At The Together Plan we are committed to protecting your personal data and being transparent about what we do with it. We will use your personal data in accordance with applicable data protection laws, and not do anything with your information that you wouldn’t reasonably expect.
Overview
This Privacy Policy sets out how and why we, The Together Plan, use and protect your personal data in accordance with applicable data protection laws. We may undertake additional processing which is subject to separate Privacy Policies and we will draw them to your attention where this is the case.
This Privacy Policy applies to our supporters, our clients, persons we support, as well as to the general public, visitors to our premises and visitors to our website, and to journalists.
For information about the rights you may have in relation to your personal data, please see your rights below. If you would like to exercise any of your rights, please contact us.
Key processing
We use your personal data for the purposes set out in this policy. The key purposes for which we handle your personal data are explained in this section and our other purposes are set out in the how we use your personal data section below.
to provide support
We support socially and economically vulnerable communities in the former Soviet Union and Eastern Europe in a number of ways, including via humanitarian aid, cultural heritage projects and community capacity building. Please see the relevant sections of how we use your personal data for further information.
marketing
We will only send you emails and post where you have consented to this; and will not send you marketing if you have asked us not to. To withdraw your consent or opt-out from receiving marketing at any time please contact us. Please see direct marketing for further information.
philanthropy
We research, and profile potential or existing high value donors, to allow us to identify and engage with suitable high value donors. This allows us to focus our fundraising resources, and to ensure that our requests for support are tailored to each individual, ultimately helping us to maximise the efficiency of our fundraising. If you would prefer that we do not carry out this type of analysis, please contact us. Please see high value donors for further information.
online advertising
We promote our aims and activities online, including via platforms such as Facebook. We may ask a platform to show our adverts to a particular group of individuals, and may also use data purchased from third parties to identify relevant audiences for our adverts. We may also track when individuals click on our adverts. We never use special category personal data (e.g. health data) to target individuals. Please see online advertising for further information.
For information about the other purposes for which we process personal data, please see how we use your personal data.
Controllers
The Together Plan will be the ‘controller’ of your personal data. This means that we are responsible for deciding how your personal data is used, and ensuring that it is used in compliance with applicable data protection law (in conjunction with other parties, where applicable).
Contact us
If you have questions about this Privacy Policy, or if you would like to exercise any of your privacy rights, please contact us by email at [email protected], or write to our Operations Manager in writing at The Together Plan, The Studio, 60 Glencoe Road, Bushey, WD23 3DS.
Miscellaneous
links
The Together Plan website may include links to other sites, not owned or managed by us. We cannot be held responsible for the privacy of information collected by websites not managed by us.
changes to this policy
We may change our privacy policy from time to time so please check back periodically. This Privacy Policy was last updated in May 2024.
What is personal data?
Personal data is any information that can be used to identify you. For example, it can include information such as your name, date of birth, email address, postal address, telephone number, IP address, credit/debit card details and CCTV footage.
special category data
Data protection law recognises that certain categories of personal data are more sensitive than others. These are known as ‘special category data’ and include information relating to health, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetics, biometrics (where used for ID purposes), sex life and sexual orientation.
We do not generally process any special category personal data about you, except in relation to limited special category personal data (namely health data) concerning some of our donors. We only process donor health information where donors tell us about a health condition or injury that means that they would prefer us to contact them again in due course to talk about their donation once they have recovered from the applicable condition or injury, or where donors tell us about a health-related reason that means they can no longer attend one of our events (and we retain this information in accordance with our retention policies in order to make reasonable adjustments).
criminal offence data
Personal data relating to criminal convictions and offences (including allegations of the same) is also subject to extra safeguards.
How do we obtain your personal data?
We may collect personal data when:
- you give it to us, or we collect it from you, directly – for example, when you sign up for one of our events or donate to us, and where you visit our websites or open our emails (with your consent where necessary: please see cookies and similar technologies);
- you give permission to other parties to share it with us – for example, when you have told an event organiser such as JW3 that you would like to hear from us, or where a friend, family member or legal representative has contacted us on your behalf; or
- your information is available publicly, for example, from Companies House, or, depending on your privacy settings, from social media and messaging services such as Facebook, YouTube etc.
mandatory information
When we ask you to provide personal data to us on a mandatory basis, we will inform you of this at the time of collection and in the event that particular information is required by the contract or statute this will be indicated. We will also explain the consequences of any failure to provide any mandatory information: for example, failure to provide us with your contact details will mean that we cannot contact you, and failure to provide us with your payment details will mean that we cannot complete a transaction.
third-parties
Apart from personal data relating to yourself, you may also provide us with the personal data of third parties, such as when you contact us on behalf of, or about, friends and family, or send us photographs including other people. Before you provide such third party personal data to us you must make sure that these third parties are aware that you will provide such data and of how it will be used by us, as detailed in this Privacy Policy.
Your rights
You have a number of rights in relation to your personal data. You should note that these rights are not absolute, so we do not always need to comply with your requests, but we will make sure we explain our reasons to you if this is the case.
To exercise any of your rights, please contact us.
We may ask you to provide additional information to prove your identity, for example, to provide a copy of an identification document, before we allow you to exercise a right. This is for your security: we consider that we have a legitimate interest in ensuring that we only allow the correct individuals to exercise the rights to which they are entitled. Our aim in this respect is to prevent fraudsters from accessing the information we hold about you.
We will respond to any such request within 1 month. Occasionally it could take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated. If we refuse a request, we will explain our reasons and let you know how you can challenge our decision.
If you are unhappy with how we’ve dealt with your request or used your data please contact us. However, if you are still unhappy you have the right to complain to the Information Commissioner’s Office (ICO). Please visit https://ico.org.uk/make-a-complaint/ or call the ICO helpline on 0303 123 1113 for further information.
Right to be informed
This Privacy Policy explains how we process your personal data.
Right to access
You have the right to ask us to confirm whether we process any of your personal data, and to provide access to any personal data we do hold about you.
Right to correct your personal data
We aim to ensure that all personal data is correct. If any of the information that you have provided us with changes, for example if you change your email address, please do contact us so that we can keep our records up to date. We will update your records as soon as possible and in any event within one month.
You have a right to require us to correct any information about you that is inaccurate, and you may also ask us to remove information which is inaccurate or to complete information which is incomplete. We may seek to verify the accuracy of the personal data before rectifying it, and in some circumstances we will need to keep a copy of the inaccurate data (for example, if we need to keep an audit trail).
Data portability
In some situations, you have a right to obtain your personal data from us in a structured, commonly used and machine-readable format and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data. This includes the right to require us, where technically feasible, to pass on information we obtained from you to another data controller.
Right to erasure (‘right to be forgotten’)
You have the right to require us to erase your personal data in certain circumstances, for example:
- where it is no longer necessary for us to continue holding or processing your personal data for a particular purpose;
- if you withdraw your consent to certain processing (in relation to which we rely upon your consent as a lawful basis); or
- if you have objected to processing in relation to which we rely upon our legitimate interests, and we have no overriding interest or that personal data is processed for direct marketing purposes (and this includes profiling to the extent that it is related to such direct marketing).
This right is not absolute: for example, we do not have to delete your data if we need to continue processing this information to comply with our legal obligations, or for the establishment, exercise or defence of legal claims. We may also need to keep some information about you in order to, for example, comply with an instruction not to contact you again.
Right to restriction of processing
You have a right to ask us to restrict our processing of your information if:
- you contest its accuracy and we need to verify whether it is accurate;
- the processing is unlawful and you ask us to restrict use of it instead of erasing it;
- we no longer need the information for processing, but you need it to establish or defend legal claims;
- you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests. If you exercise your right to restrict processing, we would still need to process your information for exercising or defending legal claims, protecting the rights of another person or for public interest reasons.
This is an alternative right to the right to be forgotten and it is not an absolute right.
Right to withdraw consent
If we rely on consent as the legal basis for processing (see how we use your personal data) you can withdraw your consent to that purpose of processing, and we will stop that particular processing.
However, we may still continue to use the same data for other purposes: for example, you withdraw your consent to receipt of direct electronic marketing from us, and also make a complaint, we may rely on our legitimate interests to process your personal data in order to investigate that complaint.
Right to object to processing
You have the right to object to: processing that is based on legitimate interests or performance of a task in the public interest (including profiling); direct marketing (including profiling for the purposes of direct marketing) and processing for the purposes of scientific, statistical or historical research.
We must comply with any request to stop processing for the purposes of direct marketing. The right to object is not absolute in relation to processing for legitimate interests and research purposes.
If you would prefer us not to profile you for the purposes of targeting or tailoring our fundraising efforts, please contact us.