Privacy notice

Conditions for Processing Data

We are only entitled to hold and process your data where the law allows us to.  The current law on data protection sets out a number of different reasons for which we may collect and process your personal data.  These include:

Legitimate Interests

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.  This may include to satisfy our external quality auditors or our Regulators.

Legal compliance

If the law requires us to, we may need to collect and process your data.   For example, we can pass on details of people involved in fraud or other criminal activity.

Consent

In some situations, we can collect and process your data with your consent.  For example, when you tick a box to receive email newsletters.

When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

When do we collect your data?

We normally collect your data when you provide it to us. You may give us your data by email; through an online web form; over the telephone; face to face; or by post.

What sort of data do we collect?

We may collect your name and contact details as well as a list of our contact with you and any memberships or donations you have given.

How do we use your data?

• providing and personalising our services
• dealing with your enquiries and requests
• administering orders, donations and membership
• maintaining information as a reference tool or general resource
• providing you with information about our activities.

We will never release your personal details to any organisation outside the Howard League for Penal Reform for mailing or marketing purposes.

How do we protect your data?

We take protecting your data very seriously and will treat your data with the utmost care and take all appropriate steps to protect it.   We have clear data protection and information security policies and procedures in place (along with Regulatory and other legal obligations to keep your data safe) and these are regularly assessed as part of our Quality Standards and compliance processes.

We protect our IT system from Cyber Attack.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

How long will we keep your data?

We only keep your data for as long as is necessary for the purpose(s) for which it was provided.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties. For example,

secure file storage and destruction companies; auditors; the company that securely hosts our off-site cloud storage servers.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Where is your data processed?

Your data is stored and processed within the EEA.  If we ever have to share your personal data with third parties and suppliers outside the European Economic Area (EEA) we will seek your specific consent to do so.

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

We may use systems like MailChimp to send you updates and newsletters.  MailChimp is based in the US and therefore some limited information (your name and email address) may be transferred to Mailchimp (and therefore to the US) for the purposes of using that system.  Mailchimp is signed up to the US EU Data Privacy Shield and we do not believe that there is any material risk associated with transferring this limited information outside of the EU.

What are your rights?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.
• That we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate.

To ask for your information, please contact [email protected]

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

The Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (please note we cannot be responsible for the content of external websites)