1.1 We, the Alfayed Charitable Foundation (with ‘ACF‘, ‘we‘, ‘our‘ or ‘us‘ being interpreted accordingly), are committed to protecting your privacy and personal information. Personal information relating to you from which you can be identified that we collect or which you provide is called personal data (‘Personal Data‘).
What Personal Data do we collect and use?
3.1 The Personal Data about you that we collect and use may include your name, address, phone and other contact details, photographs of you, your employer and/or job role, quotes from you regarding how The ACF may have helped you, a family member or your organisation, as well as any other Personal Data that you may provide to us from time to time.
How your Personal Data is collected
4.1 We collect Personal Data about you in various ways as follows:
- through your relationship and communications with us with us, for example, if you contact us to find out more about our work or how to make a funding application, or submit a funding application to us;
(b) through applications received from organisations on your behalf, from organisations of which you are a staff member, volunteer or beneficiary;
(c) from organisations to which we have donated; and
(d) from publicly accessible sources, such as your professional profile on LinkedIn.
4.2 Please also note that some of the Personal Data you supply and that we process may include what is known as ‘sensitive’ data about you, for example, information regarding your health, ethnicity, religious beliefs or sexual orientation.
Information about third parties
5.1 Please ensure that any Personal Data you supply to us which relates to third party individuals is provided to us with their knowledge of our proposed use of their Personal Data.
What we use your Personal Data for
Other than as stated above, we may use your Personal Data for one or more of the following purposes:
(a) to promote the work that we do, including by displaying photographs and information on our website;
(b) to perform identity verification and background checks;
(c) to detect and prevent fraud;
(d) to review and evaluate applications, and communicate with representatives of applicants;
(e) to keep and administer our records;
(f) to manage our staff and accounts;
(g) to enforce and/or defend any of our legal claims or rights; and/or
(h) for any other purpose required by applicable law, regulation, the order of any court or regulatory authority.
The lawful grounds on which we collect and process your Personal Data
7.1 We process your Personal Data for the above purposes relying on one or more of the following lawful grounds:
(a) where you have freely provided your specific, informed and unambiguous consent for particular purposes;
(b) where we agree to provide product(s) and/or services to you, in order to take any pre-contract steps at your request and/or to perform our contractual obligations to you;
(c) where we need to use your Personal Data for legitimate purposes relevant to us being able to promote The ACF and/or publicise our work, evaluate and improve our activities and operations, continue to operate day-to-day, to comply with our legal and regulatory obligations and to monitor such compliance. We will always seek to pursue these legitimate interests in a way that does not unduly infringe on your other legal rights and freedoms and, in particular, your right of privacy;
(d) where we need to protect your vital interests or those of someone else (such as in a medical emergency) and/or
(e) where we need to collect, process or hold your Personal Data to comply with a legal obligation.
7.2 If we process sensitive data as referred to under paragraph 5 we will only do this with your explicit consent, to protect your vital interests (or those of someone else) in an emergency, where you have already publicised such information or, where we need to use such sensitive data in connection with a legal claim that we have or may be subject to.
Our Legal Obligations regarding your data
8.1 We collect and process your Personal Data in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018 together with other applicable UK and EU laws that regulate the collection, processing and privacy of your Personal Data (together, ‘Data Protection Law‘).
Disclosing your Personal Data to third parties
9.1 We may need to disclose your Personal Data to certain third party organisations who are handling that data only on our behalf and in accordance with our instructions under contract e.g. our website hosting provider and Experian. We will make sure that they act only in accordance with our instructions and that adequate safeguards are put in place by them to protect your Personal Data.
9.2 Other than as described above, we will treat your Personal Data as private and will not disclose your Personal Data to third parties without you knowing about it. The exception is in relation to legal proceedings or where we are legally required to do so and cannot tell you.
9.3 In all cases we always aim to ensure that your Personal Data is only used by third parties for lawful purposes and in compliance applicable Data Protection Law.
10.1 In order to provide its service to us, our website hosting provider may transfer your Personal Data to the United States which is a territory outside the European Union whose laws are currently not considered to meet the same legal standards of protection for Personal Data as set out under Data Protection Law.
10.2 However, in order to safeguard your Personal Data, such a transfer will be made under a contract or another appropriate mechanism which is authorised under Data Protection Law. This is to make sure that your Personal Data is safeguarded in accordance with the same legal standards that apply to us in the United Kingdom.
How long we retain your Personal Data for
11.1 We only retain Personal Data identifying you for as long as you have a relationship with us; or as necessary to perform our obligations to you (or to enforce or defend contract claims); or as is required by applicable law.
11.2 The criteria we use for determining how long we retain your Personal Data is based on various legislative requirements; the purpose for which we hold data; and guidance issued by relevant regulatory authorities including but not limited to the UK Information Commissioner’s Office (ICO).
11.3 Personal Data we no longer need is securely disposed of and/or anonymised so you can no longer be identified from it.
Security that we use to protect Personal Data
12.1 We employ appropriate technical and organisational security measures to protect your Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.
12.2 We also endeavour to take all reasonable steps to protect Personal Data from external threats such as malicious software or hacking. However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of all data sent to us (including Personal Data).
Your personal data rights
13.1 In accordance with your legal rights under applicable law, you have a ‘subject access request’ right under which can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to as well as certain other information. Usually we will have a month to respond to such a subject access request. We reserve the right to verify your identity if you make such a subject access request and we may, in case of complex requests, require a further two months to respond. We may also charge for administrative time in dealing with any manifestly unreasonable or excessive requests for access. We may also require further information to locate the specific information you seek before we can respond in full and apply certain legal exemptions when responding to your request.
13.2 Under Data Protection Law you also have the following rights, which are exercisable by making a request to us in writing:
(a) that we correct Personal Data that we hold about you which is inaccurate or incomplete;
(b) that we erase your Personal Data without undue delay if we no longer need to hold or process it;
(c) to object to any automated processing (if applicable) that we carry out in relation to your Personal Data;
(d) to object to our use of your Personal Data for direct marketing;
(e) to object and/or to restrict the use of your Personal Data for purposes other than those set out above unless we have a legitimate reason for continuing to use it; or
(f) that we transfer Personal Data to another party where the Personal Data has been collected with your consent or is being used to perform contact with you and is being carries out by automated means.
13.3 All of these requests may be forwarded on to a third party provider who is involved in the processing of your Personal Data on our behalf.
13.4 If you would like to exercise any of the rights set out above, please contact us at the address below.
13.5 If you make a request and are not satisfied with our response, or believe that we are illegally processing your Personal Data, you have the right to complain to the Information Commissioner’s Office (ICO) – see https://ico.org.uk/make-a-complaint/.