us to place cookies on your device and use that data in accordance with this policy unless you have set your computer browser to reject them.
Information we collect and why we use it
When you engage with us by telephone, mail, in person or online, 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, bank or credit/debit card details (if you are making a donation or purchase), and details of your education and career, why you are interested in Plan International UK, and other information relating to you personally which you may choose to provide to us. You will have given us this information whilst donating to sponsor a child or any of the other ways to interact with us.
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:
- Donation processing or transactional purposes: to process your donations or other payments, to claim Gift Aid on your donations and verify any financial transactions. We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, processing your order and payment for a product from our Christmas Card shop.
- Responding to a request: to provide the services or information that you have requested, for example in response to a query or complaint.
- Administration: to update you with important administrative messages about your donation, a campaign or services, or to record and deal with a complaint, record a request not to receive further marketing information, record what our volunteers have done for us, and for other essential internal record keeping purposes.
- Monitoring and Evaluating our services: we may use your information in order to improve current and future delivery of our services.
- Processing an application to work with us: we may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and respond to you or, where you volunteer with us, to administer the volunteering 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 you marketing information by email, SMS, or telephone you if you have given us specific consent. If you withdraw your consent and then subsequently opt in to receive marketing information again, then your most recent preference will supersede your earlier one. If you have responded to an appeal letter, you may also receive fundraising mail, which you can opt out of at any time by contacting us:
Telephone: 0300 777 9779
Post: Supporter Engagement Team, Plan International UK, Finsgate, 5-7 Cranwood Street, London, EC1V 9LH
- Providing and developing our website: We may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further. This will help us target communications in a more focused, efficient and cost effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to use of your personal information for such profiling at any time by contacting us at the details set out above.
- Profiling and analysis: We want to improve how we talk to you and the information we provide through our website, services, products and information. To do this we sometimes use profiling and screening methods so that we can better understand our supporters and potential supporters, your preferences and needs to provide a better experience for you.
- Legal, regulatory and tax compliance: Where we are subject to a legal obligation, we may process your personal information to fulfil that obligation.
- Market research and surveys: We may invite you to participate in surveys or market research to help us improve our website, fundraising, services and strategic development. Participation is always voluntary and no individuals will be publicly identified as a result of this research, unless you consent to us publishing your feedback.
- Protecting your vital interests: We may process your personal 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:
1. Data matching
We may combine the personal information you have given us with data obtained from external sources, such as the Office for National Statistics, to infer likely social, demographic and financial characteristics, so we can tailor our communications and services to better meet your needs or the needs of others like you 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 contradicts your previously expressed privacy preferences.
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 may fall within a certain segment of supporters.
3. Major donor analysis
We may carry out research to determine whether an individual could be a potential major donor. We may 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
- public information on any philanthropic activities.
4. High value event planning
We may also use publicly available information to produce short biographies of people who are due to meet with our leadership or attend an event that we may be hosting.
This helps our people to understand more about those we engage with, and their interests or connection to us.
5. Ethical screening and minimising risk
As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity. Plan International UK is an organisational member of the Institute of Fundraising and is registered with the Fundraising Regulator. We ensure all our fundraising is compliant with the Code of Fundraising Practice.
This means that we may carry out background checks and appropriate due diligence on donors and potential donors or check donations to help protect the charity from abuse, fraud and/or money laundering and/or terrorist financing.
To comply with our obligations as a charity, we must take reasonable and appropriate steps to know who our donors are, particularly where significant sums are being donated. This means that we may conduct research, including accessing information which is already publicly available, on prospective donors, partners or volunteers to ensure it would be right for us to accept support whether that is from an individual or organisation. This will help to give assurance that the donation is not from an inappropriate source and to safeguard our reputation. This does not mean that we will question every donation, nor that we will research lots of personal and other details about every donor. Any information we do collect for this purpose will only consist of what is necessary for us to meet these requirements and will be processed in line with your rights
The law allows personal data 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.
In many situations, the best approach for Plan International UK and our supporters and volunteers is to process personal data because of our legitimate interests, rather than consent. If you want to 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 on 0300 777 9779 or firstname.lastname@example.org.
When we use your personal 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 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:
- Where we contact you via post about the various ways you can help Plan International UK
- Sending you information or updates about your sponsorship or donations
- Organising visits or trips to see Plan International UK work in action
- Using your personal information for data analysis or profiling
- Conducting research to better understand who our supporters are and improve the way we communicate with you
- 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 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, projects, or fundraising activities and appeals. 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 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 you have signed up for a redirection service, we will 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 for you.
You can let us know if you move house or your details change by contacting us.
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.
Any debit or credit card details which we receive on our website are passed securely to our payment processing partner, according to the Payment Card Industry Security Standards.
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 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 the Supporter Engagement Team.
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 25/06/2018.
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 supporter engagement team will be happy to help resolve any issues, queries or concerns you may have.
Supporter Engagement Team
Telephone: 0300 777 9779
Post: Supporter Engagement 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.
Fundraising Preference Service
You can also register with the fundraising preference service (FPS). This service is run by the Fundraising Regulator and allows you 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 you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days.
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.