GiveWell UK Privacy Notice – February 2022 version
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Effective Date: 8 February 2022
The first thing you should know is that all of our operational support is provided by GiveWell (aka The Clear Fund), our US partner and a tax-exempt charitable organization. Therefore, all information processing, and the observance of this policy, are implemented and enforced by GiveWell in the United States. Our data sharing with GiveWell is controlled by a Data Transfer Agreement, which includes appropriate safeguards provided by standard data protection clauses.
This Privacy Notice applies when you make a donation to GiveWell UK as well as when you otherwise share information with GiveWell UK as discussed below.
Table of Contents
Collection and use of personal data
Donor information and information of other interested individuals
If you make a donation, either online or otherwise, we will request certain information about you (such as your name, address, telephone number, email address, and debit or credit card information). We use this information to process your donation and communicate with you about it. We check in with donors throughout the year about whether you are interested in donating again. We may also use publicly available information about our donors from third-party sources, including wealth screening services, to personalize communications with donors and improve donor retention. In addition, other individuals may share personal data with us for a variety of reasons, including to keep up with our work. We may use the information of donors or other interested individuals to keep you updated about GiveWell UK’s and GiveWell’s work, also with your consent (where required). You can choose to stop receiving check-in and update information by following the unsubscribe instructions included in the materials or by contacting us at privacyUK@givewell.org. We may use such information for direct marketing with your consent (where required) or to evaluate the success of our marketing and promotional efforts.
GiveWell contracts with legal and bookkeeping professionals on behalf of GiveWell UK. In addition, GiveWell UK consults advisors in making organizational decisions and developing long-term plans. These companies and advisors have access to donor personal data as needed to perform their functions. GiveWell UK requires that these processors keep such information confidential and that they not use such information for purposes other than the functions they are assisting with. (See Security section below.)
Why we process your personal information
We may process your personal information for various purposes, including:
- to contact you, including to respond to your inquiries;
- to send fundraising solicitations;
- to send you our newsletters, topic updates, and event invites, at your request;
- for business purposes, such as analytics, research, advertising and marketing, and operational purposes;
- to consider your application for employment;
- to comply with a specific legal requirement, law enforcement and maintain our security
- to analyze publicly available information on individual wealth to tailor our communications to major donors or prospective donors; or
- as otherwise disclosed at the time of collection or use.
We do not use automatic decision-making or engage in profiling. If a situation arises where we intend to use your personal information for any reason beyond its original purpose, we will notify you and provide additional information ahead of time.
Apart from where set out elsewhere in this Privacy Notice, we do not sell, rent, or disclose donor personal data to any other party not under the employ of, or in a processor role to, GiveWell UK. The main exceptions are: (1) all information is shared with GiveWell as they are contractually responsible for conducting our operations, and (2) if you give us permission to share your name, contact information, and details of your donation with one or more of our recommended charities we do so.
We may disclose to third parties aggregate statistics regarding donations, but these statistics do not include any personal data. The information given includes the total number of donors and total amount of donations for specific periods of time.
Other disclosures
Please be advised that we may disclose your information, as required by law, to the government or to third parties pursuant to law enforcement inquiries, court orders, subpoenas, and similar lawful demands or legal processes. In addition, we may disclose your information with or without a formal subpoena if we believe in good faith that such disclosure is necessary or appropriate (a) in connection with any activity that violates the law, (b) in the event of a legal dispute, (c) to prevent or stop activity we believe may pose a risk of being illegal or unethical or that may expose us to liability, or (d) to protect the safety of the public or any person, or the rights of GiveWell UK. In addition, we may disclose your personal data to a buyer or other successor, in connection with a business transfer such as a merger, divestiture, restructuring, acquisition, sale of assets, or reorganization, or in the event of bankruptcy or other similar proceeding in which personal data held by GiveWell UK is among assets transferred.
Security
We require that GiveWell and the vendors it works with to process your online donation payments use industry-standard encryption and security protocols, and that all vendors processing debit and credit card transactions received on our behalf meet all industry standards, certify their compliance with the Payment Card Industry Data Security Standard (PCI DSS), and are audited to meet the Statements on Standards for Attestation Engagements No. 18 (SSAE 18) and/or the International Standard on Assurance Engagements No. 3402 (ISAE 3402) . We require that GiveWell follow commercially reasonable administrative, technical, and physical safeguards to protect personal data against accidental or unlawful destruction or loss, or unauthorized disclosure, access, or use. The personal data that you provide is stored in a secure location and accessible only by designated users trained in the proper handling of personal data, or by processors assisting with certain functions. GiveWell employs industry-standard techniques such as firewalls, encryption, intrusion detection, and site monitoring to protect your personal data from unauthorized access by users inside and outside the organization. You should be aware, however, that "perfect security" does not exist on the Internet or in any method of storage; third parties may unlawfully intercept or access transmissions or stored information. If we learn of a security breach involving your personal data, we will inform you of the breach in accordance with applicable law.
Your right to update your information
We work to process and maintain accurately the information that you share with us. If you have donated to us or shared personal data with us and would like to correct or update your personal data or adjust your mail preferences, you can do so by contacting us at privacyUK@givewell.org. We will respond to your request in accordance with applicable law. We provide a link to unsubscribe from each of our mailing lists in each email from that list.
Information retention
We retain your information only for so long as necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process the information for the purposes of compliance with our legal obligations. Our data retention policy is available here.
Legal bases we rely on when processing your information
We may process your personal data based on one or more of the following legal bases:
- Your consent. For example, we rely on your consent to share your personal data with one or more of our recommended charities when you direct us to do so.
- Our or a third party’s legitimate interests. For example, to communicate with you, process donations, or if you get in contact with us, we rely on legitimate interests which are not overridden by the fundamental rights and freedoms of the individuals whose personal data we process, including you.
- Legal obligation. We may need to process your personal data to comply with a legal obligation to which we are subject.
- Vital interests. We may need to process your personal data to protect your vital interests or those of another person.
- Public task. We may need to process your personal data if necessary to perform a task carried out in the public interest.
International data transfers
Please be aware that the personal data we collect may be transferred to and maintained on servers or databases located in the United States. Our data sharing with GiveWell US is controlled by a Data Transfer Agreement, which includes appropriate safeguards provided by EU/UK-approved Standard Contractual Clauses.
Where we otherwise transfer your personal data outside of the United Kingdom, where the privacy laws may not be as protective as those in your location, we currently rely on EU/UK-approved Standard Contractual Clauses where necessary to provide an adequate level of data protection.
Note to parents and children
We will never knowingly request personal data from anyone under the age of 16 without prior verifiable parental consent. If we become aware that a child under 16 has provided us with such information without consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that a child under 16 has provided such information to us, they should contact us at privacyUK@givewell.org.
Exercising your rights
Where the processing of your personal data engages our obligations under data protection law, you have certain rights under data protection law, including:
- You have the right to ask us for a copy of your personal data that we hold.
- You have the right to ask us to rectify personal data you think is inaccurate or to complete personal data about you that you think is incomplete.
- You have the right to ask us to erase your personal data in certain circumstances.
- You have the right to ask us to restrict processing of your personal data in certain circumstances.
- You have the right to object to the processing of your personal data in certain circumstances.
- You have the right to ask that we transfer the personal data you gave us to another organization in certain circumstances.
Where we rely on consent as a lawful basis, you always have a right to withdraw your consent at any time.
If you wish to exercise any of your above rights, you can do so by contacting us at privacyUK@givewell.org. If you make a request to exercise any of your rights above, we have one month to respond to you.
Your interaction with this Privacy Notice
Updates to this Privacy Notice
We may, from time to time, update our Privacy Notice, based on your comments and our need to reflect accurately our information collection and disclosure practices. Updates apply to all information we hold. If we make any material changes in the way we collect or use your personal data (for example, a significant or material change regarding the categories of information we collect, the ways we use such information, or with whom and how we share such information), we will update our Privacy Notice and use reasonable efforts to notify you by email.
Questions or suggestions and contact details
It is important to us at GiveWell UK to hear what our donors and other stakeholders have to say about our services or our practices. If you have any questions, concerns, or complaints about this Privacy Notice, or want to let us know what you think about our products and services, please contact us at privacyUK@givewell.org.
GiveWell
℅ Bates Wells
First Floor
10 Queen Street Place
London EC4R 1BE
Complaints
If you have any concerns about our use of your information, you can make a complaint to us using the contact information above. You can also complain to the UK data protection regulator, the ICO, if you are unhappy with how we have used your information. The ICO’s address is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
This Privacy Notice was last updated on 8 February 2022.