Operation Fistula collects and holds information about you as a legitimate interest as defined under the General Data Protection Regulations. This privacy policy explains how we use any personal information that we collect about you. It also informs you of your rights and our responsibilities in the processing of your personal information under the General Data Protection Regulations.
Operation Fistula
Who We Are
Operation Fistula is a charity registered in England & Wales (No 1162031) and is registered as a company limited by guarantee in the UK (No 9542896).
Operation Fistula is headquartered in London:
Shakespeare House
168 Lavender Hill
London
SW11 5TG
We also have an office in the USA:
401 Congress Avenue
Suite 1540
Austin
TX 78701
If you are a resident of the European Union (“EU”), Operation Fistula (UK) is the controller of your personal data for the purposes of EU data protection law.
Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through our work.
How to Contact us
If you have any questions or concerns regarding our Privacy Policy or our processing of your personal information, please contact:
Operation Fistula
Shakespeare House
168 Lavender Hill
London
SW11 5TG
Notification of Change of Privacy Policy
We may update this privacy statement from time to time. To keep up to date with changes, please periodically visit this section of our website.
Personal Information
How we collect personal information
We may collect information about you whenever you interact with us.
- We may collect information about you when you directly interact with us. For example, when you contact Operation Fistula regarding our activities, register as a supporter, send or receive information, engage with our social media or make a donation to us, you may provide us with your personal information.
- We may also receive information about you when you interact with third parties with whom we work. For example, where you’ve made a donation to us through a third-party website (e.g. “Just Giving”) and given them permission to share your information with us.
- We may supplement what we know about you with information that is available to the public. For example, in order to ensure that our communication with you is relevant and tailored to your background and interests, we may collect information about you from publicly-available sources – either directly or through third-party subscription services or service providers. See ‘How will we combine and analyze the information we collect about you?
- We may collect aggregated or anonymous information when you visit our website or interact with our content. For example, we may collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our website or view and interact with our content. Please see the “Cookies” section below for more detail.
The types of personal information we collect
About you
The information we collect from you directly, or from third parties with whom we work, may include:
• name;
• address;
• email address;
• telephone number;
• contact preferences;
• bank account details for setting up a regular direct debit;
• credit card details for processing credit card payments;
• employer details for processing a payroll gift;
• taxpayer status for claiming Gift Aid; and
• date of birth, age, and/or gender, where appropriate (e.g. for event enrollment).
About your use of our website
If you visit our website, we may record information about:
• the areas of the website you visit
• the amount of time you spend on the site
• whether you are new to the site, or have visited it before
• how you came to our website – for example, through an email link or a search engine
• the type of device and browser you use
We do this by using cookies, which you can learn more about in this document.
About your interactions with us
We may also collect and process information about your interactions with us, including details about our contacts with you through email, SMS, post, on the phone or in person (i.e., the date, time, and method of contact), details about donations you make to us, events or activities that you register for or attend and any other support you provide to us. We may also collect and record any other relevant information you share with us about yourself, including your interests or your affiliations with other charities, community groups, your employer or a corporate partner.
Your financial information
If you use your credit or debit card to donate to us, buy something or make a booking online, we pass your card details securely to our payment processing partner as part of the payment process. We do this in accordance with the Payment Card Industry (PCI) Data Security Standard (DSS) and don’t store the details on our website or databases. All online financial transactions will be encrypted using a recognized security layer.
‘Sensitive’ personal information
Under data protection law, certain categories of personal information are classed as “sensitive personal data”, including and information regarding your health, race, religious beliefs, sexual orientation and political opinions. We do not knowingly collect sensitive personal data about you.
How we use your personal information
We may use your information in a number of ways, including:
• To provide you with information, products or services that you have requested from us;
• To provide you with information, products or services that we feel may be of interest to you;
• To provide you with information about our work or our activities;
• To invite you to participate in interactive features on our website;
• To process donations that we receive from you;
• To fundraise in accordance with our internal procedures;
• For administrative purposes (for example, we may contact you regarding an event for which you have registered, to provide information requested from us, or with a query regarding a donation you may have made to us);
• For internal record keeping relating to any donations, feedback, or complaints;
• To invite you to participate in voluntary surveys or research;
• To contact you where you have been identified as a contact person for an organization, such as a school (if we obtain your contact details in this way, we will only use them to contact you in your capacity as a representative of that organization);
• To analyze and improve the content and operation of our website;
• To analyze and improve our internal business processes;
• To analyze the personal information that 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;
• To tailor advertising that is presented to you on the internet according to your interests, preferences and other characteristics (as described below);
• To direct advertisements and other communications to other people who may have similar interests or other characteristics to yours (as described below);
• To assess your personal information for the purposes of credit risk reduction or fraud prevention; and
• Where we are required by law to disclose or otherwise use your information.
In particular, we may contact you for marketing purposes by email or text message if you have agreed to be contacted in this manner. We may also send you service communications via email or text, for example where you place an order for goods or services on our website, or you have made a donation by text.
If you have provided us with your postal address or telephone number, we may send you information about our work or other communications of the kinds described above by direct mail or contact you by telephone unless you have told us that you would prefer not to hear from us in this way. We provide information about how you can change your marketing preferences below.
How we combine and analyze your personal information
We strive to carefully manage the communications that we send you, to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications.
In order to do this, we may combine the information that we collect about you and analyze what we know about your interests, preferences and level of potential engagement or donation. We may also use statistical analysis to analyze this data and understand the likelihood that you will be interested in or responsive to a campaign or message. We may use third party service providers to assist us in this process. For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.
Where we have identified that you have the capacity or affinity to support Operation Fistula at a higher level, we may collect additional information about you (see ‘the types of information we collect’) and combine and analyze that information in a profile of you that will assist us in engaging with you in a more personalized way.
You can opt out of your data being combined and analyzed for marketing purposes by contacting us as described below. However, this may mean that you stop receiving marketing communications from us more generally.
In accordance with our legal and regulatory obligations and our internal policies and procedures, we may also use personal information to carry out due diligence on potential or actual donors. If you opt out of analysis of your data for due diligence purposes, we may not be able to accept donations from you.
Disclosure of your personal information to outside parties
Operation Fistula may provide your information to our service providers. Subject to your communication preferences and our internal policies and procedures, this would include providing your information to third parties that work with us to deliver on our charitable purposes, and other entities that act as fundraisers for Operation Fistula, sell Operation Fistula products or provide Operation Fistula with marketing information and services.
Where you have agreed to receive email or SMS marketing communications from us, we may provide your email address or mobile phone number in an encrypted format to social media companies, such as Facebook, Instagram, Twitter or YouTube, or to digital advertising networks that are providing services to us, by displaying our advertising to you on those social media platforms and other websites, as well as identifying audiences with interests similar to yours. You can opt out of your data being used to display advertising to you by contacting us as described below. However, this will not prevent our advertisements being shown to you on a randomized basis or based on cookie data and may mean that you stop receiving marketing communications from us more generally.
We endeavor to enter into contracts with all of these service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.
We will never sell your details. Except as indicated below, we will only share your details with third parties (who are not service providers working at our direction) if you ask us to. We will not make cold telephone calls to members of the general public and, therefore, will not purchase your data in order to do so.
We may disclose your personal information if we are requested or required to do so by a regulator or law enforcement or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect Operation Fistula, for example in cases of suspected fraud or defamation, or in order to comply with any other applicable legal obligation.
Our legitimate interests in your personal information
Our Privacy Policy takes into account several laws, including:
- the Data Protection Act 1998
- the Privacy and Electronic Communications (EC Directive) Regulations 2003
- General Data Protection Regulation (EU) 2016/679, which will come into force in the UK in May 2018 and replace the Data Protection Act 1998.
Generally, our processing of your personal information as described in this policy is allowed by these laws because we have a legitimate need to carry out the processing for the purposes described above. Some processing may also be necessary so that we can perform a contract with you or because it is required by law. We only use your information to send you marketing communications by email or text with your consent, and you can always opt out of receipt of marketing communications by post or telephone as explained in this document.
Recruitment & Staff
Applicants
If you apply to work or volunteer at the Operation Fistula, we will use the information that you give us to process your application, assess your suitability for the role and to monitor recruitment statistics. We may be required to disclose information to someone outside the Operation Fistula – for example, if we need a reference, or need to get a ‘disclosure’ from the Criminal Records Bureau. If this is the case, we will make sure that we tell you beforehand.
International roles
When recruiting for a post based in another country, Operation Fistula will sometimes need to transfer your personal information to that country to progress the recruitment. It may be that that country does not provide the same level of data protection as in the European Economic Area.
Unsuccessful applicants
If you are unsuccessful in your job application, we will hold your personal information for 12 months after we’ve finished recruiting the post you applied for. After this date, we will destroy or delete your information.
If you begin employment or volunteering with us, we will put together a file about you for Human Resources purposes. We will keep the information in this file secure, and will only use it for matters that apply directly to your volunteering or employment. Once you stop working for us, we will keep this file according to our record retention guidelines. You can contact us to find out more about this.
Cookies*
Types of cookies:
There are two broad types of cookies – ‘first party cookies’ and ‘third party cookies’:
First party cookies are cookies that are served directly by the website operator to your computer, and are often used to recognize your computer when it revisits that site and to remember your preferences as you browse the site. Basically, these are our cookies.
Third party cookies are served by a service provider on behalf of the website operator, and can be used by the service provider to recognize your computer when you visit other web sites. Third party cookies are most commonly used for web site analytics or advertising purposes.
In addition, cookies may be either ‘session cookies’ or ‘persistent cookies’. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached. We use both session and persistent cookies.
Categories of cookies we use:
1. Strictly necessary cookies: These cookies are essential for the user to move around the website and to use its features, e.g. shopping baskets and e-billing.
2. Performance cookies: These cookies collect information about how the user makes use of the site, e.g. which pages the user visits most. These cookies do not collect information that identifies the user.
3. Functionality cookies: These cookies remember choices made by or attributes of the user and enhance the features and content you experience during your visit to our website, e.g. language, appeals visited or user’s location. This cookie is also used to remember a user’s preferences for a font size, or customizable parts of a web page.
4. Targeting or advertising cookies: These cookies collect information about the users’ browsing habits. This may also include your use of social media sites, e.g. Facebook, etc. or how you interact with our website which then shows you relevant content elsewhere on the internet. NB. These may also be used to choose the advertisements that are displayed to you on our website and other websites.
We have assessed our cookies based on the ICC Cookie Guide. The majority of our cookies fall into the first two categories. However, we may also use cookies on our webpages which are in categories 3 and 4.
*Cookies are small files, typically of letters and numbers, downloaded on to a device when you access certain websites or emails, including Operation Fistula’s website. Cookies allow a website to recognize your device. For more information see: http://www.allaboutcookies.org/.
What information do we collect using cookies?
We may collect some, or all, of the information available from cookies when you visit our website, depending on how you use it. We monitor how people use our website so we can improve it. We collect this information anonymously.
However, you can choose to use our website anonymously without giving us any information. Please see ‘Changing your cookie preferences’ below.
• If you visit our website, we may use cookies to record information about:
• the areas of the website you visit;
• the amount of time you spend on the site;
• whether you are new to the site, or have visited it before;
• the country, region, city and/or borough associated with your IP address or device;
• how you came to our website – for example, through an email link or a search engine;
• the type of device and browser you use;
• how you use the website and the quality of your experience – for example we may track your bandwidth when viewing videos;
• how you interact with our donation and sign up forms – for example what you select as your communication preferences; and
• any error messages that you receive on the site.
We use cookies to track how visitors come to our site. For example, we may use marketing or referring tracking codes in internet addresses (URLs) to show us whether a visitor has come to our site via a link on a referring website or in a specific piece of marketing and to give us insight into the effectiveness of our marketing.
Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously and we do not share it.
Cookie Consent
By using our website, our social media pages (such as Facebook, Twitter, YouTube, Google+ and Instagram), subscribing to our services, donating to us and/or shopping online, you agree that, unless you have set your computer’s browser to reject them, we can place the types of cookies set out below on your device and use that data in accordance with this policy.
How do you disable cookies?
Your browser will have cookie management abilities in the preferences settings, enabling you to delete or block Operation Fistula’s website cookies. Some common browsers are linked below:
• Internet Explorer cookie management
• Firefox cookie management
• Chrome cookie management
• Safari cookie management
Find more detailed information on disabling cookies from aboutcookies.org or from the help function in your browser.
Website analytics
Our website currently uses two analytics services:
1. Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which (as discussed above) are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more details, please read Google’s Analytics overview.
You can always opt-out of Google Analytics cookies by Google’s opt-out tool.
2. HubSpot analytics services. HubSpot uses “cookies”, which help the website analyze how users use the site. HubSpot uses the information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
HubSpot may also transfer this information to third parties where required to do so by law, or where such third parties process the information on HubSpot’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.
By using our website, you consent to the processing of data about you by HubSpot in the manner and for the purposes set out above. For more details please read HubSpot’s Privacy Policy.
Other third-party cookies
You may notice some other cookies that are not related to the Operation Fistula’s website whilst visiting www.opfistula.org. Some of our pages may contain embedded content such as a YouTube video, Twitter feed, Facebook likes or Google plus share. You may receive cookies delivered from these websites, but as Operation Fistula does not govern the publication of third-party cookies, please visit the relevant sites to understand more about their cookies and privacy statements.
If you do not want cookies to be stored on your PC it is possible to disable this function without affecting your navigation around the site.
Protecting Your Personal Information
How we protect your personal information
We take appropriate physical, electronic and managerial measures to ensure that we keep your information secure, accurate and up to date, and that we only keep it as long as is reasonable and necessary.
Although we use appropriate security measures once we have received your personal information, the transmission of information over the internet is never completely secure. We do our best to protect personal information, but we cannot guarantee the security of information transmitted to our website, so any transmission is at the user’s own risk. However, any payment card details (such as credit or debit cards) we receive on our website are passed securely to our payment processing provider according to the Payment Card Industry Security Standards.
For financial and technical reasons, we may, on occasion, need to use the services of a service provider outside the European Economic Area (EEA) – this may include a country which does not have the same level of data protection as in the United Kingdom. However, unless they are located in a country which has been assessed by the European Commission as ensuring an adequate level of protection for personal data, we will only use a service provider outside the EEA on the basis of an agreement with the service provider, designed to protect your data, in the appropriate form approved for this purpose by the European Commission. We will take all steps reasonably necessary to ensure that your data is processed securely and in accordance with this Privacy Policy.
Emails Terms of Use
Emails aren’t always secure, and they may be intercepted or changed after they’ve been sent. Operation Fistula doesn’t accept liability if this happens. Please do not send Operation Fistula any financial data through email.
The contents of emails reflect their author’s views and not necessarily those of Operation Fistula.
Children’s data
When you register with us, you are stating that you are 16 years of age or over, or are a minor acting with parental consent. You agree that any information you provide to us about yourself upon registration or at any time is true.
Confidentiality
We cannot be held responsible for the privacy of data collected by websites not owned or managed by Operation Fistula, including those linked through our website.
Your Rights
Accessing your personal information
You may request a copy of the personal information relating to you, which is kept on file by Operation Fistula. We will not charge you for this.
Controlling your preferences
We strive to make it clear and easy for you to choose how you hear from us. If you do not wish for us to use your personal data for marketing purposes (as outlined above) you can use the relevant box on the form that we use to collect your data to indicate your preference.
You can also change any of your marketing preferences at any time (including telling us that you don’t want us to contact you for marketing purposes) by:
- Indicating that you do not wish to receive our marketing emails by clicking the ‘unsubscribe’ link in at the end of our emails;
- Asking us to stop sending you marketing texts by sending us an “opt-out” text message, following the instructions we provide you in the marketing texts you receive from us;
- Contacting us by post at the address provided above.
- Entering your details on the Fundraising Preference Service (FPS) website and choosing ‘Operation Fistula (Charity Number 1162031). This service is run by the Fundraising Regulator and allows you to stop email, telephone, addressed post, and/or text messages from a selected charity or charities by using the online service at www.fundraisingpreference.org.uk or by calling the telephone helpline on 0300 303 3517. Once you have made a request through the FPS, we will ensure that your new preferences take effect within 28 days of your request. More information about the FPS can be found here.
If you have indicated that you do not wish to be contacted for marketing purposes, we may maintain your details on a suppression list to help ensure that we do not continue to contact you for marketing purposes. However, we may still need to contact you for administrative purposes, including (but not limited to):
- Processing a donation that you have made and any related Gift Aid;
- Providing you with the information you need in order to participate in an activity or event for which you have registered and
- Explaining and apologizing where we have made a mistake.
Updating your information
If your contact details have changed or you think any information we have about you is incorrect or incomplete, please update or correct the information we hold about you by contacting us, as explained above.
Raising complaints or concerns
You can make a complaint or raise a concern about how we process your personal data by contacting us. In some circumstances, you have the right to object to our processing of your personal data or to stop us from continuing to make active use of personal data that we retain in our records.
If you are not happy with how we have handled your complaint, you can contact the Office of the Information Commissioner, which oversees the protection of personal data in the UK, or the Fundraising Regulator, which is responsible for overseeing fundraising activities carried out by charities in the UK.
Alternatively, you may choose to contact either the Information Commissioner or the Fundraising Regulator directly about your complaint, regardless of whether you have raised it with us first.
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