Privacy Policy - Mwezi Foundation

At Mwezi, we aim to attain the highest standards in all we do. Our values of respect, transparency, cooperation, fairness, compassion and ingenuity direct all of our work, whether that’s the treatment of our donors, our staff, the schools that we visit or the schoolchildren who benefit from our solar lights.

PRIVACY POLICY.

Introduction and general terms

The Mwezi Foundation promises to take great care with your personal data. We commit to protecting any personal information we obtain about you, whether you are a financial supporter, member of staff, volunteer, partner or campaigner.

This Privacy Policy sets out how and why we obtain, use and protect personal information if you interact with us in one of these roles.

Who we are

The Mwezi Foundation is a registered charity in England and Wales (charity number 1163037). We are also a company limited by guarantee (company number 08733254).

This Privacy Policy applies to both the charity and the company.

The Mwezi Foundation’s registered address is 12 Vicarage Road, Henley-on-Thames, RG9 1HJ, England.

This Privacy Policy relates to information which is obtained by the Mwezi Foundation and for which the Mwezi Foundation is the Data Controller. That is to say, data for which the Mwezi Foundation sets the purpose of the use as well as how this data will be used.

Our purpose

The Mwezi Foundation helps schoolchildren in Kenya achieve their academic potential. We give solar lights to schools for them to lend to their students.

The solar lights enable the students to do their homework when there is no natural light, which is especially important in the run-up to their exams.

The Mwezi Foundation supports schools in rural locations where pupils don’t have any electricity at home, and often only intermittent electricity at school. We donate portable solar lights to the schools, which they lend to their students. On occasion, we also install lighting systems within schools, which can light up one or two rooms.

Our supporters help us to achieve this in a variety of ways, primarily by volunteering (fundraising, helping with social media) or donating on an individual basis. Our trustees are also very hands-on, and all work pro bono to manage the charity.

We take active steps to make sure that our supporters are aware of the ways in which they can help us achieve our overall purpose.

Why we hold and process personal data

We hold and process personal data for a number of reasons:

To keep a record of donations made and actions taken by our supporters and our communications with them.
To send our supporters information about our projects, fundraising activities and appeals, where we have their consent or are otherwise allowed to.
To support volunteers who are undertaking fundraising activities.
To record campaigning actions by supporters.
To support community-based fundraising and campaigning.
To claim Gift Aid on donations.
To fulfil contractual obligations entered into with supporters.
To comply with legal obligations.
To manage our organisation.
To ensure we do not send unwanted information to supporters or members of the public who have informed us they do not wish to be contacted.

These reasons are underpinned by the concept of “legal basis” under GDPR. We outline in the next section what these legal bases are for our main activities.

The lawful basis we rely upon

The law on data protection sets out a number of different reasons for organisations to collect and process your personal data. When collecting your personal data, we will always make clear to you which data is necessary for a particular purpose.

The Mwezi Foundation relies on the following legal bases in our marketing activities:

Consent

Wherever possible, we will ask for your consent to send you marketing information. We will do this through a clear statement of what you will receive and allow you to select only those channels that you wish to hear from us by.

For example, if you make donations to us, you will be asked whether you would like us to keep in touch about our projects, fundraising activities and appeals. You will also be asked which channel(s) of communication you would like us to use (with a choice of email or phone being offered).

Legal obligation

If the law requires us to, we may need to collect and process your data.

For example, where you sign up to the Gift Aid scheme, we will process your data for the purposes of submitting a Gift Aid claim to HMRC.

Legitimate interest

In specific situations, we process your data to pursue our legitimate interests in ways which might reasonably be expected and which do not materially impact your rights, freedom or interests. The Mwezi Foundation’s use of legitimate interest includes the following:

Sending direct marketing information by email or direct messaging to keep our supporters updated on the Mwezi Foundation’s projects, fundraising activities and appeals. We will only do this where we have reason to believe that this information will be of interest. We make it easy for you to opt out.
If you have opted in to Mwezi Foundation emails we may use your details to invite you to link your account on Facebook or other social media sites to the Mwezi Foundation’s sites in order to serve you Mwezi Foundation content.
To analyse your previous support of the Mwezi Foundation in order to offer relevant ways of supporting the Mwezi Foundation in the future.
To help identify businesses which may wish to support the Mwezi Foundation, we may send emails to individuals where relevant to their job, for instance people working in Corporate Social Responsibility.

When and why we will send you personalised marketing communications

The Mwezi Foundation will only contact you for marketing purposes – for example to keep you up to date on our work, or to let you know of ways in which you can support that work – where we have your consent or we have a legitimate interest in doing so.

We will make it easy for you to tell us if you would like to receive marketing communications from us and hear more about our work, and the ways in which you would like to receive this information (eg. email, direct messaging or phone). We will ask you to reconfirm your consent if we have evidence that suggests you may no longer wish to hear from us. We will never send you marketing material if you have told us that you do not wish to receive it.

How and when we will collect information about you

The Mwezi Foundation may collect your personal data in the following circumstances:

When you give it to us DIRECTLY

You may give us your personal data directly when you make a donation, sign up for one of our events, take part in a campaigning action, volunteer with us or communicate with us.

When you give it to us INDIRECTLY

You may give us your information indirectly when you sign up to events, contribute to the Mwezi Foundation via fundraising sites like JustGiving or Virgin Money Giving, or participate in a campaigning action with a partner. These independent third parties will pass your data to the Mwezi Foundation where you have indicated that you wish to support the Mwezi Foundation and have given your consent or it is a necessary part of completing a contract with you.

When you access the Mwezi Foundation’s social media

We might also obtain your personal data through your use of social media such as Facebook, WhatsApp, Twitter or LinkedIn, depending on your settings or the privacy policies of these social media and messaging services. To change your settings on these services, please refer to their privacy notices, which will tell you how to do this.

When the information is publicly available

We might also obtain personal data about individuals who may be interested in giving major gifts to charities or organisations like the Mwezi Foundation. In this scenario, the Mwezi Foundation may seek to find out more about these individuals – their interests and motivations for giving – through publicly available information. This information may include newspaper or other media coverage, open postings on social media sites such as LinkedIn, and data from Companies House. The Mwezi Foundation will not retain publicly available data relating to major donors without their consent, which will be sought at the earliest practical opportunity. Where we decide not to make contact, we will delete all personal data obtained, other than basic contact details, to which we will apply a flag to ensure we do not make contact in the future.

We may also gather information if your activities relate to our work. For instance, if you are a public figure such as a Member of Parliament or you represent an organisation which we work with or which is related to one of our campaigns, we may gather information about you in order to inform our campaigning. We may also use this information to make decisions – for instance, whether we engage with you to seek your support for our work, ask your constituents to write to you, or choose to work you in another way.

What information might the Mwezi Foundation collect about you

We only collect personal data relevant to the type of transaction or interaction you have with the Mwezi Foundation.

Whatever your interaction with us, this information will be minimal and linked to the purpose for which we need it.

For example, when you contact the Mwezi Foundation to make a donation, support our Gift Aid scheme, take a campaign action, or sign up to any of the Mwezi Foundation’s activities or online content (such as newsletters or message boards) or you telephone, email, write to or text the Mwezi Foundation, or engage with the Mwezi Foundation via social media channels, we may receive and retain personal information.

In these circumstances we are likely to process details such as your name, email address, postal address, telephone or mobile number, bank account details to process donations, and whether or not you are a taxpayer so that we can claim Gift Aid.

If you participate in an event we may (with your permission) take your photograph or video, or interview you.

If you participate in market research, we may ask you questions regarding your experience with us, or other survey questions relating to your experience.

If you are a campaigner, we may collect information such as correspondence with you regarding campaigning, details of your background and activities with us or relating to the issue, the events you attend, or how you would like to work with us.

Where we gather information about you which is publicly available – for instance as a major donor or your views on our campaigning activity – this may include your name, contact details, views and positions you have expressed, and details regarding your circumstances – for instance any political roles you hold or what your background is.

Sensitive personal data

We only collect “sensitive personal data” about our supporters, e.g. health status, where there is a clear and specific reason for doing so.

If you apply for a role with us, we may collect this data for equality monitoring.

Rarely, we may collect this data for the prevention of crime or dishonesty, to safeguard those with whom we work, or for another reason which is in the public interest. Where we do this we will do it carefully and in accordance with applicable laws.

Should you support the Mwezi Foundation in a substantial way, we may provide an account manager to help you tailor your relationship to suit your interests. If this is the case we may collect sensitive personal data where relevant to our relationship, such as your political or religious views. Should you disclose information to us about your health or your family, this may also be recorded, so that we can communicate with you in a considerate and appropriate manner.

All sensitive personal data is stored on a secure database, to which only a limited number of relevant staff have access. It is deleted when no longer relevant, is never shared with third parties, and is available to you at any point should you wish to see it.

How the Mwezi Foundation will use your personal data

The Mwezi Foundation will use your personal information for the following purposes:

For administrative reasons, including:

“service administration”, which means that the Mwezi Foundation may contact you for reasons related to administering any donations you have made, your tax status with regard to Gift Aid if claimed, or the completion of commercial or other transactions you have entered into with the Mwezi Foundation;
to confirm receipt of donations (unless you have asked us not to do this), and to say thank you and provide details of how your donation might be used. For example, if you donate via text you may receive a “bounce back” text message;
in relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide;
for internal record-keeping so as to keep a record of your relationship with us;
to communicate with Mwezi Foundation volunteers – to support you in your designated role or administer that role and our organisation;
to keep your data up to date – for instance we use the Royal Mail’s data on postal address changes to ensure that we can maintain contact with you where we believe you are happy to be contacted by post, and we also use services which notify us of the recently deceased to avoid any distress that continued communications would cause;
to implement any instructions you give us to with regard to withdrawing consent to send marketing information or informing us through the Fundraising Preference Service that you do not wish to receive any marketing information;
to use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries;
to protect our staff and those with whom we work, or to prevent crime and dishonesty.

For marketing and fundraising reasons (see the section “When and why we will send you personalised marketing communications”)

For market research

to invite you to participate in surveys or research about the Mwezi Foundation or our work (participation is always voluntary);
to analyse and improve the activities and content offered by the Mwezi Foundation website to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes.

Sharing your personal information

We will only use your information within the Mwezi Foundation for the purposes for which it was obtained. The Mwezi Foundation will not, under any circumstances, sell or share your personal data with any third party for their own marketing purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.

Please note, we will comply with legal requests where disclosure is required or permitted by law (for example to government bodies, statutory bodies, or law enforcement agencies for tax purposes, where it is in the public interest, or for the prevention and detection of crime, subject to appropriate protection in law).

How long the Mwezi Foundation will keep your personal information

We will hold your personal information on our systems for as long as is necessary for the relevant activity. For example, we will keep a record of donations subject to Gift Aid for at least seven years to comply with HMRC rules.

If you request that we stop sending you marketing materials we will keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us.

How to control what we send you or request we update your personal information

The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest.

If you wish to change how we communicate with you, or update the information we hold, then please contact us at info@mwezifoundation.org, or on +44 7778 795 346, or by writing to us at 12 Vicarage Road, Henley-on-Thames, RG9 1HJ, England, UK.

Email: you can opt out of marketing emails at any time by clicking the unsubscribe link in any marketing email from the Mwezi Foundation.

We endeavour to deal with any requests for changes within 48 hours of receipt of your request.

How we keep your data safe

We ensure that there are appropriate technical controls in place to protect your personal details. For example our online forms are always encrypted and our network is protected and routinely monitored.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff, volunteers and contractors.

Your rights over your personal data

You have a variety of rights in respect of your data, including the rights to see, update, restrict, object to the use of or withdraw use of your data. In particular, depending upon why we hold your data, you may have the right to request:

Access to the personal data we hold about you, including how we first obtained your details, free of charge in most cases (this is known as a “Subject Access Request”).
The correction of your personal data when incorrect, out of date or incomplete.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we remove your personal data from our systems (this is known as the “Right to be Forgotten”).
That we no longer process your data automatically to decide whether particular marketing activities are likely to be of interest, or suggest an appropriate donation level based on your previous donation history. This is known as profiling, and helps us to ensure that our marketing is relevant and appropriate.

You can contact us to request to exercise these rights at any time. Please see the section “How to control what we send you or request we update your personal information” for details of how to get in touch.

Opting out of direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We will always comply with your request.

Where we are sending you direct marketing on the basis of our legitimate interest, you can also ask us to stop. In the case of postal marketing sent on this basis, we will always comply with your request to opt out. Similarly, where we send email marketing on a soft opt-in basis (see the section “How and when we will collect information about you”), we will also comply with all requests to opt out.

Exercising your “Right to be Forgotten”

Upon request we will remove your personal data from our systems, to the extent that we are permitted to by law or regulatory guidelines. For instance under HMRC rules we are required to retain financial data for seven years for audit purposes, and so will not be able to delete donation details until this time period has elapsed.

Opting out of profiling

Upon request we will cease using your personal data to decide whether you would be interested in particular updates and other marketing. Such requests may lead to you not hearing from us in future.

Making a “Subject Access Request”

You have the right to request a copy of the personal information we hold about you. We will provide this as soon as possible, and within a month unless there are specific reasons why this would not be possible. We will always let you know if this is likely to be the case.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

How to find out more or make a complaint about the Mwezi Foundation’s approach to data protection

If you would like more information, to update your details or have any questions about this Policy, please contact: info@mwezifoundation.org, or on +44 7778 795 346, or by writing to us at 12 Vicarage Road, Henley-on-Thames, RG9 1HJ, England, UK.

To make a formal complaint about the Mwezi Foundation’s approach to data protection or raise privacy concerns directly with us, please contact Doods Dawson-Coltman, trustee, on doods@mwezifoundation.org.

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. Alternatively, you can go online to www.ico.org.uk/concerns (opens in a new window; please note we cannot be responsible for the content of external websites).

Changes to the Mwezi Foundation’s Privacy Policy

This Privacy Policy may be updated from time to time so you may wish to check it each time you submit personal information to the Mwezi Foundation. The date of the most recent revisions will appear at the top of the Policy. If you do not agree to these changes, please do not continue to use the Mwezi Foundation website to submit personal information to the Mwezi Foundation. If material changes are made to the Privacy Policy we will notify you by placing a prominent notice on the website.

Last Updated: 16 November 2022