Friends of the Holy Land (FHL) values its many supporters and wishes to assure them that any personal data they have supplied to FHL is held securely and in complete confidence. FHL recognises that many of its supporters want to be kept informed about the projects that FHL fosters so that they can see how their donations are making a lasting difference to the Christian community in the Holy Land. This inevitably involves FHL holding personal data and to protect this FHL upholds the strictest data protection standards, including the European General Data Protection Regulation (GDPR). FHL’s staff and volunteers are all trained in this and FHL aims to be completely transparent about what personal information is collected, how it is used and the ‘consent’ options that are available to its supporters.
This policy refers to supporters’ personal information held and processed by FHL in the UK, including all information gathered through the official FHL website. Please read it carefully.
You can download a print friendly version of this policy, published April 2018, here.
1. Definitions used in this Document:
Personal Information or data means any information relating to a person who can be directly or indirectly identified by it. This includes their contact details and their IP address.
Processing means any operation that is performed on personal data or on sets of personal data. It includes all stages of collecting, storing, maintaining, using and disposing of supporters’ personal information.
2. FHL Contact Details
Friends of the Holy Land (Friends of the Holy Land trading as Olivewood Products) is a UK Registered Charity (Charity Number 1130054).
Friends of the Holy Land,
Farmer Ward Road,
Tel: 01926 512980
Olivewood E-Mail: firstname.lastname@example.org
The FHL Holy Land Committee is an independent, non-governmental organisation (NGO) registered with the Palestinian National Authority as a branch of an overseas NGO in Palestine. This endows the charity with formal authority to conduct its charitable activities throughout the West Bank and Gaza. Support to Christians in Israel and Jordan is made direct from the UK or through local institutions.
3. FHL’s Charitable Objectives
We collect information purely for the purpose of helping to achieve our charitable objectives which are: raising awareness of the challenges facing the Christians of the Holy Land, encouraging prayers for their intentions, generating and channelling financial resources to give them a sustainable future and encouraging visits to the Holy Land to meet local Christians.
4. Why FHL holds Supporters’ Personal Information
Friends of the Holy Land stores and processes supporters’ personal information in order to:
· Process donations (including keeping records of supporters’ relationships with FHL and details for HMRC gift aid declarations).
· Process sales of Olivewood
· Produce statutory accounts and financial reports for audit purposes and good governance.
· Contact supporters with updates about FHL projects and FHL work.
· Contact donors if there is a problem to resolve.
· Administer enquiries including volunteering and job applications
· Contact people about opportunities to support FHL work and local fund-raising or provide information about events.
· Help us to make the FHL website work better.
· Align it with publicly available information to help tailor FHL communications and products
5. What Personal Information is held by FHL
FHL stores the personal information that is provided by supporters, including details of donations and payment transactions. It may also include enquiries, surveys, Olive Wood transaction details, event attendance and pilgrimage details. Website usage information may also be collected using cookies.
Supporters’ Personal information held by FHL includes:
· Postal address
· Email address
· Telephone/mobile numbers
· Contact preferences
· Gift Aid status
· Gender (This is automatically generated – FHL does not use this information)
· Donation details
· Correspondence and notes from interactions with FHL staff and volunteers
· Information that is publicly available (e.g. the diocese that a parish belongs to)
· Any other personal information that is provided by the supporter
· IP addresses and web browsers (and versions) used
· Information on how people use the FHL website, using cookies and page tagging, to help improve FHL’s on-line services
To comply with the GDPR procedures, FHL will use a supporter’s personal information to contact them only if one of the following conditions apply:
- Supporter has given
express permission for FHL to do so (in that way and for that reason).
- Supporter is new and
has made a donation without the usual documentation. FHL would acknowledge the
donation and seek the relevant permissions to contact the supporter, although
the supporter is under no obligation to respond to this.
- It is necessary in
order to deliver contracted goods and services.
- FHL has a legal
- It is of vital importance (it might save a person’s life).
Supporters will be able to amend these permissions or unsubscribe at any time by contacting FHL office by email, telephone or letter. Alternatively, they can use our website.
7. How FHL collects a supporter’s personal information
When a supporter gives FHL their details
For example, when a supporter makes a donation, requests further information, or attends an event. At times, a supporter might be interacting with an organisation working on FHL’s behalf such as a local FHL group, but FHL is still responsible for the information collected by that group.
When a supporter donates through a third party
For example, when a supporter makes a donation through a third-party website e.g. BT Donate, MailChimp or CAF, and gives permission for their personal information to be shared with FHL.
If a supporter engages with FHL on social media and messaging services such as Facebook, or Twitter, the supporter might give FHL permission to process information from those accounts. FHL will not be able to access a supporter’s private messages, photos, etc. but a supporter may choose to send FHL information about them self which might be requested to work out the general profile of FHL’s audience on that media service.
When a supporter visits FHL’s website
From other public information
FHL sometimes uses information that is taken from publicly available websites such as Diocese or Parish web pages or information freely available in the media.
8. Who does FHL share information with?
FHL promises to keep supporters’ personal information secure and will not sell or give supporters’ personal information to any other organisation. Information about UK donors is never shared even with the FHL Holy Land Committee or staff unless expressly authorised by the donor.
FHL may disclose supporters’ personal information if required to do so by law or if it believes that such action is lawful and necessary to protect and defend the rights, property or personal safety of Friends of the Holy Land and its stakeholders and for other lawful purposes.
FHL has contracts in place with its IT suppliers, which require those IT suppliers to comply with UK’s law on data protection and to have systems and processes in place to protect the security of FHL supporters’ personal information. These include:
FHL IT partners: Access ThankQ (industry-recognised online donor database software), CIS Hosting (industry recognised cloud-based data hosting).
FHL website and social media partners: Pink Jelly (FHL web-site provider), Mailchimp (bulk-emailing software), Facebook, Twitter.
Government Departments : To reclaim gift aid from Her Majesty’s Revenue and Customs (HMRC). UK Pensions Regulator, UK HMRC Tax and NI
9. Keeping Supporters’ Personal Information safe
FHL have physical, technical and human controls in place to keep your information secure.
FHL ensures 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 FHL cannot guarantee the security of any information received electronically so such communications are initiated at the risk of the sender. FHL advises against sending personal information using unsecure means or networks such as free public wifi.
Once FHL receives your data, every effort is made to ensure its security both on our systems and while in transit between the systems and any partners, working on FHL’s behalf.
Access to personal information is restricted to authorised personnel who require it for FHL purposes and all staff with access to personal data are trained in how to keep it safe.
FHL cannot be responsible for the privacy policies and practices of other websites, even if they are accessed using links from the FHL website so it is recommended that website visitors check the policy of each site visited.
10. Keeping Supporters’ Personal Information
FHL will hold supporters’ personal information on FHL systems for as long as it is lawful and necessary to do so. This will enable FHL to ensure that it does not communicate with supporters who have asked FHL not to, and to comply with the data protection law.
11. Supporters’ Rights
Under the GDPR data protection law, FHL supporters have the following rights regarding the processing of their personal information. For more information on supporters’ full rights, please visit the Information Commissioner’s Office website, currently at this address: https://ico.org.uk/
Supporter’s right to be informed:
FHL is required to inform a supporter clearly when, how and why it is collecting personal information and what it will do with it. FHL does this through this policy document and privacy notices which explain these points whenever FHL collects a supporter’s personal information.
Supporter’s right of change of contact method or removal:
A supporter has the right to object to FHL contacting them. FHL is obliged to give a supporter the opportunity to say how they can be contacted and for what purpose. A supporter can change these preferences at any time by accessing the FHL website, or by contacting the office by email, telephone or letter.
Supporter’s right to restrict processing:
A supporter can ask FHL not to process their personal information (though this still permits FHL to store it for legitimate business and regulatory, e.g. tax, reasons).
Supporter’s right of access:
A supporter has a right to see what personal information FHL holds about them and can request to see it.
Supporter’s right to data portability:
Making it easy for a supporter to obtain a copy of any personal information that they have provided to FHL in a machine-readable format, so they can easily transfer it to other organisations providing similar services. Any copies of personal information FHL provides upon request will be provided in plain text format
Supporter’s right to rectification:
A supporter can ask for any inaccurate personal information FHL holds about them to be corrected
Supporter’s right to erasure: (your right to be forgotten)
A supporter can ask FHL to erase their personal information that FHL holds
If a supporter would like to request a copy of their personal information held by FHL, the supporter is requested to send proof of their identity to Friends of the Holy Land, Farmer Ward Road, Kenilworth, Warwickshire CV8 2DH. Once their identity is confirmed, FHL will send a copy of the supporter’s personal information, in line with what FHL is legally required to disclose, within one month. FHL accepts no liability for the security of a supporter’s personal information, as contained in their request, until it has been received by FHL.
If you need to make a formal complaint please contact the office for a copy of our Complaints Procedure. Your complaint can be addressed any of the Management Committee not involved in the complaint. The complaint will be reviewed by one of our Executive Trustees
Supporters can also lodge a complaint about the way FHL manages their personal information with the Information Commissioner’s Office (ICO). More information is available on the ICO website, currently at this address: https://ico.org.uk/
12. Changing the way FHL contacts Supporters
A supporter can contact FHL at any time to request an amendment to how FHL contacts the supporter and what for – or to tell FHL not to contact them at all. FHL will always respect a supporter’s wishes, though please note that there may be some information that FHL has to keep such as Gift Aid or Standing Order details for reasons that are required by law where FHL must be able to contact a supporter.
Like most websites, FHL’s website uses small data files stored on a supporter’s computer called cookies. Cookies provide insight into how people use a website to help an organisation such as FHL to keep improving it. Cookies do many different things, such as helping to:
· avoid asking a supporter to register or complete details twice
· estimate the number of visitors to the website, including the source and patterns relating to this traffic
· understand how visitors use the site, and how an organisation such as FHL can enhance this experience
A supporter is able to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time, although the supporter should be aware this means that they will miss out on some personalised services. A supporter can delete their cookies through their device settings at any time.
14. A message for those supporters under 18 years old
If a supporter is under 18, they must ask for their parent or guardian’s permission before sending FHL any personal information, including photos and messages. Also, these supporters are required to include their age when contacting FHL.