Privacy Policy
This Privacy Policy applies to information we (Whisper) collect about individuals who interact with our organisation. It explains what personal information we collect and how we use it.
If you have any comments or questions about this notice, feel free to contact us.
1. Personal data that we process
The following table explains the types of data we collect and the legal basis, under current UK and EU data protection legislation, on which these data are processed.
| Purpose | Data (key elements) | Basis |
|---|---|---|
| Enquiring about our organisation and its work, or enquiring about volunteering | Name, email, message | Legitimate interests - it is necessary for us to read and store your message so that we can respond in the way that you would expect |
| Subscribing to our email newsletter which provides updates about our work and opportunities to support us | Name, email | Consent - you give your active consent when you sign up to the newsletter. |
| Making a donation or sponsoring a child | Name, email, address, payment | Legitimate interests - this information is necessary for us to fulfil your intention of donating money and your expectation of receiving a confirmation message. We accept donations through third party fundraising platforms which have their own privacy policies, for example GlobalGiving's privacy policy is here. |
| Website functionality | Website activity collected through cookies | We don't currently use cookies on our website. |
2. How we use your data
We will only use your data in a manner that is appropriate considering the basis on which the data were collected, as set out in the table at the top of this policy. For example, we may use your personal information to:
- reply to enquiries you send to us;
- handle donations or other transactions that you initiate;
- where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.
3. When we share your data
We will only pass your data to third parties in the following circumstances:
- you have provided your explicit consent for us to pass data to a named third party;
- we are using a third party purely for the purposes of processing data on our behalf and we have in place a data processing agreement with that third party that fulfils our legal obligations in relation to the use of third party data processors; or
- we are required by law to share your data.
In addition, we will only pass data to third parties outside the EU where appropriate safeguards are in place as defined by Article 46 of the General Data Protection Regulation. Messages sent to us via forms on our website are held temporarily on our web server in the USA, and communications with Whisper may be handled by designated Whisper staff in Uganda.
4. How long we keep your data
We take the principles of data minimisation and removal seriously and we have internal policies in place to ensure that we only ever ask for the minimum data for the associated purpose and delete that data promptly once they are no longer required. Where data are collected on the basis of consent, we will seek renewal of consent at least every three years.
5. Rights you have over your data
You have a range of rights over your data, which include the following:
- Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this, for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails
- You have the right to ask for rectification and/or deletion of your information
- You have the right of access to your information.
- You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.
A full summary of your legal rights over your data can be found on the UK Information Commissioner’s website. If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us. Please note that relying on some of these rights, such as the right to have your data deleted, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.
6. Cookies and usage tracking
A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, for example remembering your preferences, recording what you have put in your shopping basket, and counting the number of people looking at a website. We don't currently use them.
7. WhatsApp
We may invite participants to join a WhatsApp community or group for event coordination. Participation is voluntary, and you can leave the group at any time. WhatsApp is a third-party service. Joining the group will make your phone number visible to other group members. WhatsApp has a minimum age of 16; for participants below the age of 16, a parent or guardian can join instead. The WhatsApp group will normally be deleted within 3 months after the event. For details of WhatsApp’s own data handling, see WhatsApp’s privacy policy (UK version).
8. Jitsi
We sometimes use the Jitsi open-source online videoconferencing service. The service is hosted in the USA but it requires no download and is respectful of privacy. You can find their privacy policy here.
9. Modifications
We may modify this Privacy Policy from time to time and we will publish the most current version on our website. If a modification meaningfully reduces your rights, we will notify people whose personal data we hold and are affected.