Privacy policy

Freedom from Torture is committed to safeguarding your privacy. The collection and use of personal data by us is in accordance with the applicable data protection laws, including the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulation 2003.

This privacy policy applies to our processing of your personal data, including when you support us or when you request information from us.

Please read the following policy to understand how your personal data will be treated. This privacy policy was last updated on 18th January 2024 and may change from time to time so please check back periodically.

Who are we?

Freedom from Torture ("we" or "us") is the controller, and we are responsible for your personal data.

We are a registered charity in England (charity number: 1000340) and Scotland (charity number: SC039632), at 111 Isledon Road, London, N7 7JW.

We are also registered with the Information Commissioner’s Office as a controller under reference Z917933X for our processing activities.

If you have any queries about this privacy policy, please get in touch with us via our Contact us page.

Who do we collect data from?

Visitors to our website

When you access our website, we collect information about your computer, including, where available:

Your IP address
Operating system
Browser type
Demographic data

We do this for system administration purposes, including to analyse trends and gather broad information for aggregate use so that we can improve the site, understand campaign and marketing performance and ensure you have the best possible website experience.

Once we collect this information, we use it in aggregate form such that it would not identify you.

Like most websites, we also use “cookies” for the above and to carry out targeted advertising to you on third party websites. Please refer to our dedicated cookies page for more information.

Job and volunteer applicants

If you volunteer for us or apply for a job with us, we collect information including:

your personal information such as your age, nationality and ethnicity,
your employment details such as your employment status, previous experience depending on the context, as well as any unspent criminal convictions or pending court cases you may have), and
any other personal information you provide to us.

We collect this information as it is necessary for us to process your application, assess your suitability and for monitoring purposes.

For more information, read our separate Job applicant privacy notice.

The people we support

We collect certain personal information about the people we support. This includes:

Religion
Nationality
Ethnicity
Health
Legal status

This data is limited to such data as we require in order to provide you with our services or where you have given us your consent to collecting data. All personal data is kept in line with our data protection and confidentiality policies. Alternatively, it is anonymised for research and policy purposes where consent is given. We don’t pass on your data to a third party unless it is in your best interests.

For a copy of our policies, please get in touch with us via our Contact us page.

Supporters

We generally collect your personal data directly from you, for example when you make a donation, sign up for email updates, purchase something from our shop, open or click our emails, sign up for an event, ask us about training or otherwise communicate with us. This information is likely to include your name and contact details (including postal address, telephone number, email address) as well as other information such as (but not limited to):

your bank or credit card information where you provide these to make a payment,
the reason for donating,
information about events, activities and products which we consider to be of interest to you,
information as to whether you are a taxpayer to enable us to claim Gift Aid,
your date of birth when registering for a challenge event,
your gender when registering for a challenge event,
information relating to your health (solely for health and safety purposes, for example if you are taking part in or attending an event),
where you have left us a legacy, any information regarding next of kin which you may have provided us with to administer this, and
any other personal information you provide to us, including for the purposes outlined in the previous sections.

Third Parties

Freedom from Torture uses third party platforms for specific purposes such as petition sites, email platforms and donation processing platforms.

In all instance these platforms will collect and process your personal information for a specific reason:

A petition platform will gather data such as your name, address and email address when you sign up to a petition
A donations platform will collect data such as your name, address, email address and payment details to process your donation correctly
An email platform is used to send emails on behalf of Freedom from Torture about the work we do, work which you help to fund

Freedom from Torture also uses data held on social media platforms, such as reporting and data tools to:

Create anonymous audiences which may be used to target posts, campaigns and appeals
Analyse and optimise the performance of posts, campaigns and appeals
Ensure marketing budget is spent effectively

Data held on social media platforms is governed by the data policy of that platform and not that of Freedom from Torture. To access these policies, follow the relevant link:

Like most websites, third party platforms and social media sites use “cookies”. Please refer to their cookie policy when using them.

Public Sources

We, or our trusted service providers, may use existing data from Freedom from Torture's own database and combine this with information from publicly available sources, so that we can tailor our communications to you.

For more information, please see our section Building profiles of supporters below.

Special category data

Certain types of personal information are in a special category under data protection laws, as they are considered to be more sensitive. Examples of this would be information about health, race, ethnicity, religious beliefs, political views.

We only collect this type of information where there is a clear reason for us to do so, for example asking for health information if you are taking part in a sporting event, or where we ask for information for the purpose of providing appropriate facilities or support.

How does Freedom from Torture use your information?

We may use your information to:

provide you with the services, products or information you asked for,
respond to or fulfil any request, complaints or queries you make to us,
send you correspondence and communicate with you,
personalise our communications eg pre-filling forms on our website when you have already provided this at an earlier time, in order to improve your experience on our website,
help with reporting to improve our fundraising and communications and for improving our website,
keep a record of your relationship with us,
manage our events,
further our charitable objectives,
conduct due diligence and ethical screening,
carry out fraud prevention and money laundering checks,
process your application for a job or a volunteering position,
audit and administer our accounts,
meet our legal obligations, and
invite you to participate in surveys or research.

Administration

Please note that regardless of communication preferences, we may still contact you for administration purposes. This could include updating your Gift Aid information or updating other personal data related to your donation(s).

Appeals and Updates

If you are an active Freedom from Torture supporter or have indicated that you are interested in receiving regular information, we may send you regular communications, including fundraising, by email, post and/or phone, in accordance with your marketing preferences, for example to tell you about the difference you are making through regular updates and newsletters, or to give you the opportunity to take part in our appeals, campaigns and events.

If you no longer wish to receive marketing communications from us, you may:

Contact us via our Contact us page; or
Click on the unsubscribe link on any digital marketing communication that you receive from us.

Building profiles of supporters so we can tailor our communications

At Freedom from Torture, our work is only made possible thanks to the generosity of our supporters. It’s vital that our fundraising efforts are as effective and cost efficient as they can be, so we sometimes conduct research, through publicly available sources, to better tailor our communications to our supporters. This allows us to send information on events, areas of our work, volunteering opportunities and campaigns that are most likely to be of interest. It also reduces the risk of someone receiving information that they might find irrelevant, intrusive or even distressing.

After taking a supporter’s preferences into account, we, or our trusted service providers, may use information we hold on such supporters to research their potential to be a significant donor to Freedom from Torture and collect additional details relating to their employment and any philanthropic activity. This might also include estimating their gift capacity, based on their visible assets, history of charitable giving and how connected they are to Freedom from Torture.

We only use reputable sources, where someone would expect their information may be read by the public such as charity websites and annual reviews, corporate websites, public social media accounts, the electoral register and Companies House in order to create a fuller understanding of your interests and support of Freedom from Torture.

We avoid any data that we believe has not been lawfully or ethically obtained, and we do not use information sources which have not been broadcast or made public.

If you have opted to receive email communications from us, we will occasionally use your email address to identify you on the third party websites such as AdRoll, Google, Facebook and Twitter, which enables us to monitor public social media updates about us, target promoted posts to you and target new audiences based on aggregate profiling of our existing supporters.

We’re committed to putting you in control of your data and you’re free at any time to opt out from this activity. To find out more, please get in touch with us via our Contact us page.

What legal conditions do we rely on for processing your personal data?

There are a number of different ways that we are lawfully able to process your personal data. We have set these out below.

Where using your data is in our legitimate interests

We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.

We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:

keeping a record of people who are interested in our cause and may wish to donate in the future,
protecting our business and physical and digital assets,
developing and growing our supporter base,
informing and developing our fundraising strategy, and
enabling us to communicate with you directly.

We will use your data on the basis of legitimate interests only if you have engaged with us positively and not objected to or opted out of us using your data.

Positive engagement includes:

making a donation or payment,
taking a campaign action on our behalf, such as signing a petition or emailing an MP,
registering for an event,
informing us of new contact details, and
requesting a certain type of communication.

Where you give us your consent to use your personal data

As part of our relationship with you, we may ask you for specific consents to allow us to use your data in certain ways. If we require your consent, we will provide you with sufficient information so that you can decide whether or not you wish to consent.

For example, we ask for your consent to email, phone or text you for communication and fundraising purposes.

You have the right to withdraw your consent at any time. Please get in touch with us via our Contact us page if you wish to change or withdraw consent. See also 'What are my rights?' below.

Where using your personal data is necessary for us to carry out our obligations under our contract with you

We are allowed to use your personal data when it is necessary to do so for the performance of our contract with you.

For example, we need to collect your contact details in order to be able to communicate with you and process your donations.

Where processing is necessary for us to carry out our legal obligations

As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we may therefore use your personal data when we need to in order to comply with those other legal obligations.

Who do we share your information with?

We may disclose your information to third party service providers who require access to such information for the purpose of providing specific services to us, such as those already mentioned above, and for the purpose of processing data for sending mailings, making calls or fulfilling orders. These third parties will only be able to access your information in order to provide us with their services and will not be able to use it for their own purposes.

The third parties we may share your personal information with include:

professional advisors (such as legal advisors and accountants) or auditors, for the purpose of providing professional services to us, and
Designers and printers of postal mailings
Agencies which process and send out orders of merchandise
Telemarketing agencies making calls on behalf of Freedom from Torture

We enter into contracts with these service providers that require them to comply with Data Protection Laws and ensure that they have appropriate controls in place to secure your information.

We will never sell your data to other organisations or charities.

Legal disclosure

We may disclose your information if required to do so by law (for example to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority), or in order to enforce our conditions of sale and other agreements.

Do we transfer your personal data overseas?

The data that we collect from you may be transferred to, and stored at, destinations both within and outside the UK and European Economic Area (EEA), for example, where we use a service provider that is located outside the UK and EEA.

We want to make sure that your personal data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the UK and EEA where it is compliant with the GDPR and the means of transfer provides adequate safeguards in relation to your data. For example, this could be:

by way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws,
by transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation, or
where you have explicitly consented to the data transfer.

Where we transfer your personal data outside the UK and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

How do we keep your data safe?

We will take all reasonable precautions necessary to protect your personal data from misuse, interference, loss, unauthorised access, modification or disclosure. For example, all information that you share via our website is secured with SSL technology (secure server software).

If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partners and have no direct access to your card details. We do this in accordance with industry standards and do not store the details on our website.

However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot guarantee the security of data disclosed or transmitted over public networks.

How long will we keep your personal data?

We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to keep it or if we require it to enforce our agreements.

When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems.

What are my rights?

Under data protection law, you have rights including:

Right of access - You have the right to ask us for confirmation of what personal information we process about you and for copies of your personal information.
Right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
Right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

If you make a request, we have one month to respond to you unless certain circumstances apply which we will notify you of in advance. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. We may require you to provide proof of your identity before complying with your request.

If you would like to make a request, please get in touch with us via our Contact us page.

Withdrawing consent

Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

Complaints

If you are unhappy with any aspect of how we are using your personal data, we would like to hear about it. Your feedback enables us to learn and improve. To make a complaint to Freedom from Torture please get in touch via our Contact us page.

You have the right to lodge a complaint with our regulator, who is the Information Commissioner's Office in the UK. You can make a complaint via https://ico.org.uk/make-a-complaint

Questions

If you have any questions regarding this privacy policy or its application, please visit our Contact us page.

Last updated: 18 January 2024