This Policy contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.
The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services or your interaction with us may be impaired. For example, you will be unable to make a donation, or we could not send you email updates.
4. Lawful bases
a. When you give it to us directly
For example, personal information that you submit through our website by making a donation, signing up for our email newsletter or booking a speaker, or personal information that you give to us when you communicate with us by email, phone or letter.
b. When we obtain it indirectly
For example, your personal information may be shared with us by third parties. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.
c. When it is available publicly
Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us through platforms such as Facebook or Twitter).
d. When you visit our website
When you visit our website, we automatically collect the following types of personal information:
(a) Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
(b) Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.
In general, we may combine your personal information from these different sources for the purposes set out in this Policy.
We may collect, store and otherwise process the following kinds of personal information:
a. your name and contact details, including postal address, telephone number, email address and, where applicable, social media identity;
b. your date of birth and gender;
c. your financial information, such as bank details and/ or credit/ debit card details, account holder name, sort code and account number;
d. information about your computer/ mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;
e. personal descriptions, photographs and other biographical information;
f. details of your qualifications, experience and relevant training;
g. the status of your application to be a speaker or to work for us;
h. topics for discussion / current affairs issues which are of interest to you;
i. information about our services which you use/ which we consider may be of interest to you; and/ or
j. any other personal information which you choose to share with us as per clause 1.
Do we process special categories of data?
The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, political opinions and religious beliefs.
In certain situations, CV may collect and/or use these special categories of data (for example, by applying to be a CV speaker you will indicate your religious beliefs, and information about your political opinions may be evident from discussion topics which you indicate are of interest). We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.
Your personal information, however provided to us, will be used for the purposes specified in this Policy. In particular, we may use your personal information: to provide you with services, products or information you have requested (for example, to provide the appropriate CV speaker to comment on a particular topic);
a. to process your application to be a CV speaker;
b. to process your request to be included on our mailing list;
c. to provide further information about our work, services, activities or products (where necessary, and only where you have provided your consent to receive such information);
d. to process your donations;
e. to provide training (for example as part of our national speakers’ training programme);
f. to answer your questions and requests and communicate with you in general;
g. to manage relationships with our supporters and organisations which use our services;
h. to further our charitable aims in general, including to raise funds to keep our organisation running;
i. to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
j. to report on the impact and effectiveness of our work;
k. to run/administer our website, keep it safe and secure and ensure that content is presented in the most effective manner for you and for your device;
l. to register and administer your participation in CV events;
m. to process your application for a job or volunteer role with us when you apply through our Careers page;
n. to administer your employment/other working relationship with us (for example, to pay your salary);
o. for training and/ or quality control;
p. to audit and/ or administer our accounts;
q. to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to our status as a registered company or anti-money laundering initiatives;
r. for the prevention of fraud or misuse of services; and/or
s. for the establishment, defence and/ or enforcement of legal claims.
The GDPRrequires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:
a. Where you have provided your consentfor us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you emails about forthcoming events or similar.
b. Where necessary so that we can comply with a legal obligationto which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services or law enforcement bodies).
c. Wherenecessary for the performance of a contractto which you are a party or to take steps at your request prior to entering a contract (for example, to provide you with a speaker following your booking request).
d. Where there is a legitimate interestin us doing so.
The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).
In broad terms, our “legitimate interests” means the interests of running CV as a charitable entity and pursuing our aims and ideals – primarily to ensure that the Catholic Church is fairly and accurately represented in public discourse and in the media.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
We may use your contact details to provide you with information about our work, events, services and/ or products which we consider may be of interest to you (for example, about services you previously used, or updates about fundraising appeals and/or volunteering opportunities via our newsletter).
Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law).
Where you have provided us with your consent previously but do not wish to be contacted by us about ourprojects and/or services in the future, please let us know by email at email@example.com. You can opt out of receiving emails from CV at any time by following the instructions at the bottom of our emails.
When you use our secure online donation function you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.
As a general rule, we do not process children’s personal information. However, where we do so, where required we will not do so without their consent or, where required, the consent of a parent/ guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care.
In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see Section 12 below), we will remove it from our records at the relevant time.
If you requestto receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.
We do not sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Policy.
Non-exhaustively, those parties may include:
a. Ourcontacts at premises where CV events are held (for security purposes);
b. suppliersand sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as mailing houses (we use Mailchimp to assist us with providing updates to those who subscribe via our website) and cloud storage providers (we use Dropbox);
c. Paypal, who help to collect and process donations on our behalf;
d. professional service providers such as accountants and lawyers;
e. parties assisting us with research to monitor the impact/ effectiveness of our services;
f. externalfundraising entities/ platforms;
g. media outlets (when you speak on our behalf); and/or
h. otherCatholic Voices organisations in other parts of the world (we have reciprocal organisations elsewhere in Europe, Latin America and the Caribbean).
In particular, we reserve the right to disclose your personal information to third parties:
· in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets;
· if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
· if we are under any legal or regulatory duty to do so; and/or
· to protect the rights, property or safety of CV, its personnel, users, visitors or others.
CV is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.
Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers with features enacted to prevent unauthorised access.
Given that we are a UK-based organisation, we will normally only transfer your personal information within the European Economic Area (the “EEA”), where all countries have the same level of data protection law as under the GDPR.
However, because we may sometimes use agencies and/or suppliers to process personal information on our behalf, or because we have reciprocal organisations in other locations around the world, it is possible that personal information we collect from you will be transferred to and stored in a location outside the EEA, for example the United States.
Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy. If you have any questions about the transfer of your personal information, please contact us using the details below.
Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:
a. Right of access– you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to seethe personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
b. Right of erasure– at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.
c. Right of rectification– if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.
d. Right to restrict processing– you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
e. Right to object– you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
f. Right to data portability –to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact,andin either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.
g. Rights related to automated decision-making– you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by EU or Member State law to which CV is subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested to you.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details below.
You are further entitled to make a complaint about us or the way we have processed your personal information to the data protection supervisory authority in your home country. In the UK, the data protection authority is the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us using the details below.
We may update this Policy from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an update Policy on our website. This Policy was last updated on 24 October 2018.
We link our website directly to other sites. This Policy does notcover external websites and we are not responsiblefor the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.
Please let us know if you have any questions or concerns about this Policy or about the way in which CV processes your personal information by contacting us at the following channels:
Telephone: 07985 175980
Post: Catholic Voices, Cuckoo Hill Farm, Cuckoo Hill, Pinner, HA5 2BB