DFN Project SEARCH (“DFN”, ”we”, “our” or “us”) are committed to protecting and respecting your privacy. We are committed to maintaining compliance with the General Data Protection Regulation (GDPR), the Data Protection Act of 2018 (DPA), and any associated data protection regulations that come into force as and when required.
The data controller is DFN Project SEARCH, a charity registered in England & Wales with the charity number: 1155919 and whose registered office is 10 Norwich St, London, EC4A 1BD
Why we process your information
To undertake our charitable objectives we need to know about the people who interact with us. We therefore hold data on people for the following reasons:
- To provide you with information about our work or our activities; and to process donations we may receive from you
- To fundraise in accordance with our internal policies and procedures;
- For administrative purposes (for example, in response to an online request for information)
- For continual evaluation of the effectiveness of the Internship programme and to influence employment policy making
- For internal record keeping relating to any donations, feedback, or complaints
- To analyse and improve the content and operation of our website
- To analyse and improve our internal business processes
- To provide ongoing support and information to stakeholders
- To analyse the personal information we collect about you and use publicly available information to better understand your interests, preferences and level of potential donations so that we can contact you in the most appropriate way and to ensure that we do not send you unwanted communications
- Where we are required by law to disclose or otherwise use your information.
In limited cases we collect data on people who are under 18 or special category personal data relating to health. Where we do this we will describe the uses to which data will be put at the time of collection.
How we obtain your data
- If the law requires your consent to process data, such as sending you emails that promote our interests, then we will obtain it before carrying out that activity.
- Other activities are carried out to fulfil a contract or agreement, for example if you hold a licence to use the Project SEARCH model. If a contract is in place then we will process your data based on that contract.
- Sometimes we are legally required to disclose information to another party, for example to reclaim tax on Gift Aid.
- Special category data will be processed on the basis of legitimate interest and if explicit consent has been given to record it or if it has manifestly been made public i.e. the source is reliable and legitimate and would not be considered intrusive or negatively impact the individual and their rights.
- In all other cases the law allows us to process your data if it is in our legitimate interest to do so. We may only do this if we can demonstrate a business need and as long as your “interests and your fundamental rights and freedoms are not overridden.” In practical terms we will carry out an exercise to check that we will not cause any harm by processing your data, that the processing is not over intrusive and that we will only do so in a way which is described in this privacy notice.
The majority of the information we hold about you will have been provided directly by you when you have taken part in one or more of the activities outlined above and for which you will have been issued a fair processing notice.
The data that we collect from you will be processed and managed by the third-party IT supplier operating under direct instruction from DFN. Your data will not be used by our supplier for any purpose other than that specified by DFN.
Supporter and Prospect research
We collect the following classes of information from our key supporters:
- Name(s), address, email, phone and other relevant contact details and preferences
- Records of donations
- Information about our relationship with you, correspondence, meeting notes, attendance at events etc.
- Occupation, professional activity, networks and interests where relevant
- Age and family information, such as partner and children, where relevant
- Special category data. Processing special category data will sometimes be helpful to ensure that we can engage with you in the most appropriate way. For example, if there is a personal connection to someone with, or an individual has, a learning disability/s, autism, or both. We will only process this information under the basis of legitimate interest and if explicit consent has been given to record it or if it has manifestly been made public i.e. the source is reliable and legitimate and would not be considered intrusive or negatively impact the individual and their rights.
- Financial information and interest in philanthropy where relevant
- Records of volunteering
- Use of social media relating to DFN Project SEARCH
- Case studies, photographs and recordings produced to promote the work of DFN Project SEARCH
We keep supporter data secure in our database, which has appropriate security in place. We do not share your data with anyone else or any other organisation unless it is necessary for the purposes for which you have given us the data or described in this notice. For example:
- We will provide information to HMRC on Gift Aided donations as we have a legal obligation to provide this information.
- We may share basic information on the attendees at an event or meeting with the host or a volunteer and who has signed an NDA.
- We may pass your data to another organisation to provide specific services such as a mailing house to send a newsletter. They are not allowed to do anything with your data other than that which we have requested.
- We use anonymised statistical data to create impact reports on our beneficiaries but no personal information is revealed.
In some cases we may supplement the information you have given us with data from elsewhere. As a fundraising organisation, we undertake in-house research and from time to time engage specialist agencies to gather information about you from publicly available sources, for example, Companies House, company websites, ‘rich lists’, social networks, property registers and news archives. We do this to establish your interests and therefore affinity to our work.
We may also carry out wealth screening to establish your capacity to support but you will always have the right to opt out of this processing or any other aspects of your personal data that have been processed.
We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. We also use publicly available sources to carry out due diligence on donors in line with our Ethical Fundraising Policy and to meet money laundering regulations.
This research helps us to understand more about you as an individual so we can focus conversations that we have with you in the most effective way and ensure that we provide you with an experience as a donor or potential donor which is appropriate to you.
If you would prefer us not to use your data in this way please use the contact details below to get in touch.
Other information you provide
In order to request information about DFN, apply for a job or submit an enquiry, you will be asked to submit personal information about yourself (your name, e-mail address, telephone number). Personal information can be given via our website and when you correspond with us by phone or email. This information is used by DFN and the members of our group only for the purposes of fulfilling your request or providing a specified service, and is never given or sold by us to any third party.
We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and uses of our Site with our business partners, trusted affiliates and advertisers for the purposes outlined under cookies and tracking and to improve optimisation of our Site.
How long do we keep your data?
We won’t keep your personal data for longer than is necessary for the purpose we process it, unless there is a compliance or legal obligation to do so. Relationships with donors and a charity are often long-term, so we expect to keep this data for as long as that relationship exists and you are engaging with us.
Sharing your personal information
We do not sell, trade, rent or licence personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users of the Site with our business partners, trusted affiliates and advertisers for the purposes outlined above and to improve optimisation of our Site.
You agree that we have the right to share your personal information with any member of our group, which includes our third-party IT supplier, subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Under GDPR and DPA, DFN recognises and respects that you have rights as an individual providing personal data:
You have the right to request:
- information about how your personal data is processed
- a copy of that personal data
- that anything inaccurate in your personal data is corrected immediately
You can also:
- raise an objection about how your personal data is processed
- request that your personal data is erased if there is no longer a justification for it
- ask that the processing of your personal data is restricted in certain circumstances
Contact us or make a complaint
Contact us if you:
- have a question about anything in this privacy notice
- think that your personal data has been misused or mishandled
You can contact our Data Protection Officer (DPO):
Data Protection Officer
DFN Project SEARCH
10 Norwich St
London, EC4A 1BD
You can also make a complaint to the Information Commissioner, who is an independent regulator.
Telephone: 0303 123 1113
Information Commissioner’s Office
Cheshire SK9 5AF
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies, terms and conditions and cookies policies and that we do not accept any responsibility or liability for these policies or the security measures applied in respect of any such websites. Please check these policies before you submit any personal data to these websites.
If these changes affect how your personal data is processed, we will take reasonable steps to let you know.
Last updated June 2023