Christian Partners in Africa (CPA)
At CPA we are committed to protecting and respecting your privacy.
This policy explains when and why we collect personal information, how we use it, the conditions under which we may disclose it to others, how we keep it secure and your rights regarding the use of your personal data.
We aim to respect and protect your privacy by;
- only collecting and retaining such data as is required to fulfil our mission,
- keeping your personal data up to date,
- storing and destroying it securely,
- protecting personal data from loss, misuse, unauthorised access and disclosure,
- ensuring our third-party processors have suitable Privacy Policies, and
- ensuring that appropriate technical measures are in place to protect personal data.
Even though GDPR is a European regulation its principles are equally relevant to persons and organisations from all countries. Recital 2 of the Regulation states –
“The principles of, and rules on the protection of natural persons with regard to the processing of their personal data should, whatever their nationality or residence, respect their fundamental rights and freedoms, in particular their right to the protection of personal data.
For this reason, we commit to protecting and respecting the privacy of all persons regardless of nationality, hence this policy equally covers our commitment toward our African partners; organisations and individuals.
We believe that children, whilst having the same rights to privacy as adults, merit specific protection. Where consent is required, and you are aged 16 or under‚ we will require the consent of whoever holds parental responsibility for you.
- Your personal data – what is it?
‘Personal data’ is any information relating to an identifiable, living person who can be directly or indirectly identified by reference to that data; this includes photographs.
- Who are we?
We are Christian Partners in Africa (CPA), a registered charity – our number is 1043695. CPA is a Lincoln based charity that has worked with African partners for over 20 years. Together we support and encourage children and young people in poverty, and poor communities in Africa. We are a group of people who came together through a common desire to help the poorest of the poor in Africa.
- How do we process your personal data?
We process your personal data for the following purposes: –
- To keep you informed about our projects, events and other CPA activities;
- To be able to fulfil our obligations to help you with travel arrangements and health provisions when you participate in one of our trips to Africa;
- To help both sponsor and sponsored child maintain a healthy and informative correspondence through the controlled exchange of letters, small gifts and photographs;
- To manage and support our employees and volunteers;
- To maintain our own accounts and records (including the processing of gift aid applications); and
- To fundraise and promote the interests of our projects.
- What is the lawfulbasis for processing your personal data?
- Consent – we require your explicit consent to process your data so that we can keep you informed about CPA news, events, activities and services, or to use process your image.
- Legal – we have legal obligations under European law, to the UK Government, employment and social security and social protection law to process your personal data. For example, to process gift aid donations, pay and support our staff, and to safe guard children and vulnerable adults.
- Contract – we also need to process your personal data every time we agree to offer a service, such as sponsorship, arranged trips and recruiting staff and volunteers for various roles.
- Vital Interest – we have a duty of care to process your personal data to provide you with essential and emergency health cover whilst you are on one of our trips.
- Processing is also carried out by various third-party platforms in order to communicate with you or securely store your personal data, for example ‘Mailchimp’ to manage mailings, ‘Infoodle’ to manage contacts data and ‘Xero’ to manage our payroll and accounts.
- Sharing your personal data
Your personal data will be treated as strictly confidential and will only be shared with the directors and office staff in order to carry out the state purposes of CPA. We will only share your data with third parties outside CPA in accordance with one or other of the lawful bases stated in 4. above. Even though GDPR is a European regulation its principles are equally relevant to persons and organisations from all countries where there is a genuine desire for the mutual rule of law.
- How long do we keep your personal data?
We keep your personal data only for as long as is required. Where we rely on your consent, we will keep and process your personal data only whilst we have your explicit consent. Where the lawful basis is legal the period of retention will be in accordance with the particular guidance set out in the appropriate UK government regulations and guidance. Where the basis is contract, we will keep your personal data for as long as is necessary to fulfil our mutual obligations under the terms and conditions of the particular agreement between us.
Specifically, we retain essential health and emergency contacts data for the duration of the trip where it is deemed of vital interest to do so.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data: –
- The right to request a copy of your personal data;
- The right to request that we rectify (correct or complete) any personal data once it is found to be inaccurate, incomplete or out of date;
- The right to request your personal data is erased where it is no longer necessary legally or contractually for us to retain such data, or where the lawful basis is Consent and you wish to withdraw your consent;
- You have the right to restrict the processing of your personal data, rather than full erasure, whilst the accuracy of the data is checked and verified to your satisfaction, or where you dispute the lawful basis given for processing your data. The right to restrict is distinct from the right to rectification, however, as a matter of good practice we will automatically restrict the use of your personal data whilst you are considering its accuracy or the legitimate grounds for processing the personal data in question;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller where applicable, (known as the right to data portability), [Only applies where the processing is based on consent or is necessary for the performance of a contract with the data subject and in either case the data controller processes the data by automated means].
- The right to object to the processing of personal data, (where applicable) [Only applies where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics]
- The right to lodge a complaint with the Information Commissioners Office.
- Further processing
- Contact Details
To exercise all relevant rights, ask any questions or to register complaints please, in the first instance contact the CPA office at The Bothy, Waterwheel Lane, Branston, Lincoln, LN4 1LU, or email firstname.lastname@example.org .
You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.