Transforming Africa Initiative (TAI) promises to take great care with your personal data, and we commit to protecting any personal information we obtain about you.
This Privacy Policy sets out how and why we obtain, use and protect personal information when you interact with us.
Should you work with us in certain ways – for example, enrol in a specific event, program, apply for a job, or are a member of staff, there may be a separate Privacy Policy which describes how we use that data.
TAI is a registered charity in Scotland (charity number SC042815). We are a Scottish Charitable Incorporated organization (SCIO) and have a partnership with Ripple of Life Legacies with Inalegwu (rollwinabc.com), a blog which supports our TAI mentoring platform and provides this services for free.
This Privacy Policy applies to all the above entities, including rollwinabc.com.
TAI’s registered address is 159 Great North Road, Aberdeen. AB24 3QH.
This Privacy Policy relates to information which is obtained by TAI and for which TAI is the Data Controller.
TAI’s purpose and overall mission is to address inequality in African societies and ensure national development through research, advocacy, education, publications, community projects and quality healthcare services that employ maximum participation of target communities.
Our supporters help us to achieve this in a variety of ways, primarily by:
i. Fundraising, donating money and donating or purchasing goods for sale in TAI shops in order to support our programme of work
ii. Participating in our awards programs
iii. Campaigning for change, through signing petitions, writing letters and taking part in other campaigning actions
iv. Volunteering, including in TAI shops, at events and in our offices
We hold and process supporters’ personal data for a number of reasons:
o To keep a record of donations made and actions taken by our supporters and our communications with them
o To send our supporters marketing information about our projects, fundraising activities and appeals where we have their consent or are otherwise allowed to
o To support volunteers, whether in shops, at festivals or participating in fundraising events
o To record campaigning actions by supporters
o To support community based fundraising and campaigning
o To claim gift aid on donations
o To fulfil contractual obligations entered into with supporters e.g. online purchases
o To keep people safe, whether they are visitors to our shops, staff or participants in events
o To comply with legal obligations
o To manage our organisation
o To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted
These reasons are underpinned by a “legal basis” under GDPR. We outline in the next section what these are for our main activities.
The law on data protection sets out a number of different reasons for organisations to collect and process your personal data: When collecting your personal data, we will always make clear to you which data is necessary for a particular purpose.
TAI relies on the following legal bases in our marketing activities:
Consent
Wherever possible, we will ask for your consent to send you marketing information. We will do this through a clear statement of what you will receive and allow you to select only those channels that you wish to hear from us by.
For example, if you donate online to one of our emergency appeals, you will be asked whether you would like us to keep in touch about our projects, fundraising activities and appeals. You will also be asked which channel(s) of communication you would like us to use (with a choice of email, SMS, post and telephone being offered).
Legitimate interest
In specific situations, we process your data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests. TAI’s use of legitimate interest includes the following:
Sending direct marketing information by post, to keep our supporters updated on TAI’s projects, fundraising activities and appeals. We will only do this where we have reason to believe that this information will be of interest. We make it easy for you to opt out and, see sow to control what we send you or request we update your personal information.
Where you have bought items from the TAI online shop we will email you to tell you about other relevant offers. All such emails will include a simple opt out mechanism.
If you have opted in to TAI emails or text messages we may use your details to link to your account on Facebook or other social media site in order to serve you TAI content.
We analyse your previous support of TAI in order to offer relevant ways of supporting TAI in the future.
To help identify businesses who may wish to support TAI, we send emails to individuals where relevant to their job, for instance people working in Corporate Social Responsibility.
For activities other than marketing, we may rely on different legal bases:
Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, where you sign up to the Gift Aid scheme, we will process your data for the purposes of submitting a Gift Aid claim to HMRC.
Consent
We may ask for your consent for data – for instance where you campaign with us or engage with a program in the UK and can give you a clear choice about what information you need to provide.
Legitimate Interest
In many situations we need data in order to carry out a task, such as enrol you on a program, run an event, administer our organisation, plan or run campaigning activities etc.
Public Interest
In limited situations we may use data in the public interest. It is likely to be in the public interest to collect data to prevent crime or dishonesty, ensure that we are fair in our practices by carrying out equality and diversity monitoring, or safeguard the wellbeing of people with whom we work.
TAI will only contact you for marketing purposes – for example keep you up to date on our work, or let you know of ways in which you can support that work – where we have your consent or we are otherwise allowed to do so.
We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work and the ways in which you would like to receive this information (post, email, SMS and phone). We will not send you marketing material if you tell us that you do not wish to receive it.
Where you give us your consent to send marketing information, we will wherever possible let you know how long this consent will last. Unless we have grounds for believing that a longer period is reasonable and have explained this to you, we will understand your consent to last for 24 months. After this time, in order for us to continue to update you, we will need your refreshed consent. You can update or withdraw your consent at any time, for individual channels of communication, or for all channels.
Consent lasting more than 24 months
We will generally treat any marketing consent you give us as lasting for 24 months, but will apply the following exceptions (but only where we inform you of this at the time you give consent):
o Where you are a mentor or mentee on our mentoring program.
o Where you have committed to giving us a regular donation (usually monthly). In this situation, and unless you withdraw your consent, we will treat consent as enduring until you cancel your donation, at which point your consent will expire 24 months after the last donation. This is to enable us to keep you up to date with the impact of your gifts, and to ask whether alternative means of support would be of interest.
o Where you have notified us that you will be leaving a legacy to TAI. This is a lifetime commitment and although we will provide you with regular opportunities to shape and control your communication from TAI we will treat your consent as ongoing.
“Legitimate Interest”
We may send you marketing communications by direct mail where you are a regular supporter and we have evidence that you do not object to receiving marketing material through the post.
We will not use “legitimate interest” if you have opted out of direct mail whether direct to TAI or by registering with the Mailing Preference Service (MPS) or the Fundraising Preference Service (FPS).
“Soft opt in”
This allows organisations to send marketing communications by email and SMS to individuals who have previously purchased similar goods and services, provided they were given the opportunity to opt out at the time of purchase. In TAI’s case, this allows us to send marketing emails and SMS to previous customers of the TAI online shop. We apply a 24-month time limit, and only communicate on this basis where you have made a purchase within this period. We will not use the “soft opt in” option if you have opted out of receiving email and/or SMS, whether direct to TAI or via the Fundraising Preference Service.
TAI may collect your personal data in the following circumstances:
a. When you give it to us DIRECTLY
You may give us your personal data directly when you make a donation, sign up for one of our events, take part in a campaigning action, volunteer at one of our shops, purchase products from the TAI Online Shop, when you communicate with us or when you download the MyTAI app (when it is launched, currently in development).
b. When you give it to us INDIRECTLY
You may give us your information indirectly when you sign up to events such as the London Marathon, contribute to TAI via fundraising sites like JustGiving or Virgin Money Giving, or participate in a campaigning action with a partner. These independent third parties will pass your data to TAI where you have indicated that you wish to support TAI and have given your consent or it is a necessary part of completing a contract with you.
Sometimes your personal data is collected by an organisation working on our behalf (for example a professional fundraising agency) but as they are acting on our behalf we are the “data controller” and responsible for the security and proper processing of that data.
c. When you access TAI’s Social Media
We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.
https://www.facebook.com/policy.php
https://twitter.com/en/privacy
https://www.whatsapp.com/legal/#privacy-policy
https://www.linkedin.com/legal/privacy-policy
d. When the information is publicly available
We might also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like TAI. In this scenario, TAI may seek to find out more about these individuals, their interests and motivations for giving through publicly available information. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies House. TAI will not retain publicly available data relating to major donors without their consent, which will be sought at the earliest practical opportunity. Where we decide not to make contact, we will delete all personal data obtained, other than basic contact details, to which we will apply a suppression flag to ensure we do not make contact in the future.
We may also gather information if your activities relate to our work – for instance, if you are a public figure such as a Member of Parliament or you represent an organisation which we work with or which is related to one of our campaigns we may gather information about you in order to inform our campaigning and make decisions – for instance, whether we engage with you to seek your support for our work, ask your constituents to write to you, or choose to work you in another way.
e. When we use cookies
Cookies are a useful way for us to understand how supporters use our website and/or use MyTAI app. When you visit our web site or use MyTAI app we will collect data from your computer or other device such as a smart phone or tablet through the use of “cookies”. Cookies are created by your web browser when you visit our website. Every time you go back to the TAI website, your browser will send the cookie file back to the website’s server. They improve your experience of using our website, for example, by remembering your preference settings so that you are presented with information likely to be most relevant to you, and by measuring your use of the website to enable us to continuously improve our website to ensure that it meets your needs. Cookies can also be used to show you relevant TAI content on social media services such as Facebook – these are known as “retargeting’” or “advertising” cookies.
If you visit our website as an anonymous visitor (e.g. you switch off cookies), TAI may still collect certain information from your browser, such as the IP address (an IP address is a number that can uniquely identify a computer or other internet device).
In instances where our website contains hyperlinks to other websites owned and operated by other organisations (for example the BBC, research organisations and think tanks, our partners, other related charities and TAI affiliates in other countries), we urge you to review their privacy policies as they will govern the use of personal information you submit or which is collected by cookies whilst visiting these websites. We cannot accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
We only collect personal data relevant to the type of transactions or interaction you have with TAI.
Whatever your interaction with us this information will be minimal and linked to the purpose for which we need it.
For example, when you contact TAI to make a donation or purchase an item online, we may receive and retain personal information.
In these cases we are likely to process details such as your name, email address, postal address, telephone or mobile number, bank account details to process donations and whether or not you are a tax payer so that we can claim gifts and donations.
If you participate in an event we may (with your permission) take your photograph or video, or interview you.
If you participate in market research, we may ask you questions regarding your experience with us, or other survey questions relating to your experience.
If you are a campaigner or work with our campaigns team, we may collect information such as correspondence with you regarding campaigning, details of your background and activities with us or relating to the issue, the events you attend, or how we would like to work with you.
Where we gather information about you which is publicly available – for instance as a major donor or your views on our campaigning activity – this may include your name, contact details, views and positions you have expressed, and details regarding your circumstances – for instance which political roles you hold or what your background is.
Sensitive Personal Data
We only collect “sensitive personal data” about our supporters, e.g. health status, where there is a clear and specific reason for doing so, such as participation in a marathon or volunteering at a music event or TAI events.
We collect this data where we need it to ensure that we provide appropriate facilities or support to enable you to participate in the event or carry out your role. Clear notices will be provided on application forms so that it is clear what information we need and why we need it. In certain circumstances, such as when we recruit volunteer festival stewards, we need to obtain information about criminal convictions (where these are unspent) in order to check that it is appropriate for you to undertake the role.
If you apply for a role with us, we may collect this data for equality monitoring. Further details regarding this are outlined in our recruitment privacy policy.
Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this we will do it carefully and in accordance with applicable laws.
Should you support TAI in a substantial way, we may provide an account manager to help you tailor your relationship to suit your interests. If this is the case we may collect sensitive personal data where relevant to our relationship, such as your political or religious views. Should you disclose information to us about your health or your family, this may also be recorded, so that we can communicate with you in a considerate and appropriate manner.
All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.
TAI will use your personal information for the following purposes:
a. For administrative reasons, including:
o “service administration”, which means that TAI may contact you for reasons related to administering any donations you have made, your tax status with regard to Gift Aid if claimed, the completion of commercial or other transactions you have entered into with TAI or the activity or online content you have signed up for;
o to confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used. for example if you donate via text you will receive a “bounce back” text message;
o in relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide;
o for internal record keeping so as to keep a record of your relationship with us;
o to fulfil sales contracts you have entered into with TAI, such as the Tag Your Bag (Gift Aid) scheme, under which we are required to notify you of the proceeds from sale of items you have donated to TAI shops;
o to provide logistical and fundraising information to people who are taking part in a fundraising event in aid of TAI, such as the TAI awards events, or Marathons;
o to communicate with TAI volunteers – to support you in your designated role or administer that role and our organisation;
o to keep your data up to date – for instance we use the Royal Mail’s data on postal address changes to ensure that we can maintain contact with you where we believe you are happy to be contacted by post, we also use services which notify us of the recently deceased to avoid any distress that continued communications would cause;
o to implement any instructions you give us to with regard to withdrawing consent to send marketing information or informing us through the Fundraising Preference Service that you do not wish to receive any marketing information;
o to use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries;
o to protect our staff and those with whom we work, or to prevent crime and dishonesty.
b. For marketing and fundraising reasons (see ‘When and why we will send you personalised marketing communications’).
c. For market research
o to invite you to participate in surveys or research about TAI or our work (participation is always voluntary);
o to analyse and improve the activities and content offered by the TAI website to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
We will only use your information within TAI for the purposes for which it was obtained. TAI will not, under any circumstances, share or sell your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.
TAI’s suppliers
We may need to share your information with service providers who help us to deliver our projects, fundraising activities and appeals, for instance through handling responses to our emergency appeals. These “data processors” will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
Facebook and other Social Media Sites
We may also use your email address and phone number to match to your account on Facebook or other social media sites in order to show you TAI content while using these services. We only do this where you have opted in to marketing emails or phone calls and we keep your data secure by encrypting it. No data we hold about you is retained by the third party.
In addition, we may also use your email address and phone number to link to Facebook or other social media sites in order to identify other users of these sites whom we believe would be interested in TAI, and we may then show them TAI content. No data we hold about you is retained by the third party.
There are two ways to prevent this use of your data, you can either update your preferences at TAI by opting out of the relevant channel of communication or you can do this via the social media site:
Facebook: https://www.facebook.com/help/568137493302217
LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931
Twitter: https://business.twitter.com/en/help/troubleshooting/how-twitter-ads-work.html
Updating your preferences with TAI will not guarantee that you never see TAI content on social media, since the social media site may select you based on other criteria and without your data having been provided by TAI.
Where legally required
We will also comply with legal requests where disclosure is required or permitted by law (for example to government bodies, statutory bodies, or law enforcement agencies for tax purposes, where it is in the public interest, or the prevention and detection of crime, subject to appropriate protection in law).
TAI may transfer your personal data outside the EEA. If it does so, this may occur under the protections of the European Commission’s standard contractual clauses, but will otherwise only take place where appropriate standards and safeguards are in place.
We will hold your personal information on our systems for as long as is necessary for the relevant activity, for example we will keep a record of donations subject to gift aid for at least seven years to comply with HMRC rules.
If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.
Legacy income is vital to the running of the charity. We may keep data you provide to us indefinitely, to carry out legacy administration and communicate effectively with the families of people leaving us legacies. This also enables us to identify and analyse the source of legacy income we receive.
Where you contribute material to us, e.g. user generated content or in response to a particular campaign, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest.
If you wish to change how we communicate with you, or update the information we hold, then please contact us:
o email us using our web form
o write to us at: 159 Great North Road, Aberdeen. AB24 3QH
o Log into your TAI or Rollwinabc.com account using details you have been provided and amend or delete your account/details.
Additionally you can opt out of email separately:
o Email – You can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from TAI.
How long will it take for these changes to be effective?
We endeavour to meet the following service levels where supporters request we do not send them marketing information:
o Email – 24 hours from receipt of email
o Telephone – 24 hours from receipt of request to opt out
o Mail – 28 days from receipt of ‘do not mail’ request. This period is longer than for other channels due to the production times for mailing campaigns, and in most cases we would expect the change to be effective much more quickly.
o Web forms- you may also use our web forms to contact us about any information we hold against your details or any amendments you are happy to make to information held against you in our databases.
Should you request we stop marketing to you by completing our preferences web page, it may take up to 10 days to complete your request due to the manual nature of this process.
We ensure that there are appropriate technical controls in place to protect your personal details. For example our online forms are always encrypted and our network is protected and routinely monitored.
We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.
We use external companies to collect or process personal data on our behalf. We do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect on our behalf, or have access to. We have a robust partner monitoring framework to ensure these contractual obligations are met.
These organisations – referred to as “Data Processors” also have legal liability for the way in which your data is used, providing you with additional protection.
The information collected includes those volunteered by you and those relating to activities you carried out while visiting our website. This information is collected to help us know more about you, help us to send you solicited information about TAI, to help us better understand how our services are used and to help us further develop our services.
You have a variety of rights in respect of your data, including the rights to see, update, restrict, object to the use of or withdraw use of your data. In particular, depending upon why we hold your data, you may have the right to request:
o Access to the personal data we hold about you, including how we first obtained your details, free of charge in most cases (this is known as a ‘Subject Access Request’).
o The correction of your personal data when incorrect, out of date or incomplete.
o That we stop using your personal data for direct marketing (either through specific channels, or all channels).
o That we delete your personal data from our systems (this is known as the “Right to be Forgotten”).
o That we no longer process your data automatically to decide whether particular marketing activities are likely to be of interest, or suggest an appropriate donation level based on your previous donation history. This is known as profiling, and helps us to ensure that our marketing is relevant and appropriate.
You can contact us to request to exercise these rights at any time.
Opting out of Direct marketing
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request.
Where we are sending you direct marketing on the basis of our legitimate interest, you can also ask us to stop. In the case of postal marketing sent on this basis, we will always comply with your request to opt out. Similarly, where we send email marketing on a soft opt in basis (see ‘How and when we collect information about you’), we will also comply with all requests to opt out.
Right to be Forgotten
Upon request we will delete your personal data from our systems, to the extent that we are permitted to by law or regulatory guidelines. For instance under HMRC rules we are required to retain financial data for 7 years for audit purposes, and so will not be able to delete donation details until this time period has elapsed.
Opting out of profiling
Upon request we will cease using your personal data to decide whether you would be interested in particular updates and other marketing. Such requests may lead to you not hearing from us in future.
Subject Access Requests
You have the right to request a copy of the personal information we hold about you. We will provide this as soon as possible, and within a month unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
If you would like more information, to update your details or have any questions about this policy, please contact us by email using our web form or write to us at: 159 Great North Road, Aberdeen. AB24 3QH.
To make a formal complaint about TAI’s approach to data protection or raise privacy concerns directly with our data protection team, please contact:
The Data Protection Officer
159 Great North Road, Aberdeen. AB24 3QH
Email: using our web form and with the heading “data protection”.
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 +44(0)303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites).
This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to TAI. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use the TAI website to submit personal information to TAI. If material changes are made to the Privacy Policy we will notify you by placing a prominent notice on the website.
Q. Does TAI obtain data from other organisations?
A. TAI may receives data from a limited number of Third Parties, including:
o CACI Ltd – who provide summarised data at postcode level (this is typically 16 houses). This includes data such as age, income, house type, and the ages of children in the household. We use this information to decide who to target for our marketing campaigns, so as to improve the effectiveness of our fundraising, and to ensure we do not send out marketing information which is unlikely to be of relevance.
o UK changes – who provide data on house movers and the deceased so that we can keep our records up to date and make sure we only send marketing materials where appropriate. This data is only obtained where it is consistent with current data protection laws and TAI’s Fundraising Policy, and where you have given permission for it to be shared for this purpose.
o Publicly available sources such as Twitter, Facebook, LinkedIn, parliamentary records, or statements which you make publicly, depending upon our relationship with you – in particular we are likely to collect these in connection with our campaigning activities
o From the following suppression services;
§ The Mail Preference Service (MPS), which ensures we do not send unsolicited mail to those who have indicated they do not wish to receive it.
§ The Telephone Preference Service (TPS), which ensures we do not telephone people who do not wish to receive unsolicited phone calls.
§ The Fundraising Preference Service (FPS), which ensures we do not send unsolicited marketing material to people who have indicated that they do not wish to hear from TAI.
Q. Does TAI use profiling as part of its marketing campaigns?
A. How we target our marketing campaigns (profiling)
Profiling is a common technique used in direct marketing and involves analysing data to improve the targeting of communications. TAI uses profiling techniques to help ensure our communications are relevant. Profiling allows us to target our resources effectively, which donors consistently tell us is a key priority for them. It enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would. The data may have been provided to TAI by our supporters when responding to our marketing campaigns, or when using our website, or social media sites such as Facebook. It may also have been provided by external organisations as described below.
When building a profile we may analyse geographic, demographic and other information relating to you, as well as your previous responses to our marketing campaigns. We do this in order to determine whether we believe a particular marketing campaign might be of interest. Some of the data is provided by external organisations and may be provided at an aggregate level (e.g. by postcode). Where it relates to you as an individual we check that you have provided your express consent to the relevant third party for this use of your data. This helps to maximise the effectiveness of our campaigns and to minimise the wastage that would result from sending marketing information where it is not of interest. You have the right to request we cease this profiling, for details see ‘Your rights over your personal data’.
This page was last updated on 24/05/2018