Keyword:
CWI PRIVACY POLICY


1. Introduction

1.1. Christian Witness to Israel (CWI) is a UK-based interdenominational evangelistic society committed to sharing the Good News of Jesus the Messiah with the Jewish people.

1.2. CWI values everyone who engages with us. We take your privacy seriously and we are committed to do all we can to protect your privacy and be transparent about what information we hold about you. This Policy sets out how we will handle your Personal Data securely and in accordance with your rights.

1.3. If you use our website, or provide us with any personal information, we will bring this Policy to your attention so that you are fully aware of how your information will be used and disclosed.

1.4. Please read this Privacy Policy carefully to understand how we will treat your Personal Data.


2. Our Privacy Policy in Summary

2.1. It’s important that you read the full policy to understand what information we hold, how we may use it and what your rights are. But here’s a quick summary:

  • We only collect the Personal Data that we need. Personal Data is any information that can be used to identify you.

  • We collect information from information that you give us directly (eg when you make a donation); information from your use of the CWI website (eg details of pages visited); information that we get as a result of your giving information to other organisations (eg Just Giving or Facebook); and information from public sources (including information that can be accessed through search engines like Google.)

  • We do not collect sensitive data (eg medical data) unless there is a clear reason to do so.

  • We use your information for a variety of purposes. Some of the most common ones include: keeping you up-to-date with our latest news and prayer requests; asking for financial support; processing donations; dealing with queries; or storing your data to make it easier for you to provide information when you come back to our website.

  • We never sell your data to other organisations or allow them to use data for their own purposes. But we do share information with organisations who deliver services to us (eg payment processing). We also share information where we are legally obliged to do so.

  • We use a variety of legal bases of processing. We make extensive use of legitimate interests in using postal communications for direct marketing.

  • We do our best to keep your data safe and secure.

  • We only store data for as long as necessary for the things we need to do

  • You have many individual rights over your data and we respect these at all times

 

3. Who we are?

3.1. Christian Witness to Israel (CWI) is a UK-based interdenominational evangelistic society committed to sharing the Good News of Jesus the Messiah with the Jewish people. Like the apostle Paul, we reason from the Hebrew Scriptures to demonstrate and prove that the Messiah must suffer and rise from the dead and that Jesus is the Messiah, the Saviour of the world promised through the ancient Jewish prophets.

3.2. CWI’s charity registration number is 271323. We are also registered as a company in England and Wales under the company number 01254746. We are registered as a charity in Scotland SCO41720.

3.3. CWI is registered with the Information Commissioner’s Office as data controller under registration number ZA161405. You can find out more about our registration by visiting https://ico.org/uk and looking for information under our registration number.

3.4. CWI’s registered address is Suite 6, Chilbrook 1 Oasis Park, Stanton Harcourt Road, Eynsham Witney OX29 4TP.

3.5. For further information about our privacy policy and data protection, please contact us by:

  • e-mailing Gaenor Hall at ghall@cwi.org.uk
  • writing to our registered address; or
  • calling us on 01865 887830


4. What Personal Data do we collect from you and where do we collect it from?

4.1. We will only ever collect information we need, including data to help improve our service, or which you agree we can collect. Personal Data is any information that can be used to identify you. For example, it can include information such as your name, title, postal address, email address, telephone number, and bank account details, credit /debit card details and whether you are a tax payer so that we can claim Gift Aid on any donations you may make.

4.2. Personal data also includes Internet Protocol (IP) addresses (the location of your computer on the internet), details of webpages visited and files downloaded.

4.3. We collect information from the following sources (each of which is explained in more detail below):

  • Information that you give us directly;
  • Information from your use of our website;
  • Information that we get as a result of you giving permission to other organisations;
  • Information from public sources.

4.4. Information that you give us directly: we collect personal data each time you deal with us, for example when you make a donation, request materials or information, engage with our social media, complete a survey, questionnaire or feedback form or otherwise provide us with personal information. Please note that you do not have to disclose any of this information to browse our website.

4.5. Information from your use of our website: we collect non-personal data such as Internet Protocol (IP) addresses, details of pages visited and files downloaded. Website usage information is collected using cookies. For information please click on our cookies policy http://www.cwi.org.uk/cookies.html

4.6. Information that we get as a result of your giving permission to other organisations: we collect information from fundraising sites such as Paypal, Just Giving, BT MyDonate and Virgin Money Giving where you have agreed to support CWI and have given your consent. We may also collect information that you make available on social media channels such as Facebook and Twitter. You should check their privacy policies to find out more information on how they will process your data.

4.7. Information from public sources: We may collect information available from public sources to gain a better understanding or our supporters so that CWI can be as relevant to you as possible, and be better able to tailor any requests for support that we might make. Such information may be found at places such as Companies House, or published online and accessed through search engines such as Google.

4.8. Sensitive /special categories of data: Data Protection regulations recognise that certain categories of data are sensitive. They include: racial or ethnic origin, political opinion, religious of philosophical beliefs, health or sexual orientation. We do not collect sensitive data unless there is a clear reason for doing so. For example, if CWI was to organise a challenging physical event such as a long-distance walk or run, we would need to collect some medical information to ensure that, as event organisers, we were providing an appropriate duty of care to our participants.

4.9. Under 16’s: If you are aged 16 or under and would like to get involved with us, or make a donation, please make sure that you have your parent or guardian’s permission before giving us your personal information.


5. How we use your Personal Data?

5.1. CWI will use your Personal Data for the following purposes:

  • to keep you up to date on news and stories about CWI’s work through publications such as the Herald
  • to communicate with you, including sending you information about products and services which we think may be of interest to you. This will include asking for financial support (for example through fundraising appeals) or non-financial support such as prayer;
  • to process donations you give us, including administering Gift Aid. This cover donations online (such as our web donation page) or offline (such as letters enclosing a cheque);
  • to facilitate you downloading content from our website (such as CWI Talks);
  • to contact you via e-mail, phone or mail to thank you, answer queries or deal with complaints;
  • to complete surveys that we use for research purposes, although you do not have to respond to them;
  • to improve the service we provide, for example to allow us to analyse your personal preferences and personalise our services to you so that we can provide a more tailored experience to you;
  • to store your data to pre-populate fields to make it easier for you to provide information when you return to our site;
  • to validate your Personal Data (and, in some cases, match it against information that has been collected by a third party) to check that the Personal Data we hold about our customers/users is accurate, consistent and up to date;
  • to comply with any legal obligations to which we are subject on the basis that processing is necessary to comply with our legal obligations;
  • in pursuit of our legitimate interests, such as developing and/or consolidating CWI defending our legal rights and/or seeking advice from our professional advisors.


5.2. Direct marketing: The provision of Personal Data for the purposes of direct marketing is voluntary. You can choose at any time which marketing materials you want to receive from CWI. If there is something you would prefer not to receive, please e-mail ghall@cwi.org.uk or by post to Data Protection, CWI, Oasis Park, Stanton Harcourt Road Eynsham Witney OX29 4TP. Alternatively, you can select "unsubscribe" on the relevant marketing communication.

5.3. We will endeavour periodically to check that the personal data we store for you is accurate. If you would like to update the personal data we hold about you, please contact us on ghall@cwi.org.uk with your request.

5.4. Using website data:

  • Cookies: Like many organisations, we use cookies. A cookie is a text file that is sent from our website as soon as you visit the site. It is stored on your computer and helps us identify your computer (not you) and collects information anonymously. We use cookies to help make our website, and the way you use it, work better and to track information about how people are using them. To use CWI’s website to the full, we recommend that you leave cookies turned on, but you can choose to turn cookies off You can find out more information about cookies by following this link http://www.cwi.org.uk/cookies.html
  • Google Analytics: we use Google Analytics and other services to collect information about how our website is used. These services used aggregated, anonymised data, to know how often users visit our website, what pages they visit and when, what other websites they visit when moving to and from our website.

 


6. When do we share your Personal Data and who with?

6.1. We never sell your Personal Data to other organisations.

6.2. We never share your Personal Data with other organisations for them to use for their own purposes.

6.3. We do share information with other organisations who provide a service to us. These include: third party payment gateways and companies who print and fulfil direct mail newsletters and fundraising appeals. We will ensure that our service providers enter into compliant processing agreements with us to ensure that your Personal Data is processed in accordance with applicable data protection legislation. We will also ensure that appropriate controls are in place

6.4. We do share data where we are under a legal obligation to do so (for example, Gift Aid audits by HMRC) or in order to enforce or apply our rights (including in relation to our website or other applicable terms and conditions) or to protect CWI (for example in cases of suspected fraud or defamation).

 

7. What is our legal basis of processing?

7.1. We mainly rely on three different legal bases for processing Personal Data depending on the purpose of the activity being undertaken.

  • Legitimate Interest
  • Consent
  • Compliance with a Legal Obligation

7.2. We rely on legitimate interests for a variety of purposes (particularly for direct marketing via postal communications). More specifically:

  • using direct mail to send newsletters such as the Herald;
  • using direct mail to send fundraising appeals;
  • using direct mail to follow up with those who have signed up at a church event but who didn’t make an immediate financial gift;
  • using publicly available information to help research supporters so that CWI can better meet the needs of individual supporters.

7.3. In relying on legitimate interests, we balance the interests of CWI against your rights and freedoms, having due regard to your reasonable expectations about the use of your Personal data. We have written Legitimate Interest Assessments to show how we have come to these decisions. These Assessments are available on request by e-mailing Gaenor Hall at ghall@cwi.org.uk or writing to Data Protection, CWI, Oasis Park, Stanton Harcourt Road Eynsham Witney OX29 4TP; or calling us on 01865 887830

7.4. In relying on legitimate interests for direct mail marketing activity, on every mailing CWI gives all its supporters the opportunity to opt-out of receiving direct mail. You can let us know at any time if you would prefer not to receive direct mail communications by e-mailing Gaenor Hall at ghall@cwi.org.uk or writing to Data Protection, CWI, Oasis Park, Stanton Harcourt Road Eynsham Witney OX29 4TP.; or calling us on 01865 887830

7.5. We use consent for all e-mail activity relating to news and fundraising appeals. Every e-mail you receive provides a clear opportunity for you to unsubscribe from future e-mails. Alternatively, you can let us know by e-mailing Gaenor Hall at ghall@cwi.org.uk or writing to Data Protection, CWI, Oasis Park, Stanton Harcourt Road Eynsham Witney OX29 4TP.; or calling us on 01865 887830.

7.6. We use compliance with a legal obligation as the basis of processing for any legally required activities such as HMRC’s requests for information in response to Gift Aid audits.

 

8. How do we store your Personal Data and keep it safe?

8.1. Security: We place great importance on the security of all Personal Data held by CWI.

8.2. We ensure that we have in place appropriate technical controls to protect your Personal Data. For example we ensure that any online forms are encrypted and our network is protected and routinely monitored.

8.3. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

8.4. Unfortunately, the transmission of information via the internet cannot be completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

8.5. Payments: If you use your credit or debit card to donate to us either over the telephone or by mail, we will process your information securely in accordance with the Payment Card Industry Data Standard http://www.theukcardsassociation.org.uk/security/what_is_PCI%20DSS.asp

8.6. We do not store your full debit or credit card details once your transaction has completed. All card details are securely destroyed once your donation or payment has completed.

8.7. We hold bank account details for the purposes of collecting direct debits in accordance with direct debit mandate rules.

8.8. Transferring your information outside Europe: Although most of the information we store and process stays within the UK, some information may be transferred to countries outside the European Economic Area (EEA) because of the use of cloud-based systems for example or because individuals have asked for communication directly with a CWI person outside of the EEA. These countries may not have the same standards of protection for personal data as the UK. We will, however, always use every reasonable effort to ensure sufficient protections are in place to safeguard your Personal Data. Specifically, CWI will always need to give permission for this data to be processed.

 

9. How long do we store your Personal Data for?

9.1. We only store your Personal Data for as long as necessary for the purposes described in this Privacy Policy.

9.2. We have a data retention policy to implement this. For example, we will retain details of donations for seven years to meet the requirements that HMRC sets for Gift Aid audits.

9.3. If you request that we stop sending you direct marketing information (news, prayer and fundraising appeals), we will keep a record of your contact details to enable us to comply with your request not to be contacted by us.

9.4. Where your information is no longer required we will ensure that it is disposed of in a secure manner.

 

10. What are your rights?

You have the following rights:

  • To be informed: which we aim to achieve through a transparent Privacy Policy
  • Access to your Personal Data: You may request access to a copy of your Personal Data (known as a subject access request) which we will meet without undue delay and at the latest within one month.
  • Rectification: You may ask us to rectify inaccurate Personal Data held about you. If you would like to update the Personal Data we hold about you, please contact us using the details below and provide the updated information. We will meet requests without undue delay and at the latest within one month.
  • Erasure: You may ask us to delete your personal data. If you would like us to delete the personal data we hold about you, please contact us using the details below, specifying why you would like us to delete your personal data.
  • Right to restrict processing: You may ask us to restrict the processing of your personal data in certain circumstances. This means that you can limit the way that CWI uses your data.
  • Portability: You may ask us to provide you with the Personal Data that we hold about you in a structured, commonly used, machine readable form, or ask for us to send such personal data to another data controller. We will meet requests without undue delay and at the latest within one month.
  • Right to object: You may object to our processing of your personal data for example for direct marketing purposes. We explain how you can object in section 7.5 and 7.6.
  • Ask not to be subject to automated decision making including profiling. The only type of profiling we do is to use your donation history to work out the donation ask that you receive in an e-mail or postal communication. You may object to this by contacting us as set out below.
  • Make a complaint: You may make a complaint about our data processing activities to a supervisory authority. For the UK, this is the Information Commissioner's Office, at ico.org.uk.
  • To make enquires and/or to exercise any of your rights in this Privacy Policy please contact Gaenor Hall at ghall@cwi.org.uk or write to us at data Protection, CWI, Oasis Park, Stanton Harcourt Road Eynsham Witney OX29 4TP

Please note that if we are not sure who you are, we may ask you to provide a form of identification verification before providing you with information or carrying out any of the above actions.


11. Changes to our Privacy Policy

11.1. We may modify this Privacy Policy from time to time, so please review it regularly.

11.2. If we change this Privacy Policy in a way that may substantially alter the purposes for which we process your personal data we shall notify by means of notice on our website at www.cwi.org.uk.

11.3. This Privacy Policy was last amended in April 2018

 

12. Contact Us

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to Gaenor Hall, who can be contacted at ghall@cwi.org.uk address of CWI Oasis Park, Stanton Harcourt Road Eynsham Witney OX29 4TP

 

 


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