Privacy Notice

Introduction

We understand that the privacy of all of our donors, funders, supporters, staff, volunteers, grant applicants, health professionals, those requesting health information, people interested in our work and website visitors to www.wcrf-uk.org is important to them and that they care about how their personal data is used. In this Privacy Notice, we refer to all of those individuals as “you” for convenience.

We respect and value your privacy and will only collect, hold, use or share your personal data in ways that are described here, and in a way that is consistent with our obligations and your legal rights.

1. Who we are and how to contact us

World Cancer Research Fund is a registered charity number 1000739, a charitable company limited by guarantee registered in England under number 2536180 whose registered address is 140 Pentonville Road, London, N1 9FW, and is regulated by the Charity Commission.

We are subject to UK GDPR and the Data Protection Act 2018, and registered as a data controller with the ICO under registration number Z6021605.

We are registered with the Fundraising Regulator.

For enquiries regarding how we collect and use your personal data, including to object to direct marketing, to object to profiling and research, and to update your details if they change, please contact our Supporter Services team:

By post: Supporter Services, World Cancer Research Fund, 140 Pentonville Road, London, N1 9FW
By telephone: 020 7343 4205

You may also contact our Data Protection Officer by emailing dpo@wcrf.org.

2. What does this Notice cover?

3. What is personal data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What are my rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 1.
The right to access the personal data we hold about you. Part 10 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate, incomplete or out of date.
The right to erasure, i.e. the right to ask us to erase or otherwise dispose of any of your personal data that we hold.
Where possible we will check with you to see if it is better for you to have your details suppressed (your right to object to processing) rather than erased. By exercising your right of erasure, we cannot guarantee that you will not receive further mailings from us in the future; for example if WCRF rents a list of names after we have actioned your request for erasure and if your details are on this new list, you may well receive a communication from us. This is because we check all new lists against our database and once a name has been erased from our database we have no way of checking if that name is on the new list and has previously requested not to be contacted..
The right to restrict (i.e. prevent) processing your personal data, where we store your data but do not use it for any purpose. This would normally for a period of time whilst we are investigating our use of your data, in response to a request from you. It is often linked to your request to exercise another of your rights.
The right to object to us using your personal data for a particular purpose or purposes.
You may object if the processing is for
- A task carried out in the public interest;
- The exercise of official authority vested in us;
- Our legitimate interest (or those of a third party processor).
You have an absolute right to object to the processing of your personal data for any profiling for direct marketing purposes.
You also have an absolute right to object to the processing of your personal data for direct marketing purposes.
Unlike your right to erasure, restricting processing means that we still hold your personal data, but our systems are instructed not to process your data in the ways that you do not want. Therefore, should WCRF rent or purchase a new list of names after your request for suppression, we can cross reference this list with your details. Should your details appear on the new list and because we still have your basic details on our database, we will know that you do not want to receive communications from us and because of this you will not receive communications.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. Part 6 explains more about how we use your personal data, including profiling. You also have rights in relation to automated decision-making, but we do not process any personal data in this way.
You also have the right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 1.

It’s important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office website www.ico.org.uk or their helpline 0303 123 1113.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 1.

5. What personal data do you collect and how?

Depending on the ways in which you engage with us, we may collect and hold some or all of the personal data set out below, using the methods set out there.

We do not collect any ‘special category’ (‘sensitive’) personal data apart from that relating to health, where it is relevant. We do not collect data relating to criminal convictions and/or offences.

Where we collect and manage information from under-18s, we aim to manage it in a way which is appropriate to the age of the child. Before processing personal data of children under 13 years of age, who cannot give their own consent, we will always obtain the consent of a legally responsible adult (normally a parent or guardian).

We may collect personal data about you using the following methods:

Provided by you
By a direct interaction with you
Via our website
By a third party when you choose that they pass this information to us, for example when you register to attend an event or make a donation

We may collect the following types of personal data:

Identity Information including name, title, date of birth, gender.
Contact information including postal address, email address, telephone number (landline and/or mobile).
Professional information including qualifications, expertise, areas of interest
Profile information including preferences, interests, login details, purchase history, website pages you click to, through and from
Donation information including amounts, dates, requested purposes and whether you self-select as qualifying to donate by Gift Aid
Technical information including IP address, browser type version and plugins, operating system, time zone, operating systems and platforms
HR information including applications and employment history for staff and volunteer recruitment, and employment administration
Grant information including applications, grant reviews and panel members for the awarding and management of the science grant programme
Supporter story information for the creation and management of supporter stories
Third party data, including identity, contact and profile information, from publicly available sources and data procurement companies.

Our website may contain links to other websites that are outside our control and are not covered by this Privacy Notice. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours. Please make sure that you check the privacy notices of these sites.

6. How do you use my personal data?

Under UK data protection legislation, we must always have a lawful basis for using personal data.

The possible lawful bases for processing are set out in Article 6 of the UK GDPR and are:

Consent: you have given clear consent for us to process your personal data for a specific purpose.
Contract: the processing is necessary for a contract we have with you, or because you have asked you to take specific steps before entering into a contract.
Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
Vital interests: the processing is necessary to protect someone’s life.
Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

The following table describes how we may use your personal data (our purpose of processing), and our lawful bases for doing so:

Purpose of processing	Our lawful basis
Charity administration: Administering our charity	Legitimate interests Legal obligation
Communications: managing our relationship with you, as a supporter and communicating with you, including where you enquire about us and our work, health information, activities, volunteering, events, and ways of supporting us	Legitimate interests Consent for all marketing communications by email or SMS
Fundraising: managing our relationship with you, as a donor, receiving a donation from you and claiming Gift Aid on your donations	Legitimate Interests Consent for all marketing communications by email or SMS
HR: Managing our relationship with you, as a volunteer or employee, including recruitment and development	Contract Legal obligation for any information required under the Equality Act 2010
Health Information: Providing Health information to the general public	Legitimate Interests Consent for all marketing communications by email or SMS
Science, Policy and Health Professionals: Managing the network of scientists, policy experts and health professionals including membership and development	Consent for communications and development Contract for providing services as part of the network
Science grants: management of the science grant programme	Contract
Supporter stories: management of the supporter stories programme	Consent
Events: Managing our events and your registration and attendance	Contract
Website: Managing your experience of visiting our website wcrf-uk.org	Legitimate Interests Consent for all marketing communications by email or SMS

In addition, when processing special category data the additional condition for processing is Consent unless otherwise stated.

With your permission and/or where permitted by law, we may use your personal data for marketing purposes, which may include contacting you by email and post with newsletters, fundraising appeals, campaigns, or other information or with information about our products or services. You will not be sent any unlawful marketing or spam.

We will always work to fully protect your rights and comply with our obligations under the UK data protection legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We will always comply with requests to opt-out made through the Fundraising Preference Service or the Mailing Preference Service.

If your details are included on either the telephone preference service or fundraising preference service lists, but you provide us with your telephone number during one of our marketing campaigns, we will treat the provision of your telephone number to us as an indication that you do not object to receiving telephone marketing calls from us for the time being. You can change your preference at any time by contacting us using the details in Part 1.

We will never share, rent or sell your personal data to third parties for their own marketing purposes.

We do not use automated systems for carrying out decision-making. We may use automated or manual profiling and screening techniques to ensure communications are relevant and timely, and to provide an improved experience for our supporters. Profiling also allows us to target our resources effectively. We do this because it allows us to understand the background of the people who support us, and helps us to make appropriate requests to supporters who may be able and willing to give more than they already do. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would. We may also supply your name and address to specialist processors on a single-use basis, for the purpose of creating profiles that help us identify the characteristics of likely new supporters.

When building a profile, we (or one of our trusted partners) may combine information you provide to us with publicly available information such as geographic, demographic, wealth and other information relating to you, and we may use additional information from third-party sources when it is available. We believe that we have a legitimate interest in processing your personal data in this way, in order to better understand the way you interact with our website, your interests and your preferences, and so that we can contact you with the most relevant communications. If you would prefer us not to use your personal data in this way, contact us using the details above.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 1 below.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the data protection legislation and your legal rights.

We use FundraiseUp for the of processing regular and one-off donations via our website. The FundraiseUp platform uses some automation known as machine learning, in order to recommend suggestion donation amounts and other actions, and this is based on analysis of publicly available data related to your location, browser type and device, website activity, and any previous donations made to us through FundraiseUp. This information is only ever used anonymously and in ways that cannot identify you or any individual.

This does not involve any automatic decision making, and you may ignore any suggested donation amount. We use this functionality based upon our legitimate interest to support our fundraising and charitable work, and you are welcome to contact us for more information.

7. How long will you keep my personal data?

We will not keep your personal data for any longer than is necessary in light of the purpose(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of data	How long we keep it
Identity, Contact, Professional, Profile, Technical, Third party	While we have a lawful basis for processing your data, and provided that you have not exercised your rights to erasure or object withdrawn your consent This will generally be while you are engaged with WCRF and for 2 years afterwards.
Donation	A minimum of 6 years from the completion of our last financial audit, but longer where there is an ongoing relationship and whilst we have a lawful basis
HR	Recruitment (unsuccessful) – 6 months from receipt date Other HR – minimise on termination, then review annually
Grant	Successful – 6 years from tenure end date Unsuccessful – 3 years from application date
Supporter Story	While we have consent, refreshed every 12 months

8. How and Where Do You Store or Transfer My Personal Data?

We may store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We may store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

We may store some of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

We will use standard contractual clauses (“SCC’s”) which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 1 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is important to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;
requiring compliance with relevant Payment Card Industry Data Security Standards (“PCI DSS”) for processors handling card payments.

10. How can I access my personal data?

If you want to know what personal data we hold about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a data subject access request (“DSAR”).

All DSAR’s should be made in writing and sent to the email or postal address shown in Part 1. There is not normally any charge for a DSAR. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your DSAR within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.