Hope for Justice Privacy Policy

Hope for Justice (“we”/“us”) will look after any personal information that you share with us. This is a large part of our values as an organization. We want everyone who engages with us to feel confident about how any personal information that they share will be looked after or used.

This personal information is important to us because it allows us to gather our supporters together to grow a movement to prevent exploitation, rescue victims, restore lives and reform society in the area of modern slavery. Your personal data helps us communicate information, define our programmes, improve our services and fundraise more effectively to achieve our goals.

We are registered with the Information Commissioner for the United Kingdom. Within the UK and EEA our processing and retention of personal information is governed by the General Data Protection Regulations, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003. However, our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements.

Hope for Justice is a charity set up with the express aim of ending slavery worldwide. It is a charity registered in England and Wales (No. 1126097) and Scotland (no. SC045769). Our company number is 06563365 and our registered office is The Lexicon 3^rd Floor, Mount Street, Manchester M2 5NT.

Supporters & Service Users

• Directly from you: You may give us your information when you sign a donor form such as a Guardian (regular giving) form or through our website when you sign up for one of our events, sign up for a Hope Challenge, Pledge your Birthday, join an Abolition Group, book a speaker, book or attend education of training events, contact us to ask about our activities, make a donation to us, fundraise on our behalf, apply for a job or to volunteer, or otherwise give us personal information. Sometimes when you support us, your information is collected or processed by an organisation working for us (e.g. JustGiving, Stewardship, Charities Aid Foundation, Virgin Money Giving, Stripe, GoCardless or a data processing company). Where they are doing it purely on our behalf, we will be responsible for your information at all times.
• When you give permission for other parties to share it with us: Your information may be shared with us by other parties, for example event organisers or fundraising sites like JustGiving, Stewardship, Charities Aid Foundation, Virgin Money Giving or GoCardless. These independent third parties will only share your information with us when you have indicated that you wish to support Hope for Justice with your consent. You should check their Privacy Policy when you provide your information to understand fully how they will process your data.
• From publicly available data: We may collect information from Companies House, the Charities Commission, the electoral roll or information published in newspapers, articles or blogs.
• Social Media: Depending on your settings or the privacy policies for social media and messaging services like Facebook, Instagram, TikTok, WhatsApp or Twitter, you might give us permission to access information from those accounts or services. We may combine information you provide to us with information available from external sources in order to gain a better understanding of our supporters to improve our fundraising methods, products and services.
• When we collect it as you use our website: Like most websites, we use “cookies” to help us make our site – and the way you use it – better. Cookies mean that a website will remember you. They’re small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields. There are more details in our Cookies Policy (see below). In addition, the type of device you’re using to access our website or apps and the settings on that device may provide us with information about your device.

Those we seek to help

• Directly from you: We will collect personal data including sensitive data from you upon receiving your consent in a Form of Authority.
• Indirectly from other parties: We may receive personal data, including sensitive data, about you from other agencies that are involved in helping you. These could include social services, employers, law enforcement, individuals or other Non-Governmental Organisations.

Supporters & Service Users

• Personal identifiers such as your title, name and year of birth (to verify that you are 18 years or over);
• Contact details such as email address, postal address, post code and telephone number;
• Bank details if you become a regular donor;
• Whether you are a UK tax payer for Gift Aid purposes if relevant;
• Records of your contact with us and activities you undertake to promote us or fundraise on our behalf.
• If you are under 16, you must get your parent or guardian’s permission before sharing any personal data with us.

Those we seek to help

• Personal identifiers such as your title, name and year of birth;
• Contact details including email address, postal address, post code and telephone number;
• Sensitive data including but not limited to age, gender, sexuality, nationality, ethnic origin and medical history.

We will only use personal information in the ways that are expected and necessary.

Supporters

• We will keep you up to date with our work including: how we are campaigning to improve the situation for victims of Modern Slavery; raising awareness and promoting understanding of Modern Slavery; fundraising purposes.
• Provide or administer all activities related to the work we do including updating you with important information; help identify you when you contact us; and to help us maintain appropriate records.
• Improve our work with you. We may use your information to improve our services to you, to fulfil purchase orders, gift aid declarations (UK only), to improve our information and communications or to make our website better service your needs.
• Provide information to you about what we are doing. This may include letting you know about services we offer now and hope to offer in the future; providing you with information which may be of interest to you, news and events; and/or providing you with fundraising updates.

We will do this with your consent and you can change your mind and remove or add your consent at any time by contacting us.

Direct Marketing

With your consent, we will contact you for the following purposes:

• To keep you informed of our ongoing activities, news, campaigns and appeals;
• To invite you to events we think you might be interested in.

We will only contact you in the ways you have specified, and our forms have clear marketing preference questions. We also include information on how to opt out when we send you marketing. If you do not want to hear from us, let us know when you provide your data, or contact us on: 0300 008 8000 or info@hopeforjustice.org

Those we seek to help

• Provide you with advice and support that you have asked for. This could be advice after being identified as a victim of Modern Slavery, advice through our publications or other services or advice given to third parties about an individual;
• Provide or administer all activities related to the work we do including updating you with important information; help identify you when you contact us; and to help us maintain appropriate records;
• Analyse the personal information we collect so that we can better understand trends in Modern Slavery, understand your needs as a victim of Modern Slavery, and understand supporters’ needs. This then informs of wider internal and external practices, legislation, policies and procedures;
• We may need to disclose your information if we are required to do so by law (for example to comply with applicable laws, regulations, codes of practice or in response to a request from a competent authority); or in order to enforce other agreements.
• Subject to your consent, we may use your story as a victim of Modern Slavery, on an anonymized basis, to draw attention to the issue, promote our activities and campaign to achieve the end of slavery.
• Particularly Sensitive Information: If you contact us for advice by telephone, email or because we have assisted in identifying you as a victim of Modern Slavery you may provide information which is very sensitive. We will use this data for the purposes of dealing with your enquiry; training; quality-monitoring; evaluating the services; assessing trends in Modern Slavery, including support gaps which then informs changes to policy and law which need to be made. We will not pass on your personal details to another person without your permission except in exceptional circumstances. Examples of this might be if you report serious issues such as self-harm, and/or you pose a threat to others; to prevent or detect crime, including if you disclose to us other victims in the same situation as you; or if we are required to do so by law, for instance if the court orders us to disclose information. Additionally, we can process and pass on your personal data without consent if the data is anonymized.
• If you provide us with sensitive personal data by telephone, email or by any other means we will treat this information with extra care and in accordance with this Privacy Policy.

• Consent: All new supporters and service users from 1st April 2018 will have their data processed on the basis of consent. If, before 1st April 2018, you were on our database as a supporter but not a donor, we will process your data on the basis of fresh consent received before 25th May 2018.• Legitimate Interest: We have carried out a Legitimate Interest assessment and have determined that all supporters who were donors at 1st April 2018 will have their data processed on the basis of Legitimate Interest.• Contractual: We process personal data relating to employees and volunteers on the contractual basis.

Where you provide personal data and sensitive personal data when applying for a job with us, such as the information on your CV, we will process, store and disclose the personal data we collect to:

• Support the recruitment process;
• Enable you to submit your CV, apply online for jobs and to subscribe for alerts about job types of interest to you;
• Answer any questions you may have;
• Use any third parties to provide services such as references, qualifications, criminal referencing, checking services, verification of information you have provided, health screening and psychometric evaluation or skills tests;
• Provide anonymized data to monitor compliance with our Equality and Diversity Policy.

Where you provide personal or sensitive data, such as dietary, mobility requirements or health information, to volunteer or travel on a trip with us, we will store, process and disclose the personal information we collect to:

• Deliver the volunteering opportunity, including the disclosure of sensitive data, such as medical information, to our partner(s) to deliver a safe trip or event for all involved;
• Provide information including fundraising materials or equivalent of the volunteer role description;
• Provide the administration of these events or opportunities to serve;
• Monitor the quality of the volunteering opportunity or trip provided;
• Answer any questions or feedback you may have;
• Provide anonymized data to monitor compliance with our Equality and Diversity policy.

The personal information we collect about you may be looked at by staff and volunteers on a ‘need–to-know’ basis, so that we can best know how to help you and deliver services to you. We also work with other organizations that assist us or act on our behalf to deliver services.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by the appropriate personnel.

Additionally, we may have to disclose your personal information to legal, statutory or regulatory authorities if required to do so by law.

This never involves us selling or sharing your personal information with organizations so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.

We will only ever share your data in other circumstances if we have your explicit and informed consent.

We may occasionally for the purposes of our legitimate interests use your personal information to conduct profiling of our supporters or potential supporters. This will help us target communications in a more focused, efficient and cost-effective way, helping us reduce the chances of supporters and potential supporters receiving inappropriate or irrelevant communications. You can object to such use of your personal information for profiling at any time by contacting us at the details set out at the end of this Privacy Notice.

Our profiling and analysis activities usually fall into four categories:

1) Segmenting

We conduct analysis of supporters by group, post code or particular area where supporters may be based. This is to ensure that campaigns or mailings are sent to those who will be most interested or likely to respond. This type of activity is not aimed at identifying specific individuals to target, but rather many individuals who may fall within a certain segment of supporters.

2) Major donor analysis

We may carry out research to determine whether an individual could be a potential major donor. We may use publicly available information from third party sources such as Google; Companies House; Mint UK; Wealth-X; published biographies and publicly available LinkedIn profiles. The type of information we collect can include:

• career overview
• gift capacity
• areas of interest
• history of giving to us and others
• how the individual is connected with us and others
• public information on any philanthropic activities.

3) High value event planning

We may also use profiling to produce short biographies of people who are due to meet with our leadership or attend an event that we may be hosting. This helps our people to understand more about those we engage with, and their interests or connection to us.

4) Ethical screening and minimising risk

As a registered charity, we are subject to a number of legal and regulatory obligations and standards. The public naturally expect charities to operate in an ethical manner and this is integral to developing high levels of trust and demonstrating our integrity. This means that we may carry out appropriate due diligence of donors, check donations and implement robust financial controls to help protect the charity from abuse, fraud and/or money laundering. We may carry out background checks and due diligence on potential donors or anyone planning on making a significant donation or gift before we can accept it.

We value you whether you are a supporter, donor or client and we always like to keep donors and supporters updated with our progress, plans and how you can support us. Where you have given your consent, we would like to keep in touch with you by post, telephone, email text and any other electronic means.

We respect any information that you share and you can change your mind and remove or add your consent at any time by contacting us at info@hopeforjustice.org or following the unsubscribe instructions on communications you receive.

If you consent to us having your information you also consent to us:

• Using data processors whose servers are not located in the UK. If this is the case we will ensure the correct legal protections and agreements are in place to control this processing;
• Transferring your information to countries or jurisdictions which may not provide the same level of data protection as the European Economic Area (“EEA”). This may include transfers to and from the UK, United States of America, and other countries in which we operate. We do take steps to ensure that your personal information is treated securely and in accordance with this policy and any applicable law.

We retain personal information for as long as we reasonably require it for legal or business purposes. Personal information is normally stored for the periods set out in our Data Retention Policy. In determining data retention periods, we consider local laws, contractual obligations, and your expectations and requirements.

To request a copy of our Data Retention Policy, contact Hope for Justice:

• In writing – To the Data Protection Administrator at Hope for Justice, PO Box 5527, Manchester, M61 0QU. United Kingdom.
• By telephone – +44 (0)300 008 8000
• By email info@hopeforjustice.org

We take the security of your personal information extremely seriously. We’ve implemented appropriate physical, technical and organizational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss. We only keep information as long as is reasonable and necessary, which may be to fulfil statutory obligations (for example, the collection of Gift Aid – UK only).

Here are the ways we protect your personal information:

• Online, we strive to protect your information but it is not possible to guarantee the total security of information over the internet;
• Offline, your personal information is kept securely in our databases, offices and data centres;
• We will take all reasonable steps to protect your personal information, but data can never be guaranteed as 100% secure. Please note that we will not be liable for any breach of security unless we have been negligent;
• Our website may contain links to other sites. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices employed by other sites. Please be aware that advertisers or websites that have links on our site may collect personally identifiable information about you. This privacy policy does not cover the information practices of those websites or advertisers. If you choose to visit links to other sites it is important that you look at these sites’ privacy policies, data protection standards and security procedures before you submit information via these sites, as we have no control over data submitted to or collected by third parties;
• Any credit card details we receive on our website are passed securely to Sage Pay, Stripe, or other similar payment processing partners according to the relevant Payment Card Industry Security Standards.

Your communications with our teams (including by telephone or email) may be monitored and/or recorded for training, quality control and compliance purposes, to ensure that we continuously improve our services to you as a client, customer or supporter.

You may ask us at any time to correct or remove information you think is inaccurate or you no longer wish us to have. You also have a right to know what personal information Hope for Justice holds about you. You can ask us to update your details, or request a copy of your personal information we hold, by contacting Hope for Justice:

• In writing – To the Data Protection Administrator at Hope for Justice, PO Box 5527, Manchester, M61 0QU. United Kingdom.
• By telephone – +44 (0)300 008 8000
• By email info@hopeforjustice.org

Please also contact our data controller using the information above if you require any further information about our confidentiality, data protection or privacy policies.

This Privacy Policy is reviewed regularly to ensure that it reflects the most up to date law and to evaluate how information is used. This Privacy Policy was last updated on September 14th, 2021.

What are cookies?

“Cookie” is a name for a small text file, usually of letters and numbers, which are placed on your computer or other devices like your mobile phone or tablet when you visit a website.

They are widely used and they let websites recognise your device, so that the sites can work, or work better and also gathers information about how you use the site. A cookie, by itself, cannot be used to identify you. A cookie often contains a unique number, which can be used to recognise your computer when a user of your computer returns to a website that it visited previously.

How we use cookies

We only use anonymous analytic cookies to track visits to our site and visitor journeys around our site. As with all statistics about visitors to our website, this tracking is anonymous and aggregate and does not relate to any information we might hold on individuals.

Managing cookies

You can manage website cookies in your browser settings. You always have the choice to have your device warn you each time a cookie is being sent or change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:

• Mozilla Firefox®
• Microsoft®Edge
• Google Chrome™
• Safari®

Third party cookies

We use websites such as Flickr, YouTube and Vimeo to show image galleries and videos promoting and illustrating our work. Pages from these providers may use cookies. As some of these services are based outside of the UK and the EU, they may fall outside of the jurisdiction of EU and UK laws. If you are concerned about this, you can visit the Information Commissioner’s website (www.ico.org.uk) for more information and/or change the cookies settings on your browser as above.

If you share content from our website on social media sites such as Facebook and Twitter, these providers may use cookies. You should check those websites for their cookies policy to understand how they use them. Such third party cookies are not within our control.

This Cookies Policy was last reviewed and updated on September 14th, 2021.