Privacy Policy

Our Privacy Policy

Unbound Philanthropy processes both personal data and confidential information.  The relevant law considered when preparing this Notice includes:

• The Data Protection Act 2018
• The General Data Protection Regulations (2017)
• The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019
• The data protection regulation contained within the European Union (Withdrawal) Act 2018

Together this is now known as UK GDPR.

As Unbound operates between the United Kingdom and the United States of America, some data is transferred to and processed in the US.   We are satisfied that the nature of the data transferred and the safeguards we have in place are such that proper and adequate data protection is maintained.  Insofar as data is processed in the US it is processed in accordance with this policy and any relevant federal and state laws.

Unbound Philanthropy’s Data Protection Policy is available on request. We take steps to ensure compliance with all relevant legislation and best practice.

Our general approach is:

• We will never hold personal data unless we have a lawful basis for doing so;
• We will always be open and transparent about what data we hold; why we are processing it; and who we share it with;
• We will never use personal data for any purpose other than that for which it was provided (or so far as we are otherwise allowed to under the relevant legislation)
• We will ensure that any data is held and processed securely and that we take steps to ensure that it is not lost, destroyed or inappropriately disclosed;
• We will ensure that personal data is destroyed or anonymised when we no longer have a lawful basis for processing it;
• We will not transfer personal data outside of the EU (or as otherwise allowed under relevant legislation) unless we are satisfied that it is protected in accordance with this policy and relevant law
• We will assist data subjects to exercise their rights under the legislation, including in respect of access to their data; rectification and, if appropriate, destruction / deletion of data.

This Privacy Notice explains, in detail, the types of personal data we may collect about you when you interact with us.  It also explains how we’ll store and handle that data and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Unbound use your data.  We hope the following sections will answer any questions you have but if not, please do get in touch with us.

The Data we Process

Unbound is a Data Controller and the types of personal data we process include:

• Identifying and contact information about grant applicants and grantees and about other partners and stakeholders;
• Anonymised data about individuals who have been helped as a result of Unbound funding.

Conditions for Processing Data

We are only entitled to hold and process your data where the law allows us to.  The current law on data protection sets out a number of different reasons for which we may collect and process your personal data.  These include:

Contractual obligations

Where we have a contract with you or a grant agreement the lawful basis on which we process your personal data is in performance of that contract / agreement.

Legitimate Interests

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running Unbound or complying with our legal obligations (subject to this materially impacting your rights, freedom or interests). We may also retain data for limited archiving and research purposes.

Legal compliance

If the law requires us to, we may need to collect and process your data.   For example, we may be required pass on details of individuals who we suspect are involved in fraud or other criminal activity.

Consent

In some situations, we will collect and process your data with your consent.  For example, when you tick a box to receive email updates.   When collecting your personal data, we’ll always make clear to you when we believe your consent is necessary and you will be able to choose whether to give that consent.

When do we collect your data?

We normally collect your data when you provide it to us or when it is provided to us by others (your employer for example in the context of a grant application or report).  You may give us your data by email; through an online web form; over the telephone; face to face; or by post.

What sort of data do we collect?

We collect information like your name, phone number and email address.

How do we use your data?

We only use your data for the purposes dealing with your enquiries and / or for processing grant applications and managing grants thereafter (and for associated reasonable purposes).

How do we protect your data?

We take protecting your data very seriously.  We recognise that some of the data we hold may be sensitive and confidential.  We have a clear data protection and data security policy in place and have undertaken a full review of our data processing.

With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.   We have clear data protection and information security policies and procedures in place (along with Regulatory and other legal obligations to keep your data safe) and these are regularly assessed as part of our review processes.

We take reasonable steps to protect our IT system from Cyber Attack.  Access to your personal data is password-protected where possible.

How long will we keep your data?

We only keep your data for as long as is necessary for the purpose(s) for which it was provided.   A copy of our data retention schedule is available on request. We keep your data for these periods either because we are required to keep the files for that period by our data retention policy or because keeping the files for this long protects you should you need access to your data.

For some cases we may decide that it is proper and appropriate to keep data for longer than that the periods set out above, but we will notify you if we believe that your data falls into this category.

Who do we share your personal data with?

We sometimes share your personal data with trusted third parties.  We only do this where it is necessary for providing managing your employment or grant etc. or for the effective operation of our organisation.

For example, we may share your data with IT storage and support companies; accountants; contractors and freelance consultants

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to provide their specific services;
• They may only use your data for the exact purposes we specify in our contract with them;
• We work closely with them to ensure that your privacy is respected and protected at all times;
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Where is your data processed?

Your data is stored and processed within the European Economic Area (EEA) and in the United States of America (as Unbound is a US based foundation).  If we ever have to share your personal data with third parties and suppliers outside the EEA (other than with Unbound in the US) we will ensure that it is sent and stored securely and, where appropriate, we will seek your specific consent to do so.

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.

Insofar as we process data in the US we do so in accordance with our data protection and data security policy and any US federal or state laws.

What are your rights?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• The deletion of your personal data, for example when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end – though we are not required to delete your data where data where we are required to hold it for complying with our own legal obligations.
• That we stop any consent-based processing of your personal data after you withdraw that consent.

To ask for your information, please contact Ingrid Rasmussen at:

irasmussen@unboundphilanthropy.org

If we choose not to action your request, we will explain to you the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

The Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns