Privacy Policy

This policy refers to supporters’ personal information held and processed by FHL in the UK, including all information gathered through the official FHL website. Please read it carefully. 

This Privacy Policy sets out how FHL collects, stores, maintains, uses and ultimately disposes of supporters’ personal information. By providing FHL with personal information, supporters consent to FHL processing it in accordance with this Policy. Occasionally, FHL may make changes to this Policy, so supporters are advised to refer to the FHL website, which will always display the latest version.

 

Definitions used in this Document:

Personal Information or data means any information relating to a person who can be directly or indirectly identified by it. This includes their contact details and their IP address.   

Processing means any operation that is performed on personal data or on sets of personal data. It includes all stages of collecting, storing, maintaining, using and disposing of supporters’ personal information.

 

FHL Contact Details

Friends of the Holy Land is a UK Registered Charity (Charity Number 1202568). 

Registered Office:

Friends of the Holy Land,

Farmer Ward Road,

Kenilworth,

Warwickshire.

CV8 2DH

Tel: 01926 512980

E-Mail: [email protected]

Web-Site: www.friendsoftheholyland.org.uk 

The FHL Holy Land Committee is an independent, non-governmental organisation (NGO) registered with the Palestinian National Authority as a branch of an overseas NGO in Palestine. This endows the charity with formal authority to conduct its charitable activities throughout the West Bank and Gaza. Support to Christians in Israel and Jordan is made direct from the UK or through local institutions.  

 

FHL’s Charitable Objectives

We collect information purely for the purpose of helping to achieve our charitable objectives which are: raising awareness of the challenges facing the Christians of the Holy Land, encouraging prayers for their intentions, generating and channelling financial resources to give them a sustainable future and encouraging visits to the Holy Land to meet local Christians.

Why FHL holds Supporters’ Personal Information

 Friends of the Holy Land stores and processes supporters’ personal information in order to:

• Process donations (including keeping records of supporters’ relationships with FHL and details for HMRC gift aid declarations).
• Process sales of Olivewood
• Produce statutory accounts and financial reports for audit purposes and good governance.
• Contact supporters with updates about FHL projects and FHL work.
• Contact donors if there is a problem to resolve.
• Administer enquiries including volunteering and job applications
• Contact people about opportunities to support FHL work and local fund-raising or provide information about events.
• Help us to make the FHL website work better.
• Align it with publicly available information to help tailor FHL communications and products

 

What Personal Information is held by FHL

FHL stores the personal information that is provided by supporters, including details of donations and payment transactions. It may also include enquiries, surveys, Olive Wood transaction details, event attendance and pilgrimage details. Website usage information may also be collected using cookies.

Supporters’ Personal information held by FHL includes:

• Names
• Postal address
• Email address
• Telephone/mobile numbers
• Title
• Contact preferences
• Gift Aid status
• Gender (This is automatically generated – FHL does not use this information)
• Donation details
• Correspondence and notes from interactions with FHL staff and volunteers
• Information that is publicly available (e.g. the diocese that a parish belongs to)
• Any other personal information that is provided by the supporter
• IP addresses and web browsers (and versions) used
• Personal information derived from wealth screening
• Information on how people use the FHL website, using cookies and page tagging, to help improve FHL’s on-line services

 

Restrictions

To comply with the GDPR procedures, FHL will use a supporter’s personal information to contact them only if one of the following conditions apply:

• Supporter has given express permission for FHL to do so (in that way and for that reason).
• Supporter is new and has made a donation without the usual documentation. FHL would acknowledge the donation and seek the relevant permissions to contact the supporter, although the supporter is under no obligation to respond to this.
• It is necessary in order to deliver contracted goods and services.
• Where a supporter’s interests for privacy are not deemed to outweigh their legitimate interests in our mission.
• FHL has a legal obligation.
• It is of vital importance (it might save a person’s life).

 

Supporters will be able to amend these permissions or unsubscribe at any time by contacting FHL office by email, telephone or letter. Alternatively, they can use our website.

 

How FHL collects a supporter’s personal information

• When a supporter gives FHL their details
  For example, when a supporter makes a donation, requests further information, or attends an event. At times, a supporter might be interacting with an organisation working on FHL’s behalf such as a local FHL group, but FHL is still responsible for the information collected by that group.
• When a supporter donates through a third party
  For example, when a supporter makes a donation through a third-party website e.g. JustGiving, or CAF, and gives permission for their personal information to be shared with FHL.
• Social media
  If a supporter engages with FHL on social media and messaging services such as Facebook, or Twitter, the supporter might give FHL permission to process information from those accounts. FHL will not be able to access a supporter’s private messages, photos, etc. However, supporters may choose to send FHL information about themselves from which FHL can work out the general profile of our audience on that media service.

When a supporter visits FHL’s website

A Supporter’s data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. A Supporter’s personally identifiable data will only be used where it is necessary for the analysis required, and where a Supporter’s interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply:

 

• A Supporter’s data will be made available to our website provider only.
• The data that may be available to them include any of the data we collect as described in this privacy policy.
• Our website provider will not transfer a Supporter’s data to any other third party or transfer a Supporter’s data outside of the EEA.
• They will store a Supporter’s data for a maximum of 7 years.
• This processing does not affect a Supporter’s rights as detailed in this privacy policy.
• From other public information
  FHL sometimes uses information that is taken from publicly available websites such as Diocese or Parish web pages or information freely available in the media. We also may carry out wealth screening

As we are a fundraising organisation, we carry out limited profiling and research about our supporters to help us better understand and communicate with our supporters and potential supporters.

 

For this reason, we may gather information about you from publicly available sources – for example, Companies House, the Electoral Register and the PUBLIC Media – to help us to understand more about you as an individual and your ability to support the Charity.

 

We may carry out wealth screening, a process which uses trusted third-party partners to automate some of this work. We may use information gathered from public sources alongside the information you provide us to undertake analysis of who might support FHL and to understand the preferences of our supporters about events, communication and services.

 

By doing this, we can focus conversations we have with you about fundraising and volunteering in the most effective way, and ensure that we provide you with an experience as a supporter or potential supporter which is appropriate for you.

 

Carrying out research and processing in this way allows us to conduct high value fundraising, which is in our legitimate interests in operating FHL, delivering our charitable purposes and carrying out our mission – in this case, our ability to run friends of the holy land and carry out our mission. however, we will always endeavour to do so with great care and in a way that does not impact your rights and freedoms.

We may also use publicly available sources to carry out due diligence on supporters to meet anti-money laundering regulations.

You can opt out of your data being used for profiling and wealth screening techniques by contacting us at any time.

Staff access to all such information will be limited on a need to know basis, and staff will be made aware that it is only to be used for purposes stated here in conjunction with our Privacy Policy. This statement does not affect the other policies and legal duties laid out in our Privacy Policy.

 

Who does FHL share information with?

FHL promises to keep supporters’ personal information secure and will not sell or give supporters’ personal information to any other organisation.  Information about UK donors is never shared even with the FHL Holy Land Committee or staff unless expressly authorised by the donor. 

FHL may disclose supporters’ personal information if required to do so by law or if it believes that such action is lawful and necessary to protect and defend the rights, property or personal safety of Friends of the Holy Land and its stakeholders and for other lawful purposes.

FHL has contracts in place with its IT suppliers, which require those IT suppliers to comply with UK’s law on data protection and to have systems and processes in place to protect the security of FHL supporters’ personal information. These include: 

 

• FHL IT partners:

Access UK Limited -  ThankQ (industry-recognised online donor database software),

• FHL website and social media partners:

Access UK Limited (FHL web-site provider), Sendinblue (bulk-emailing software), Facebook, Twitter, Instagram, LinkedIn.

• Research partners:

Prospecting for Gold Ltd Office 7, Henley Enterprise Park, Greys Road, Henley on Thames, Oxon, RG9 1UF wealth screening

 

• Government Departments

To reclaim gift aid from Her Majesty’s Revenue and Customs (HMRC). UK Pensions Regulator, UK HMRC Tax and NI

 

Keeping Supporters’ Personal Information safe

FHL have physical, technical and human controls in place to keep your information secure.

FHL ensures that extra controls are in place for financial, sensitive and special categories of information, meeting regulatory and legal requirements for managing these types of information.

The transmission of information over the internet is never completely secure and FHL cannot guarantee the security of any information received electronically so such communications are initiated at the risk of the sender. FHL advises against sending personal information using unsecure means or networks such as free public wifi.

Once FHL receives your data, every effort is made to ensure its security both on our systems and while in transit between the systems and any partners, working on FHL’s behalf.

Access to personal information is restricted to authorised personnel who require it for FHL purposes and all staff or volunteers with access to personal data are trained in how to keep it safe.

FHL cannot be responsible for the privacy policies and practices of other websites, even if they are accessed using links from the FHL website so it is recommended that website visitors check the policy of each site visited.

Sometimes FHL may transfer information to a service provider or partner outside the European Economic Area (EEA) – which may include a country that does not have the same level of data protection as the UK. In these circumstances, the information that must be shared is minimised and all reasonable steps are taken to ensure the safety and security of all information as set out in this Privacy Policy. This is primarily to enable us to send you updates by email.

 

Keeping Supporters’ Personal Information

FHL will hold supporters’ personal information on FHL systems for as long as it is lawful and necessary to do so. This will enable FHL to ensure that it does not communicate with supporters who have asked FHL not to, and to comply with the data protection law.

 

Supporters’ Rights

Under the GDPR data protection law, FHL supporters have the following rights regarding the processing of their personal information. For more information on supporters’ full rights, please visit the Information Commissioner’s Office website, currently at this address: https://ico.org.uk/

• Supporter’s right to be informed
  FHL is required to inform a supporter clearly when, how and why it is collecting personal information and what it will do with it. FHL does this through this policy document and privacy notices which explain these points whenever FHL collects a supporter’s personal information.
• Supporter’s right of change of contact method or removal
  A supporter has the right to object to FHL contacting them. FHL is obliged to give a supporter the opportunity to say how they can be contacted and for what purpose. A supporter can change these preferences at any time by accessing the FHL website, or by contacting the office by email, telephone or letter.
• Supporter’s right to restrict processing
  A supporter can ask FHL not to process their personal information (though this still permits FHL to store it for legitimate business and regulatory, e.g. tax, reasons).
• Supporter’s right of access
  A supporter has a right to see what personal information FHL holds about them and can request to see it.
• Supporter’s right to data portability
  Making it easy for a supporter to obtain a copy of any personal information that they have provided to FHL in a machine-readable format, so they can easily transfer it to other organisations providing similar services. Any copies of personal information FHL provides upon request will be provided in plain text format
• Supporter’s right to rectification
  A supporter can ask for any inaccurate personal information FHL holds about them to be corrected
• Supporter’s right to erasure (your right to be forgotten)
  A supporter can ask FHL to erase their personal information that FHL holds

 

If a supporter would like to request a copy of their personal information held by FHL, the supporter is requested to send proof of their identity to Friends of the Holy Land, Farmer Ward Road, Kenilworth, Warwickshire CV8 2DH. Once their identity is confirmed, FHL will send a copy of the supporter’s personal information, in line with what FHL is legally required to disclose, within one month. FHL accepts no liability for the security of a supporter’s personal information, as contained in their request, until it has been received by FHL.

 

If you need to make a formal complaint, please contact the office for a copy of our Complaints Procedure. Your complaint can be addressed any of the Management Committee not involved in the complaint. The complaint will be reviewed by one of our Executive Trustees

Supporters can also lodge a complaint about the way FHL manages their personal information with the Information Commissioner’s Office (ICO). More information is available on the ICO website, currently at this address: https://ico.org.uk/

 

Changing the way FHL contacts Supporters

A supporter can contact FHL at any time to request an amendment to how FHL contacts the supporter and what for – or to tell FHL not to contact them at all. FHL will always respect a supporter’s wishes, though please note that there may be some information that FHL has to keep such as Gift Aid or Standing Order details for reasons that are required by law where FHL must be able to contact a supporter.

 

How FHL uses cookies

Like most websites, FHL’s website uses small data files stored on a supporter’s computer called cookies. Cookies provide insight into how people use a website to help an organisation such as FHL to keep improving it. Cookies do many different things, such as helping to:

• avoid asking a supporter to register or complete details twice
• estimate the number of visitors to the website, including the source and patterns relating to this traffic
• understand how visitors use the site, and how an organisation such as FHL can enhance this experience

A supporter is able to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time, although the supporter should be aware this means that they will miss out on some personalised services. A supporter can delete their cookies through their device settings at any time.

Supporters can find out more about cookies at www.allaboutcookies.org and www.youronlinechoices.eu/

 

A message for those supporters under 18 years old

If a supporter is under 18, they must ask for their parent or guardian’s permission before sending FHL any personal information, including photos and messages. Also, these supporters are required to include their age when contacting FHL.