Transform Europe Network understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our supporters, volunteers and partners and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
Transform Europe Network (also known as ‘TEN’)
Registered Charity – Eurovangelism [Eurovangelism is a registered with the charity commission in England and Wales(no: 1140592). We are also a company limited by guarantee (no. 7507682)
Registered address: 23 Apex Court, Woodlands, Bradley Stoke, Bristol. BS32 4JT
Main trading address: 23 Apex Court, Woodlands, Bradley Stoke, Bristol. BS32 4JT
Data Protection Officer: James Chilcott
Email address: james.chilcott@ten-uk.org
Telephone number: 0117 961 5161
We are regulated by the Charity Commission of England and Wales.
We area member of the Information Commissioner’s Office (ICO) under registration ZA482896. We are registered with the Fundraising Regulator.
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
Under the Data Protection Legislation, you have the following rights, which we will
Transform Europe Network – Privacy Notice 2 always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves however, so please contact us first, using the details in Part 11.
We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. We only collect ‘special category’ or ‘sensitive data’ where it is relevant.
| Data Collected | How we Collect the Data |
|---|---|
| Identity Information including: Name, title. Date of birth is only collected where it is required in relation to your relationship with Transform Europe Network. | Data is collected via, email online forms either via our website or Microsoft forms, paper forms, in person or over the phone. |
| Contact information including address, phone number, email and social media address | Data is collected via, email online forms either via our website or Microsoft forms, paper forms, in person or over the phone |
| Organisation information including business name, job title, business contact information. | Data is collected via, email online forms either via our website or Microsoft forms, paper forms, in person or over the phone |
| Payment information including card details and bank account sort code and bank account number. | Data is collected via, our website donation system, over the phone, our online Stripe and Paypal payment systems, by paper form; we do not store credit card details |
| Data from third parties E.g. name, contact information and communications preferences | Online giving tools such as Enthuse, Donr and Stewardship. |
| Data related to a ‘special category’ or sensitive data is only collected when relevant related to your involvement and relationship with TEN. E.g. a team trip |
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
| What We Do | What Data We Use | Our Lawful Basis |
|---|---|---|
| Administering our business. | Identity data, contact information, payment data | Legitimate Interest – financial, consent |
| Supplying our services to you. This includes things such as our Essential Gifts Catalogue. | Identity data, contact information, organisation information | Legitimate interest |
| Managing payments related to donations or purchase of products or services. | Identity data, contact information, payment data | Legitimate interest – financial |
| Communicating with you. | Identity data, contact information, organisation information | Legitimate interest and consent. |
| Supplying you with information by emailand post that you have opted-in-to (you may opt-out at any time by by written or digital sign up form, over the phone | Identity data, contact information, organisation information | Consent |
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, post or phone with information, news, and offers on our work and how you can support it and get involvement with it.] You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. Wewill always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
[We] will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
| Type of Information | Retention Period |
|---|---|
| Supporters | Those who donate, volunteer, receive information as requested, pray for the work of TEN |
| Donor Personal Information |
Information connected to donations will be retained until seven full financial years have elapsed since a donors’ last gift Thereafter all data relating to the data subject will be deleted as part of an annual data hygiene programme. In the case of a deceased donor, UK GDPR no longer applies but we will delete records once seven full financial years have elapsed since their last gift or legacy. The records of Donors who have expressed an interest in leaving a gift in their Will to TEN will be retained until they expressly state that they will not be leaving such a gift or until seven full financial years have elapsed from our notification of their death. This will enable us to identify the correlation between expressions of interest and subsequent actions. The record of donors whose data is held on microsites such as MailChimp but who request to stop receiving emails will be changed to reflect the request as soon as possible following the request. If a donor request removal from a data set e.g. electronic communications we will follow procedures to ascertain whether the supporter would like to continue to receive information through other means |
| Donor Financial Information | The same policy as for donor personal information |
| Non-Donor Information |
The record of non-donors who have asked to be removed from the database will be removed within six months of the request. The record of non-donors who have asked to no longer receive a specific type of communication such as electronic or postal communications will be removed from the database within six months if we have no basis for continuing to process their data. If we hold information that allows us to contact them in other ways we will follow our processes to ascertain whether the supporter would like to continue to receive information through other means. Return to Sender received – if we have no other supporter information than postal address and no way to contact the supporter their data will be removed after six months. If we hold other contact information we will follow our processes to ascertain whether the supporter would like to continue to receive nformation through other means. |
| Business/Organisation Information |
Business information will be retained for as long as needed for the business of TEN now and / or in the future. From time-to-time business information held is reviewed and where deemed no longer needed now or in the future it will be deleted within one year. |
We will store some of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.
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We will store some of your personal data] within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
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We may store some of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
If needed we will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
If we sell, transfer, or merge parts of our business or assets, your personal data maybe transferred to a third party. Any new owner of our business may continue to useyour personal data in the same way(s) that wehave used it, as specified in this Privacy Policy.
In some limited circumstances, wemay be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of James Chilcott)
Email address: james.chilcott@ten-uk.org
Telephone number: 0117 9615161
Postal Address: 23 Apex Court, Woodlands, Bradley Stoke, Bristol. BS32 4JT
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
This Privacy Notice was last updated on 9th February 2024.
