Guest Blogger 2 – Cian O’Donovan on Big Data
Cian is an activist, technologist and academic.
Campaign Bootcamp is committed to safeguarding the privacy of our website visitors. We believe you have the right to privacy on the web. This policy sets out how we will treat your personal information.
We update this notice from time to time. This was last updated 4th December 2020.
1. Purpose of this Notice
Campaign Bootcamp (“we” or “us”) takes the protection of your personal data seriously. This Privacy Notice explains how we use any personal information that you supply to us, or that might be collected from a third party, and sets out your rights in respect of our processing of your personal information. We process data in accordance with UK law which includes but is not limited to The Privacy, Data Protection and Electronic Communications Regulation (UK GDPR), The Privacy and Electronics Communications Regulation (PECR) and the Data Protection Act 2018. If you reside outside of the UK, other laws may be applicable.
In particular, this Notice explains:
1.1 the kinds of personal information we collect about you;
1.2 the means by which we obtain your personal information;
1.3 the ways in which we use your personal information;
1.4 the basis on which we use your personal information;
1.5 the length of time that we keep your personal information;
1.6 who we share your personal information with;
1.7 how we protect your personal information; and
1.8 where and why we transfer your personal information outside of the UK.
We may collect your personal data in your capacity as a volunteer, donor, applicant, purchaser from our online shop, participant in our events or training sessions, subscriber to our marketing lists, or because you are a subscriber or visitor to our website (https://campaignbootcamp.org) (the “Site”).
2. About Us
Campaign Bootcamp is the trading name of Campaign Academy Limited, a charitable company limited by guarantee. Campaign Academy Limited is a registered charity in England and Wales (charity number 1169639) and a registered company (company number 08390873). Our principal and registered address is 27 Dingley Place,London, EC1V 8BR,
United Kingdom., United Kingdom. As such we are a Data Controller in accordance with the UK GDPR and are registered as such with the Information Commissioner’s Office.
Campaign Bootcamp is a charity whose main purpose is to educate and support campaigners, including by delivering training sessions to them.
3. How to Contact Us
If you have any questions about this Notice or want to exercise your privacy rights, please contact us by:
• sending an e-mail to [email protected]; or
• writing to us at Privacy Enquiries, Campaign Bootcamp, 27 Dingley Place,London,
EC1V 8BR, United Kingdom.
4. How We Collect Your Personal Information
We may collect your personal information in the following ways:
4.1 When you give it to us directly You may give us your personal data directly in various ways, for example when you apply to attend one of our events, when you interact with us on social media, when you apply for employment with us, when you apply to volunteer with us, when you contact us by phone, email or post or when you donate money to us.
4.2 When we receive your information indirectly your information may be shared with us by third parties, for example independent event organisers, other fundraising entities, sponsors and supporters of our organisation and services. Your information may also be provided to us when you follow us or otherwise interact with us on or via Twitter, when you like and/or join our page on Facebook or interact with us in other ways on or via Facebook.
4.3 When you give permission to other organisations to share it with us or if you have made it publicly. We may combine information you provide to us with information available from external publicly available sources. We use this information to gain a better understanding of you and to improve our communications and fundraising activities but only where this is not considered to be intrusive.
5. The Information We Process
We may process the following kinds of personal data:
5.1 your name and contact details, including physical address, telephone number and e-mail address, and social media identity;
5.2 financial information, such as payment-related information, including bank details or debit/credit card details;
5.3 personal information we receive in the course of providing services to you, including details of why you have decided to contact us/apply to one of our events, details of trainings you have attended, details of topics/areas of interest to you, responses to surveys you have completed;
5.4 technical information, including information about your visits to and use of our Site and the device you used to access the Site, your IP address, geographical location, browser type, referral source, length of visit and number of page views;
5.5 marketing information, including information about the services you use, services and products of interest to you or any marketing and/or communication preferences you give; and/or any other information shared with us as per paragraph 1 above.
We may process the following kinds of special category data:
5.6 your ethnic origin;
5.7 details of any dietary requirements;
5.8 details of any disability or access requirements;
5.9 although we do not routinely process data relating to health in addition to the disability and access requirements data mentioned above, we may process data relating to health, including mental health, if you disclose this information to us and either you have given us your explicit consent to process it or we consider that it is necessary to process it in order to protect your vital interests; we have a separate Safeguarding Policy for the protection of vulnerable persons.
6. How and Why We Use Your Personal Data
We may use your personal information to:
6.1 Advance our charitable objects of providing (a) education; and (b) citizenship, in particular (but without limitation) by providing training designed to improve individuals’ knowledge of and capacity to participate in and engage with public affairs and political processes in democratic societies; and to undertake such other purposes as are exclusively charitable in English law.
6.2 Manage and administer our relationship with you, including providing you with services and information you have requested;
(3) Market our services, including sending you information about our work, trainings, organisation and any other information, products or services that we provide;
6.3 Administer our Site, including monitoring its use;
6.4 Administer payments;
6.5 Administer your employment and/or volunteering application;
6.6 Conduct research and data analysis into the impact of our trainings;
6.7 Deal with enquiries and complaints made by or about you relating to the Site or us in general;
6.8 Audit and/or administer our accounts;
6.9 Conduct supporter research and profiling;
6.10 Manage individuals’ preferences, including administering suppression files;
6.11 Administer security requirements, including data and systems security;
(13) Conduct financial management and control;
6.12 Meet any of our legal, regulatory and risk management obligations.
Using our services
If you apply to join one of our Bootcamps or a local training programme, then we will process your personal information in order to consider your application and, if successful, provide that service to you.
We may use your personal information to undertake research to gather further information about you from publicly accessible sources. This helps us gain a better understanding of your background, interests and preferences, in order to improve our communications and/or interactions with you, to help ensure they are targeted to be relevant and appropriate, and to provide information about trainings and other aspects of our services which we consider may be of interest to you.
Where you have provided us with your physical address, we will contact you by post and where you have provided appropriate consent, also by email, with targeted marketing communications to let you know about our events and/or activities that we consider may be of particular interest, about the work of the company and to ask for donations or other support.
We may use some of your personal information to participate in Facebook’s Custom Audience and Lookalike Audience programs, which enable us to display adverts to both existing and prospective supporters when they visit Facebook. We may provide your email address to Facebook so that Facebook can determine whether you are a registered account holder. Our adverts may then appear when you access Facebook. For more detailed information please see https://www.facebook.com/business/help/744354708981227 and Facebook’s data policy at https://en-gb.facebook.com/policy.php.
Using our Site
When you use our Site, you may be asked to provide us with personal information. When you provide us with personal information in this way, we only use it for the purposes stated to you at the time we collect the information.
7. Lawful Basis for Processing your Personal Information
We are required to have one or more lawful grounds to process your personal information. We use your personal information on the following bases:
7.1 Personal information is processed on the basis of a data subject’s consent
7.2 Personal information is processed on the basis of a contractual relationship
7.3 Personal information is processed on the basis of legal obligations
7.4 Personal information is processed on the basis of legitimate interests
We will ask for your consent to use your information to send you electronic communications such as newsletters and marketing and fundraising emails, for targeted advertising, and if you ever share special category data with us.
7.6 Contractual relationships
Most of our interactions with subscribers and website users are voluntary and not contractual. However, sometimes it will be necessary to process personal information so that we can enter contractual relationships with people. For example, if you apply for employment or to volunteer with us.
7.7 Legal obligations
Sometimes we will be obliged to process your personal information due to legal obligations which are binding on us. We will only ever do so when strictly necessary.
7.8 Legitimate interests
Applicable law allows personal information to be collected and used if it is reasonably necessary for our legitimate activities (as long as its use is fair, balanced and does not unduly impact individuals’ rights).
7.9 We will rely on this ground for processing the data of all applicants and attendees of our programs, managing our fundraising activities and promoting our programs to relevant organisations, where their information is publicly accessible.
7.10 Where we have relied upon your consent as the ground for lawful processing, you are entitled to withdraw your consent at any time, and such withdrawal of consent will not undermine the lawfulness of processing based upon consent prior to the withdrawal.
7.11 Where we have relied upon legitimate interests as the ground for lawful processing, you are entitled to object to our processing on this ground.
7.12 We may use a combination of these lawful grounds for processing your data but not for the same purposes.
In you wish to exercise either of these rights, then please contact us as directed in Section 15 of this Policy.
8. Children’s Data
Our services are not aimed at children and we do not knowingly process data of any person under the age of 16. If we come to discover, or have reason to believe, that you are 15 and under and we are holding your personal information, we will delete that information within a reasonable period and withhold our services accordingly.
9. Security of and Access to Your Personal Data
We have in place appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure of or access to your personal information.
Your information is only accessible by appropriately trained staff, volunteers and contractors and we provide training on the protection of personal data.
We may transfer and/or store personal data collected from you to and/or at a destination outside the European Economic Area (“EEA”). Such personal data may be processed by agencies and/or suppliers operating outside the EEA, where the standard of protection for personal data may be lower than in the EEA, including lower security requirements and fewer rights for individuals. If we transfer and/or store your personal data outside the EEA we will take reasonable steps to ensure that the recipient of your data implements appropriate measures to protect your personal data. Such measure may include but are not limited to EU Standard Contractual Clauses. However, such safeguards will only be implemented on a case by case basis.
10. Your Rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for direct marketing purposes or to be unsubscribed from our email list at any time. You also have the following broad rights but please note that they only apply in certain circumstances:
10.1 Right to be informed – you have the right to be told how your personal information will be used. This Policy and other policies and statements used on our website and in our communications are intended to provide you with a clear and transparent description of how your personal information may be used.
10.2 Right of access – you can write to us to ask for confirmation of what information we hold on you and to request a copy of that information. Provided we are satisfied that you are entitled to see the information requested and we have successfully confirmed your identity, we have 40 days to comply. We will have one month to comply (although those time limit may be extended in certain circumstances).
10.3 Right of erasure – You may ask us for your personal information to be deleted from our records in certain circumstances.
10.4 Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated.
10.5 Right to restrict processing – you have the right to ask for processing of your personal data to be restricted in limited circumstances, including if you dispute its accuracy or while an objection to processing on the ground of legitimate interests is under investigation.
10.6 Right to data portability – in certain circumstances, you have the right to ask us to provide data you have sent to us to another service provider in a machine-readable format.
10.7 Right to object to processing – you have an absolute right to object to processing for direct marketing purposes and a qualified right to object to processing in certain other circumstances, for example on the ground of legitimate interests. In order to unsubscribe from email marketing, please use the following link: [please insert link].
To exercise any of the above rights, please contact us using the details in section 15 below. For further information on your rights as a data subject, we suggest that you consult the guidance of the Commissioner’s Office (ICO) – https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
Finally, you are further entitled to make a complaint to the ICO about us or the way we have processed your personal data. For further information on how to exercise this right, please see the guidance at https://ico.org.uk/for-the-public/personal-information. The contact details of the ICO can be found here: https://ico.org.uk/global/contact-us/.
12. Data Retention
We keep your personal information only for as long as is necessary for our purposes. In considering how long to keep it, we will take into account of its relevance to our business and our legal and regulatory obligations.
13. Policy Amendments
14. Third Party Websites
15. Contacting Us
You may contact us with any privacy concerns – including to update your information or exercise your rights as a data subject – by emailing us at [email protected]