Privacy

PRIVACY POLICY

BACKGROUND

The Sarwar Foundation understands that your privacy is important to you and that you care about how your personal data is used.

We take responsibility for the personal information we collect about you and we aim to be transparent about how we handle it and give you control over it.

This privacy notice aims to inform you about how we collect and process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. It tells you about your privacy rights and how the law protects you.

We are committed to protecting your privacy and the confidentiality of your personal information. Our policy is not just an exercise in complying with the law, but a continuation of our respect for you and your personal information.

We are also committed to complying with General Data Protection Regulation (GDPR), which came into force on 25 May 2018.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

WHO WE ARE

The Sarwar Foundation is a Charitable Company limited by Guarantee. Our Company registration Number is 03949712. We are a registered charity in England and Wales (1083036) and Scotland (SC041327). ICO Registration Number CSN4703969.

Our registered address is 47 Theydon Street, London, E17 8EN.

Our main trading address is 320 Victoria Road, Glasgow, G42 7RP.

This Privacy Policy relates to information which is obtained by the Sarwar Foundation.

HOW TO GET IN TOUCH

We have appointed a data protection officer (DPO) who is responsible for ensuring that our policy is followed.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, Mohammed Rajak.

Post:

Mohammed Rajak

The Data Protection Office

320 Victoria Road,

Glasgow

G42 7RP.

Email : rajak@sarwarfoundation.org

Phone:+44(0)141 423 4242

THE SARWAR FOUNDATION'S PURPOSE

Vision, mission and values statement

Our vision is to save lives, transform the lives of those in need, and create fulfilling lives.

Our mission is to save lives by providing access to quality healthcare and clean drinking water, and tackle poverty by educating children, empowering women, and helping those in need in Pakistan, the UK and across the world.

Our values are driven by social justice, the principles of equality and fairness, promoting greater diversity, and a sense of pride in our history and communities.

Objectives

Health: We aim to provide greater access to quality healthcare and free medicines including the treatment of tuberculosis and hepatitis. With Pakistan’s health system lacking basic medical facilities, we run two hospitals and regular medical camps.

Clean water: We aim to increase the availability of clean water in Pakistan, to prevent unnecessary illness and death. We build and maintain water treatment plants in areas of need.

Education: We aim to improve educational opportunities in Pakistan, we run a foundation school and educate children at training centres with their mothers.

Women empowerment: We aim to increase women empowerment in Pakistan. We run training centres (Hunargahs) which enable women to learn new skills.

Global poverty: We aim to tackle global poverty, including in the UK. We run an annual toybank appeal in Scotland and provide disaster relief support across the world.

HOW DO WE COLLECT INFORMATION?

We may collect information about you directly whenever you interact with us. For example, when you contact the Sarwar Foundation regarding our activities, register as a supporter, send or receive information, engage with our social media or make a donation to us, you may provide us with personal information.

We may also receive information about you when you interact with third parties with whom we work. For example, where you’ve made a donation to us through a third-party website (e.g. JustGiving) and given them permission to share your information with us.

DATA WE PROCESS

We may collect, use, store and transfer different kinds of personal data about you. We have collated these into groups as follows:

Your identity includes information such as first name, last name, title, date of birth, and other identifiers that you may have provided to us at some time.

Your contact information includes information such as address, email address, telephone numbers and any other information you have given to us for the purpose of communication or meeting.

Your financial data includes information such as your bank account and payment card details.

Transaction data includes details about payments or communications to and from you and information about donations you have made.

Taxation Status if you have chosen to include Gift Aid in a donation to us, then we are hold information including your tax status.

Technical data includes your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Employer details for processing a payroll gift.

Marketing data includes your preferences in receiving marketing from us; communication preferences; responses and actions in relation to your use of our services.

Non-personal information such as IP addresses (the location of the computer on the internet) and pages accessed. This helps us to determine how many people use our website, the frequency of visits and how popular our pages are. This information doesn’t tell us anything about who you are or your address, it simply allows us to monitor and improve our service.

HOW WE MIGHT USE YOUR INFORMATION IF YOU ARE A SARWAR FOUNDATION SUPPORTER WHO RECEIVES MARKETING MATERIALS OR MAKES DONATIONS

We may use your information for administration purposes

  • Processing your donation

When you make a donation to the Sarwar Foundation, we will use your payment and contact details, payment amount, date and time of payment to process that payment and take any follow-up administrative action needed (for example, sending a receipt).

If you choose to include Gift Aid in a donation to us, then we will also ask for your address and UK taxpayer status as this information is required by law.  You can read more about how Gift Aid works here. This information is needed for us to fulfil our obligations under tax (sections 413 to 430 Income Tax Act 2007) and charity law. Information associated with Gift Aid declarations must be retained for 7 years. This information will be shared with HMRC for tax regulation purposes and may also be shared with the Fundraising Regulator and the Charity Commission in the event of an enquiry or investigation.

  •  Responding to enquiries

If you contact us with a question, comment, compliment or complaint then we will keep a record of this correspondence and any associated documents so that we have the information available in the event of a follow-up, dispute or investigation.

  • Requesting information if you are attending our events

If you participate in an event that we have organised, we may ask you to provide information to make sure we can manage the event safely and efficiently. We may also ask you for details of any accessibility need which you may have, so that we ensure our event is inclusive, in line with the provisions of the Equality Act 2010.

  • Sharing marketing and fundraising materials with you

Marketing and fundraising materials that we might share with you includes information about our activities and their impact, our news, events and fundraising appeals, as well as other ways you can become involved with us. For these we share information about our activities and events to people we think will be interested and individuals who have signed-up.

Where you have provided your postal address or telephone number, we may send this information to you by post or by calling your telephone unless you have asked us not to. We may also email you this information or send by SMS if you have agreed for us to do so, or if you are a representative of an organisation and would interested in our message.

You can let us know at any time, if you’d prefer to change how we share this information with you or stop it altogether. Simply use the details we’ve provided in the ‘Controlling your own details’ section to let us know your preferences.

We will keep your personal information for no longer than is necessary for the purposes for which it is processed (in accordance with our internal policies/retention policy). If you ask us not to contact you, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future. If you have told us that you would like to leave the Sarwar Foundation a gift in your Will, we may keep your donor record for longer than others, unless you tell us not to.

  • Targeting our communications and researching our supporters

We have a duty to make sure that we’re spending your donations wisely, and that means doing some research and analysis to inform our decisions. We want to send the most effective messages that we can in the most efficient way possible. In order to work out who to contact, what to say and when to get in touch, we carry out the following activities:

  • Analysing how emails are opened and read

We track emails which we have sent to you to see which messages have the highest response rates and whether there are messages that resonate with particular groups of people. We do this by logging whether emails we send have been opened, deleted and interacted with (for example, by clicking on links within the emails). Although we only use this information to look at general patterns, it is still personal information because it is linked to your email address. We may ask you occasionally whether you still want to receive emails, and unsubscribe you if we do not hear from you. We use email platforms such as Mailchimp  (which have their own privacy policies) to manage and send fundraising, newsletter and project update emails, and to ensure you are unsubscribed if you opt out of email messaging.

  • Analysing Comments

 When a comment is left on the site we collect the data shown in the comments form, and also the your IP address and browser user agent to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar Service Privacy Policy is available here. After approval of your comment, it will be visible to the public.

  • Analysing our supporter base to send different communications to people who might choose to give higher donations

We undertake in-house research to help us identify people who may be able to support us with a larger gift; using information you have given us and publicly available records such as the electoral roll. We use this information to tailor our communication with you.

  • Social Media 

Depending on your settings or the privacy policies of the social media platforms and messaging services you use (e.g. Facebook, YouTube, Twitter, Instagram, WhatsApp etc.) you may allow us to access information from those services for example if you publicly “like” or “follow” us we may be able to collect information from your social media profile.  We strongly advise you to check the privacy settings on your social media accounts to ensure that you know what information is shared with us and others.

  • CCTV

Our  premises in Victoria Road, Glasgow has CCTV and you may be recorded when you visit this property. CCTV is there to help provide security and to protect both you and the Sarwar Foundation. CCTV will only be viewed when necessary (e.g. to detect or prevent crime). Unless it is flagged for review, CCTV footage will be recorded over. Sarwar Foundation complies with the ICO’s CCTV Code of Practice, and we put up notices so you know when CCTV is in use.

  • We may use your information to enforce and comply with the law

We ensure that our activities comply with the law. Therefore we may need to share or use your personal information if we are required to do so by law and we may use information from other sources for the purposes of fraud prevention, for example to comply with money laundering regulations, or to protect people’s rights, property or safety.

If certain levels of donation are made, the Fundraising Regulator’s Code of Fundraising Practice requires us, and all charities in the UK, to perform checks. More details can be found here.

HOW WE MIGHT USE YOUR INFORMATION IF YOU ARE A VOLUNTEER FOR THE SARWAR FOUNDATION

We have a small number of volunteers including our Board of Trustees, among others who do fantastic work to support the Sarwar Foundation’s mission. We collect and process your contact details, keep track of the support you provide to the charity and may need to collect or process other information about you to ensure we comply with laws such as health and safety, data protection and anti-fraud. We will make it clear what this information is for and how we are using it. We will send you information about similar ways you can get involved, and may ask for your permission to send you information about other Sarwar Foundation events, fundraising information and updates by email.

We hold your information on our secure network and only allow access to our employees who need your information to do their jobs. If we are required by law to share your information, we will do so.

HOW WE MIGHT USE YOUR INFORMATION IF YOU HAVE VISITED OUR WEBSITE

We log the IP address of the computer you are using in order to protect our servers against abuse and malicious activity. This is done by the means of cookies. When you login we will set up a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
We will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed

Other information is used to measure the performance of the website, the volume of traffic that the site receives, how site users move around the site and what sort of users the site attracts. You can find out more in our website and cookies policy.

When you access our websites, some cookies are saved to your computer, for example if you have chosen a particular language setting. You can also turn off your cookies so that we can’t access that information.

TRANSFER OF INFORMATION OUTSIDE OF THE EUROPEAN ECONOMIC AREA

Information is stored by the Sarwar Foundation in the UK. As a result of the work we undertake, we may when necessary transfer the information to other offices and third party organisations, these may be situated outside the EU.

We are aware that countries outside the European Economic Area have differing approaches to data privacy laws, and that enforcement may not be as robust as it is within Europe’s borders. Under data protection law organisations that want to transfer personal data outside of the EU must assess whether the country the data would go to has an adequate level of protection for individuals. The European Commission decided whether countries are considered adequate, either partially or fully. The transfer of your information is governed by EU model contract clauses which set out how the organisation outside the EEA is required to protect your privacy rights by adhering to European data protection standards.

We do use third parties such as mailchimp, google and YouTube, we will ensure that any such third-party is signed up to an approved transfer mechanism such as the EU-US Privacy Shield where the organisation is based in the United States of America.

  • MailChimp

We use MailChimp to send emails and newsletter.  MailChimp is based in the U.S.A. and subscribes to the EU-US Privacy Shield meaning that MailChimp has adopted work practices that are approved by the EU in relation to data protection practices.  The MailChimp registration on the Privacy Shield is available to review on the Privacy Shield website here.

  • Google Web Fonts

For uniform representation of fonts, this website uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our plugin.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data can be found here and in Google’s privacy policy here.

  • YouTube

Our website uses plugins from YouTube, which is operated by Google. The operator of the pages is YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA.

If you visit one of our pages featuring a YouTube plugin, a connection to the YouTube servers is established. Here the YouTube server is informed about which of our pages you have visited.

If you’re logged in to your YouTube account, YouTube allows you to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your YouTube account.

YouTube is used to help make our website appealing.

Further information about handling user data, can be found in the data protection declaration of YouTube here.

HOW LONG WILL WE KEEP YOUR DATA?

We only keep your information for as long as we need to. We will keep it and delete it in accordance with our internal polices.

If you have kindly added Gift Aid to a donation we must record the fact that you are a UK taxpayer. HMRC requires that we maintain a record of that Gift Aid for seven years after your last donation to us.

If you apply for a job with us and share sensitive information as part of the application process, the information will be stored in a personnel record if you are successful, or for six months after the closure of the recruitment campaign if your application has been unsuccessful. If you request we will keep your information on file for future positions.

For volunteers we keep information for two years after your last interaction with us.

For donors, four years after your last donation or if you request to receive no further contact from us, we’ll continue to keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

Comments

if you choose to leave them on our website, the comment and the metadata are retained indefinitely. They will be removed if you request us to do so.

Where someone has left the Sarwar Foundation a gift in their Will we will maintain a record of that pledge to carry out legacy administration and communicate effectively with the families of people leaving us a legacy.

HOW DO WE PROTECT AND SECURE YOUR PERSONAL INFORMATION?

The Sarwar Foundation is committed to protecting your personal information. We use appropriate technical and organisational measures, including encryption, to protect personal information and privacy, and we review them regularly. We protect your information using a combination of physical and IT security controls, including secure servers, firewalls and access controls that restrict and manage the way that information and data is processed, managed and handled. We also make sure that our staff are adequately trained in protecting personal information.

Our procedures mean that we may sometimes ask for proof of identity before we share your personal information with supporters or members – for example to check that we are speaking to the owner of that personal information.

In the unlikely event of a security breach that compromises our protection of personal information, and we need to let you know about it, we will do so.

CONTROL OVER YOUR OWN INFORMATION

It is important that the information we hold about you is accurate and current. Please keep us informed if your personal data changes.

Contact us on +44(0) 141 423 4242, email info@sarwarfoundation.org or write to us at 320 Victoria Road, Glasgow, G42 7PR to:

Update your personal information

Change your personal information

Change your contact preferences

You have a number of rights under data protection legislation:

You can request any information we hold on you. Email us at info@sarwarfoundation.org or write to us at 320 Victoria Road, Glasgow, G42 7PR and ask for it in writing. We’ll supply any information you ask for as soon as possible, but this may take up to 30 days. You may be asked for proof of identity.

You have the right to ask us to stop using or to restrict the processing of your personal data in certain cases, e.g. where it’s no longer needed to do what you provided it to us for, or if there is some disagreement about its accuracy.

You can withdraw your consent to us processing your data at any time (where such processing is based on consent e.g. to send you electronic direct marketing).

If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. To update your records please get in touch with us using the details above.

In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database), or transferred to another organisation (“data portability”). Where you have requested that we don’t send you marketing materials we’ll need to keep some limited information in order to ensure that you’re not contacted in the future.

If you have any concerns about the way your data is being used or if you’d like to make a complaint please contact us at info@sarwarfoundation.org or write to us at 320 Victoria Road, Glasgow, G42 7PR.

If your complaint is not dealt with to your satisfaction you can raise this with the Information Commissioner’s Office (ICO) website here or on 0303 123 1113.

CHANGES TO OUR PRIVACY POLICY

This privacy policy may change from time to time. For example, we will continue to update it to reflect new legal requirements.

If we make any significant changes in the way we treat your personal information we’ll make this clear on our websites or by contacting you directly.

THIS POLICY WAS LAST UPDATED IN OCTOBER 2019