CHILD-FRIENDLY PRIVACY POLICY

Introduction

This document is aimed at under 18s and tells you how, when and why we collect data from people, and what we use it for. Your data is anything that tells us something about you, eg your address, your age, things you’re interested in.

At Toilet Twinning we want to keep any information you give us about you safe.

We only keep information about you if we need to use it for a specific reason, eg to get in touch with you about something. After that, we won’t keep the information. We also won’t give the information to anyone else unless you’ve asked us to.

We also have rules like this for our website, and you can read about that here. There is also a full privacy policy here.

We’d love to hear from you if you want to talk or ask questions about any of this. Just call us on 0300 321 3217 or email info@toilettwinning.org

WHO WE ARE

Toilet Twinning is a water and sanitation charity initiative. We help those in desperate poverty to have access to a latrine, clean water, and the information they need to be healthy.

In this document, when we say ‘us’, ‘we’ or ‘our’, that means Toilet Twinning as part of Tearfund.

Tearfund is a charity registered in England and Wales (number 265464) and Scotland (SC037624). Our company number is 994339 and our registered office is 100 Church Road, Teddington, TW11 8QE.

WHEN AND HOW WE COLLECT INFORMATION

When you get in touch with us

If you give us your personal information, we save it and use it to contact you. Personal information means things like your name and contact details.

You send us these details when you donate, ask us for Toilet Twinning packs or information, sign up for an event, provide comments or complete surveys.

When you visit our website

We collect non-personal data about people who visit our website. That’s things like IP addresses (which tell us, for example, where in the country a person’s computer is when they log on), which pages people visit and which files they download. This helps us find out if our website is working well and helps us make it better. This information is collected using cookies – you can read more about cookies below.

Information you put online

Sometimes we use information that people put on places like Twitter, Facebook or LinkedIn. You can check these organisations’ privacy policies to find out how they use or share your information and to make sure you’re happy with it.

Information we get from other organisations

If you tell them they can, other organisations might send us information about you. This could be an event organiser (for example, a marathon organiser) or a website like Just Giving when you fundraise for Toilet Twinning. You can check their privacy policies to see how they look after information about you.

Personal or private information

If you send us personal information about yourself, for example about your religious beliefs, or your physical or mental health, remember that we might keep this information unless you tell us not to. We only keep this if we need it, for example to keep you safe while you volunteer with us, and we promise to keep it secure.

OUR RULES FOR USING INFORMATION

If you got in contact with us for the first time on or after 25 May 2018

We will only use information about you in the ways you’ve asked us to.

You can change this at any time – see the section ‘Your choices and telling us when things change’ below.

If you had already contacted us by 25 May 2018

We will only email you if you have told us we can. But we might also write to you or call you if we have a clear reason to.

For example, if you send money for our work, we may send you back information about how your money is helping people, or about other work we want to do. But we won’t do that if you’ve already asked us not to. If you’re not happy with how we contact you at the moment, let us know by phone, post or email. See the section ‘Your choices and telling us when things change’ below.

WHAT DO WE DO WITH IT?

Answering requests, Toilet Twinning actions and activities

We may use your personal information to:

  • process Twin Your Toilet requests and donations
  • support your fundraising for us, including sending you things you’ve bought, sending statements and invoices, and collecting payments from you
  • keep you up-to-date on news and stories about our work
  • ask you to give money or help in other ways, eg volunteering
  • process donations you give us, or encourage you when you fundraise for us
  • send out information or packs, for example school packs you’ve asked for
  • make information we give you relevant to you, eg showing you website content that would interest you or putting your name on emails we send you
  • make it easier for you to use our website and find or see things that interest you
  • keep a record of when you’ve been in touch with us or what you’ve done with us, eg toilets twinned

Marketing that’s just for you

We might use your data to:

  • tell you about our work, and how you can get involved, eg volunteering, community fundraising
  • show you, digital advertising about our work, on social media websites such as Google and Facebook. We may also reach out to people who have similar interests to you. For example, we might use Facebook’s Custom Audience Programme. If you have said Tearfund can send you emails, we send Facebook your email address. Facebook then shows adverts about us to you – it will also show our adverts to other people who have said they have similar interests to yours. If you don’t have a Facebook account, Facebook just deletes the information. There are more details on Custom Audiences at Facebook Business, and you can read Facebook’s Privacy policyhere.
  • help us tell you about things that are relevant to you. For example, we will look at where you live and your interests so we can invite you to a local event or tell you about a need to do with a certain topic you’re interested in.
  • do market research – eg finding out about the types of people who might want to support us

Volunteering with us

We use Kingsley Management Consultancy Limited to do the admin for Toilet Twinning. When you apply to volunteer with Toilet Twinning, any personal or private information you send by completing an application form will go to Kingsley Management Consulting Limited.

This could include dietary or mobility requirements or health information. Kingsley Management Consulting Limited will store and use this to:

  • make sure you’re safe and have everything you need so you can volunteer with us. This may include sharing your private personal data, such as medical information, to keep you safe, but only after you have agreed to this
  • give you information, including fundraising materials (see the ‘What do we do with it?’ section) or information about your volunteer role
  • organise events or opportunities to serve
  • check if the volunteer role was a good one
  • answer any questions you may have or take feedback
  • check we’re making these volunteering opportunities and trips available to everyone (equal opportunities policy)

HOW AND WHERE WE STORE YOUR INFORMATION

How long?

We will keep information about you only for as long as we need it to do any of the above things.

In deciding how long we need to keep information for, we think about:

  • what we have to do by law
  • what we have to do to sort out money and tax
  • how we might need to use it to complete the task

When we do this, we follow our data retention policy – this sets down strict rules about how long we can keep information about you.

When you tell us you’re happy for us to contact you, we will keep getting in touch for five years, unless you tell us you don’t want to hear from us anymore. We decided on five years by asking Tearfund’s supporters what they thought would be a good length of time.

If you have any questions about how long we keep information about you, please write to us at:

Data Protection Officer
Toilet Twinning
1052-1054 Christchurch Road
Bournemouth BH7 6DS
United Kingdom

Or email to:
info@toilettwinning.org

Remember if you are 12 or under you will need to get your parent or guardian to do this.

Keeping information about you safe

We have IT controls to make sure we keep safe any information you give us. For example, online forms are encrypted and our network is protected and regularly checked.

The only people allowed to look at your information are Kingsley Management Consulting Limited (who do our administration, fundraising and marketing) and the Tearfund staff or volunteers who can’t do their jobs without it. These people are specially trained so they know how to keep the information safe.

Sometimes we may use other companies to help us organise people’s personal information. We carry out checks on these companies and agree on and sign contracts with them, and then keep checking them regularly. When we do use external companies, it’s still up to us to keep information about you safe.

However, don’t forget that, the internet is never 100 per cent safe, and whenever you share information about yourself there is still a risk.

Credit/debit card security

Each time you or a parent or guardian makes a donation or payment through our website, it goes through PayPal or Stripe. You can read PayPal’s ‘Privacy Policy for PayPal Services’ at Paypal.com. We also sometimes use Stripe – for more information visit Stripe.com/gb/privacy.

We do not keep any credit or debit card details – that information is all kept by PayPal or Stripe.

Where we store your personal information

We use cloud-based systems, eg Google drive, to organise information about you – that means the information might be sent outside the European Economic Area (EEA) while it’s being organised. We only let this happen when we believe the information will be kept secure. We do everything we can to make sure information about you is kept safe as described in this document.

By sending us information, you agree to us using the cloud-based system to store and organise it.

WHEN WE SHARE YOUR INFORMATION

In line with our values, and the importance we place on privacy, we do not share or swap your information with any other charities for them to send you marketing.

When we have to share information by law

We may need to pass on information if required by law or by organisations such as the police or Charity Commission.

Other companies

We will only share information about you with PayPal or Stripe (who handle our online payments) if we have to use it to deal with your payment.

Kingsley Management Consultancy Limited does the admin for Toilet Twinning, things like fulfilling orders, and sorting orders and donations. Occasionally we may use other companies to help with this work. They are bound by contract to keep information about you safe and it is our responsibility to make sure they do the right thing.

We may give other companies general information about the people who use our website, but this information is all anonymous. For example, we may tell them ten people visited our donation page, but they won’t know who those people are. However, we may use an IP address (which tells us the exact location of a computer) to identify a person if we feel that they are dangerous to others, or if we need to by law.

COOKIES

What are cookies?

We collect online information using cookies. A cookie is a text file that gets sent to us from our website as soon as you visit it. This helps us identify your computer (not you) and collects information about how you use our site – it doesn’t tell us who you are or give us any personal information about you. And when the data comes to us it’s bulked together with details about all the other visitors to our site.

Cookies may be used to tell us about visits to our website. For example, how many people are visiting, the locations where people are using our site, whether people are looking at our site on phones/tablets/computers etc, the date and time people visit and the pages they visit.

Almost all major websites use cookies. You can read more about cookies at http://www.allaboutcookies.org/ or https://www.aboutcookies.org/

How we use cookies on our website

To make the most of our website you should leave cookies turned on, otherwise you might not be able to get to parts of the site.

We may use information from cookies to:

  • tailor our website and make it interesting to you, and to help us understand what you might want to see on our website
  • deal with any requests, applications or payments
  • help us with internal administration and analysis

Turning cookies off

You can turn off the cookies on most internet browsers, eg Google. To find out how, why not speak to your parent or guardian, or search under the help function on your browser?

Cookies from other organisations

Toilet Twinning works with a number of other organisations who set cookies on our website. PayPal and Stripe will also send you cookies. Further information can be found within PayPal’s Privacy Policy for PayPal Services or at Stripe.com Our other third party providers are mainly used for reporting and advertising purposes so we can get better at communicating.

We use websites such as Youtube and Vimeo to embed videos, and these websites may send you cookies. We don’t control the setting of these cookies, so you should check these other websites to turn them off if you want to.

Toilet Twinning also uses other web organisations to do some tasks, such as Facebook, HotJar and Google Analytics, which may also use cookies. They may also use tracking pixels in adverts – this works out whether an advert is effective or not.

At any point you can turn off Google’s tracking cookies. Google uses cookies to inform and show you ads based on what you’re interested in. If you don’t want us to advertise to you based on this information, you can use Google’s Ad Personalisation Tool.

None of this information recorded by Google’s cookies will tell us who you are or give us any personal information about you. However, these services help us understand how people browse our website and the number of visits each page has had. If you don’t want Google to include you in this information, you can install the Google Analytics Opt Out Tool.

You can also visit the Digital Advertising Alliance website to change the way you see advertising on the internet.

As some of these internet services are based outside of the UK and the European Union, they might not be protected by UK law. If you are worried about this, you can change your cookie settings (see above). For more information about this visit https://ico.org.uk/

CHILDREN

Aged 12 or under

Whenever we identify that a child is sending us their personal data, for example, if they sign up for a school pack or a community event, if they are 12 or under, we will ask their parent or guardian to sign up on their behalf.

YOUR CHOICES AND TELLING US WHEN THINGS CHANGE

What we send you and how we contact you

You can change what you want us to send you and how you want us to contact you at any time. Remember, if you are 12 or under you need to get your parent or guardian to do this.

Call us on:
0300 321 3217

Email us on:
info@toilettwinning.org

Write to us at:
Toilet Twinning
1052-1054 Christchurch Road
Bournemouth BH7 6DS
United Kingdom

Updating your details

It’s really helpful if you keep your details with us up-to-date. You can do this in the same way as telling us what to send you and how to contact you (above).

We may use a Post Office address search, postcode lists or other available sources to check information you send us, eg if we are unsure of the address you have written on a form.

We will not use these sources to gather information you haven’t given us, eg if you’ve left your telephone number blank. Nor will we automatically update changes of address – we will normally only update your address when you tell us it’s changed.

Your rights (for example, telling us to stop using information about you)

You have the right to:

  • ask us to delete information we have about you
  • limit how we keep and use information about you
  • disagree with our reasons for keeping and using information about you
  • disagree with us using information about what interests you and where you live to send you messages about our work or events that are tailored to you
  • ask for information about you to be given electronically to another organisation
  • access your information. You have the right to know what information we hold about you. We will reply to you within one month.

You can exercise these rights at any time. Remember, if you are 12 or under you will need to get your parent or guardian to do this.

Write to us at:
Data Protection Officer
Toilet Twinning
1052-1054 Christchurch Road
Bournemouth BH7 6DS
United Kingdom

Email us on:
info@toilettwinning.org

Call us on:
0300 321 3217

For more information about your rights under the General Data Protection Regulation you can visit the website of the Information Commissioner’s Office at https://ico.org.uk.

CHANGES TO TOILET TWINNING’S PRIVACY AND SECURITY POLICY

Changes to this policy

This child-friendly policy was last updated in May 2018. We’ll amend this policy if there are any changes to how we do things or changes to data protection or other laws. If we make any significant changes we’ll show you clearly on our website.

When you contact us through our websites, social media, email or telephone, or by otherwise sending us information about you, we will process your information as explained in this policy. By giving us your information, you will have agreed to this policy. If you do not agree, please do not give us information about you.

Feedback

We’d love to hear what you think of this document and any questions you have.

Call us on:
0300 321 3217

Email us on:
info@toilettwinning.org

Write to us at:
Data Protection Officer
Toilet Twinning
1052-1054 Christchurch Road
Bournemouth BH7 6DS
United Kingdom

Complaints

You can also contact us if you are worried about anything in this document or if you want to complain. Remember, if you are 12 or under you will need to get your parent or guardian to do this.

Call us on:
0300 321 3217

Email us on:
info@toilettwinning.org

Write to us at:
Data Protection Officer
Toilet Twinning
1052-1054 Christchurch Road
Bournemouth BH7 6DS
United Kingdom

You also have the right to make a complaint about how we use information about you with the Information Commissioners Office (ICO), the UK data protection regulator. You can do this by calling the ICO helpline or through the ICO website. For details, visit https://ico.org.uk/concerns/