Privacy Policy and Data Protection

The Anne Frank Trust is committed to protecting your personal information and respecting your privacy, and to being transparent about what information we hold about you. This privacy notice explains to you what information we collect, how we collect it, what we use it for and why. It is important that you read this privacy notice so that you are fully aware of and understand how and why we use your personal information.

This Policy sets out why we collect personal information about individuals and how we use that information. It explains the legal basis for this and the rights you have over the way your information is used.

For the purposes of the General Data Protection Regulations (GDPR) and any subsequent UK legislation covering data protection the Data Controller is The Anne Frank Trust UK, registered charity number 1003279, of Star House, 104-108 Grafton Road, London NW5 4BA.

This Policy covers the Charity in relation to the collection and use of the information you give us. We may change this Policy from time to time. If we make any significant changes we will advertise this on the website or contact you directly with the information. Please check this page occasionally to make sure you are happy with any changes.

If you have any questions about this Policy or concerning your personal information please email [email protected] or send by post to Star House, 104-108 Grafton Road, London NW5 4BA.

What type of personal information we collect

Personal information means any information about you by which you can be identified. The information we collect from you is necessary and required and relevant to the activity for which it is being collected. The ultimate goal of all the information we collect is to ensure we are able to continue working towards our vision of a society free from prejudice and discrimination.

The type and amount of information we collect depends on why you are providing it. Below is the type of information we collect and use:

Supporters

If you are a supporter (for example making a donation, volunteering, registering to fundraise, signing up for an event), in addition to asking for your name and contact details (your name, email address, home address, business name and address and phone numbers), we may also ask you for other information (for example, reasons for supporting the Charity’s work or particular interests).

Attending events

If the event is live and ‘in person’ we will need to store your details for security reasons.

Additionally if you are a supporter who is coming to our annual lunch, we may also ask you for information such as dietary requirements.

 

If you have been a supporter for a while, we will hold information about your transactional history, the number and amount of donations you have given to us in the past plus whether we hold a gift aid agreement form yourself.

Payments to the Trust are processed securely and can be made in various forms:

• Cheques and/or charity vouchers
• BACS
• Credit cards
• PayPal

Bank and credit card details are shredded once payments have been processed.

We will also ask you about your marketing and communication preferences for receiving further information from us, including how your support has helped, further opportunities for support, and about our campaigns.

Programme Participants

For monitoring purposes, we collect information about our participants, mainly from our young people who are Peer Guides and/or Anne Frank Ambassadors and adults who may be supporting one of our programmes such as a teacher or maybe directly involved in one of programmes such as a prisoner guide. For under 16s, this information is only collected with the parents’ permission, is held securely, is aggregated and used to gain a better understanding of the range of participants we work with as a whole and impact of our programmes

For a number of our programmes we may collect and keep the following information

• Personal information – e.g. name and age
• Characteristics – e.g. ethnicity, language, nationality, religion
• Attendance information – e.g. programmes attended
• Assessment information – e.g. completion of impact questionnaire

For evaluation purposes, we ask participants about the impact our programmes have had on their knowledge, skills and confidence, as well as any changes they think it has brought about in their attitudes towards others. The data we collect from participants is used to help us understand how our programmes work and how we can improve them in future. For U16s, it is not collected without parents’ consent and all the data is aggregated and it is not possible to identify individuals. It is analysed and broad trends are reported. We share this information internally and externally, through reports and for marketing purposes.

This information is aggregated and used to understand the impact of our programmes to both inform the school, programme funder and the Trust of the impact of the programme and improve it where possible.  

We ask permission from participants to collect this information, and from their parent/guardian if they are under 16.

It is optional for participants to provide this information and if they choose not to provide this information, it is not a barrier to taking part in our programmes. Participants, or their parents/guardians, can ask for this data to removed and deleted at any time.

We collect publicly available data on the schools and prisons we work with (e.g. Ofsted reports, school characteristics data). This is used to better understand the context of the schools and prisons we work in and allow us to contact these organisations.

We hold contact information on our lead contacts from the schools and prisons we work with, including their email address and telephone numbers.

Job applicants

If you are a job applicant, the information you are asked to provide is as set out in the advertisement and necessary for the purposes of our processing your application.

How we collect information

We may collect information from you whenever you contact us or have any involvement with us for example when you:

• visit our website (see our Cookies policy https://annefrank.org.uk/about-us/privacy-policy-and-data-protection)
• donate to us or fundraise for us
• enquire about our activities or services
• sign up to receive news about our activities
• post content onto our website/social media sites
• volunteer for us
• attend a meeting with us and provide us with information
• take part in our events
• contact us in any way including online, email, phone, SMS, social media or post

Where we collect information from

We collect information:

• From you when you give it to us directly: You may provide your details when you ask us for information or make a donation, volunteer, attend our events contact us for any other reason.
• When you give it to us indirectly: Your information may be shared with us by other organisations such as fundraising sites like Just Giving or Virgin Money if you are fundraising for us. They should only do so in the way they have set out in their own Privacy Policy which you should check when you give your details.
• When you use our website: When you use our website, information about you is recorded and stored. See the information about the use of cookies under that heading below.
• We may use information that is already in the public domain (information that has been published in print or online) to identify individuals who may be interested in supporting our work further. These publicly available sources of information include Companies House, the electoral register, the Charity Commission Register of Charities, Who’s Who, LinkedIn, company annual reports and articles in newspapers and magazines. We do not use publicly available sources which we consider would be intrusive for this purpose, such as Facebook, Twitter, JustGiving, the Land Registry, online planning applications, or similar websites.

How we use your information

We will use your personal information in a number of ways which reflect the legal basis applying to processing of your data. These may include:

• providing you with the information or services you have asked for
• processing donations you make, including processing for Gift Aid purposes
• organising volunteering activity you have told us you want to be involved in and in relation to the fundraising for us you are involved in
• sending you communications that may be of interest including marketing information about our services and activities, campaigns and appeals asking for donations and other fundraising activities and promotions for which we seek support
• sending invitations for events we are holding, decide on catering
• when necessary for carrying out your obligations under any contract between us
• seeking your views on the services or activities we carry out so that we can make improvements
• maintaining our organisational records and ensuring we know how you prefer to be contacted
• analysing the operation of our website and analysing your website behaviour to improve the website and its usefulness
• processing job applications
• using profiling and database segmentation techniques to analyse your personal information and create a profile of your interests, preferences and ability to donate. This allows us to ensure communications are relevant and timely in order to provide an improved experience for our supporters. It also helps us understand our supporters’ backgrounds so that we can make appropriate requests to those who may be willing and able to donate more than they already do or leave a gift in their Will. This enables us to raise funds more quickly and cost-effectively.
• Process your legacy gift to us

Our legal basis for processing your information

The use of your information for the purposes set out above is lawful because one or more of the following applies:

• Where you have provided consent to us to use your personal information in a certain way. You may withdraw or change consent at any time by emailing us at [email protected]. This will not affect the lawfulness of processing of your information prior to your withdrawal of consent being received and actioned.
• It is necessary for us to hold and use your information so that we can carry out our obligations under a contract with you or to take steps you ask us to prior to entering into a contract.
• It is necessary to comply with our legal obligations.
• If it is in the legitimate interests of the organisation to do so. In these cases we are always careful to ensure we balance the potential impact on you, both positive and negative against the requirements of the activity to help us reach our vision of a society that is safe from discrimination and prejudice.

Under data protection legislation you have the right to object to your data being processed in any of the above ways. If you want to contact us about your preferences please contact [email protected] or call on 020 7284 5858.

We will never use your information to send you details about fundraising and marketing when you have explicitly said you do not wish to receive them.

How we keep your information safe

We understand the importance of security of your personal information and take appropriate steps to safeguard it. We hold all our supporter information on our database, Salesforce, which is a cloud based database and password protected. Any transfer of data is done on secure systems.

We have malware protection – Mimecast anti-spam protection – and a number of CISCO products  are installed on our network systems to protect us from the risk of hacking and keep your data secure. Our detailed ICT policy sets our procedures for managing data securely, including use of password protection and physical storage.

We always ensure only authorised persons have access to your information, which means only our staff, volunteers and contractors as required, and that everyone who has access is appropriately trained to manage your information.

No data transmission over the internet can however be guaranteed to be 100% secure. So while we strive to safeguard your information, we cannot guarantee the security of any information you provide online and you do this at your own risk.

Who has access to your information?

• Third parties who provide services for us for example designers, printers, sending mailings, CRM support, IT support. We select our third party service providers with care. We provide these third parties with the information that is necessary to provide the service and we will have an agreement in place that requires them to operate with the same care over data protection as we do.
• Third parties if we run an event in conjunction with them. We will let you know how your data is used when you register for any event.
• Analytics and search engine providers that help us to improve our website and its use.

Other than this, we will not share your information with other organisations without your consent and we will never sell your information to another company for their marketing purposes.

Keeping your information up to date

We really appreciate it if you let us know if your contact details change. You can do so by contacting us at [email protected].

Our use of “cookies”

“Cookies” are small pieces of information sent by a web server to a web browser, which enables the server to collect information from the browser. They are stored on your hard drive to allow our website to recognise you when you visit. We only use cookies for the following purposes:

• To monitor how visitors are using the website. We use Google Analytics to learn information about our users, such as which country they live in and which pages are most read and how long they are read for. This enables us to improve our website. It does not allow us to obtain personal information about visitors.
• To allow users to link to the site on social media.

We do not use cookies for the following purposes:

• To collect any personally identifiable information, unless you have chosen to give it to us.
• To pass any information to advertisers or any other third parties.

Under the European Union’s e-Privacy Directive, we need your permission to store cookies on your computer or device. Like many charities, we need time to develop the website to enable us to record permission from our visitors. Until that time, the best means for us to get your consent is by letting you know here how we use cookies. If your internet browser’s settings accept cookies then we assume that you are happy for us to use them. If you do not wish us to use cookies, then please change your browser settings to turn them off and delete them from your browsing history. For guidance on controlling cookies on different browsers and devices, a helpful guide can be found here. Please be aware that disabling cookies may affect your experience of using the website.

Children’s information

We appreciate that our supporters are of all ages. The Charity has in place safeguarding policies and processes to protect the children and young people (under 16s) who take part in its educational programmes.

We will always ask for a consent from a parent or guardian to collect monitoring and evaluation information about children and/or to film or photograph them as part of our education programmes.

We will never publish details that might identify a child who has taken part in our education programmes. Any photo captions in publications and/or on our website or Facebook pages will only give the forename of the child and their town or their role (e.g. Anne Frank Ambassador) and their school, unless we have received explicit permission and consent from the child and their legal guardians to do so

How long we keep your information for

We will hold your personal information for as long as it is necessary for the relevant activity. By way of example, we hold records of donations you make for at least six years so we can fulfil our statutory obligations for tax purposes. Please see our Records Retention Policy.

Where we rely on your consent to contact you for direct marketing purposes, we will treat your consent as lasting only for as long as it is reasonable to do so. This will usually be for two years beyond the active relationship ends. We may periodically ask you to renew your consent.

If you ask us to stop contacting you with marketing or fundraising materials, we will keep a record of your contact details and limited information needed to ensure we comply with your request.

Your rights

You have the right to request details of the processing activities that we carry out with your personal information through making a Subject Access Request.  Such requests have to be made in writing. More details about how to make a request, and the procedure to be followed, can be found in our Data Protection Policy. To make a request contact us at [email protected].

You also have the following rights:

• the right to request rectification of information that is inaccurate or out of date;
• the right to erasure of your information (known as the “right to be forgotten”);
• the right to restrict the way in which we are dealing with and using your information; and
• the right to request that your information be provided to you in a format that is secure and suitable for re-use (known as the “right to portability”);
• rights in relation to automated decision making and profiling including profiling for marketing purposes.

All of these rights are subject to certain safeguards and limits or exemptions, further details of which can be found in our Data Protection Policy.  To exercise any of these rights, you should contact the Chief Executive at the above address.

If you are not happy with the way in which we have processed or dealt with your information, you can complain to the Information Commissioner’s Office.  Further details about how to complain can be found at https://ico.org.uk/for-organisations/guide-to-data-protection

Changes to this Privacy Policy

This Policy may be changed from time to time. If we make any significant changes we will advertise this on our website or contact you directly with the information.

Do please check this Policy each time you consider giving your personal information to us.

Updated June 2021