Purpose of this Policy
In particular, this Policy explains:
- the kinds of personal information we collect about you;
- the means by which we obtain your personal information;
- the ways in which we use your personal information;
- the basis on which we use your personal information;
- the length of time that we keep your personal information;
- who we share your personal information with;
- how we protect your personal information; and
- where and why we transfer your personal information outside of the EU.
We may collect your personal data in your capacity as a partner, donor, applicant, supplier, participant in a research project or training session, subscriber to our marketing lists, or because you are visitor to our website (www.moreincommon.com) (the “Site”).
More in Common’s mission is to understand the forces driving us apart, to find common ground and help to bring people back together. We publish groundbreaking research and we test and find solutions. We work with partners that have the capacity to make a real difference by working at scale. And we help build the larger field of efforts to make democratic societies stronger, more united and more resilient.
More in Common’s four offices across the United States, the United Kingdom, France and Germany work closely together and share a commitment to advancing the common good. While we believe that a similar set of forces are threatening our societies, we also believe that our sense of identity and belonging has unique national and regional characteristics. We believe that every country can benefit from others’ experiences in building a sense of the ‘bigger us’ against the ‘us-versus-them’ forces of tribalism and division.
How to Contact Us
If you have any questions about this Policy or want to exercise your privacy rights, please contact us by sending an e-mail to firstname.lastname@example.org:
How We Collect Your Personal Information
We may collect your personal information in the following ways:
(1) When you give it to us DIRECTLY
You may give us your personal data directly in various ways, for example when you interact with us on social media, when you apply for employment with us, when you contact us by email or sign up to our newsletter online.
(2) When we receive your information INDIRECTLY
Your information may be provided to us when you follow us or otherwise interact with us on or via Twitter, when you like and/or join our Linkedin or interact with us on other social media platforms.
(3) When you give permission to OTHER ORGANISATIONS to share it with us or it is AVAILABLE 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.
(4) When you visit our WEBSITE
The Information We Process
We may process the following kinds of personal data:
- your name and contact details, including physical address, telephone number and e-mail address, and social media identity;
- financial information, such as payment-related information, including bank details or debit/credit card details;
- personal information we receive in the course of providing services to you, including details of why you have decided to contact us, details of trainings you have attended, details of topics/areas of interest to you;
How and Why We Use Your Personal Data
We may use your personal information to:
(1) Manage and administer our relationship with you, including providing you with services and information you have requested;
(2) Market our services, including sending you information about our work, trainings, organisation and any other information, products or services that we provide;
(3) Administer our Site, including monitoring its use;
(4) Administer payments;
(5) Administer your employment application;
(6) Conduct research and data analysis into the impact of our trainings;
(7) Deal with enquiries and complaints made by or about you relating to the Site or us in general;
(8) Audit and/or administer our accounts;
(9) Manage individuals’ preferences, including administering suppression files;
(10) Administer security requirements, including data and systems security;
(11) Conduct financial management and control;
(12) Meet any of our legal, regulatory and risk management obligations.
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.
We will contact you by e-mail with targeted marketing communications to let you know about our work 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.
Using our Site
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:
- Personal information is processed on the basis of a data subject’s consent
- Personal information is processed on the basis of a contractual relationship
- Personal information is processed on the basis of legal obligations
- 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 updating you about our work
(2) 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.
(3) 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.
(4) 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).
We will rely on this ground for processing the data of all applicants and attendees of our training events, managing our fundraising activities and promoting our work to relevant organisations, where their information is publicly accessible.
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.
Where we have relied upon legitimate interests as the ground for lawful processing, you are entitled to object to our processing on this ground.
In you wish to exercise either of these rights, then please contact us as directed in Section 14 of this Policy.
Our work is 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.
Security of and Access to Your Personal Data
We want to ensure your data is safe and so have put 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 employees of More in Common and we provide training on the protection of personal data.
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:
(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.
(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, as of 25May 2018, we have 30 days to comply.
(3) Right of erasure – as of 25 May 2018, you may ask us for your personal information to be deleted from our records in certain circumstances.
(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.
(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.
(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.
(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.
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/.
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.
Third Party Websites
You may contact us with any privacy concerns – including to update your information or exercise your rights as a data subject – by email at email@example.com