Introduction
JUSTICE takes the privacy of its supporters very seriously and adheres to all aspects of UK General Data Protection Regulation (UKGDPR).
This is our Privacy Policy, where we tell you how we use and look after your personal information. This privacy policy tells you what to expect us to do with your personal information. We will tell you what information we collect about you, how we use this data, with whom we share it, and how we store it and keep it safe. As we collect and process data from different groups of people, the policy is broken down into smaller sections. The first section is for everyone to read, this is followed by sections which are written especially for the type of interaction you have with us.
The main points to note are:
- We will only ask for what we really need to know.
- We will collect and use the personal data that you share with us transparently, honestly and fairly.
- We will always respect your choices around the data that you share with us and the communication channels that you ask us to use.
- We will put appropriate security measures in place to protect the personal data that you share.
- We never intentionally sell, rent, or share your details without your consent and/or unless we have a legitimate interest in doing so.
- We will never intentionally share your details with other organisations for the purposes of their own marketing.
- We may share your personal data with third party organisations who are completing a service on our behalf but only where we have your permission or where we have a legitimate interest in doing so, such as to better understand the background and interests of our supporters and potential supporters and to ensure we allocate our resources more effectively and raise funds sooner and in a cost-effective manner.
- You can visit our website without revealing identifying details such as your name, email or IP address according to our Cookies policy which you can access here.
- You can opt out of any part of our policy that does not suit you at any time by contacting dataprotection@justice.org.uk
By visiting our website, using our services or participating in our activities, you agree to your personal information being collected and used in the manner set out in this Privacy Policy as updated from time to time. When updated, should there be any material changes and/or changes that could negatively impact you we will make reasonable efforts to notify you in advance and give a reasonable period of time for you to object to such changes. When making smaller changes, we’ll update this notice and post a summary of the changes on our website. We last updated our privacy notice in October 2023.
If you have any requests concerning your personal information or our practices, please contact dataprotection@justice.org.uk.
This Policy explains the privacy and the data protection practices about:
- Who we are
- Why we collect your data
- How you are in control
- Changes to this Policy
- For supporters and volunteers of our charity
- What personal information is collected
- How we get and use your information
- Profiles and Screening
- What information we disclose to other parties
- How we store personal information and how long we keep your information for
- Online security
- For job applicants, voluntary staff and Trustees
- What personal information is collected
- How we get and use your information
- How we store personal information and how long we keep your information for
- Online security
- For website users
- Cookies
- Online security
- Links to other website
Who we are
JUSTICE is a cross-party law reform and human rights organisation working to strengthen the justice system – administrative, civil and criminal – in the United Kingdom. We are a membership organisation, primarily of the legal profession, comprising barristers, solicitors, legal executives, academic lawyers, law students and interested non-lawyers. We work on an all-party basis, seeking to inform debate, frame issues and influence decision-makers from across the political spectrum. JUSTICE is a small charity, with limited resources. We rely very heavily on the help – both practical and financial – of our supporters. Without that support we simply could not continue our work. In this policy, the words ‘We’, ‘Us’ or ‘Our’ refer to JUSTICE ‘the charity’.
JUSTICE is a charity registered in England and Wales (1058580) and Scotland (SCO43518). JUSTICE is also a company registered in England and Wales (registered number: 03216897) at 2nd Floor Lincoln House, 296-302 High Holborn, London, WC1V 7JH.
JUSTICE’s Data Protection Representative is Samantha Burridge. You can contact Samantha at dataprotection@justice.org.uk or write to our postal address above.
Why we collect your data
Under law, we use a condition called ‘legitimate interest’ to process your data. We process your data in our legitimate interest to pursue the aims and purpose of JUSTICE through research, providing practical solutions and influencing policy makers for creating a fairer justice system and fundraising through direct marketing campaigns and events. We only process your personal data to the extent that it is necessary to achieve these aims. In doing so, we have balanced the interests of JUSTICE against your individual interests, rights and freedoms.
If you are a supporter (such as member, donor, fundraiser, working party member), follow or engage with us on social media, have attended an event or volunteered with us we have taken the view that in you providing your personal data to us you do so to support the Charity. We will therefore process your data according to the way in which we have received your information as detailed for supporters and volunteers of our charity - How we get and use your information section below.
We may collect data about you if we consider you are a potential supporter or donor and/or be able to assist JUSTICE in other ways such as volunteering or speaking at an event.
How you are in control
We will send you information about JUSTICE according to any preferences you submitted: by phone, post or email. You can alter your preferences by contacting us at dataprotection@justice.org.uk or by calling 02073295100, Monday-Friday, 9am-5pm.
Please note, if you ask us not to contact you for marketing purposes, we will retain your details on our suppression list to ensure we do not accidentally contact you in the future.
You are in control of the data we hold about you and at any time you can request:
- to have any inaccuracies in your personal data corrected
- to restrict the data held about you
- to have a copy of the personal data held about you
- to have your data deleted
You can make a request for any of the above by writing to dataprotection@justice.org.uk. We may request proof of identity to be able to fulfil your request.
Whilst we will endeavour to adhere to your wishes we may not be able to delete your data if there is a legal obligation to retain it, this includes where financial data must be retained for six years or where data must be retained to enable us to defend our legal rights. We will inform you of the basis of any such decision not to delete your data as appropriate.
If you are unhappy or concerned about how JUSTICE collects, uses or stores your personal information, you can let us know by emailing dataprotection@justice.org.uk or writing to: Data Protection Officer, 2nd Floor Lincoln House, 296-302 High Holborn, London, WC1V 7JH
You can also complain to the ICO (the UK supervisory authority for data protection) if you are unhappy with how we have used your data. Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline number: 0303 123 1113. ICO website: https://www.ico.org.uk
Changes to this policy
JUSTICE reserves the right to modify its website and/or this Privacy Policy at any time. When updated, should there be any material changes and/or changes that could negatively impact you we will make reasonable efforts to notify you in advance and give a reasonable period of time for you to object to such changes. When making smaller changes, we’ll update this notice and post a summary of the changes on our website.
The policy was last updated in October 2023.
For supporters and volunteers of our charity
What personal information is collected?
We collect personal information such as: name(s), contact information (for example, postal address, telephone number, email address), donation history, card payment details* or bank details (for Direct Debits)*, accessibility requirements, dietary requirements, relationships, job title and employer, whether a donor pays tax (for Gift Aid), communication preferences, reason for support, and communication history.
We also collect information such as: which web pages you visit, social media used, etc. This is captured using Cookies (see below for more information). We also use newsletter analytics which records and monitors the success of our emails and any click through’s. Any preferences that you have informed us of, such as how you want to hear from us and which aspects of the charity are of particular interest, will also be retained.
At JUSTICE we comply with the GDPR principles of data minimisation and purpose limitation, and only collect information that we need. We only use information for the intended purpose. For example, we only ask for accessibility and dietary requirements in relation to in-person events; and we only ask if an individual is a UK taxpayer to work out if we can claim Gift Aid on their donation or for due diligence purposes.
*Any information you give us relating to credit card and bank account details is handled by a PCI DSS compliant supplier (Blackbaud Merchant Services, Access and SagePay) and encrypted using secure server technology. For more information, please contact dataprotection@justice.org.uk
How we acquire and use your information Most of the information we process for supporters is taken from the information you submit via registration forms. This may be when you join as a member, make a donation, register for an event (Blackbaud NetCommunity), fundraise for us or make a donation towards a fundraising event (JustGiving), complete a survey (SurveyMonkey), follow us, or click through from a social media advert (eg. Facebook, Twitter (X), LinkedIn). We partner with these suppliers to host these forms to provide the best experience to you and anyone who fills out these forms.
JUSTICE is the data controller, and these suppliers are data processors.
We may also process information from written correspondence, meetings and phone calls.
When we collect your information in this way we are either doing so to carry out an agreement with you (contractual performance) or for our legitimate interest, to understand more about our supporters so that we can raise money sustainably to continue the work we do. For example, we will or may process your data for the following purposes:
- Help deal with your enquiry, request, or application.
- If you join us as member, we will use your data to manage your membership subscription and renewals, to keep you updated with our work and events via monthly newsletters and ad hoc emails.
- If you donate to us, we will use your data to record and acknowledge your donation and to keep you informed of our work and future fundraising campaigns.
- Process your membership or a donation and maintain any preferences you have for receiving information from us and to ensure we suppress your contact when you have requested us to do so
- Provide further information about our work, activities or products by email or post.
- Seek your ideas and feedback, via research or surveys.
- Register and administer your conference or event participation and we may reach out to you about the charities work, fundraising efforts, events or with other items that we deem relevant to your experience with JUSTICE.
- When you follow us on social media or engage with us on social media we may use this information to tailor communications to you, engage you in our work or fundraising including potential screening, profiling, or marketing.
- Use in-house tools and public domain information to analyse who supports us or receives services from us and in what ways.
- Use the insight to improve our work, services, fundraising activities and communications.
- Provide a more personalised service, such as using your details, interests and behaviours to customise communications we may send you or the web pages you see.
- Screening and profiling (see further below)
- Provide it to a professional body if required by law or to comply with a legal process.
- Notify you about changes to our Service.
- In each of the cases listed above, one of the reasons for collecting your data may be to enable us to reach out to you about the charities work, fundraising efforts, events or with other items that we deem relevant to your experience with JUSTICE.
We only process your personal data to the extent that it is necessary to achieve these aims. In doing so, we have balanced the interests of JUSTICE against your individual interests, rights and freedoms.
Data can also be shared with us by other companies, such as JustGiving who share information with us, such as your name, contact information and communication preferences provided you have given your consent. This enables us to say thank you and where appropriate send follow up communications and information about fundraising events and ask for donations in the future.
We may also collect information about you from third party screening, profiling, marketing or insight companies or AI software to assist us in ensuring that our communications with you are relevant (see profiling section below).
JUSTICE may also work with companies to look at the personal information we store in our database Raisers Edge and match it against publicly available records to add value to our database and improve the quality of the data. JUSTICE has a legitimate interest in working with these companies. It helps us to avoid sending communications to people who are recently deceased. We may record home moves and changes of address where the data is publicly available. This helps us to save money by only contacting those people who would be most interested in our communications. JUSTICE is the data controller, and the companies are the data processor.
We also work with companies to research the potential of donors and fundraisers to be a significant donor and collect additional details relating to their employment and any philanthropic activity. We may estimate gift capacity, based on visible assets, history of charitable giving and their connection to JUSTICE. JUSTICE has a legitimate interest in working with these companies. It helps us to understand our donors and fundraisers more and means that we can be more cost-effective. JUSTICE is the data controller, and the companies are the data processor. For clarity we have provided more details on this below.
Profiles and Screening
- At JUSTICE, our critical work is only made possible thanks to the generosity of our supporters – so it is vital that our fundraising efforts are as effective as they can be. By developing a better understanding of our supporters through our own research of them using publicly available sources such as published rich lists, newspapers and corporate websites, we can tailor and target our fundraising events, communications and approaches (including volunteering and speaking opportunities) to those most likely to be interested in them. This research helps us to understand more about you as an individual so we can focus conversations we have with you about fundraising and volunteering in the most effective and appropriate way.
- We may also carry out our own 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. This may include people connected to our current major supporters, trustees or other lead volunteers. This allows us to be more efficient and cost-effective with our resources and to assist our vital fundraising efforts, and also reduces the risk of someone receiving information that they might find irrelevant or intrusive.
- We may also obtain information about potential donors or individuals, such as wealth indicators, who might want to support us by fundraising or by speaking about their experiences with the legal system where these have been shared publicly, where they have not previously provided us with information.
- Additionally, as part of our legitimate interests, we have considered that screening is an effective way for us to ensure that we are contacting you with appropriate and relevant messages. We operate a number of different programmes to nurture support and want to make sure that when we make a request of any of our supporters, it is an appropriate one. As such, in some instances, we do make use of third-party screening and insight companies who combine information we provide about our supporters with publicly available information to help us determine which of our supporter programmes any particular supporter is best suited for. We may estimate gift capacity, based on visible assets, history of charitable giving and their connection to JUSTICE. This helps us to understand our donors and fundraisers more and means that we can be more cost-effective. JUSTICE is the data controller and the companies are the data processor. The information we may provide is set out below in the section entitled “Which information do we use?” We will only provide information to any of these third parties where we have a contract do so to. For information on the current list of suppliers that we use for this activity please contact dataprotection@justice.org.uk
Which information is used for profiling and screening?
- Data which has been provided directly to JUSTICE by supporters is used for profiling and screening (in particular by third party screening and insight companies), for example, when becoming a member or registering for events, and combine this with information from publicly available sources such as: Companies House, the Electoral Register, company websites, ‘rich lists’, social networks such as LinkedIn, political and property registers and news archives and other publicly available information and AI predictive software or insight company information, in order to create a fuller understanding of someone’s interests and support of JUSTICE. We only use reputable sources, where someone would expect their information may be read by the public. We avoid any data that we believe has not been lawfully or ethically obtained, and we do not use information sources which are not publicly accessible.
- Before seeking or accepting major donations we are required to conduct a minimum level of due diligence. This is in accordance with our legal and regulatory obligations and our internal risk management policies and procedures. Your rights - opting out of profiling and screening While this does form a crucial and necessary part of our strategy to secure voluntary income, we are committed to putting you in control of your data and you’re free at any time to opt out of your data being used for profiling or screening. To find out more, please contact dataprotection@justice.org.uk.
What Information we disclose to other parties
We never sell or rent your personal information with other charities or companies for their own marketing purposes.
We do share your information with organisations who are completing a service on our behalf.
The only time your Information is shared with other organisations is or may be:
- Where you have given your permission and/or we have a legitimate interest for us to do so.
- When we are obliged to do so by law such as sending your Information to be checked against the Telephone Preference Service, or if contacted by the authorities with a reasonable request for information.
- To our third-party service providers, business partners, supplier’s agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to process your payments, send you mailings or marketing information). These third parties have access to your Information only to perform these specific tasks on our behalf and are legally obligated not to disclose or use it for any other purpose.
- If you commit to leaving a legacy, we may share your Information with co-beneficiaries.
- If we have a legitimate interest and/or your permission, we may share your Information with analytics and search engine providers or use predictive AI software, insight companies or marketing segmentation companies to better engage and communicate with you.
- We make sure that all suppliers of services take as much care with your data as we do.
Where possible, we ensure that suppliers process your data in the UK, or in the EEA (European Economic Area) and therefore are subject to the same rules as we are.
How we store personal information and how long we keep your information for
We store the data of our members, donors, fundraisers, and event attendees in our database Raiser’s Edge. Raiser’s Edge is hosted in the cloud by Blackbaud, to read more about Blackbaud’s security please visit https://www.blackbaud.com/security. We also use Microsoft business services and stored data in Microsoft’s cloud document and storage system, SharePoint, as well as in other Microsoft applications. To read more about Microsoft’s data storage and security please visit Microsoft’s Trust Centre.
JUSTICE has a Data Retention Policy, which determines how long we store personal information for and we retain data in line with this policy for example if you support our charity by becoming a member, donating, attending an event or signing up to our mailing list, we will keep you details in our database for six years after your last activity, for individuals and indefinitely (with periodic reviews) for organisational records. This is so that if you reconnect with us, we will have history of how you have supported the Charity in the past.
In the event that you ask us to stop sending you direct marketing/fundraising/other electronic communications, we will keep your name on our internal suppression list to ensure that you are not contacted again. We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations (for example the collection of Gift Aid). For more information, please contact dataprotection@justice.org.uk.
Online security
We endeavour to ensure that there are appropriate and proportionate technical and organisational measures to prevent the loss, destruction, misuse, alteration, unauthorised disclosure or of access to your personal information.
Your information is only accessible by appropriately trained staff, volunteers and contractors.
The security of your personal information is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. As such we make no warranties as to the level of security afforded to your data, except that we will always act in accordance with the relevant UK and EU legislation.
For job applicants, voluntary staff and Trustees
What personal information is collected?
We collect personal information such as: name(s), contact information (for example, postal address, telephone number, email address), emergency contact information, marital status, communication preferences, references, proof of ID (e.g. passports, driving license), country of residency, education information, employment history, social mobility information, relevant skills and experience, reason for applying, pre-interview assessment results, interview notes, and photos (with consent).
We may also collect the following sensitive category information: health and medical data, ethnicity and sexual orientation.
At JUSTICE we do our very best to stick to the GDPR principles of data minimisation and purpose limitation, and only collect information that we need when we need it. We only use information for the intended purpose. For example, we only ask for information on religion, ethnicity and sexual orientation for monitoring and evaluation purposes. No one is obliged to provide such personal information and can decline to answer any such questions.
How we get and use your information
We collect personal information when you apply for a paid, voluntary staff position or trustee position via our website. We use information you provide to assess your suitability for a position and contact information to let you know if you have been successful (contractual performance).
We collect special category personal data, such as ethnicity and sexual orientation so that we can ensure that our recruitment processes are fair and unbiased. We also use this anonymised data to help us decide on the best ways of recruiting talent. JUSTICE is collecting information for our legitimate interest, to understand more about our role applicants so that we can make sure that we are providing opportunities to all.
We are also sometimes given personal information by recruitment agencies to increase the number of candidates applying for a position. At first, any information shared by a recruitment agency (the data controller) will be anonymous until we have decided to offer the potential candidate an interview. Only at this point are details such as name and contact details shared at which point JUSTICE will become a data controller of the candidates’ data.
How we store personal information and how long we keep your information for
We store the data of role applicants, trustees and volunteers in Microsoft’s cloud document and storage system, SharePoint, as well as in other Microsoft applications. To read more about Microsoft’s data storage and security please visit Microsoft’s Trust Centre.
JUSTICE has a Data Retention Policy, which determines how long we store personal information for, and we retain data in line with this policy. Sometimes this will be for as long as we are actively using the data. In other cases, there is a legal requirement for us to store data (such as financial data for payroll) for a fixed minimum period of time. For more information, please contact dataprotection@justice.org.uk.
Online security
We endeavour to ensure that there are appropriate technical and organisational measures to prevent the loss, destruction, alteration, unauthorised disclosure or of access to your personal information.
Your information is only accessible by appropriately trained staff, volunteers and contractors.
The security of your Personal Information is important to us but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. As such we make no warranties as to the level of security afforded to your data, except that we will always act in accordance with the relevant UK and EU legislation.
Otherwise, than as set out in this Privacy Policy, we will only ever share your data with your informed consent.
For Website Users
Cookies
We use ‘cookies’ on our website to help us improve its look and feel. To do this, we place cookies on your device. A cookie is a small text file which is placed on your hard drive whenever you visit a website. It collects statistics by tracking your movements and can also be used to identify when you return to a website. For more information, please read our Cookies Policy.
Links to other websites
Our website may contain information linked to or provided by other companies (such as third-party events, etc). They are outside of our control and not covered by this Privacy Policy. Please be aware that, should you access other sites using the links provided, the operators of these sites may have a privacy policy which differs from our own. We do not accept any responsibility or liability for such privacy policies. Please check the relevant policies before you submit any personal data to these websites.