Guernsey For Freedom: Privacy Notice
Guernsey for Freedom believes in the importance of human rights and we recognise that the lawful use of personal data is part of those fundamental rights. We are committed to following best practices in use of your personal data; we recognise it is important to you and it is important to us.
This privacy notice provides information on how we collect and process your personal data.
Who we are and how you can contact us
Guernsey for Freedom is a charity registered in Guernsey with charity number CH 550. We are the 'data controller' and so decide how we use your personal information. Our contact details are:
Address: Les Padins, St Saviour, Guernsey GY7 9JJ
Email address: firstname.lastname@example.org
Telephone: +44 1481 265231
The data we collect about you
The exact information we hold on you will depend on your relationship with us. The types of information that we hold include:
Your contact details (for example postal address, email address and phone number)
If you have made a donation then we may collect your bank details along with the amount and date you made a donation and, particularly where donations are large, we may collect information about the source of your funds
If you volunteer to help us then we need to have information about your background, particularly if you are in a position of special trust (for example treasurer, chair or trustee).We will also need to keep records about the operation of the charity so your decisions and opinions may be recorded in those minutes or documents
We may hold a photograph of you to support our fundraising or awareness raising activities
We try not hold the type of particularly sensitive information about you called "special category personal data" although sometimes we are provided with sensitive information by people making enquiries of the organisation or as part of our awareness raising activities. For example we might be told about a person's race or ethnic origin, their religion or provided with information about their health or criminal record. Where we are provided with that information we try to hold it for as short a time as possible and securely delete it.
In order to satisfy legal requirements (such as anti-money laundering and countering the financing of terrorism) we may need to request information about the backgrounds of volunteers or those who make donations, including criminal records checks.
How we collect your personal data
In the vast majority of cases we will get your personal data directly from you. This might be, for example, when you make enquiries of us, when you register to attend or attend one of our events or when you make a donation to us. Alternatively it might be when you volunteer to help us and you provide us with your information as part of that volunteering relationship.
Occasionally we may conduct an online or paper survey using facilities such as surveymonkey (see their separate privacy notice on how they use personal data). We may publish statistical findings but these are not published in a way that would identify any individual.
Where we are helping bring villages to freedom we work with a partner organisation called Voices 4 Freedom. Occasionally personal data is provided to us by Voices 4 Freedom, but if your personal data is passed to us by Voices 4 Freedom then they will have explained to you what they would be doing with your data before providing it to us so that you can control whether or not your data is passed to us.
Rarely do we collect personal data from publically available sources.
Why we have your data and how we use your personal data
Depending on your relationship with us, we may use your personal data to:
Thank you for making a donation
Process donations you give us
To keep records of your relationship with us
For fundraising, awareness raising or event organisation
As part of conducting a survey
To comply with legal obligations on us
Provide information or resources you have requested
To provide support and assistance to you
Our legal basis for using your personal data
We use the following legal bases to use personal data provided to us.
Legitimate interest – We may use your information to administer a donation or to work to further our charitable aims. When using your personal data on this legal basis we undertake what is called the "legitimate interest test" which means that we think about:
What benefit our outcome we have in mind
If using the personal data is necessary for this benefit or outcome or if there is another way that would not involve using your personal data, and
If the hoped for outcome is overridden by your interests, rights or freedoms
Contractual – where the processing of information is necessary for a contract we may have with you or which is in your benefit.
Legal obligations – as a charity we are under certain legal obligations, such as to comply with legislation applicable charities or the creation and operation of trusts, our tax obligations as well as complying with the anti-money laundering and countering the finance of terrorism regime.
Not-for-profit basis – as a not for profit organisation we can use the personal date of people who have regular contact with us provided we do not share that personal data.
Consent – this is an indication that an individual expressly agrees to their personal information being used in a specific way. It represents a positive choice by an individual to give clear and explicit permission.
How we share your personal data
Generally we do not share your personal data. There may be occasions where the law requires us to share your information with relevant authorities (eg the Guernsey Revenue Service or the Guernsey Registry). If you have been brought to freedom then, only with your prior consent (obtained by Voices 4 Freedom) your photograph may be shared with patrons, donors or at fundraising events.
How long we keep your data
We try to keep as little personal data as possible and look to swiftly and securely delete personal data where we can. Where information needs to be kept for compliance with tax, charity law or anti-money laundering/countering financing of terrorism obligations then we typically hold the information for 7 years (or occasionally 6 years). Information connected with the core obligations about the trust (for example the personal data of trustees) will be retained for 18 years.
If you would like more information about our retention periods then please get in touch with us.
Do you have to provide us with your information?
You do not have to provide us with your information. However where you are looking attend an event or support us (either financially or by volunteering) then we may need your information in order to fulfil obligations on us and without that information you might not be able attend the event or provide that support.
If you are entering into a contract with us (for example in relation to an event or other fundraising activity) then we may not be able to properly discharge the contract without that personal information.
We do not transfer any personal data outside Guernsey unless we are required to do so by law.
We do not undertake any automated processing.
Your information - your rights
If you have any questions about how your data is handled please contact us using the contact details below.
We are registered with the Office of the Data Protection Authority in Guernsey. The data protection law gives you the following rights:
Right of access – you are entitled to see a copy of the information about you that we hold
Right to rectification – if you dispute the accuracy or completeness of personal data that we hold about you, you have the right to require us to rectify or change that data
Rights to erasure or restriction – In some circumstances you have the right to prevent us using your personal data or to restrict our use of the information
Right to object to processing – this is particularly where information is used for direct marketing, is being used on the grounds of public interest or for historical or scientific purposes.(We do none of these things)
Right not to be subject to decisions based on automated processing.(We do not undertake automated processing
Right to data portability – you can instruct us to transmit your personal data to another organisation who you wish to have control of your personal data
For more information on these rights please see the website of the Office of the Data Protection Authority in Guernsey (www.odpa.gg). If you are unhappy with how we have used your personal data we hope that you will get in touch with us. You also have the right to lodge a complaint with the Office of the Data Protection Authority, St Martin's House, Le Bordage, St Peter Port, Guernsey GY1 1BR (telephone: +44 1481 742074, email: email@example.com)
Changes to this privacy notice
We regularly review this privacy notice to make sure is it accurate and we may amend it from time to time to take account of changes to our processes or changes to data protection or other relevant legislation. When we update this privacy notice then we will promptly place the updated version on our website.
We have appointed Jenette Bales as our data protection manager and she can be contacted using the contact details below.
If you have any questions about how your data is handled please contact us at:
Address: Les Padins, St Saviour, Guernsey GY7 9JJ (for the attentionof Jenette Bales)
Email address: firstname.lastname@example.org
Telephone: +44 1481 265231
Date: 30 June 2022