1. PURPOSE OF THIS NOTICE
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of this Site and sets out your rights in respect of our processing of your personal information.
This privacy notice will inform you how you can verify which of your personal information is collected by us through the Site and how you can request that we delete, update or transfer it. The notice only applies to the use of personal information collected by us from your use of the Site or during your communications with us. It does not apply to personal information collected during your communications with third parties.
2. WHO ARE WE AND WHAT DO WE DO?
The Site is operated by Transform Justice and Unlock (“we” “us” or “our”).
Transform Justice is a national charity that conducts research and evidence to campaign for a more open, fairer justice system. Unlock is a national charity advocating for change to the criminal records disclosure regime.
Unlock is the data controller responsible for your personal information. Unlock is registered at the UK Information Commissioner’s Office with registration number Z2545847.
Unlock is a charity with registered charity number 1079046 and whose registered address is Maidstone Community Support Centre, 39-48 Marsham Street, Maidstone, Kent, ME14 1HH.
Transform Justice is a charity with registered charity number 1150989 and whose registered address is 43 Lawford Road, London NW5 2LG.
3. HOW TO CONTACT US?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by sending an e-mail to firstname.lastname@example.org or writing to Unlock, Maidstone Community Support Centre, 39-48 Marsham Street, Maidstone, Kent, ME14 1HH
4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Personal information is collected from you in the following ways:
a) Information you voluntarily provide to us
– we collect and maintain personal information that you voluntarily submit to us during your use of the Site (e.g. when using our website to complete an online form) or when you correspond with us directly by telephone or email. In particular we collect:
- e-mail address;
- first line of address; and
- other information that you provide to us (which may include information provided in any comments submitted through the site).
b) Information we collect through your use of the Site
- IP address of device(s) used;
- browser type;
- operating system and device type;
- approximate location (e.g. London);
- access times and dates; and
- referring website addresses
5. HOW DO WE USE YOUR PERSONAL INFORMATION?
Our primary goal in collecting personal information from you is to:
(i) carry out requests made by you on the Site, for example sending a letter to your MP;
(iI) processing and dealing with any enquiries, including advice, guidance or other support
(Iii) help us improve the Site, improve our campaigns and develop new campaigns and areas of interest;
(Iv) comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
(v) enforce our agreements with you such as our website terms and conditions of use;
(vi) protect the rights, property or safety of us or third parties, including other users of the Site;
(vii) provide support and security for the Site and the Functionality; and
(viii) use as such information as otherwise required or permitted by law.
If you have consented to us doing so we will add you to our mailing list for purposes of movement updates and other communications. This mailing list is used to provide you with further information about the #FairChecks movement if you want it.
We may share your personal information collected on the Site with third parties as appropriate to:
(i) carry out the activity or request made by you on the Site, for example your name and contact details may be sent to your local MP alongside your template letter if you use our site to write to your MP;
(ii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator;
(iii) enforce our agreements with you
(iv) protect the rights, property or safety of us or third parties, including other users of the Sites;
(v) perform investigative security analysis on the Site; or
(vi) as otherwise required or permitted by law.
Unlock is the data controller responsible for your personal information. Transform Justice acts as a data processor in relation to the collection and processing of your personal data and will only process such personal data in accordance with data protection law.
We rely on our website development partner 89up to develop the Site and deliver the Functionality. 89up acts as data processor in relation to the collection and processing of your personal data and will only process such personal data as directed by us in accordance with data protection law.
We may also share your personal information with professional advisers or regulatory authorities:
(i) to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
(ii) to comply with our legal obligations;
(iii) to enforce our legal rights; or
(iv) protect rights of third parties.
Any other purposes for which we wish to use your personal information will be notified to you either by updating our privacy notice or otherwise from time to time including the legal basis of such use.
Our web pages and emails contain web beacons or “pixel tags”. Web beacons and pixel tags allow us to track receipt of an email to you, to count users that have visited a web page or opened an email and collect other types of aggregate information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site (and use this information to improve the Site). This allows us to learn what pages are most attractive to our visitors, which parts of our Site are the most interesting and what kind of information our registered users like to see.
Some of the web beacons that are placed on our Sites are used only by us, and other web beacons are used by our service providers on our behalf to analyse how our Site is being used. Once you click on an email that contains a web beacon, your contact information is subsequently cross-referenced to the source e-mail and the relevant web beacon or pixel tag information.
6. HOW DO WE OBTAIN YOUR CONSENT?
Where we may use your personal information in ways other than those outlined above, we will ask for your explicit consent. For example, to be added to our mailing list to receive regular updates about the #FairChecks movement. You can provide such consent at the time of submitting your personal information by following the instructions provided, or by informing us by e-mail, post or phone using the contact details set out in this privacy notice.
8. Third Party Links and Services
It is likely the Site will contain links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this privacy notice no longer applies. This privacy notice applies solely to personal information collected by us through our Site and Functionality and does not apply to these third party websites and third party service providers.
9. TRANSFERS OUTSIDE THE EEA
We do not transfer your personal information outside of the EEA
10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We do not keep your personal information for any specific period but we will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our movement and our legal and regulatory obligations. If your information is only useful for a short period e.g. for specific campaigns, we will delete it once the campaign has finished.
11. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.
12. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?
You have the following rights in relation to the personal information we hold about you:
a) Your right of access
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
b) Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
c) Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
d) Your right to restrict processing
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
e) Your right to data portability
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, standardised and machine-readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.
f) Your right to object
You can ask us to stop processing your personal information, and we will do so if we’re relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing.
g) Your rights in relation to automated decision-making and profiling
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
h) Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
i) Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
13. CHANGES TO THIS PRIVACY NOTICE
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.
Last update – 16 July 2019