The controller and who we are
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, (collectively the “Data Protection Laws”) the Data Controller is The Social Change Agency Ltd, registered in England and Wales under company number 08382892, with registered office address at 237 Pentonville Road, London, N1 9NG; and The Social Change Nest CIC, registered in England and Wales under company number 12611737, with registered office address at 237 Pentonville Road, London, N1 9NG
We act as a fiscal host, which means we facilitate payment of financial contributions (“Contributed Funds”) made by contributors (”Financial Contributors”) for the benefit of certain organisations or groups with a shared purpose (a “Collective”).
We use the Open Collective Inc’s platform (“OC Platform”), in relation to our involvement as a fiscal host for Collectives, which is used as a means of promoting transparency and make it easier to track incoming and outgoing Contributed Funds for the benefit of the relevant Collective. Further information regarding the Open Collective, the OC Platform and how it processes your personal data can be found at https://opencollective.com/.
As a facilitator of Contributed Funds, we engage with certain members of Collectives through the OC Platform or other channels (e.g. e-mail), including “Expense Submitters”, who submit payment requests to us in connection with an expense incurred in support of a Collective and “Collective Administrators”, who have administrator responsibilities for a Collective, including the ability to approve expense payments submitted by an Expense Submitter.
Your personal information and how we collect it
We collect and process some or all of the following types of information from you in the course of your use of the website or as you may otherwise supply to us as part of our role as a fiscal host:
- Information that you provide as part of your claim in connection with an expense you have incurred in support of a Collective. This includes information you provide through private notes or public threads using the OC Platform.
- Specifically, we will process personal details such as your name, email address, bank account number and any information input by you when communicating with us through the OC Platform or other means of communication such as e-mail.
- If you contact us, we may keep a record of that correspondence.
- Information that you provide in the course of registering as a Collective Administrator with us and when approving expense claims, which may be through the OC Platform or in general communication with us as part of our provision of fiscal host services.
- Specifically, we will process personal details such as your name, email address, social media accounts and any information input by you when communicating with us through the OC Platform or other means such as e-mail.
- If you contact us, we may keep a record of that correspondence.
We will process your name, e-mail address, telephone number provided by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- enquire about our services through our website;
- request marketing to be sent to you;
- enter a survey; or
- give us feedback or otherwise contact us.
As you interact with our website, we will automatically collect data relating to your visits to our website including, but not limited to, your IP Address, traffic data, location data, weblogs, other communication data and the resources that you access.
Uses made of your information
Lawful basis for processing
We rely on legitimate interest and/or performance of a contract with you as the lawful basis on which we collect and use your personal data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
Purposes of processing
to respond to enquiries through our website or by email, and to allow interested individuals to refer us to their Collectives;
to provide you with our fiscal hosting services, including registering you as a Collective Administrator or paying claims for expenses using Contributed Funds;
to carry out our obligations arising from any other contracts entered into between you and us;
to keep your data secure;
to keep our records updated, our website updated/relevant and develop our business.
In addition to the above uses, we may use your information to notify you about services which may be of interest to you. Where we do this, we will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want us to use your data in this way please either (i) tick or untick (as applicable) the relevant box situated on the form on which we collect your data; (ii) unsubscribe from our electronic communications using the method indicated in the relevant communication; or (iii) inform us at any time by contacting us at the contact details set out below.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your information
We will only share your information with third parties listed below for the purposes described above in the “Uses made of your information” section.
We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or
- to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with to provide the website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be of interest to you.
Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties without giving you notice by updating this notice.
Storing your personal data
We take appropriate measures to ensure that any personal data is kept secure, including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also depend on you to protect your information. Where required. please set up a strong password and keep it confidential. If you become aware of any breach of security, please notify us immediately.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the website; any transmission is at your own risk.
Keeping your personal data up to date
It is important that the information you provide to us is accurate and up to date, and that you inform us without delay of any significant change.
If your personal details change you may update them by contacting us using the contact details below.
We will endeavour to update your personal data within seven (7) working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. In particular:
- Where we hold your personal data subject to a legal requirement (e.g. as required by HMRC), we will hold your data with the relevant legally required period;
- Where we hold your personal data in connection with the performance of a contract with you, we will hold your data, and in particular any communications between you and us in relation to the negotiation or performance of that contract, for so long as that contract is in force;
- Where we hold your personal data in connection with the marketing or promotion of our business, or monitoring our commercial relationship with you, we will hold your data for up to 2 years, or for up to 2 years after you last communicated with us, if later;
- In respect of website usage data, we hold your data for 5 years from the date of collection.
Where we store your personal
All information we hold about you is stored on secure servers in the United Kingdom.
The data that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom or European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to appropriate safeguards (as permitted under Article 46(5) of the General Data Protection Regulation) that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact us (see ‘Contact’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us (contact details provided below),
- let us have enough information to identify you (e.g. name, login details),
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates, including any account or reference numbers, if you have them.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information.
The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.
We may collect website usage data. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our website.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies we use include:
- “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the website when they are using it. This helps us to improve the way the website works, for example, by ensuring that users are finding what they are looking for easily.
- “Strictly necessary” cookies. These are cookies that are required for the operation of the website. They include, for example, cookies that enable you to log into secure areas of the website.
Cookies which are strictly necessary for the core functionality of the website are enabled by default, and set automatically at the point you access the website.
Any cookies which are not strictly necessary for the functioning of the website will not be set unless you expressly consent to them through the cookie banner by clicking “accept”.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website.
Changes to our privacy and cookies policy
We reserve the right to modify this notice at any time. Any changes we may make to our notice in the future will be notified to you.
All questions, comments and requests regarding this notice should be addressed to firstname.lastname@example.org or by post at 237 Pentonville Road, London, N1 9NG.