What is Gift Aid?

• When you give it to us directly
  For example, personal information that you submit through our website by making a donation, signing up for our email newsletter or filling in a form to register your interest in our activities, or personal information that you give to us when you communicate with us by email, phone or letter.
• When we obtain it indirectly
  For example, your personal information may be shared with us by third parties including, our business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers and search information providers. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.
• When it is available publicly
  Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us through platforms such as Facebook, Instagram or Twitter).
• When you visit our website
  When you visit our website, we automatically collect the following types of personal information:

1. Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
2. Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

We also collect and use your personal information by using cookies on our website – please see our Cookie Notice.

In general, we may combine your personal information from these different sources for the purposes set out in this Notice.

We may collect, store and otherwise process the following kinds of personal information:

• your name and contact details (including emergency contacts), including postal address, telephone number, email address and, where applicable, social media identity;
• your date of birth and gender;
• your financial information, such as bank details and/ or credit/ debit card details, account holder name, sort code and account number;
• information about your computer/ mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;
• personal descriptions and photographs;
• details of your qualifications/ experience;
• immigration/ emigration information;
• information about our services which you use/ which we consider may be of interest to you; and/ or
• any other personal information which you choose to share with us as per clause 1.

Do we process special categories of data?

The UK General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and political opinions.

In certain situations, the IRCF may collect and/or use these special categories of data (for example, to provide our services to you if you are a beneficiary since we need to know your health information). We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.

Your personal information, however provided to us, will be used for the purposes specified in this Notice. In particular, we may use your personal information:

• to provide you with services, products or information you have requested;
• to provide services to our beneficiaries;
• to provide further information about our work, services, activities or products (where necessary, and only where you have provided your consent to receive such information);
• to process your donations;
• to answer your questions/ requests and communicate with you in general;
• to manage relationships with our supporters and beneficiaries;
• to further our charitable aims in general, including for fundraising activities;
• to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
• to report on the impact and effectiveness of our work;
• to run/ administer our websites, keep them safe and secure and ensure that content is presented in the most effective manner for you and for your device;
• to register, administer and personalise online accounts;
• to register and administer your participation in events;
• to process your application for a job or volunteer role with us when you apply through our Careers page;
• to administer your employment/ other working relationship with us (for example, to pay your salary);
• to provide references, for example to landlords and new employers;
• for training and/ or quality control;
• to audit and/ or administer our accounts;
• to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
• for the prevention of fraud or misuse of services; and/or
• for the establishment, defence and/ or enforcement of legal claims.

The GDPR requires us to rely on one or more lawful basis to use your personal information. We consider the grounds listed below to be relevant:

• Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you fundraising material by email, and we may ask for your explicit consent to collect special categories of your personal information).
• Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
• Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, if you apply to work for/ volunteer with us).
• Where it is in your/ someone else’s vital interests (for example, in case of medical emergency suffered by a beneficiary).
• Where there is a legitimate interest in us doing so.

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).

In broad terms, our “legitimate interests” means the interests of running IRC as a charitable entity and pursuing our aims and ideals; for example providing information about current humanitarian crises, processing donations, administering events and taking applications for volunteers.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

We may also analyse your personal information to create a record of your interests and preferences. This allows us to ensure communications are relevant and timely, to contact you in the most appropriate and relevant way and in general to provide you with an improved supporter experience. It also helps us to understand the background of our supporters so that we can make appropriate requests to those who may be willing and able to give more than they already do, enabling us to raise funds and help clients sooner and more cost-effectively.

As part of this activity, we undertake research and profiling of supporters who may have an interest in, and financial ability to, further support IRCF.

When undertaking research on supporters we may collect information from publicly available sources such as Companies House, the Charity Commission, the Electoral Role, Land Registry, newspaper and online articles, as well as open social media profiles such as LinkedIn. The information we review from these sources includes things such as whether a person is a company director or trustee of a charity and is combined with the information we already hold about you in order to create a profile, which could include an overview of your career, the level of donation/gift you may be able to make, how you are connected to us and others, and your philanthropic and other interests. To undertake this work, as well as to understand our supporters’ capacity to become a potential major donor, we may also draw on publicly available information compiled by third party companies, such as Wealth-X.

We may also use behavioural and transactional profiling which tracks the recency, frequency and value of gifts to the IRCF, which enables us to better target our campaigns and appeals.

We may also ‘segment’ our database of supporters using third parties to assist us with this activity, such as CACI Limited (Acorn) (acorn.caci.co.uk). These organisations provide aggregated data on averages and information relating to the general public (such as consumer attitudes, habits, motivations and behaviours), providing a snapshot of the demographic make-up of different areas of the UK. This type of activity is not aimed at identifying specific individuals. This information helps us target our fundraising to reach new potential supporters, ensuring we reach out to those likely to be interested in our work with the ability to financially support our organisation.

As part of our supporter research and profiling, we apply a balancing test, to ensure that the research is necessary, proportionate and does not override your individual privacy rights or unduly impact on you. We undertake this research on the basis of it being within our ‘legitimate interests’ – see section 4 of this policy which explains what that term means.

If you would prefer us not to use your personal information for supporter research, please let us know by using the contact details below.

We may also undertake due diligence on individuals and organisations before accepting major donations from them – this is in accordance with our legal and regulatory obligations and our own internal risk management procedures.

We may use your contact details to provide you with information about our work, events, services and/ or products that we consider may be of interest to you (for example, about services you previously used, or updates about fundraising appeals and/or volunteering opportunities via our newsletter).

Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law).

Where you have provided us with your consent previously but do not wish to be contacted by us about our projects and/or services in the future, please let us know by email at co*****@**cf.uk. You can opt out of
receiving emails from the IRCF at any time by clicking the “unsubscribe” link at the bottom of our emails.

When you use our secure online donation function you will be directed to a specialist payment services provider who will receive your financial information to process the transaction. We will provide your personal information to the payment services provider only to the extent necessary for the purpose of processing your donation.

When we process children’s personal information, where required we will not do so without their consent or, where required, the consent of a parent/ guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care.

In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see Section 13 below), we will remove it from our records at the relevant time.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

We do not sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice:

1. IRCF Ukraine and other IRCF affiliates;
2. healthcare professionals and organisations involved in the provision of care, facilities and/ or supplies;
3. suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers;
4. parties administering our benefit payments, reward programmes and pension contributions;
5. insurers;
6. financial companies such as Paypal and WorldPay that collect or process donations on our behalf;
7. professional service providers such as accountants and lawyers;
8. parties assisting us with research to monitor the impact/ effectiveness of our services;
9. external fundraising entities/ platforms;
10. news media outlets;
11. social media platforms (certain online identifiers, such as IP address, only);
12. regulatory authorities, such as tax authorities;
13. advertisers and advertising networks (certain online identifiers, such as IP address, only); and/or
14. analytics and search engine providers (certain online identifiers, such as IP address, only).

In particular, we reserve the right to disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets;
• if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
• if we are under any legal or regulatory duty to do so; and/or
• to protect the rights, property or safety of IRCF, its personnel, users, visitors or others.

IRCF is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.

Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers with features enacted to prevent unauthorised access.

Given that we are part of an international organisation and because we use agencies and/ or suppliers to process personal information on our behalf, it is possible that personal information we collect from you will be transferred to and stored in a location outside the UK and European Economic Area (“EEA”), for example the United States

Please note that some countries outside of the UK and EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the UK and EEA in a country that does not offer an equivalent standard of protection to the UK and EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Notice. If you have any questions about the transfer of your personal information, please contact us using the details below.

Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.

Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:

• Right of access – you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
   
• Right of erasure – at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.
   
• Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.
   
• Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
   
• Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
   
• Right to data portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.
   
• Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by UK law to which IRCF is subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested to you. Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details below.

You are further entitled to make a complaint about us or the way we have processed your personal information to the data protection supervisory authority in your home country. In the UK, the data protection authority is the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us using the details below.

We may update this Notice from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an update notice on our website. This Notice was last updated on 08 December 2024.

We link our website directly to other sites. This Notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.

Please let us know if you have any questions or concerns about this Notice or about the way in which IRCF processes your personal information by contacting us at the following channels:

• Email: co*****@**cf.uk
• Telephone: +44 808 273 47 55
• Post: Infrastructure Restoration Charitable Foundation, 4. St. Lukes Yard, London, W9 3AN