Education Sub Saharan Africa (registered charity number 1166958) (“ESSA”) is committed to protecting and respecting your privacy. This Privacy Notice (“Notice”) sets out our data processing practices and your rights and options regarding the ways in which your personal information is collected (including through our website: www.essa-africa.org) and used. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services or your interaction with us may be impaired. For example, you will be unable to attend one of our events without first registering.
1. Information we may collect from you
We may collect information about you:
(a) directly whenever you interact with us. For example, when you contact us regarding our activities, register as a supporter, send or receive information, engage with our social media or make a donation to us.
(b) Indirectly from third parties with whom we work. For example, if you’ve donated to us through a third-party website (eg Just Giving) and given them permission to share your information with us.
(c) When you visit our website. For example, we automatically collect information about your computer, including (where available) your IP address, operating system and browser type.
We may also collect and use your personal information by using cookies on our website. Please see our Cookie Notice for more information.
In general, we may combine your personal information from these different sources for the purposes set out in this Notice.
2. Where and how we store your personal information
In order to administer the Site, the data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (‘EEA’). It may be processed by staff operating outside the EEA who work for us or for one of our suppliers.
Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Notice. If you have any questions about the transfer of your personal information, please contact us using the details below.
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 our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
3. How and why we will use your personal information?
Your personal information, however provided to us, will be used for the purposes specified in this Notice. In particular, we may use your personal information:
(a) to contact you in response to your query;
(b) to communicate with you with information about ESSA and events you might be interested in;
(c) to provide you with the services you have requested (for example, attendance at an event or a subscription to our newsletter);
(d) to consider your submissions to our educational research database;
(e) to evaluate your application to enrol on our Massive Open Online Course (“MOOC”);
(f) to process your donations;
(g) to further our charitable aims in general, including fundraising activities;
(h) to analyse and improve our work, services, activities, offerings and information (including our website), or for our internal records;
(i) to report on the impact and effectiveness of our work;
(j) to run/administer our website, keep the website safe and secure and ensure that content is presented in the most effective manner for you and your device;
(k) to process your application for a job or volunteer role with us;
(l) to administer your employment/other working relationship with us (for example, to pay your salary);
(m) to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work); and/or
(n)for the establishment, defence and/or enforcement of legal claims.
4. Lawful bases
The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:
(a) Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you information about ESSA by email, and we may ask for your explicit consent to collect special categories of your personal information).
(b) Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
(c) Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, if you apply to work for/ volunteer with us).
(d) Where there is a legitimate interest in us doing so.
The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).
In broad terms, our “legitimate interests” means the interests of running ESSA as a charitable entity and pursuing our aims and ideals; for example providing information about education in sub-Saharan Africa, processing donations, administering events and taking applications for volunteers.
When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).
5. Communications for marketing/fundraising
We may use your contact details to provide you with information about our work, events, services and/ or products which we consider may be of interest to you (for example, about services you previously used, or updates about fundraising appeals and/or volunteering opportunities via our newsletter).
Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law).
Where you have provided us with your consent previously but do not wish to be contacted by us about our projects and/or services in the future, please let us know by email at [email@example.com]. You can opt out of receiving emails from ESSA at any time by clicking the “unsubscribe” link at the bottom of our emails.
6. How long do we keep your personal information?
In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the
date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see Section 13 below), we will remove it from our records at the relevant time.
If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.
7. Will we share your information?
We do not share, sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice.
Non-exhaustively, those parties may include:
(a) [partner organisations in Africa]
(b) suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers;
(c) parties administering our benefit payments, reward programmes and pension contributions;
(e) financial companies such as Paypal and WorldPay that collect or process donations on our behalf;
(f) professional service providers such as accountants and lawyers;
(g) parties assisting us with research to monitor the impact/ effectiveness of our services;
(h) external fundraising entities/ platforms; and
(i) regulatory authorities, such as tax authorities.
8. Exercising your rights
Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:
(a) Right of access – you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
(b) Right of erasure – at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete your personal information entirely.
(c) Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.
(d) Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
(e) Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
(f) Right to data portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.
(g) Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by EU or Member State law to which ESSA is subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.
We may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested to you.
Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details below.
You are further entitled to make a complaint about us or the way we have processed your personal information to the data protection supervisory authority in your home country. In the UK, the data protection authority is the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us using the details below.
How to contact us
If you have any concerns or questions regarding the above please send an email to firstname.lastname@example.org or contact us via post at ESSA, 3rd Floor, Chancery House, St Nicholas Way, Sutton, Surrey SM1 1JB, United Kingdom.
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