Global Fund for Children
1411 K St., NW, Suite 1200
Washington, DC 20005 USA
Email address: [email protected]
Telephone number: (202) 331-9003
Fax number: (202) 331-9004
You have the right to make a complaint at any time to the applicable regulatory body (a list of which is available on the European Commission’s website: https://edpb.europa.eu/about-edpb/board/members_en) which, in the UK, is the Information Commissioner’s Office (the “ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the applicable regulatory body, so please contact us in the first instance at [email protected].
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences other than as part of standard background checks on field staff and board members conducted during the employment/hiring process, and standard checks carried out on grantee partners who have been selected to receive grants from GFC.
If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you or in order to provide you with the services, products or information you have requested, and you fail to provide that data when requested, we may not be able to, to provide you with goods, services or information you requested or to accept your donation. In this case, we may have to cancel the contract we have with you or your donation or the product or service you have with us, as applicable, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Most commonly, we will use your Personal Data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at [email protected].
Purposes for which we will use your Personal Data
We have set out below a description of the ways we may use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out below.
For the purposes of the information immediately above, the following terms shall be defined as follows:
Legitimate Interest means the interest of our charity in conducting and managing our charity to enable us to fulfil our charitable aims. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected].
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.
We strive to provide you with choices regarding certain Personal Data uses, particularly around fundraising and marketing and advertising.
You can ask us or third parties to stop sending you messages at any time by following the opt-out links on any message sent to you or by contacting the DPO at any time.
Where you opt out of receiving these messages, this will not apply to Personal Data provided to us as a result of a product/service purchase or donation you have made.
Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the DPO.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your Personal Data with the parties set out below for the purposes set out in section 5 above.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We share your Personal Data within the GFC Group. This will involve transferring your data outside the European Economic Area (“EEA”).
Many of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA.
Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know such information. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
GFC’s contact database is hidden behind a firewall, is not accessible via the internet, is password protected and only accessed by authorized GFC personnel.
Acknowledgment may include mailings of GFC’s own materials, such as annual reports, which list donors who do not desire anonymity and those in whose honour donations were made.
When information is provided by a parent or guardian, GFC will use the information only for those limited purposes.
The EU General Data Protection Regulation (“GDPR”) and the US Children’s Online Privacy Protection Act (“COPPA”) protect the personally identifying information of children. GDPR and/or COPPA extends protection to personally identifying information collected online, including name, residential and email addresses, and telephone number, as well as to information about hobbies and interests when linked to personally identifying information. In accordance with GDPR and COPPA, GFC is deeply committed to ensuring the safety of all children, and to the protection of their personally identifying information.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our donors (including Contact, Identity, Financial and Transaction Data) for a certain period, for example in the EU for six years after they cease being donors.
In some circumstances you can ask us to delete your data: see section 11 below for further information.
In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have the following rights under data protection laws in relation to your Personal Data:
If you wish to exercise any of the rights set out above, please contact the DPO, whose contact information is listed above.
No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of your other rights set out above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Global Fund for Children (GFC) UK Trust, created in 2006, is a UK registered charity (UK charity number 1119544). We work to generate vital income, create new fundraising opportunities, and raise awareness of the invaluable work of GFC’s grassroots grantees. Our aim is to extend the reach of GFC in the United Kingdom, Europe, and beyond.
Central Working Paddington, 2 Kingdom Street
London W2 6BD