SUPPORTER & PARTNER PRIVACY NOTICE
This is a summary of how we process and store your information in line with the General Data Protection Regulation (GDPR).
We are committed to GDPR compliance and value the information you share with us, therefore we will endeavour to keep your information up-to-date, to store and destroy it securely, and to protect it from loss, misuse, unauthorised access and disclosure. We will not collect or retain excessive amounts of data and will ensure that appropriate operational and technical measures are in place to protect the information we hold.
WHO WE ARE
Speak Life looks to captivate church and world with the love of Jesus. We are a member of the Evangelical Alliance, and a registered CIO since September 2019. Speak Life formally operated as The Hour of Revival Evangelistic Association, which was founded in 1952 [charity number 232509].
- Our principal address is 13 Lismore Road, Eastbourne, East Sussex, BN21 3AY
- Our registered charity number is 1185137
Our Information and Privacy Co-Ordinator is Emily Lynch. If you have any concerns regarding the contents of this notice or require further information, please contact email@example.com or if the matter is of an urgent nature, please call 01323 725231.
WHAT ARE THE LEGAL BASES FOR PROCESSING INFORMATION
There are a number of scenarios in which Speak Life may obtain or process your information, and for each we will have identified the lawful bases for processing. There are five lawful bases for processing your information:
(a) Consent: you have given clear consent for us to process your personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract we have with you, or because we have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for us to comply with the law.
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) 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.
(f) 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 the individual’s personal data which overrides those legitimate interests.
Many of the lawful bases for processing depend on the processing being “necessary”. This does not mean that processing has to be absolutely essential. However, it must be more than just useful, and more than just standard practice. It must be a targeted and proportionate way of achieving a specific purpose. The lawful basis will not apply if we can reasonably achieve the purpose by some other less intrusive means, or by processing less data.
For many of our day-to-day functions Speak Life will process your personal information on the basis of consent. This means you will be asked to consent to us using, storing and processing your personal information. We will look to request additional consent for a specific purpose, if it falls out of our normal remit of work or charitable objectives.
We may have reason to process or store your personal information in line with another lawful basis, in which case consent may not be required. This will be kept to a minimum and only as required, such as when we need to carry out our obligations under employment, social security or social protection law, or a collective agreement. If the processing of information is deemed significant and not in line with our standard processes, we will make every reasonable effort to inform you prior to, or as soon after following, the processing of your information. Examples of when we may refer to a basis, other than consent, may be:
- Our legal obligation to retain financial records for a period of seven years.
- Legitimate interest when processing data relating to supporter engagement, as long as the collection of data is not excessive, and for the claiming back of tax under the governments Gift Aid scheme as we are a not-for-profit body with religious aims.
If we wish to use your information for a new ongoing purpose, not covered by this policy, then we will provide you with a new or amended privacy notice, explaining the changes, prior to processing your information.
WHAT INFORMATION DO WE USE
Personal data for the purpose of GDPR is defined as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. In simpler terms, this means any information about you that enables you to be identified. We may collect several types of personal information, such as:
- basic personal information, such as full name and contact details including email
- demographical information, such as gender, age, date of birth, nationality, dependants, marital status, hobbies etc
- financial information, including reason and amount of any donations, account details, card number and your gift aid declaration
- information concerning your involvement with Speak Life, such as engagement, communications, course attendance, date of membership, any goods and services you may have used / requested etc);
- information regarding involvement within your local church
- information on your workplace, ministry or university
- information concerning any DBS application made via Speak Life;
- visual images, videos and personal appearance, such as copies of passports, CCTV images and Church Suite
- visual images, audio recording, videos and personal appearance, such as those procured for the purpose of promotional materials, creative content – both audio and visual and film-making etc
- for those employed by Speak Life, employment information, such as NI number, tax code, student loan payments, pension contributions. Staff should refer to the staff and student privacy notice for further information.
- online profile and social media information and activity, based on your interaction with us, our website and applications, including ChurchSuite, for example your login information, Internet Protocol (IP) address, smart device information, location coordinates, searches, and site visits – please see the section on cookies for further information.
The GDPR recognises some information as ‘sensitive personal data’. The information we process may constitute ‘sensitive personal data’ because, as a Christian ministry, the fact that we hold your information may be suggestive of your religious beliefs.
Other ‘sensitive personal data’ includes (but is not limited to) racial or ethnic origin, sex life, mental and physical health, details of injuries or medical treatment received, data concerning sexual orientation, children’s data and criminal records, fines and other judicial records. If you provide any sensitive personal data, we will ensure that it is processed in accordance with the GDPR guidelines, and only for the purposes for which it was provided.
WHY DO WE USE THIS INFORMATION
We use your information so that we can best serve you, the community, and work towards our charitable
objectives. Your information may be used in several ways, such as:
Governance and finance
- to recruit, support and manage staff, trainees and volunteers;
- to carry out comprehensive safeguarding procedures (including due diligence and complaints handling) in accordance with best safeguarding practice;
- to maintain the security of property and premises;
- to enable us to meet our legal and statutory obligations;
- to process any payments or donations you make, including claiming Gift Aid as appropriate;
- to make payment to you, as required;
- to maintain our financial accounts and records;
- to respond effectively to enquirers and handle any complaints appropriately;
Communication and charitable objectives
- to communicate or deliver Speak Life’s mission and charitable objectives to our supporters and the world (such as images used in our written publications and online content);
- to pray over projects, people, and partners;
- to inform you of upcoming activities, events or unforeseen changes (direct marketing, subject to your chosen communication preferences);
- to keep you informed and updated of the media, works, mission and impact of Speak Life
- to produce reports and statistical data regarding Speak Life, impact and growth;
- to promote events (visuals, where appropriate consent has been obtained);
- to operate the Speak Life website;
Supporter and partner experience
- to maintain our database of supporters and partners;
- to monitor individuals’ engagement with Speak Life;
- to oversee and manage our training, courses and events;
- to join in partnership with others through speaking and mission;
- to build relationship and connect like-minded or creative individuals and organisations with one another (subject to their chosen communication preferences);
- to communicate and allocate serving or volunteer opportunities;
- to provide services to the community, for example room hire to local charities;
- to promote our goods and services;
WHEN DO WE OBTAIN INFORMATION
We collect personal information in a number of ways, such as;
(a) When you give it to us directly, for example when you;
- use or update Church Suite (through the use of forms, events or giving);
- complete manual or online forms (such as a Connect card);
- contact us via telephone, email or in person;
- visit the studios;
- visit a connect point at locations Speak Life is speaking or exhibiting;
- sign up to attend training, a course or event;
- make a payment;
- sign up to be a volunteer;
- complete a giving instruction or Gift Aid Declaration;
- make an application to work at Speak Life;
- engage with our safeguarding procedure;
- support a project;
- run a Speak Life course at your church (such as 321);
- use or download media;
- subscribe, follow or view any Speak Life content on social media;
- work, volunteer or partner with us on a production;
- work, volunteer or partner with us in creating content;
- partner with us (such as your interests); or
- provide us with personal information, verbally or in writing.
(b) When we obtain it indirectly;
- From third parties who provide services to you or us (such as PayPal, Stripe, CAF, Stewardship, YouTube), third parties that we use to deliver our charitable objectives and communications (such as LearnWorlds, Discord, our SLD distributors), our bank (if you give directly to our accounts), home office or other government bodies (when you have submitted a DBS application or similar);
(c) When it is available publicly
- Information that we may gather from publicly available sources, such as the press, electoral register, company registers and online search engines;
(d) When you visit our website
- Information that we may gather from the technology you use to access our services, website and ChurchSuite, such as your IP address or location data from your mobile phone and cookies.
WHEN WILL WE SHARE YOUR INFORMATION
We look to keep your information as secure as possible, however to undertake some of our processes, deliver on services or charitable objectives or to comply with our legal obligations we may have to share certain information with third party organisations (data processors). If this is the case, we limit the information we share to that which is required to undertake the task for which they were appointed, or that is required by law. Where we have appointed a data processor, we will have confidentiality agreements in place that restrict the use of your information and ensure that they comply with GDPR. We do not sell on your information.
We may share information in order (but not limited) to:
(a) Provide you with services that are in line with our charitable objectives;
- selected third party data processors, that have been appointed to manage, maintain, communicate or deliver our services in order to achieve our charitable objectives (such as, but not limited to, LearnWorlds, Discord, our SLD Distributors, our CRM provider – currently Church Suite)
- event or training organisations when attending or undertaking a course;
- postal services (should we need to send you a letter);
- travel providers, when organising travel for you on behalf of Speak Life;
(b) To undertake administrative and financial functions;
- payment processor (such as banks, when we need to make a payment to you);
- IT software and security contactors (to maintain, secure and develop our software and servers);
- professional services or appointed data processors (such as accountants for the purpose of compiling annual accounts);
(c) When we are required to by law;
- statutory bodies and organisations (such as the Home Office for DBS checks, HMRC when claiming gift aid);
- for the purpose of safety and safeguarding;
- When necessary, by government entities, tax authorities or regulatory bodies.
This notice only covers information that Speak Life holds. Where you are utilising Speak Life services that are provided by a third party – such as our YouTube Channels, Discord Server and our courses learning platform, which is hosted by LearnWorlds (CY) Ltd – Speak Life advises you to refer to the provider’s privacy notice. Where reasonably practical, Speak Life will provide links to notices of its chosen third-party suppliers and processors.
WHERE WE STORE YOUR INFORMATION
We have taken appropriate operational and technical measures to ensure your information is secure. All
information that is provided to us directly, or that we obtain, is stored within the EU, or on systems complying with measures giving equivalent protections of personal rights through international agreements or contracts approved by the European Union*. Your information will only be processed by appropriately trained staff, volunteers and appointed data processors. We store information in several ways, such as:
- paper files;
- CRM provider (Church Suite);
- Archived database providers and mailing lists (such as MailChimp);
- Google workspace;
- Computer / network (such as work completed on Microsoft office suite, including Outlook);
- accounting software (QuickBooks / Xero);
- communications software (such as email, telephone, WhatsApp).
*Our website is accessible from overseas so on occasion some personal data (images etc) may be accessed from outside the EU. This notice only covers information that Speak Life holds. Where you are utilising Speak Life services that are provided by a third party – such as our YouTube Channels, Discord Server and our courses learning platform, which is hosted by LearnWorlds (CY) Ltd – Speak Life advises you to refer to the provider’s privacy notice. Where reasonably practical, Speak Life will provide links to notices of its chosen third-party suppliers and processors.
We have additional measures in place where personal information concerns a child or young adults under the age of 18.
OTHER WEBSITES AND SOCIAL MEDIA
The Speak Life website may provide links to other sites, this privacy notice only applies to the Speak Life
website, therefore if you select a link, we would encourage you to read the privacy notice or policy of each site visited.
HOW LONG WILL WE STORE YOUR INFORMATION
We will keep your information only as long as we need to.
For most records this will include the period you are waiting to access services, are actively engaged with the work or are a supporter or partner of Speak Life, and then for a maximum of 3 years following your last interaction with Speak Life.
However, we are required to retain some records for an extended period of time including (but not limited to) financial transactions, employment records and information regarding safeguarding. In these cases we will retain records in accordance with the current UK legislation or guidelines.
Information pertaining to appearance, visual or audio recording, which is used for the purpose of content
creation, filmmaking or advertisement will remain the property of Speak Life.
All other personal information following this time will be deleted (if electronic record) or securely disposed of (if paper record).
HOW CAN YOU UPDATE YOUR INFORMATION OR WITHDRAW YOUR CONSENT
We use ChurchSuite as our principal place to store information. If you wish to update any information, including financial information we may have, or you wish to withdraw your consent please email firstname.lastname@example.org
If you withdraw your consent, Speak Life will aim to delete (if electronic record) or securely dispose of (if paper record) your information within 72 hours, or within a maximum of 1 month from the date of your request. If for any reason this is not possible you will be informed in writing, usually via email.
YOUR RIGHTS AS A ‘DATA SUBJECT’
You have several rights over the information we hold on you, such as:
- right to access the information we hold;
You may request a copy of the personal information we hold on you, and information concerning why we use it, where we obtained it from and who we share it with. Your first request is free of charge, any future requests may incur a charge.
- right to have your information erased;
You may request that we delete your personal information. We will respond within one month confirming if this has been possible and if not the reason why it has not been deleted.
- right to rectify your information;
You may update or request your information to be updated, if you believe it is inaccurate.
- right to restrict processing;
You have the right to request that we restrict processing if there is a disagreement about its accuracy or legitimate use.
- right to object;
You have the right to request that we stop processing your data, unless we can demonstrate compelling and legitimate grounds for processing, which may override your own personal interests.
- right to data portability;
If you provide personal information, by completely automated / electronic means, for the purpose of providing us with your consent for processing information or in order to enter into a contract with us, you have the right to have a copy of the information provided to you in a portable format.
- rights related to automated decision-making;
You have the right not to be subject to a decision based solely on automated processing of your personal information.
COOKIE AND WEBSITE POLICY
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
This website is directed to adults; it is not directed to children under the age of 13. We operate our site in
compliance with the Children’s Online Privacy Protection Act, and will not knowingly collect or use personal information from anyone under 13 years of age.
INTRODUCTION: WHAT IS A COOKIE?
“Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other
website-browsing equipment for record-keeping purposes. Cookies allow the Website to remember important information that will make your use of the site more convenient. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a randomly generated unique number or other value.
Session Cookies are temporary cookies that remain in the cookie file of your browser until you leave the website.
Persistent Cookies remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie). When we use session cookies to track the total number of visitors to our website, this is done on an anonymous aggregate basis (as cookies do not in themselves carry any personal data).
Google Analytics collects information about your computer and about your visits to and use of this website (these are information about your browser, your IP address, your general location as determined from your IP address and provided by your browser, the site from which you come, and the links followed when leaving our site). This information is also collected through cookies.
The information is used for statistical purposes and analysis in order to administer the website or improve our services. All of our activity falls within the bounds of the Google Analytics Terms of Service.
Want to opt out of tracking? You can opt out of Google’s advertising tracking cookie or use a browser plugin to opt out of all Google Analytics tracking software.
You have the ability to accept or decline cookies by modifying your Web browser; however, if you choose to decline cookies, you may not be able to fully experience the interactive features of the site.
A web beacon is a transparent image file used to monitor your journey around a single website or collection of sites. They are also referred to as web bugs and are commonly used by sites that hire third-party services to monitor traffic. They may be used in association with cookies to understand how visitors interact with the pages and content on the pages of a web site.
Browsers can be set to accept or reject cookies or notify you when a cookie is being sent. Privacy software can be used to override web beacons. Taking either of these actions shouldn’t cause a problem with our site, should you so choose.
TWITTER ADS POLICIES
This policy applies to Twitter’s conversion tracking and tailored audience products.
For more information about Twitter’s paid advertising products, click here.
For information about Twitter’s other policies, click here.
|Name of cookie owner/service||Cookie name||Description|
|Google Analytics||_ga||‘_ga’, the main cookie used by Google Analytics, enables a service to distinguish one visitor from another and lasts for 2 years. Any site that implements Google Analytics, including Google services, uses the ‘_ga’ cookie.|
|Youtube||LAST_RESULT_ENTRY_KEY, nextId, remote_sid, requests, VISITOR_INFO1_LIVE, VISITOR_PRIVACY_METADATA, YSC, |
|Set and controlled by Youtube videos are embedded. They control watch history, suggested videos, player preferences and any other features Youtube runs on videos.|
|Moove GDPR||moove_gdpr_popup||Used to store your cookie preferences and control whether our other third party cookies are added or not.|
|X||i/jot/embeds||Used when Tweets are embedded. Sets a unique ID for the visitor, that allows third party advertisers to target the visitor with relevant advertisement. This pairing service is provided by third party advertisement hubs, which facilitates real-time bidding for advertisers.|