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BEO

Privacy policy

1. Introduction

Black Equity Organisation (“BEO“) CIO (a charitable incorporated organisation registered in England and Wales with registered charity number 1195506 has been established  to promote economic, political and social equity for Black communities in Britain in order to ensure equal opportunity for progress and prosperity.

In providing this service, BEO (“us”, “we” or “our”) collect elements of information about you when we engage with you. We only use this information in the context of providing our services. We respect your privacy and are committed to protecting your personal data. Personal data, or personal information, means any information about an individual from which that person can be identified.

This notice explains how we will process your personal information when you engage with us, and provides you with additional information regarding your privacy rights. It is important that you read this Privacy Notice so that you are fully aware of how and why we use your personal data in the context of the services we provide.

Our Privacy Notice is designed to be as clear and informative as possible, but do not hesitate to let us know if you have any questions about the ways in which we use your personal information. We may amend this Privacy Notice from time to time. If we do, we will post a notice of the change on the website.

2. Who is primarily responsible for your personal information?

BEO is primarily responsible for the personal information we collect about you when you engage with us. We are therefore termed the ‘controller’ under the UK version of the General Data Protection Regulation (UK GDPR).

Our registered office address is: Black Equity Organisation, 86-90 Paul Street, London, EC2A 4NE. You can also contact us via telephone on +44 20 4566 5390 or via email at info@blackequityorg.com.

3. How is your personal data collected?

We receive personal data directly from people we interact with in the following circumstances:

If you apply for employment with us.

If you volunteer with or provide pro bono services to us.

If you contact us by email.

If you contact us by phone.

If you sign up to our mailing list.

If you make a donation to us.

If you take part in our research projects.

If you sign up to attend one of our events.

If you use our website.

4. How we use your personal information

We will only use your personal data when the law allows it and only to the extent necessary in order to fulfil the purpose for which we need to collect it. Below we set out these purposes, the lawful basis we rely on in order to do so, and how long we keep your personal information for.

Purposes for which we use your personal data:

If you apply for employment with us.

What type of personal data are we using and how are we using it?

When you apply to work with us, you will submit personal data to us, in the form of your application. We process this data for the purpose of filling the post you applied for. Your application itself would be stored in a password protected part of our Office365 environment. In tandem with the application process, we also will ask you to complete an anonymous diversity survey. This is optional and contains no direct questions that serve to identify you.

If you are not successful in your application, we will securely destroy the application after the vacancy has been filled.

On occasion, we may ask for your permission to hold on to your application even if your application was not successful. This is in order for us to get back to you if we feel another job opening might suit you. We would retain this data for up to a year after your application to the post.

If your application is successful, then the context in which we hold your personal data changes. It would then be governed by our internal HR procedures.

In any of the above cases, your personal contact details (name, email address, telephone number and postal address where available) will be added to our contact relationship management system.

What lawful basis do we rely on to use your personal data in this context?

The legal basis for our processing of your data in the context of recruitment is consent, which you can withdraw at any time. Please contact us at recruitment@blackequityorg.com to withdraw your consent in this context.

If you volunteer with or provide pro bono services to us.

What type of personal data are we using and how are we using it?

We work with volunteers and people employed by other organisations working with BEO on a pro bono basis.

To facilitate our work with volunteers and pro bono supporters, we store their personal contact details (name, email address, telephone number and postal address where available) on our contact relationship management system.

We will retain copies of communications about your volunteering and pro bono work in a password protected part of our Microsoft Office365 system.

What lawful basis do we rely on to use your personal data in this context?

The legal basis for our processing of your data in the context of volunteering and providing pro bono services is consent, which you can withdraw at any time. Please contact us at recruitment@blackequityorg.com to withdraw your consent in this context.

If you contact us by email.

What type of personal data are we using and how are we using it?

Your email address, as well as the contents of your email which may contain further personal data such as your name and telephone number, will be stored on our Office365 environment, provided by Microsoft.

In addition, we may create or update a record for you in our Salesforce contact relationship management system. The record will contain your personal contact details (name, email address, telephone number and postal address where available).

What lawful basis do we rely on to use your personal data in this context?

The legal basis for our processing of your data where you contact us by emailing us is our legitimate interest in being able to provide a well-functioning office environment where we can serve enquiries from a diverse range of people.

If you contact us by phone.

What type of personal data are we using and how are we using it?

Depending on your query, we may create or update a record for you in our contact relationship management system. The record will contain your personal contact details (name, email address, telephone number and postal address where available).

What lawful basis do we rely on to use your personal data in this context?

The legal basis for our processing of your data where you contact us by phoning us is our legitimate interest in being able to provide a well-functioning office environment where we can serve enquiries from a diverse range of people.

If you sign up to our mailing list.

What type of personal data are we using and how are we using it?

The personal data you provide to us when signing up to our mailing list, i.e. your name and email address, will be saved on our Salesforce database. Data is initially captured on our website using Engaging Networks software.

What lawful basis do we rely on to use your personal data in this context

The legal basis for our processing of your data in this way is consent, which you can withdraw at any time by unsubscribing from the newsletter. Simply click the unsubscribe button on any of our mailings to do so.

If you make a donation to us.

What type of personal data are we using and how are we using it?

When you make a donation, we collect personal data to facilitate making the payment. We also use your personal data to claim Gift Aid on your donation if you have told us that you would like us to do so. When we do so, we transfer your name and address to HMRC’s systems.

Depending on which method of payment you use, the personal data you entered on our website, as well as additional payment details (such as your account number, or debit card number) will be provided to Stripe, our payment providers.

From time-to-time, we also accept donations through other fundraising platforms (e.g. JustGiving, Virgin Money Giving and CrowdJustice).

We also synchronise donation payment details with our contact relationship management system. Therefore, if you make a donation to us we will add your personal contact details (name, email address, telephone number and postal address where available) to our Salesforce database. This will allow us to contact you for further donation opportunities in future.

What lawful basis do we rely on to use your personal data in this context?

The legal basis for our processing of your data is our legitimate interest to generate revenue, take payments, document transactions that might be audited at a later stage and to be able to handle enquiries from you about any money you have contributed to us.

With regards to adding your personal data to the contact relationship management system in this context, we rely on your consent which you will be able to withdraw at any time. Please contact us at info@blackequityorg.com to withdraw your consent in this context.

If you take part in our research projects.

Each individual research project is governed by its own Privacy Notice and you will be provided with it, as well as contact persons for that project, at the time you sign up for it.

If you sign up to attend one of our events.

What type of personal data are we using and how are we using it?

We organise public as well as private events to further our cause. We collect your personal data to facilitate your attendance, such as providing you with the particulars for the event and to contact you if there is an emergency during the course of the event.

In addition, if the event is chargeable, some of that data, as well as your payment details are provided to your payment provider of choice: GoCardless for Direct Debits, or Paypal or Stripe for individual payments.

We synchronise data about our event attendees with Salesforce, our contact relationship management system. We do this in order to facilitate event administration and contact you about future events. Therefore, if you sign up to attend an event, we will add your personal contact details (name, email address, telephone number and postal address where available) to our contact relationship management system.

We may also use photographs or video footage featuring you when you attend our events.

What lawful basis do we rely on to use your personal data in this context?

The legal basis for our processing of your data is our legitimate interest to use the personal data you share with us to ensure we can effectively arrange your attendance at our events, contact you in the event of an emergency and facilitate payment for the event.

With regards to adding your personal data to the contact relationship management system in this context, we rely on your consent which you will be able to withdraw at any time. Please contact us at info@blackequityorg.com to withdraw your consent in this context.

In relation to the photographs and video footage, it is in our legitimate interests to use photographs or video footage of attendees at our events to highlight the services we provide. We will always give you the option during the arrangement of the event to opt out of any video footage or photographs that we take for promotional purposes.

If you use our website.

What type of personal data are we using and how are we using it?

BEO uses Google analytics software that allows it to track people’s interaction while on the website.

We also use other unobtrusive web technologies, such as session cookies to provide a functioning or pleasant website as a whole.

Large parts of this analysis rely on anonymous data. Some data, such as your IP address, is personal.

 What lawful basis do we rely on to use your personal data in this context?

The legal basis for this processing is our legitimate interest in being able to provide an engaging and welcoming online platform to support the mission of BEO.

5. Retention

We will only retain your personal data while it is necessary for the purpose we collected it for. This means that we do not retain your personal data if we have no reason to do so.

We may need to keep your personal data for longer than this where it is necessary (i) to establish, bring or defend legal proceedings or to comply with a legal or regulatory requirement; or (ii) to preserve records to be able to deal with external or internal audits.

If you would like us to actively delete your personal data even if it is still required for some of our stated aims, then you can make use of your right to erasure.

6. Change of purpose

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason, and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. However, we may process your personal data without your knowledge or consent where this is required or permitted by law.

7. Other parties who will have access to your data

Your personal data may be disclosed by us to the following third parties:

  • third parties which assist us with providing our services to you, such as Engaging Networks – our website data capture provider, Salesforce – our contact management system, Stripe – our card payment provider, WPEngine – our website host;
  • other service providers including IT suppliers, administration services providers;
  • public bodies, including regulatory bodies, where we are obliged or permitted by law to do so (this may include the Information Commissioner’s Office); and
  • our professional advisors including lawyers and auditors.

We may also disclose your personal data to third parties to whom we choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to obtain or merge with other organisations. If a change happens to our organisation, then our new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

8. Transferring your personal information overseas

Your personal data will in limited circumstances be transferred outside the UK.

We will only share personal data with others outside the UK when we are legally permitted to do so, namely where:

  1. the UK government has decided that the relevant country has adequate protective rules in relation to data protection in place (an “adequacy decision”);
  2. we have entered into the relevant “standard contractual clauses” with the recipient of your personal data (these are a set of obligations about how your data is protected and used); or
  3. we can rely on another basis under the law such as that we have to share the personal data because this is necessary for the purpose of a court case, investigation or to protect our legal rights.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being lost, used, accessed, altered or disclosed in an accidental or unauthorised way. We are committed to ensuring that all reasonable and appropriate steps have been taken to protect your personal data which incudes, where appropriate, utilising encryption measures.

We have also put in place procedures to deal with any suspected personal data breach and will notify you and any relevant regulator of a breach where we are legally required to do so.

10. Your data protection rights

Under certain circumstances, you have a number of rights under data protection laws with regard to the personal data we use about you. These are described in the sections below. To exercise any of your rights in relation to BEO please contact us by email at info@blackequityorg.com or by telephone on +44 20 4566 5390.

Right of access to personal data – You have a right to request a copy of the personal data we hold about you.

Right to rectification – If you believe the personal data we hold about you is incorrect, you can contact us to request for any incomplete or inaccurate data that we hold about you to be corrected. However, we may need to verify the accuracy of the new information you provide to us.

Right to erasure – You have the right to request the deletion or removal of personal data we hold about you where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to us holding your information, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with law. Although we will consider every request for erasure on its merits, we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at that time of your request.

Right to object to processing – You have a right to object to the processing of your personal data where we are using it for the purpose of our legitimate interests. If we agree that your objection is justified we will stop using your information for those purposes. Alternatively, we will explain why we still need to use your information.

Right to restrict processing of your personal data – You have a right to request us to suspend the processing of your personal data in the following situations:

  • for the period it takes us to rectify any inaccurate data about you;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you want to prevent us from deleting your data at the end of the retention period in the event that you need it to establish, exercise or defend a legal claim;
  • where you have objected to our use of your data, but we need to verify whether we (or a third party) have overriding legitimate grounds to use it.

Right to request the transfer of your personal data to you or to a third party – You have the right to ask us to transfer certain information we hold about you to a third party you have chosen, or directly to you. Where your request is valid, we will provide you with your personal data in a structured, commonly used, machine-readable format.

11. Right to lodge a complaint

If you have any complaints about how we handle your personal data, please contact us by email at info@blackequityorg.com or by telephone on +44 20 4566 5390 and we will do our best to assist.

You also have a right to make a complaint to the supervisory authority in your country of residence or employment or place of the alleged infringement. The Information Commissioner’s Office (“ICO”) is the UK supervisory authority for data protection issues. You can contact the ICO:

by Telephone:      0303 123 1113 or 01625 545 745

or in writing to:   Information Commissioner’s Office (ICO)

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

or via their website:       https://ico.org.uk/