Privacy Policy
We update this notice from time to time. This was
last updated 21st June 2022.
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 an employee, 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”).
This Privacy Notice is intended to assist you in making informed decisions
about your personal data. Please take a moment to read and understand it.
Please note that it should be read in conjunction with our Website Terms of
Use.
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. 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 contact@civicpower.org.uk; 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 or take up 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. Where your personal data has been collected
for the purposes of reporting on the goals and culture of the organisation we
may share with interested parties and with the public.
4.3 When you give permission to other organisations to share it with us or if
you have made it public. 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.
4.4 When you visit our website, we use cookies when you visit our website,
which may record personal information about you. Please refer to our Cookies
Policy for details on the way we use cookies. We will ask you for your consent
to use cookies, you are not obliged give us your consent. Your consent is not a
precondition for using our website. (see https://campaignbootcamp.org/cookie-policy/).
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 personal data
relating to members of staff is collected and processed to comply with legal,
regulatory and corporate governance requirements related to the employment
relationship and for the process of reporting on our culture and lessons
learned;
5.5 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;
5.6 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.
5.7
We may process your personal data for the purposes
of any proposed restructuring of any part of our business (including
liquidation).
5.8 We may process special category data
including your ethnic origin, details of any dietary requirements, details of
any disability or access requirements. 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 To administer our employment relationship with
you including making arrangements for the end of our working relationship with
you, and reflecting on our practices and experiences.
6.3 Manage and administer our relationship with you, including providing you
with services and information you have requested;
6.4 Market our services, including sending you information about our work,
trainings, organisation and any other information, products or services that we
provide;
6.5 Administer our Site, including monitoring its use;
6.6 Administer payments;
6.7 Administer your employment and/or volunteering application and your
employment or the end of your employment with us;
6.8 Conduct research and data analysis into the impact of our trainings;
6.9 Deal with enquiries and complaints made by or about you relating to the
Site or us in general;
6.10 Audit and/or administer our accounts;
6.11 Conduct supporter research and profiling;
6.12 Manage individuals’ preferences, including administering suppression
files;
6.13 Administer security requirements, including data and systems security;
6.14 Conduct financial management and control;
6.15 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.
Supporter/research profiling
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.
Marketing
Marketing methods
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.
Facebook marketing
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.
We also use cookies on our Site, which may collect
your personal information. For example, we may use Google Analytics to review
some of your personal information, in order to analyse our digital performance,
record how you are using our Site and/or assess the popularity of marketing
campaigns. This helps us improve our Site. For more information on how we use
cookies, please view our cookie policy by clicking this link
https://campaignbootcamp.org/cookie-policy/ .
Payments
Financial transactions carried out on our website
are handled through Stripe, Inc. (“Stripe”) and Go Cardless, third party
payment services providers. We recommend that you read Stripe’s privacy policy
and Go Cardless’ privacy policy (available at https://stripe.com/gb/privacy and
https://gocardless.com/legal/privacy) prior to effecting any transactions with
us. We will provide your personal data to Stripe or Go Cardless only to the
extent necessary for the purposes of processing payments for transactions you
enter into with us. We do not store your financial details.
We do, from time to time, use other third-party donation platforms or payment
processors and recommend that you read their privacy policy before using them.
The platforms we currently use are GoFundMe, Facebook Donations and PayPal.
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
7.5 Consent
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. We will also rely on this ground for
processing where we are administering our employment relationship with you
including making arrangements for the end of our working relationship with you,
and reflecting on our practices and experiences.
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
We keep this Privacy Policy under regular review and reserve the right to amend
it from time to time by posting an updated version on our Site, not least
because of changes in applicable law. We recommend that you check this Policy
occasionally to ensure you remain happy with it. We may also notify you of
changes to our Policy by email.
14. Third Party Websites
We link our Site directly to other websites. This Privacy Policy does not cover
third party websites and we are not responsible for the privacy practices or
content of those sites. We encourage you to read the privacy policies of any
external websites you visit via links on our website.
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 contact@civicpower.org.uk