What is in this policy?
This policy tells you:
- who we are
- what information we might collect from you
- how we might use your information
- what information of yours we might share with others
- how long we might keep your information for
- your rights about the personal information you give us
Who we are
Global’s Make Some Noise is an appeal operated by Global Charities, a registered company (04359098) and charity in England & Wales (1091657) & Scotland (SC041475), which trades through its trading company Global Charities (Trading) Ltd a company registered in England and Wales under number 04374705 with its registered office at 30 Leicester Square, London WC2H 7LA (“GMSN”).
This statement explains how we collect and use information about you when you interact with Global’s Make Some Noise.
What personal information do we collect about you?
The information we may collect about you will vary depending on how you interact and engage with us. It may include the following:
A. General identification and contact information
We may collect the following when you get in contact with us for example, when you visit our website, enter a competition or challenge, or apply for funding:
- phone number
- email address
- IP address
- date of birth
B. Financial information
We may collect financial information to transfer a cash prize to you if you have won one of our competitions or when you make a donation. These may include:
- bank account details
- tax status
C. Usage Information
We may collect information about how you’ve engaged with Global’s Make Some Noise, such as the competitions you’ve entered and your favourite radio station to listen to.
D. Sensitive information
Under data protection law, certain categories of personal information are recognised as sensitive.
We will only collect sensitive personal information (also known as ‘special category personal data’) from you if you provide us with it. Sensitive personal information includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life or sexual orientation.
We may also process some criminal offence data. This type of data includes personal data relating to the alleged commission of offences or proceedings for an offence committed or alleged to have been committed, including sentencing. This is collectively referred to as ‘criminal offence data’.
For example, you may share your dietary or health information to ensure that we provide appropriate facilities or support to enable you to participate in an athletic event like a marathon to raise money for the charities we support. We may process sensitive information such as health information or sexuality information to provide case studies for our selected charities.
We will only ask for this information for legitimate purposes and process it with a lawful basis in place.
What do we use your information for?
If you are a Donor or participate in one of our fundraising events:
We may hold and use your personal information for a number of reasons:
- To keep a record of donations you have made and our communications with you;
- To send you marketing information about our projects, fundraising activities and appeals where we have your consent or are otherwise allowed to do so;
- To claim gift aid on donations;
- To fulfil obligations entered into with donors e.g. auctions at events or competition prizes;
- To register your participation at third party events on your behalf (e.g. running events, cycle events, and other challenges)
- To keep people safe at our events;
- To comply with legal obligations;
- To ensure we do not send unwanted information to donors or other members of the public who have informed us they do not wish to be contacted;
- On occasion we may also use your personal information for research and analysis purposes so that we can improve our services, achieve our objectives and better meet the needs of our beneficiaries.
If you are applying for a Grant or are a beneficiary of a Grant:
We may hold and use your personal information for a number of reasons:
- To assess your application for funding;
- To fulfil our legal and tax obligations i.e., to protect against fraud;
- For administration and management purposes, including checks and audits;
- For promoting your charity’s story and GMSN’s involvement in the public sphere including through using GMSN’s broadcasting and all other associated platforms.
If you make a grant application, you will be provided with more information during the assessment process.
If you are a challenge participant/fundraiser:
- We may hold and use your personal information for a number of reasons:
- To send you relevant fundraising information or other communications (unless you didn’t sign up or you tell us you no longer want to hear from us);
- To provide any reasonable adjustments you may need to participate in our fundraising activities;
- To tell your story and/or promote our fundraising and charitable aims where you have consented to this. For example, we or Global Media Group Services Limited [“Global” ] may share your fundraising story or images on Global’s radio stations, website or social media platforms, or use them for marketing purposes. We would never disclose full names, addresses or contact details to the public.
- To contact you about any submission or content you provide. This includes where you have told us about your fundraising activity or story or have shared it on social media or you have set up an online fundraising page and agreed we may contact you.
- To allow us to better understand our fundraiser base and measure fundraising income.
- To keep a record of your interactions with us so we can do all of the above and provide support to you in an effective way.
If you are a competition entrant:
We may hold and use your personal information for a number of reasons:
- To enter you in our competitions or prize draws upon your submission;
- To inform you about the outcome of our competitions and prize draws;
- If you are successful in any of our competitions or prize draws we also process your personal data in order to award you with the relevant prizes.
Please be aware that if you log in via any social media platform e.g. Facebook, Twitter to a Global’s Make Some Noise website you will be giving that social media platform permission to share some of your details with us depending on your privacy settings on their site. For example, if your Facebook privacy settings are set to allow it, they will provide us with your public profile which includes your name, profile picture, email address, age range, spoken language and gender.
Any social media posts or comments you send to us will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) and could be made public. Before you make any comments, you should check the social media platform’s terms and privacy policies so you understand how they will use your information, what information they will place in the public domain, and how you can stop them from doing so if you’re unhappy about it.
GMSN’s use of photography, images and film
Photography, images and film provided to us is used in various ways such as on our website, Global radio stations, on social media, in publications, in printed or online fundraising materials, in fundraising and awareness films or by our corporate partners who help us raise money to support our causes.
Photography, images and film created for case studies is taken and used with your consent.
We will discuss with you how your, and/or your child’s, image and information is going to be used and ensure you are happy for it to be used in this way. If you would like to revoke your consent and no longer want content featuring yourself and/or your child to appear on our platforms, please contact us at [email protected].
Whilst we will make reasonable efforts to remove all content, please be aware that once information is out in the public domain, it may be impossible to completely remove all traces. For example, if content is shared on social media and is shared on other accounts.
Data research and analysis
We may also carry out analysis of the personal information we collect about you and add publicly available information to create a profile of your interests, preferences and your ability to support us, including the amount or level of a potential donation or legacy you may be able to give.
We have a legal obligation to carry out this due diligence as a registered charity.
This information is compiled from sources such as public registers (e.g. listed Directorships), internet search engines, the electoral roll, newspaper articles and social media posts.
Please let us know if you would prefer us not to process your data in this way by contacting us: [email protected]
Our research and analysis activities can be broken down as follows:
Key donor identification
We have a legal obligation to carry out research to determine whether an individual could be a potential key donor. We may use publicly available information from third party sources such as Google; Companies House; Mint UK; published biographies and publicly available LinkedIn profiles. The type of information we collect can include:
- career overview
- gift capacity
- areas of interest
- history of giving to us and others
- how you are connected with us and others
- publicly available information about any philanthropic activities or interests
High value event planning
We may also produce short biographies of you if you are due to attend an event that we may be hosting. This helps our people to understand more about you and your interests or connections to us.
Ethical screening and minimising risk
As a registered charity, we are subject to a number of legal and regulatory obligations and standards.
This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering.
We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it.
Lawful basis for processing
The legal basis that we rely on for processing your data will depend upon the circumstances in which it is being collected and used, but will in most cases fall into one of the following categories:
- where you have provided your consent to allow us to use your data in a certain way;
- where the processing is necessary to carry out for the performance of a contract with you;
- where the processing is necessary in order for us to comply with a legal obligation; or
- where it is in our legitimate interests to perform our functions.
Our legitimate interests include the following:
- Sending you administrative communications in order to deliver our charitable purposes and contract fulfilment;
- Understanding our existing and potential donors;
- Putting on events and challenges, including encouraging fundraising.
Who do we share your personal information with?
We will not sell your personal information to organisations.
We use service providers to help us achieve our purposes such as:
- fundraising agencies, event caterers, direct mailing companies, mobile marketing providers, market research companies, product suppliers, prize fulfillment companies and software platform providers) to help us achieve our purposes.
International Transfers of Personal Information
Personal information which you supply to us is generally stored and kept inside the UK.
For any transfers of data from the EEA to the UK, please be aware that the UK is subject to an adequacy decision located here.
We may give relevant persons within these service providers access to your personal information, but only to allow them to perform their services for us. Some service providers may be based outside of the UK and European Economic Area (EEA).
If we do need to transfer your personal information in this way, we take steps to ensure your level of privacy including data minimisation, anonymising data, pseudonymising data (a technique that removes or replaces certain information in a data set that could identify people), encryption (a security measure to protect data), undertaking due diligence on the recipients of data and putting in place contractual obligations on them to take care of your data, for example by using approved Model Contractual Clauses (as published by the European Commission). Please contact us for further information on international data transfers.
Legal or regulatory obligations
We may also disclose your personal information when required to by law, for example, to HMRC for tax purposes or to police forces for the prevention or detection of crime.
How long do we keep your information for?
We hold personal information for different purposes and the length of time we keep your information will vary depending on the services or products we are providing. We will only keep your data for a reasonable period of time, which is based on the purpose for which we are using your data. Once that purpose has been fulfilled, we will securely delete your data or anonymise your information (so that we, or anyone else, can no longer tell that data relates to you) unless we are required to retain the data longer for legal, tax or accounting reasons.
To determine the period we store personal information, we always stick to these principles:
- we will only keep your information for as long as we need to, and
• we think about what type of information it is, the amount collected, how sensitive or intrusive it might be and any legal requirements.
Partnerships / events: Gift aid declarations – 6 years post event.
Shop: Gift aid data – 7 years. Customer relationship management data – 6 years.
Finance: Gift aid records – 6 years. Payment details – until a donation has been processed.
Charities: Beneficiary data – 4 years from the date of we receive permissions. Anonymised impact and grants data (e.g., diversity reporting)- Indefinite.
Challenges: Retained as per the legal requirement.
Donors: 6 years.
Email marketing: 24 months after an individual last engages.
Your rights in relation to how we use your personal information.
Data Protection laws give you certain rights in respect of your personal information. Please contact us using the contact details below if you wish to exercise any of your data rights.
You have the following rights:
- Right to be Informed
- Right to rectification
You have the right to have your personal information corrected if it is inaccurate or incomplete. You can also correct personal information yourself if you have registered with us via an account on one or more of our website.
- Right of access
- Right of erasure
You have the right of erasure (also known as the ‘right to be forgotten’) which allows you to request the deletion or removal of your personal information where there is no compelling reason for us to continue processing it. This right is not absolute, and there are circumstances where we may need to continue processing your data despite a request for erasure.
- Right to object and opt-out of marketing
You have the right to object to certain types of processing of your personal information. This includes the right to object to direct marketing. You can exercise your right to opt-out of further direct marketing when you receive such communications from us (via the ‘unsubscribe’ option we include in each email or you can contact us directly).
- Right to portability
You have the right to receive certain personal information from us in a commonly used electronic format (such as a Microsoft Excel file) so that this personal information can be used in a different service.
- Right to restrict processing
You have the right to restrict or ‘block’ the use of your information in certain circumstances such as when you think your data rights outweigh our legitimate interests in the processing of your data. When you exercise this right, we can still store your information but cannot undertake further processing.
- The right to withdraw consent
If you have given your consent to anything we do with your personal information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal information with your consent up to that point is unlawful).
If you wish to submit a request in relation to any of your rights above, please contact us at: [email protected].
Please note you may be asked to supply us with proof of identity and other additional information before we will be able to provide you with a response. We aim to respond within one month of receiving your request or identifying information (if required), and we will let you know if we anticipate your request taking any longer.
While we usually act on requests, we can refuse to do so (or may charge a reasonable fee to cover our administrative expenses) where you make baseless, excessive or repeated requests or ask us for further copies of information we have already provided.
Contact Us and Complaints
If you do have any concerns, we would like you to give us the opportunity to know about them so we would encourage you to contact us first so we can help you. For a query or complaint, please email [email protected] or write to our Data Protection Officer at [email protected].
If you do not think we are handling your personal information adequately, you have the right to lodge a complaint with the relevant supervisory authority in your country. In the UK this is the Information Commissioner’s Office, which may be contacted here.