Introduction
We value our supporters, without whom we could not carry out our crucial work with children affected by war across the world. It is important to us that we are clear with you about how we respond when you support us and provide your data.
At War Child UK (hereon ‘War Child’) we believe in your right to privacy. We work hard to ensure that any personal data we hold is securely protected and used appropriately. We are committed to:
- being transparent about what information we hold about you;
- being accountable for how and why we use your personal information;
- only storing the information we need for as long as we need it.
The purpose of this Privacy Policy is to give you a clear explanation of how War Child and our subsidiary War Child Trading Limited collects and uses personal data, including how we work with third parties, and to give you information on your rights.
This Privacy Policy applies to our supporters; customers; individuals or organisations we work in partnership with; ambassadors; suppliers; journalists; and the general public. We may undertake additional processing which is subject to separate privacy policies, and we will draw them to your attention where this is the case.
We may make changes to this Policy occasionally so please check back periodically for updates. We may also contact you regarding any significant changes to the Policy.
This Privacy Policy was last updated on 12 October 2021.
Child-friendly summary
We have also created a child-friendly summary of this policy. Please see the summary for more information.
How to contact us
If you have any queries or would like more information on anything in this policy, please get in touch with our Supporter Care team.
Email: [email protected]
Phone: 020 7112 2556
Post: War Child UK, Dunn’s Hat Factory (4th Floor) 106-110 Kentish Town Road, NW1 9PX
Our Data Protection Officer is Victoria Sadler, Internal Auditor. She can be contacted at [email protected] or via our postal address. Please mark the envelope ‘Data Protection Officer.’
About War Child
At War Child we protect, educate and stand up for the rights of children in war. We help keep them safe, give them an education, and equip them with skills for the future. We also work with children and young people to change systems and practices that affect them. We campaign on the root causes of conflict, and we demand that children are at the centre of all humanitarian responses.
War Child UK are a charitable company limited by guarantee, with company number 3610100, and registered charity number 1071659. We are also a Data Controller registered with the Information Commissioner’s Office, registration number ZA042748.
Our registered office is at Dunn’s Hat Factory (4th Floor) 106-110 Kentish Town Road, NW1 9PX.
Key ways in which we use your data
This Privacy Policy sets out all the ways in which we use your personal information, but we would like to draw your attention to these key activities:
Marketing
We will only send you emails and texts promoting our cause or activities where you have given consent for this. You can withdraw consent at any time by contacting us. See Direct Marketing for more information.
We will never sell your data or share it with another organisation for their own marketing purposes.
Understanding our supporters
We carry out research about some donors and individuals we work with in order to better understand how they may be interested in supporting us and to tailor our communications to the issues and events that interest them most. We only use publicly available information for this. See Research for more information.
We analyse data about how individuals and organisations interact with War Child to help us measure the effectiveness of our fundraising activity. We also segment our data in order to tailor our communications, for example by asking people for an appropriate level of support. See Profiling for more information.
Social Media
We use social media, such as Facebook, to promote our aims and activities. We may use their services for targeted advertising, and we may track when individuals click on our adverts. See Social Media for more information.
What personal data we collect
From you directly
We collect information you provide when you engage with us. For example, when you make a donation; volunteer or raise money for us; enter a prize draw; buy something from our online shop; engage with our gaming activations; or work with us as a partner, artist, ambassador, or journalist.
We collect, store and use the following kinds of personal information:
- Names and contact details, including email address, postal address, telephone number and social media profile;
- Date of birth;
- Financial information you provide when you make a payment to us, such as bank details or credit/debit card details;
- Information about whether you are a taxpayer so that we can claim Gift Aid;
- Your communication preferences;
- Information about which of our campaigns, services, events or activities you engage with;
- If you are travelling with War Child to visit our programmes, passport details and other information required, such as for a visa or DBS checks.
- Any other personal information you choose to share with us, such as your job or personal interests.
From third parties
We work with a range of other organisations to help us put on events, support your efforts to raise money for War Child, and support our fundraising programmes. We collect, store and use personal information from the following types of third parties:
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Through use of the website
We collect information about how visitors use our websites, such as which pages they visit, information about the devices used, and IP addresses. We place our own and third-party cookies and trackers on our website to gather this information. Please see our Cookies Policy for more information.
Publicly available information
We may use websites and directories in the public domain to carry out research about existing and potential donors, supporters, music and gaming partners, ambassadors, and corporate partners. We collect, store and use the following types of information from the public domain:
- Professional information, such as job title or non-executive positions;
- Involvement with other organisations and charities, such as trusteeships, board membership, partnerships;
- Donations and support given to other charities;
- Personal interests relevant to War Child, such as other charities you support and personal interests that correlate with War Child fundraising programmes, in particular in Gaming and Music.
Information we generate
When you interact with War Child, for example by making a donation, attending an event or purchasing something from the online shop, we may use that information which helps us communicate with you more effectively and analyse the performance of our fundraising campaigns. For example, if you have previously attended music events, we may invite you to similar events in the future.
Lawful basis for processing
UK Data Protection law requires us to identify the lawful basis on which we collect, store and use your personal information. We explain these purposes and the corresponding lawful basis in the section below on how we use your personal data.
Generally, we apply one of the following bases:
- Consent: We have obtained your consent to use the data for the stated purpose;
- Contract: The processing is necessary for us to meet our contractual obligations to you; or in order to take steps at your request prior to entering into a contract;
- Legal Obligation: The processing is necessary for compliance with a legal obligation to which we are subject.
- Legitimate Interest: The processing is necessary for our legitimate interests, which are identified with each purpose below. We balance this against your rights and freedoms to ensure that our interests do not override the impact on you.
Special category and criminal offence data
Under UK Data Protection law some categories of data are considered more sensitive than others. These are referred to as special category data and include information about health, sexuality, ethnicity, political opinions, religious or philosophical beliefs, and trade union membership.
In order to process special category data, we need to have a particular reason to do so, in addition to a lawful basis as described above. We do not generally collect special category data but when we do it is usually to ensure equality of opportunity or treatment of supporters, attendees at events, and individuals we work with. Where possible we will only collect and use this data either with your explicit consent or where you have manifestly made public this information. We may rely on other conditions and lawful bases where these are not applicable and further information is available on request.
We rarely process criminal offence data, but where we do, we will always have identified a lawful basis and appropriate conditions under UK Data Protection law. Typically, any processing of criminal offence data is for the safeguarding of children and individuals at risk in the context of our programmes and is done so on the basis of consent.
How we use your personal data
To understand current and potential supporters
Research
We undertake research about some of our current and potential major donors, ambassadors, high profile supporters, artists, and gamers. This is in order to better understand areas of our work that you may be interested in, ways you may wish to work with us, and how to best communicate with you.
For this research we use data collected from you directly, such as meeting notes or email exchanges we have with you, and data collected from the public domain, including:
- Professional profiles, for example corporate biographies or LinkedIn profiles;
- Search engine and public social media results;
- Resources such as Companies House and the Charity Commission;
- Third party publications such as Debrett’s, Who’s Who and the Sunday Times Rich List;
- Third party aggregators and insight platforms such as Pearlfinders and The Media Eye.
If you would prefer us not to undertake research about you, please contact us at [email protected] or 020 7112 2556.
Lawful basis
We rely on Legitimate Interest as our lawful for basis for carrying out research about current and potential supporters and partners.
It is important for us to be able to build effective relationship with the individuals we work with, or may work with in future. These relationships are the foundation of many of our fundraising programmes, and without them we would not be able to raise the funds to carry out our work with children affected war.
We limit the data we process to what is necessary, however, and it is only used by specific members of staff that are directly involved in relevant fundraising activity.
Profiling
We carry out the analysis and segmentation of data for our marketing purposes, which includes the creation of dashboards in our database, mailing lists, and KPI reports. We use information you give us, and data created by how you engage with us (such as purchasing an item, making a donation or attending an event), to better understand what may be of interest to you in the future, and how best to communicate with you. We do this in order to make our fundraising activity more successful, as it enables us to track the performance of specific projects and campaigns, and tailor the marketing communications we send out, so they are appropriate for the audience.
If you would prefer us not to use your data in this way, please contact us at [email protected] or 020 7112 2556.
Lawful basis
We rely on Legitimate Interest as our lawful basis for profiling in this way. It is important for us to be able to make sure our fundraising activity is effective, so that we do not spend resources inappropriately. It also enables us to improve the performance of our campaigns, which helps make sure War Child’s funds are spent as efficiently as possible. We only process the data we need, however, and do not acquire any data from third parties for this purpose. Tailoring our communications is also in the interests of our supporters, as it helps ensure they receive relevant messages.
Vetting
In line with Charity Commission requirements and legal frameworks we follow a vetting process to assess the financial soundness, credibility, and reputation of individuals who:
- Have made or are likely to make a significant donation to War Child;
- Enter into a partnership with War Child, either as an individual or as part of an organisation;
- Act as an ambassador or high profile ‘influencer’ for War Child in any context;
As part of this process we will conduct research using the methods above, and use software called Amber Road to check for criminal convictions and whether individuals are on UK or US sanctions lists.
Lawful basis
We rely on Legitimate Interest as our lawful basis for our vetting processes. It is essential that we can be reassured that our donors and supporters are financially sound and support our principles, to mitigate the reputational, compliance and financials risks that come with working with third parties.
If we need to process criminal offence data as part of this process, we do so on the condition of regulatory requirements relating to unlawful acts and dishonesty.
If we need to process special category data as part of this process, so we do on the basis of public interest, and a condition of regulatory requirements.
To contact you and promote our cause
Administrative messages
We use your data to send administrative and service messages in relation to your engagement with War Child, including when you make a donation; order something from our online shop; enter a prize draw; book to attend an event; update your details with us; or ask us a question. We may get in touch by email, phone, post, text message or social media, depending on the channel you used to engage with us, and what contact details we have for you.
Lawful basis
We rely on Legitimate Interest as our lawful basis for sending administrative and service messages. We believe it is in both our and your interests to send communications in relation to your engagement with us. We make sure to only process the data we need and to only send messages that are relevant and appropriate.
Direct marketing
We may contact you about our work, how you can support us, and activities and events you might be interested in. What we send you and the channel we use will depend on how you have engaged with us in the past, and your communication preferences. We will consider how many communications you receive from us, and what the topic is, to ensure that our messages are appropriate.
Every time we communicate with you in this way, we will tell you how you can stop receiving marketing, or change how you hear from us, for example by providing you with a link in an email to unsubscribe, or by asking you on the phone.
If you ask us not to contact you, we will keep some basic information about you on our database in order to make sure we do not send you unwanted material in the future.
Lawful basis
We rely on Consent as our lawful basis to send you emails and SMS messages. This means that we will only contact you using these channels if you have opted-in to receiving marketing in this way. You can withdraw your consent at any time by clicking the unsubscribe link in emails or following the instructions in SMS messages you receive. You can also contact us [email protected] or 020 7112 2556 to withdraw your consent or change your preferences.
We rely on Legitimate Interest as our lawful basis to send you mail in the post or to call you for marketing purposes where you have provided your address and/or phone number, unless you have previously opted-out of these channels; told us you do not want to be contacted in this way; or are registered with the Telephone Preference Service. Fundraised income is an essential source of funds for our work with children affected by war so it is important for us to be able to promote our cause and the ways you can support us. We are careful to only communicate in ways we think you will find appropriate and will always respect your wishes if you tell us you do not wish to hear from us in this way.
To enable you to support us
Donations and Fundraising
If you make a donation to War Child, we will ask you to provide us with certain information so that we can process your donation, and claim Gift Aid if you have asked us to do that.
If you sign up to participate in a fundraising event for War Child, such as the Royal Parks Half Marathon, or tell us that you are raising money in aid of War Child, we will record the details of your fundraising activity and how much money you raise. We will also communicate with you during your fundraising activity to provide relevant support and information.
We will also use the information you give us for financial reporting and carrying out audits.
Lawful basis
We rely on Legitimate Interest as our lawful basis for processing your donation and using details of your gift(s) and/or fundraised income in subsequent reports and audits. It is essential that we are able to process the donations we receive, and maximise them through the Gift Aid scheme, and report on the performance of our fundraising activity. We only process the necessary data for these purposes and store it securely in our databases.
We rely on Legal Obligation as our lawful basis for keeping financial records as we are subject to a legal requirement to do so.
We rely on Contract as our lawful basis for communicating with you during your fundraising activity, as we have agreed to provide you with information and/or resources to support that activity. Once you have completed your fundraising activity, we will no longer contact you about your fundraising. We may contact you in other ways described in this Privacy Policy, depending on your communication preferences.
Partners, ambassadors and volunteers
If you support us as an ambassador, influencer or volunteer, or in connection to a corporate or commercial partnership, we will keep your contact details, information about the nature of your relationship with War Child, the support you give us, and information you share with us about your interests and motivation for supporting War Child. We use this information to communicate with you about your involvement with War Child, and to keep records for analysis and reporting purposes.
Lawful basis
We rely on Legitimate Interest as our lawful basis for keeping information about our partners, ambassadors, influencers and volunteers. This kind of support is crucial for many of our fundraising programmes, so it is essential that we are able to maintain relationships with our supporters and report on our activities involving them. The information is only used by relevant members of the Fundraising department, is stored securely in our database, and not used for any other purpose.
When you buy something or enter a draw for tickets
If you purchase something from our shop or enter a free draw to win an item or event tickets, we will use the contact details you provide to confirm your payment and to fulfil your order. If you have entered a draw, we will also use your contact details to tell you if you have won a prize. We may also retain information about the items you have purchased or the draws you have entered for our records and to analyse the performance of our fundraising activities.
Your data may be shared with a fulfilment company or ticketing agency if we are using one to fulfil purchases and/or prizes.
Lawful basis
We rely on Contract as our lawful basis for using your personal information to fulfil purchases and manage prize draws. Full terms and conditions are provided in our online shop and during prize draws.
Website and online services
Cookies
Cookies are small text files stored on your computer or device when you visit certain websites. We use first-party cookies (cookies that we have set, that can only be read by our website) to personalise your online experience. We also use third party-cookies (cookies that have been set by other organisations) to help us measure and analyse the use of our website, and to provide targeted advertising. You can control the use of cookies via your browser.
Please see our Cookies Policy for further information.
Lawful basis
We rely on Legitimate Interest as our lawful basis for using cookies which are strictly necessary as we rely on having a working website in order to fundraise for our cause.
We rely on Consent as our lawful basis for using all other cookies on our website, and to process the personal data collected by them. You can withdraw your consent at any time, either by setting your cookie preferences on our website, or through the settings in your Internet browser.
Social media
We use social media platforms including Facebook, Instagram, Twitter, TikTok, Twitch and Discord to promote our work and our fundraising activity. If you engage with our content or posts we may like, follow or reply to them.
We use social media tools including Facebook Custom and Lookalike audience, and Facebook Charitable Giving. This may involve us receiving your personal information from Facebook or Instagram, for example if you make a donation through these platforms. We may also share your email address with Facebook and YouTube (Google) in order to help make our posts visible to the most relevant audiences. Some of this data may come from third-party cookies on our website. This means that you may be shown advertising related to War Child that we think you may be interested in seeing, or your profile may be used to identify those with similar characteristics to you, such as age or gender, who may also be interested in our work or fundraising activity.
You can find more information about how social media platforms use personal data in their privacy policies.
Lawful basis
We rely on Consent as our lawful basis for using data collected by third-party cookies as described above.
We rely on Legitimate Interest for the other ways we process data as part of our use of social media, including profiling and sharing that data with social media platforms for them to process on our behalf. Identifying the most appropriate audiences for our posts and content is necessary to enable us to fundraise efficiently and raise awareness of our cause.
Children's data
We only collect and use data belonging to individuals under 18 in the following ways:
When you buy something or enter a draw for tickets
If you purchase something from our shop or enter a free draw to win an item or event tickets, we will use the contact details you provide to confirm your payment and to fulfil your order. If you have entered a draw, we will also use your contact details to tell you if you have won a prize. Your data may be shared with a fulfilment company or ticketing agency if we are using one to fulfil purchases and/or prizes. We will delete your data once we have fulfilled your purchase or completed the prize draw.
Lawful basis
We rely on Contract as our lawful basis for using your personal information to fulfil purchases and manage prize draws. Full terms and conditions are provided in our online shop and during prize draws.
To enable you to support us
If you make a donation to War Child, we will ask you to provide us with certain information so that we can process your donation and thank you. If you sign up to participate in a fundraising event for War Child, such as Peace Band, or tell us that you are raising money in aid of War Child, we will use your information to communicate with you during your fundraising activity to provide relevant support and information. Once we have thanked you and/or you have finished your fundraising activity we will delete your data.
Lawful basis
We rely on Legitimate Interest as our lawful basis for processing your donation. It is essential that we are able to process the donations we receive, and we believe it is in your best interests to enable you to make donations if you wish, and to thank you for them. We only process the necessary data for these purposes and store it securely.
We rely on Contract as our lawful basis for communicating with you during your fundraising activity, as we have agreed to provide you with information and/or resources to support that activity. Once you have completed your fundraising activity, we will no longer contact you about your fundraising.
When you contact us
If you contact us we will use your data to send administrative and service messages in relation to your engagement with War Child. We may get in touch by email, phone, post, text message or social media, depending on the channel you used to engage with us, and what contact details we have for you. Once the correspondence with you is complete we will delete your data.
Lawful basis
We rely on Legitimate Interest as our lawful basis for sending administrative and service messages. We believe it is in both our and your interests to send communications in relation to your engagement with us. We make sure to only process the data we need and to only send messages that are relevant and appropriate.
Your rights
You have a number of legal rights in relation to our processing of your personal information, including the ones below:
Right to be informed
You have the right to be informed about the collection and use of your personal data, and we are required to ensure that we are transparent about how we use your information. This Privacy Policy, and other notices on this website and in our communications explain how we use your personal information.
Right of access
You have the right to access and receive a copy of your personal data from us. We may require you to confirm your identity before providing you with your data.
Right to rectification
You have the right to have inaccurate personal data rectified or completed if it is incomplete. You can also ask us to check the personal information we hold about you if you are unsure whether it is up to date.
Right to erasure
You have the right to have personal data erased, otherwise known as the ‘right to be forgotten’. We may have an overriding legitimate reason to not delete all of your personal data, such as to comply with a legal obligation in the case of financial records.
Right to restrict processing
You have the right to request the restriction or suppression of your personal data, so that while we may retain your personal data, we will not use it.
Right to object
You have the right to object to the processing of your data in certain circumstances, including an absolute right to stop your data being used for direct marketing.
Right to withdraw consent
You have the right to withdraw consent where we process your data on that basis, for example for direct marketing.
If you would like to discuss or exercise any of these rights, please contact our Supporter Care team on 020 7112 2556 or [email protected].
Third parties and data sharing
We will never sell your data or share it with another organisation for their own marketing purposes.
We also share information with other organisations when we are legally required to. For example, if you agree to us claiming Gift Aid on your donations, we are required to share your name and address with HMRC. We do share information with organisations who are working on our behalf, including fulfilment companies, fundraising agencies, and music and event venues. We carefully select our partners and will only share information with them where we are confident that they will protect it and comply with the law. We will have a contract and data sharing agreement in place to assure this.
We also receive personal information from third-party organisations where they provide a service on our behalf, such as ticketing agencies or fundraising platforms such as JustGiving and Tiltify. We only receive the data you have agreed for us to receive, and we carefully choose which companies to work with.
Data storage and retention
Your personal information is stored securely in authorised War Child systems. We have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk. For example, we use strict procedures and security features to prevent unauthorised access to your personal information.
Your personal information is only kept for as long as we need it, for the purposes set out in this policy. We have a data retention policy which sets out periods that data is kept for different purposes. The criteria for this policy are based on our reasons for holding the data, how we use it, legal requirements and guidance issued by relevant regulatory authorities including the Information Commissioner’s Office (ICO).
When we no longer need it, your personal information will be deleted securely or anonymised so you can no longer be identified by it.
We never store payment card data after the transaction has been completed.
We will keep your personal information within the UK or the European Economic Area (EEA). We sometimes use services or suppliers that host data outside of these areas, and in these cases we will ensure contractual clauses are in place to safeguard your data and make sure it is looked after to a standard as if it were in the UK or EEA.
Payment card security
If you use your credit or debit card to make a donation, buy something or enter a prize draw on our website we will use a specialist payment processor. We ensure that your card details are handled securely under Payment Card Industry Data Security Standards (PCI DSS).
If you provide your card details to make a donation by phone, we will follow robust processes to make sure that your information is kept secure. We will never store your credit or debit card details following the completion of your transaction. All card details and validation codes are securely destroyed once the payment or donation has been processed.
When we use suppliers to take payments on our behalf, we will make sure they process your debit or credit card details securely and in line with PCI DSS.
How to complain
If you are unhappy with how we have used or stored your data, or with how we have responded to your questions or requests relating to your personal information, please contact us so that we can resolve it with you. You can find more information in our Complaints Policy.
However, if you are still unhappy you have the right to complain to the Information Commissioner’s Office (ICO), the UK’s data protection regulator. They can investigate your claim and take action against anyone who has misused personal data. Please see their website for details of how to complain, including contact details: https://ico.org.uk/make-a-complaint/.
