About this Policy

1. At Conservative Humanists we are committed to putting humanism into practice. We aim to advance free thinking and freedom of choice so everyone can live in a fair and equal society.
2. When doing this, we process personal data about people who provide us with support through campaigns, donations, volunteering, or signing up as members. We are committed to protecting your privacy and take this responsibility very seriously. We therefore take care to safeguard it. This notice outlines what data we collect, how we may use it, how we protect your data and your rights, and how you can exercise those rights.
3. References to ‘we’ or ‘us’ are to Conservative Humanists, registered company no: 12226681 (England & Wales); 26 Briars Wood, Horley RH6 9UE
4. We regularly check this notice to ensure we provide you with the most up-to-date information regarding our data processing activities. We strongly advise you to read this page from time to time to ensure you are happy with any changes that might be made.
5. This privacy policy was prepared to be as comprehensive as possible, but it does not include an exhaustive list of every aspect of our collection and use of personal information. We are happy to provide any further information or explanation about our practices on request.
6. If you have any questions about this policy, please contact us using the details in the ‘Contact us’ section below.
7. This privacy policy was last updated on 25 September 2023.

Why we collect your data

8. We collect personal data for many reasons, including to provide you with services, communicate with you, and send you information you have requested, and administer campaigns, membership, and donations. Depending on how you interact with us, we may process data for the following reasons:
   1. to provide you with advice, support, or information about Conservative Humanists, humanism, conservatism or other related activities that you have requested.
   2. To provide you with direct support, advice, signposting, and referrals to other support organisations and agencies
   3. to administer your membership
   4. to communicate with you about our work, fundraising, and campaigning activities
   5. to process job applications or volunteer placements
   6. to provide you with information about and to administer events, including mass participation events where we may be present (such as festivals, public gatherings) 
   7. to record and contact you regarding payments you make to us
   8. for our own internal administrative purposes, and to keep a record of your relationship with us
   9. to manage your communication preferences
   10. to conduct surveys, research and gather feedback
   11. to obtain information to improve our services and supporter experiences
   12. to carry out research to find out more information about our supporters’ and prospective supporters’ backgrounds and interests
   13. to comply with applicable laws and regulations, and lawful requests from statutory agencies.

Information we collect

9. We may collect some or all of the following personal information:
   1. your name
   2. contact details – including your postal address, telephone number(s), and email address(es)
   3. date of birth
   4. details of relevant personal circumstances when providing you with advice and support
   5. your bank details (held separately by our payments processing company)
   6. records of your correspondence and engagement with us
   7. details of your donations to us
   8. information you may enter via our websites 
   9. photographs, video or audio recordings
   10. occupation
   11. biographical information
   12. IP addresses (for analytics purposes, not stored with your profile or membership record)
   13. other information you share with us
10. This information may be collected via:
    1. any paper forms you complete
    2. telephone conversations or face-to-face interactions
    3. digital forms completed via our websites, or online surveys
    4. third-party companies and websites such as JustGiving
    5. publicly available sources
    6. communication via social media
11. We sometimes also collect sensitive, personal data about individuals. This includes information about health, religion or belief, sexual orientation, ethnicity, political and philosophical beliefs, and criminal records. We will normally only record this data where we have your explicit consent, unless we are permitted to do so in other circumstances under data protection law. For example, we may make a record that a person is in a vulnerable circumstance to comply with requirements under charity law and fundraising best practice, to ensure that we do not send fundraising communications to them.

Using your personal data

Conservative Humanists Services and Information provision

12. We will keep all your information – including notes, letters and information given to us about you – in a confidential record that is specific to you. We use a customer relationship management system (CRM) to support our activities. This means that we can keep the information you provide us. We take information security very seriously. No one is allowed access to our files unless they need this to provide one of the purposes discussed in this notice.
13. We may use your data for statistical reports. These statistics will not include any information that could be used to identify any individual.

Fundraising/campaigning/direct marketing

14. We want to keep you up to date with our fundraising, marketing, and campaign activity.
15. We use a range of marketing activities and channels to contact our supporters – including our website, email, face-to-face fundraising, direct mail, social media, and telephone.
16. We will always obtain consent to contact you by email and text message for marketing purposes. We will also obtain consent from all new members to make marketing calls.
17. We will sometimes send marketing by post, on the basis of it being within our legitimate interests to do so, unless you opt out. See section 10 (‘Our legal basis for processing data’) for more information about our use of legitimate interests. We will also contact existing supporters by phone on this basis (unless they are registered with the Telephone Preference Service or have opted out of receiving marketing communications from us).
18. We send the following marketing materials:
    1. updates about our work – including email and paper newsletters and other publications informing you about our work
    2. information about our campaigning activities, including how you can support such campaigns (for example by lobbying influential figures or signing a petition), and updates about the progress of our campaigns
    3. fundraising appeals, including requests for donations, information about how you can leave us a gift in your will, how you can raise money on our behalf, attend or take part in a fundraising event, communications relating to auctions and raffles, and updates on the impact that your fundraising activities have had on our work
    4. details of events. Please note that if you sign up to a Conservative Humanists event we will also send you administrative communications about how you can take part. We will also send you a reminder about similar events in future years, in case you want to participate again
    5. information about how you can help support Conservative Humanists by giving your time as a volunteer or using your influence to progress our aims, along with updates on the impact of your work
19. We will never share or sell your personal data to a third-party organisation for its marketing, fundraising, or campaigning purposes.
20. You can withdraw your consent and unsubscribe from or update your marketing preferences at any point using the details in the ‘Contact us’ section below.
21. Any ‘mass’ electronic communications, such as emails, will have a link to unsubscribe from future electronic communications, so you can manage your own communication preferences.
22. If you make any changes to your consent, we will update your record as soon as we possibly can. It may take up to 30 days for our systems to update and stop any postal communications from being sent to you. Email communications will be stopped within a week and usually immediately. If you tell us you do not wish to receive marketing, fundraising or campaign communications, you may still receive transactional and service-based communications confirming and servicing other relationships you have with us (as described below). You can also opt out of receiving marketing communications from us by signing up to the Fundraising Preference Service.
23. Where possible, we cleanse and remove out-of-date data. This helps us to improve the delivery rate of our mailings and minimise wasted expenditure.

Administrative communications to members and supporters

24. In addition to the fundraising and marketing communications that you receive from Conservative Humanists, we will also communicate with you by post, telephone, and email in relation to administrative and transactional matters. For example, we may call you after you have set up a Direct Debit to confirm your details, and will contact you upon cancellation to check this was your intention. There may be other occasions where we need to contact you about your contribution – for example, if there is a problem with a payment.
25. As mentioned above, we may still need to communicate with you for administrative purposes even where you have opted out of marketing communications from us. For example, members will be contacted about membership renewal and governance aspects of membership such as the AGM.

Member and Supporter research and analysis

26. We may use profiling and database segmentation to analyse your personal information, and create a profile of your interests, preferences, and ability to donate. This allows us to ensure communications are relevant and timely, to provide an improved experience for our supporters. 
27. We are legally required to carry out checks on individuals who give us large donations, to comply with our duties in respect of anti-money laundering legislation and the prevention of fraud.

Social media/digital

28. When someone visits conservativehumanists.org.uk we collect standard logging information and details of visitor behaviour – such as which pages are visited, and how long is spent on each one. We do this to find out things such as the number of visitors to the various parts of the site, and how people are using our site. These website statistics and data are collected by Google Analytics and Hotjar. Google’s system also provides us with non-personally-identifiable ‘Interest’ and ‘Demographics’ data, which is collected using the widely-used Google Advertising Network DoubleClick cookie (see here for more information on this cookie, including how to opt-out). Conservative Humanists collects this data so that we can find out the kinds of people visiting our site, and we use this data to help us deliver our messages as effectively as possible. See below for more information about cookies, and here for a way to opt out of Google Analytics on all websites you visit.
29. Our website also uses web beacons or pixels through third-party service providers that allow us to track activity on our website – as well as generating advertisements that appear on Meta (henceforth referred to as ‘Facebook’ or ‘Instagram’), Reddit, X (henceforth referred to as ‘Twitter’), for you and other potential users.
30. We also track whether you respond to an advert on these services, or whether you engage with us having seen an advert. This is known as ‘conversion tracking’, and uses ‘cookies’ on your machine. We do not provide these third-parties with identifiable information. However, if you have an account on these services it will be possible for them to match up your account to the visit to our site, and as such they may use this to inform future advertising on those services.
31. If you are logged in to your Reddit/Twitter/Facebook/Instagram account and visit a page on our site, one way or another this will be tracked and these sites will know about it and may use this data to inform their advertising algorithms. We will update this page if we add more organisations. You can opt-out of this kind of tracking. On Twitter you can do this here. You can manage your Facebook settings here. You can manage your Instagram settings here. You can manage your Reddit settings here. Your web browser allows control of most cookies through the browser settings. 
32. Depending on your settings or the privacy policies for social media messaging services like Reddit, Facebook, Twitter, and Instagram, you may receive targeted advertisements through our use of social media audience tools. For example, Facebook’s ‘Custom’ and ‘Lookalike’ Audiences’ programmes enable us to display adverts to our existing supporters when they visit Facebook, or other people who have similar interests or characteristics to our supporters. We may provide your data (including your email address) to Facebook, so it can determine whether you are a registered account holder with them, or so that Facebook create a ‘lookalike’ audience or to exclude you from receiving ads. Our adverts may then appear when you access Facebook. We only work with social media networks that provide a facility for secure and encrypted upload of data, and who immediately delete any records not matching with their own user base. For more information, or to manage your social media ad preferences, please see Facebook’s ‘About Custom Audiences’ guide and its Data Policy.
33. We use ‘cookies’ to collect data from your browser when you visit our website. A cookie is a small text file that is stored on your computer via your web browser. This file allows us to temporarily store information about your website usage. For example, a cookie is created when you login, so that as you continue to navigate the website we can understand who you are and show you the appropriate content. Cookies are also created whenever you click ‘Remember me’ on a website. Next time you visit that website, it checks to see if there is a cookie in place – if there is, you don’t have to login next time. Cookies can also be used by third-parties, and sites such as Facebook can use them to see which websites you have visited. Our site has various cookies in place – see the rest of this policy for details of the organisations we work with, and how we ensure that your data is secure. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
34. If you receive an email and you open it, or don’t open it, or click a link in it, we collect this information to ensure that the information we send to people is received and relevant.

Professional contacts

38. We may collect data about professional contacts and partners with whom we work, or to whom we provide professional services – such as training, publications, or volunteer placement. Personal data collected in this way will be processed in accordance with data protection legislation and this policy.
39. We may send our professional partners information and updates about our work (primarily by email). Such contacts can opt out of receiving this information at any time.
40. We maintain a record of information related to MPs and other holders of public office, to enable us to undertake our campaigning activity in furtherance of our aims. This will include keeping a record of contact details such as address, telephone number, and email address as well as publicly available voting records and committee and group memberships.

Our legal basis for processing personal data

41. 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). Four of these are relevant to the types of processing that we carry out. This includes information that is processed on the basis of:
    1. a person’s consent (for example, to send you direct marketing by email)
    2. a contractual relationship (for example, your membership)
    3. processing that is necessary for compliance with a legal obligation (for example, carrying out due diligence on large donations)
    4. Conservative Humanists legitimate interests (please see below for more information)
42. 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.
43. 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:
    1. Governance: including delivery of our published aims, statutory and financial reporting, and other regulatory compliance purposes
    2. Administration and operational management: including responding to solicited enquires, providing information and services, research, events management, the administration of volunteers and employment, and recruitment requirements
    3. Fundraising and Campaigning: including administering campaigns and donations, sending direct marketing by post (and in some cases making marketing calls), sending thank you letters, analysis, targeting and segmentation to develop communication strategies, and maintaining communication suppressions
44. If you would like more information on our uses of legitimate interests, or to change our use of your personal data in this manner, please get in touch with us using the details in the ‘Contact us’ section below.

Disclosure of your personal data

45. We will not share any of your personal data with any third party – except where:
    1. the transfer is to a secure data processor, which carries out data processing operations on our behalf (please see sections 50-54 for more information)
    2. we are required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
    3. it is necessary to protect the vital interests of an individual, including where is it necessary to safeguard you or another individual
    4. we have obtained your consent, for example:
       1. with Government or Parliament as part of a petition,
       2. with a Humanists UK, the Conservative Party, or another institution to coordinate a volunteering activity.

46. We will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.
47. Conservative Humanists may also use personal information itself to contact people for marketing or administrative purposes. From time to time, we agree with other like-minded organisations (for example Humanists UK, or the Conservative Party) to write to some of each other’s supporters, for the mutual benefit of both; in this case marketing materials are exchanged but not your data.

Security of your personal data

48. 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.
49. Unfortunately, the transmission of information via the internet cannot be guaranteed to 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 website. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
50. We encourage you to review the privacy statements of websites you choose to link to from the Conservative Humanists website, so that you can understand how those sites collect, use and share your information. We are not responsible for the privacy statements, security, or other content on sites outside of our control.

Use of data processors

51. We may use a third-party supplier to manage mailings for fundraising appeals, campaigns, conduct research surveys, server analysis, support needs, or storage of your personal information on our behalf. You can find out more about the suppliers that we use by getting in touch with us using the details in the ‘Contact us’ section below.
52. We actively screen and monitor these companies and contractors to maximise the protection of your privacy and security. They are only permitted to use the data in accordance with relevant data protection legislation, under strict instructions from us, and in accordance with a data processing agreement entered into between us and them.

Transfers of data outside of the European Economic Area

53. We endeavour to keep all personal data hosted within the EEA. If it is ever desirable to transfer your data outside of the EEA, we look at this on a case-by-case basis to ensure that robust data-sharing agreements are in place. For example, MailChimp hosts its data in the US and is a member of the Privacy Shield scheme. This scheme has been declared by the EU to provide adequate protection for personal data, and as such we are happy to use it.
54. We use Google products, which are multi-tenant cloud services, for our internal office use as well as for hosting of documents and other files. This means that internal documents and information generated by us are stored in cloud services hosted by Google outside of the EEA. Google is a member of the Privacy Shield scheme and we have extensive contracts in place with them to safeguard your data. We have a business-level account with Google, and personal data is never scanned for advertising purposes.
55. In cases where we transfer your data outside the EEA, we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information, for example, by entering into a contract that includes prescribed clauses about the use of data (and if the company is based in the United States, checking that it is accredited under the EU-US Privacy Shield).

Retention of your data

56. The length of time that your data will be kept may depend on the reasons for which we are processing the data and on the law or regulations that the information falls under, such as financial regulations, Limitations Act, Health and Safety regulation etc., or any contractual obligation we might have – such as with government contracts or if we have a business case, such as with research data. For business case data, we will anonymise the data so no individual is identifiable.
57. Subject to the above, we will typically store data relating to donors and people who have taken campaign actions for seven years after their last donation or interaction, and people to whom we provide services to for seven years after completion of those services. Personal data about unsuccessful job applications are held for 12 months after the recruitment exercise is complete for that position.
58. Once the retention period has expired, the information will be confidentially disposed of.
59. If you request to receive no further contact from us, we will keep some basic information about you on our suppression list to avoid sending you unwanted materials in the future.

Your rights

60. You have many rights under data protection legislation. These include:

Right of Access

1. You have the right know what information we hold about you and to ask, in writing, to see your records.
2. 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.
3. This is called a data subject access request, and can be made by:
   1. emailing info@conservativehumanists.org.uk.
   2. writing to the Chairman, Conservative Humanists, 26 Briars Wood, Horley RH6 9UE

Right to be informed

4. 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

5. 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

6. 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.

Right to restrict processing

7. 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

8. 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

9. 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

10. Where we are processing your personal data because you have given us your consent to do so, in some circumstances you have the right to request that the data is transferred to an equivalent organisation.

Complaints

61. If you have any complaints about the way in which we have used your data, please get in touch with us using the details in the ‘Contact us’ section below. We would be happy to help and discuss your concerns.
62. In addition, you are also entitled to make a complaint to the Information Commissioner’s Office.

Contact Us

63. If you have any questions about this policy, would like more information, or want to exercise any of the rights set out in section 68 above, you can get in touch with us in the following ways:
    1. info@conservativehumanists.org.uk
    2. https://conservativehumanists.org.uk/contact-us/
    3. Conservative Humanists, 26 Briars Wood, Horley RH6 9UE