Last updated September 2019
It’s so important to us that you can support our work in complete confidence. As well as working hard to ensure you know where your money goes and how it has made a lasting difference to people’s lives, we also want to be completely transparent about what personal information of yours we collect and what we do with it.
If you reside in the United Kingdom or Europe, we will process your personal information in accordance with the General Data Protection Regulation 2016/679 (the “GDPR”) and similar European and UK data protection and data security laws (“Data Protection Laws”). We are registered with the Fundraising Regulator as part of our commitment to ethical fundraising and are not required to register by paying a fee to the ICO.
This policy sets out how we collect, store and use your personal information. Please read this policy carefully.
By providing us with your personal information, you consent to AfriKids processing your personal information in accordance with this policy. From time to time, we may make changes to this policy, please always refer to the latest version on our website.
Quick links to sections of this policy:
How to contact us
Telephone: (+44) 0 207 269 0740 (available 09.00-17.30 Monday-Friday)
Post: AfriKids, 21 Southampton Row, London WC1B 5HA, United Kingdom
For any personal information queries, please contact AfriKids by emailing email@example.com.
Who we are
“AfriKids” generally refers to the partnership between AfriKids Limited and AfriKids Ghana, two legally independent organisations, run by different management teams and governed by different boards of Trustees, but who work in very close partnership.
AfriKids Limited is a UK Registered Charity (charity number 1141028) and a company limited by guarantee (company number 07534096). AfriKids Limited’s registered office is located at 21 Southampton Row, London WC1B 5HA.
AfriKids Ghana is an independent, non-governmental organisation certified by the Department of Social Welfare in Ghana (NGO number DSW/3024) and a company limited by guarantee in Ghana (company number G-16,465). AfriKids Ghana is based on the Bolgatanga-Navrongo Road, Bolgatanga, Upper East Region, Ghana.
This policy refers to the personal information processed by AfriKids Limited only, and includes all information processed by the official AfriKids website. Under the applicable Data Protection Laws, AfriKids is a “data controller”.
‘Personal information’ means any information we hold about you from which you can be or are identified. Personal data may be held in paper or electronic format or in another recorded form including photographs or video clips. This includes a person’s name, mailing and email addresses, other contact information in which you can be identified, and financial information specifically linked to your account (such as if you make a donation).
‘Processing’ means any operation or set of operations which is performed on personal information or on sets of personal information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Processing refers to all stages of collecting, storing and using your personal information.
The Information Commissioner’s Office or ICO is the UK’s independent body set up to uphold information rights.
‘Data subjects’ means any person whose personal information is being collected, held or processed. This includes: donors; fundraisers; web traffic; visitors to Ghana; staff, trustees and associated personnel; partners; enquirers and suppliers.
‘Data sites’ are trusted third-parties (suppliers and subcontractors, partners, payment providers, agents or service providers, external fundraising entities and platforms etc.) used by AfriKids to process your personal information. We ensure that any data site used is compliant with the Data Protection Laws and has its own internal due diligence process that ensures their compliance with those laws.
How we collect personal information
We collect information in the following ways:
When you interact with us
There are many ways that you can interact directly with AfriKids which includes, but is not limited to; in person, over the phone, online (through our websites or social media), complete a form or attend an event.
When you interact with third parties
From time to time, you might be interacting with an organisation working on our behalf. AfriKids remain responsible for how we process your information that we have access to through our third-party partners. AfriKids only uses of third-party partners who are GDPR compliant ensuring the safety and security of your personal information.
Via Social media
If you engage with us on social media and messaging services like Facebook, Instagram, WhatsApp or Twitter, you might give us permission to process information from those accounts. The data we are given access to by social media services will vary but will always be in line with the terms of that particular service.
When you visit our website
Upon visiting our website, information about your visit is recorded and stored. Please see the section below on the Use of our Cookies for more details.
When your information is available from public sources
We may also collect or receive information about you from other sources, including public sources. The public sources include but are not limited to: Companies House, the Electoral Register, land records, the Charity Commission of England and Wales, the Scottish Charity Regulator, social networks (such as LinkedIn), and the media or information published in the media.
What personal information we collect
The type of personal information that will be processed by AfriKids depends upon its intended use.
The following list provides some examples of data processed by AfriKids:
- identity data; including your name, username, DOB, gender etc.
- contact data; including your phone number(s), email address, postal address, and phone number
- financial data; including bank details, renumeration
- transactional data; including donation details and taxpayer status (used for processing Gift Aid claims)
- technical data; including cookies and IP address
- marketing data; including your communication preferences for receiving communications from AfriKids
- any other personal information provided to us as outlined above (please see the ‘How we collect personal information’ section)
- any other personal information which is provided to third-party partners
Where it is appropriate, we may ask what your motivation is for supporting AfriKids and your specific interests in our work. This is because we want to ensure that our communications with you are relevant and appropriate to you as an individual supporter.
Sensitive personal information
We may also ask you to provide specific information about your interests or lifestyle and where appropriate, for example if you take part in a challenge event or visit Ghana with AfriKids, we may collect details about your health or your passport information.
Why we process your personal information
We process information solely for the purpose of helping our work towards our mission and for the following key purposes:
- to administer donations (i.e. keeping records of our supporters’ relationships with us and Gift Aid declarations)
- to help us promote and raise funds for our work
- to deliver exceptional supporter experience
- to understand why people support our work, so we can better meet their needs and find more people like them
- to contact people (see ‘Communicating with you’ below)
- to analyse it alongside publicly available information to carry out due diligence and build supporter profiles on our donors and to help tailor our communications and products and we may from time to time engage specialist agencies to speed up this process (see ‘Supporter analysis’ below)
- to show us how people are using our website, so that we can keep improving it (see ‘Use of our cookies’ below)
- to administer enquiries including volunteering and job applications
- to deliver goods/services people expect from us e.g. supporting community fundraisers
- to run our charity (internal operations) ensuring we manage risk and are complaint with the law and best practice (e.g. safeguarding, duty of care)
- to deliver charitable services
- for legal purposes: we may use and share personal information for legal purposes, including financial, regulatory, tax and other legal obligations and to respond to governmental or regulatory requests or for litigation purposes
- for our legitimate interests and those of a third party: we may use your personal information to manage our legal, regulatory, financial and business requirements, including obtaining legal advice, in the course of disputes and litigation, internal and/or regulatory investigations and other legitimate interests
- for our business purposes: we may use your personal information to help us manage the objectives of our organisation for other purposes: subject to the applicable Data Protection Laws, we may use your personal information for additional purposes in connection with the website or for the purposes of our organisation, where you have provided your prior consent
Communicating with you
Subject to any relevant Data Protection Law, AfriKids and our third-party service and business providers may send you communications. These communications fall into two categories: administrative communications and marketing communications.
We will communicate with you using the contact details you have provided for essential administrative purposes, such as to administer a donation or to provide you with information regarding an event.
This may include but is not limited to communications relating to; our organisation, updates regarding our work, opportunities to support our work and other notifications including important news that could affect your relationship with us.
If you have given consent for us to do so, we will contact you for marketing purposes via email, phone and SMS. We may also send you communications by post, on the basis it is in our legitimate interest to do so (unless you have asked us not to).
Marketing materials might include updates on our work, campaign and appeal information, opportunities to support through donations and fundraising, event information and volunteering opportunities.
Where applicable Data Protection Laws prevent us from doing so, we will not send you marketing communications without consent or if you have withdrawn consent.
If you would like to change your marketing preferences please contact us. Please allow a grace period of 28 working days following a withdrawal of consent.
Social media is an excellent way for us to update our supporters about our work and show our supporters the difference that their support is making. Social media is the most efficient way for us to reach more people who are likely to take an interest in our work.
We participate in Facebook’s audience matching program which enables us to display adverts to our existing supporters when they visit Facebook. We provide your email address, mobile number and address, to Facebook so they can determine whether you are a registered account holder with them. Our adverts may then appear when you access Facebook. Your data is sent in an encrypted format that is deleted by Facebook if it does not match with a Facebook account.
We may also use your data to create ‘lookalike’ audiences on Facebook. This means that Facebook will match interests, behaviour and demographics of AfriKids supporters to identify other Facebook users who closely match their interests. Facebook will then service adverts to these people promoting AfriKids’ work.
We may sometimes share your personal information with our media partner agencies who may also share email addresses with Facebook on our behalf.
If you would like to opt out of Facebook audience matching, please contact us. Please allow a grace period of 28 working days following a withdrawal of consent.
We also participate in Facebook’s audience preference services. This service remembers supporters who have responded in the past to AfriKids fundraising and marketing requests. There are two ways to prevent this use of your data, you can either update your preferences at AfriKids by opting out of the relevant channel of communication or you can do this via the social media site:
We only use your personal information in this manner if you have opted in to receive marketing communications from us. No data we hold about our supporters is retained by the third party.
We analyse our supporter data alongside publicly available information to carry out due diligence on our donors and to help tailor our communications and products. This process is carried out both automatically and manually.
We may also carry out research using publicly available information to identify individuals who may have an affinity to our cause but with whom we are not already in touch. This research will be used to build a profile about you, your interests and preferences. This provides background information about our supporters and helps us to tailor appropriate communications to them as well as helping us to improve the quality of our supporter’s experience with us.
The research carried out to build supporter profiles is undertaken in-house but, from time to time, AfriKids will engage with third-party partners to undertake these activities on behalf of AfriKids. The personal information collected in house will be collected from publicly available sources. These sources include, but are not limited to: Companies House, the Electoral Register, land records, the Charity Commission of England and Wales, the Scottish Charity Regulator, social networks (such as LinkedIn), and the media or information published in the media. We may also carry out wealth screening to fast track the research using our third party processors.
Additionally, we may use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.
We take this approach in order to ensure that we develop relationships appropriately and that you always receive the most appropriate communications. This also helps ensure that our fundraising activity is as effective as it can be. In some cases, for example in the case of very large donations, this information is also helpful for due diligence purposes.
If you would like to opt out of supporter analysis please contact us. Please allow a grace period of 28 working days following a withdrawal of consent.
Use of our cookies
Like most websites, our website uses small data files stored on your computer called cookies. Cookies give us insight into how people use our website and help us keep improving it. Cookies do lots of different things, such as helping us to:
- avoid asking you to register or complete details twice;
- estimate the number of visitors to our website, including the source and patterns relating to this traffic; and
- understand how visitors use the website, and how we can enhance this experience.
If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of our website may not operate correctly.
When you enter information into our website and start but don’t complete (submit) it (e.g. in a form or when making a donation or purchase), we may send you an email to check and see if there is any help we can give. You are under no obligation whatsoever to respond or act on this.
You can find out more about cookies at www.allaboutcookies.org and www.youronlinechoices.eu/
Our legal basis for processing your information
We will only process personal information when one of the below conditions (each term as defined by the relevant Data Protection Law) applies:
You have given your consent for us to process your personal information in the way and for the reason stated by your communication preferences.
This consent can be withdrawn at any time. If you wish to change your communication preferences, please contact us and allow 28 working days for your request to be processed.
Where we have a contractual relationship with you.
It is necessary for us to process your personal information in order to deliver contracted goods and services including donations made to AfriKids.
We have a legal obligation to comply with regulations put in place by governing bodies. In these circumstances we will from time to time be obliged to pass on personal information. These governing bodies may include: HMRC (relating to Gift Aid), Charities Commission, Companies House and the Fundraising Regulator.
It is of vital interest for us to process your personal information, i.e. it might save a person’s life.
Where there is a ‘legitimate interest’, when it is not obviously annoying or intrusive and would reasonably be expected. AfriKids’ legitimate interests are ultimately to afford our charitable objectives.
Under the applicable Data Protection Laws, you have the following rights regarding our processing your personal information. For more information on your full rights, please visit the Information Commissioner’s Office (“ICO”) website.
Your right to information/to be informed.
It is our responsibility to ensure you are clearly informed of when, how and why we are collecting your information and what we will do with it. We do this through this policy and privacy notices which explain these points any time we collect your data.
Your right to object.
You can object to us contacting you. We provide the opportunity for you to say how we can contact you and what for on our website and you can change these preferences at any time.
Your right to restrict processing.
You can ask us not to process your personal information (however this still permits us to store it).
Your right to rectification.
You can ask for us to rectify any inaccurate personal information which we may hold about you.
Your right to erasure (your right to be forgotten).
You can ask us to erase the personal information we hold about you.
Your right to data portability.
Making it easy for you to obtain a copy of any personal information you have provided to organisations in a machine-readable format so you can easily transfer it to other organisations providing similar services. Any copies of personal information we provide upon request will be provided in plain text format.
Your right not be evaluated on the basis of automated processing
You can ask that we do not include your personal information in any automated profiling exercises that might make assumptions about you in order to get insight into our supporter audience (in order to tailor communications and reach more people that might be interested in supporting us).
Your right of access
You have a right to see what information we hold about you and can request to see it.
You can also lodge a complaint about the way we manage your data with the ICO. For more information or to exercise your rights, please contact us.
If you would like to request a copy of the personal information we hold about you, please send a description of the information you would like as well as proof of your identity, either by email or post. Once your identity is confirmed, we will aim to send you a copy of your personal information, in line with what we are legally required to disclose, within one month. Where we were unable to do so within one month, we will notify you of the soonest practicable time within which we can respond to your request. We accept no liability for the security of your personal information, as contained in your request, until it has been received by us. There are certain exemptions and restrictions of these rights under the applicable Data Protection Laws that enable personal information to be retained, processed or withheld from access and we will inform you of these if applicable.
If you would like to make a complaint about how we process your personal information, please contact us.
If you feel that we have not satisfactorily resolved your complaint then please proceed to contact the Information Commissioner’s Office.
Please note that you can also register with the following services to stop receiving unsolicited marketing communications from a selected charity or charities:
How we keep your information safe
We have physical, technical and human controls in place to keep your information secure.
We ensure that extra controls are in place for financial, sensitive and special categories of information, meeting regulatory and legal requirements for managing these types of information.
The transmission of information over the internet is never completely secure and AfriKids cannot guarantee the security of any information you transmit to us, and you do so at your own risk. We advise against sending personal information using unsecure WiFi (e.g. free public WiFi).
Once we receive your data, we make every effort to ensure its security both on our systems and while in transit between our systems and those of any third-party partner working on our behalf.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We cannot be responsible for the privacy policies and practices of other websites, even if you access them using links from our websites and we recommend that you check the policy of each website you visit.
Who we share your information with
We never sell or share your data with third-parties for commercial use. We will always keep your details safe and will not sell or swap your information with any other organisation.
We may from time to time share your information with external data sites to process your data to help us with our work or to help us better understand our supporters. We always ensure they comply with the Data Protection Laws as well as the Institute of Fundraising Code of Conduct by carrying out internal compliance checks before we start to work with them.
We have contracts in place with the data sites that we work with, so that there is robust data protection requirements. These data sites will only use your information under our instruction and will not use it for their own purposes.
We might also have a legal or regulatory duty to share your personal information so we may disclose your details to the police, regulatory bodies or legal advisers, and/or, where we consider this necessary to protect the rights, property or safety of AfriKids, its personnel, visitors, users or others.
International data transfers
From time to time we may transfer information submitted by you to other organisations who are a part of the AfriKids partnership (these include, but are not limited to: AfriKids Limited, AfriKids Ghana, Friends of AfriKids Inc.) or we may need to use a service provider or partner outside the European Economic Area (EEA) – which may include a country that does not have the same level of data protection as the UK.
In these circumstances, we minimise the information that is shared and take all reasonable steps to ensure the safety and security of your information as set out in this policy. Where such transfers occur, you acknowledge and where required, consent to such transfer.
How long we keep your information
We will only hold your personal information for as long as it is reasonably necessary to fulfil the purpose for which the data was collected. This includes retaining personal information for complying with any legal requirements. For example, HMRC requires us to keep all Gift Aid details for a minimum period of six years following the date of each donation.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable Data Protection Laws.
Our practice is to hold your personal information on our systems only for as long as necessary to carry out the service for which the data was provided.
When personal information is no longer required, this data will either be deleted it in a secure way or anonymised (as above described above).
We may keep information relating to gifts in wills indefinitely, this permitted by the applicable Data Protection Laws. This enables us to administer these gifts and communicate appropriately with the families of those leaving a legacy to AfriKids.
How to change the way we contact you
It is easy for you to change your communication preferences or unsubscribe from communications with us at any time.
Please contact us at any time if you have questions regarding this policy or if you would like to review, update, or remove your personal information. Please note that complete removal may not be immediate, and in some instances, archival copies may be impossible to delete. AfriKids may retain a copy of personal information, in accordance with this policy, for commercially reasonable business purposes, including to enforce agreements with you and our policies, or reasons required by any applicable Data Protection Law.
If you change your consent preferences or withdraw consent entirely in relation to the public sharing of personal information, we will ensure that no further personal information of yours is shared publicly going forward but we will be unable to retract anything already shared outside of AfriKids’ own website.
What if I'm under 18?
Although we do not actively collect information from children (under 18s), we do appreciate that our supporters are of all ages. We will always ask for consent from a parent or guardians to collect information where appropriate. If we become aware that we have collected personal information from children without obtaining consent from that child’s parent or guardian, we take steps to remove that information from the relevant data sites.
Each AfriKids event will clearly indicate whether the participation of children is permitted. The collection of data in relation to each event will be managed on an event by event basis, with appropriate safeguarding measures for children in place where appropriate.
Under the applicable Data Protection Laws, consent provided by an EEA child between the ages of 13 and 16 to process their personal data shall be valid. Under those Data Protection Laws, that child is obliged to provide us with evidence of their consent, or if required, an authorisation to process the personal data of the child from the individual who has legal responsibility for that child. We may refuse to process, or continue to process, the child’s personal information until we receive this evidence.
If you do use our sites to find out about fundraising, campaigning or supporting the work of AfriKids, please let an adult know.