- About this Policy
This website is operated by Edge Fund, a registered society under the Co-operative and Community Benefit Societies Act 2014, and is available to you on the basis of the terms below. Our registration number is 31939R.
Edge Fund is committed to protecting and respecting personal privacy. We collect as little information as possible from our applicants, members, and supporters, however there is a minimum of information that we need to have in order to ensure our funding process works, is transparent, and democratic.
If you have any questions about the policy or Edge Funds use of personal information, please email firstname.lastname@example.org
- The information we collect, and why we collect it
‘Personal data’ is defined as information relating to an identified or identifiable natural person (examples might include a person’s name, age, address, date of birth, gender and contact details). Edge Fund will never sell, trade or rent your personal information to others, and would only share personal data with authorised third parties where we are required to do so by law or for regulatory or statutory purposes.
We collect the following personal data:
- Your name, email address and sometimes your telephone number if you have provided this.
- While we do not ask for, or hold any information about your gender, ethnicity, disabilites, etc. we do keep a record of which ‘community committee’ and/or ‘advisory group’ that you have decided to join. This information is not made public, and we only use it for governance and to assist in funding rounds. (More information on how we use this information can be found in 3B about funding rounds)
- Your name, address, telephone number, bank details; so that we can effectively process your donations.
- Your donation history; so that we can more effectively understand our donors.
- We usually hold a name, email address, phone number, general location of your group. All of this information is essential for us, it is the minimum we need in order to run our funding rounds, and ensure grants are given out. (More information is in 3B about funding rounds)
- Any information that you provide to us for the purpose of subscribing to email updates / newsletters, which includes your name, email address and sometimes your telephone number if you have provided this
Some information is also collected automatically from anyone who visits our site: this includes what pages you view, the number of bytes transferred, the links you click, the materials you access and other actions taken within our site. We may combine this information with your personal information to and use the combined information in accordance with this privacy statement. We also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the site and the website from which you linked to one of our sites. We do not combine this standard information with other personal information.
Some other kinds of information we collect:
- If you contact us, we may keep a record of that correspondence;
- Information we gather on social media (including, but not limited to, Facebook and Twitter);
- Feedback from you about our website or Edge Fund generally;
- Any other information that you choose to send to us.
If you object to the collection and use of your personal data as described here we may be unable to keep you involved or updated about Edge Fund, due to data regulation requirements. Please see section 9 for more information about your rights and objections.
For the purposes of meeting the Data Protection Act 2018 territorial scope requirements, the United Kingdom is identified as the named territory where the processing of personal data takes place.
- How we use your personal data
- Our general day-to-day work. This includes:
- sending you general (non-marketing) communications;
- sending you email notifications which you have specifically requested;
- administering our website and for internal operations such as troubleshooting, data analysis or research
- dealing with enquiries and complaints made by or about you in relation to Edge Fund
- Funding rounds
- How your data is used during a funding round
- Bullet points to add about funding rounds:
- We remove all personal information from funding applications received in order for them to shared with members for the purposes of scoring
- We contact applicants via email and telephone to update them about their funding application
- We contact applicants for feedback
- Shortlisted applicants will be contacted for further information to administer paying out grants
- Fundraising/Campaigning and “Direct Marketing”
Our fundraising and campaigning activity is very important to us, so that we can keep supporting the radical grassroots groups that our members value, and that are making real lasting change in society.
We use a range of activities and channels to ensure we have a wide range of members involved, and that we get the donations we need to keep the Edge Fund going. This includes our website, face-to-face fundraising, SMS/text campaigns, emails and phone calls.
Those of you who we currently have a relationship with, before 25th May 2018, we will continue to use your data as before, and offer an explicit opt-out for any communications you no longer wish to have, if any. We base this off our ‘legitimate interests’ (see below).
Those of you who have become involved following the 25th May 2018, we will ensure that there is an explicit opt-in at the start of our relationship, and that you will be able to opt-out at any time.
Third-party communications services:
We use a third-party email and data services, MailChimp and Nationbuilder. This is to manage our list of subscribers and email communications to you and MailChimp and NationBuilder act as a data-processor on behalf of Edge Fund.
MailChimp is a US company and has staff based outside the EEA, and stores your data in the US. MailChimp is certified under the EU-US Privacy Shield framework. When you sign up to our email alerts, you agree to your data being stored in this way.
As a subscriber to our newsletter, we may contact you from time to time to ask for your feedback on how to improve our email alert service.
As a data processor on behalf of Edge Fund, MailChimp will use your information to send you email alerts if you request them. You can find out more about how MailChimp collects and stores your information.
- Our legal basis for processing personal data
We need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Three of these are relevant to the types of processing that we carry out. This includes information that is processed on the basis of: a person’s consent; processing that is necessary for compliance with a legal obligation; ‘legitimate interests’ (see below).
Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned.
When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair.
Our legitimate interests include:
- Good Governance: including delivery of our charitable purposes, statutory and financial reporting and other regulatory compliance purposes, engaging and involving our members in the democratic governance of the Edge Fund
- Administration and operational management: including responding to inquiries, providing information, and events management, and most importantly keeping our membership informed and involved in the Edge Fund
- Fundraising and Campaigning: including administering campaigns and donations, sending thank you communications, analysis, targeting and segmentation to develop communication strategies, and maintaining communication. To ensure the financial security of the Edge Fund, so that we can keep supporting the grassroots.
- Disclosure of your personal data
We will not share, sell or rent any of your personal data to any third party unless we are required to do so by law, for example to law enforcement or regulatory bodies where this is required under the relevant legislation. We will not share your information with third parties for marketing purposes.
Third Party Service Providers working on our behalf
We may pass your information to our third-party service providers, agents subcontractors and other associated organisations (e.g. hosting website, web agency, etc.) for the purpose of completing tasks and providing services to you on our behalf (e.g. to send you mailings or check web analytics). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have an agreement in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.
- Security of your personal data
We use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of your personal data. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot 100% guarantee the security of your data transmitted to us. Once we have received your information, we use strict procedures and security features to try to prevent unauthorised access.
How do we protect your personal information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
We also use an SSL certificate to ensure that your privacy is protected while visiting our website. An SSL certificate (also known as HTTPS) is a layer of protection between our website and your browser. Short for Secure Sockets Layer, an SSL is used to encrypt potentially sensitive information like the input fields in a contact form.
- Retention of your data
- Applicant data: We only keep the details of your application for 1 year following your receipt of the grant
- Donor data: We keep your data for as long as you remain a donor with us
- Member data: We only keep your data for as long as you remain a member of our organisation
Individuals are provided with legal rights governing the use of their personal data. These grant individuals the right to understand what personal data relating to them is held, for what purpose, how it is collected and used, with whom it is shared, where it is located, to object to its processing, to have the data corrected if inaccurate, to take copies of the data and to place restrictions on its processing. Individuals can also request the deletion of their personal data. These rights are known as Individual Rights under the Data Protection Act 2018. Individuals can exercise their Individual Rights at any time.
In exercising your Individual Rights, you should understand that in some situations we may be unable to fully meet your request, for example if you make a request for us to delete all your personal data, we may be required to retain some data for regulatory and other statutory purposes.
Your rights include:
Right of Access
- You have the right know what information we hold about you and to ask, in writing, to see your records.
- We will supply any information you ask for that we hold about you as soon as possible, but this may take up to 30 days. We will not charge you for this other than in exceptional circumstances.
- You will be asked for proof of identity as the person dealing with your request may not be the staff member you have met before. We need to be sure we are only releasing your personal data to you.
Right to be informed
- You have the right to be informed how your personal data will be used. This policy, as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.
Right to withdraw consent
- Where we process your data based on your consent (for example, to send you marketing texts or emails), you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.
Right to object
- You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the ‘Contact us’ section below.
- You also have the right to complain to the UK’s data protection supervisory authority, the Information Commissioner’s Office (ICO). The ICO may be contacted via its website which is https://ico.org.uk/concerns/, by live chat or by calling their helpline on 0303 123 1113.
Right to restrict processing
- In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
Right of erasure
- In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials, we will need to keep some limited information to ensure that you are not contacted in the future.
Right of rectification
- If you believe our records are inaccurate, you have the right to ask for those records concerning you to be updated. To update your records, please get in touch with us using the details in the ‘Contact us’ section below.
Right to data portability
- Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.
- Third Party Websites
This website may contain links to and from the websites of groups or organisations that have been funded by Edge Fund or involved with Edge Fund in other non-commercial ways. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
- Contact us