GLAN's privacy notice - how we deal with data privacy
The Global Legal Action Network (GLAN) is committed to protecting and respecting your privacy. GLAN is a registered charitable organisation in England and Wales (registered charity number 1167733). Our registered offices are at Garden Court Chambers, 57-60 Lincoln's Inn Fields, London, WC2A 3LJ.
This privacy statement sets out the basis on which we will process any personal information that we may collect about you as a visitor to our website or premises or as one of our clients, supporters or partners. If we collect your data, we want you to know exactly what we are using it for and to be reassured that we are keeping it securely. If you have a specific query about your data, please send it to firstname.lastname@example.org: we would be happy to advise you.
The information that we collect about you
We may collect and process the following information about you:
Information that you give us: This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete) or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address and telephone number; your date of birth, gender and bank account information; information about your relationship with GLAN (including your donation history and feedback you have provided to GLAN); information about your professional role, background and interests.
Information that our website and other systems collect about you:
If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.
If you want to contact us without automatically leaving such details in our IT systems, please use our Signal number. We may still record the interaction within our own secure filesystem.
Other information: We may also collect some information from other sources. For example:
If we have a business relationship with the organisation that you represent, your colleagues or other contacts may give us information about you such as your contact details or details of your role in the relationship.
We may collect information from third party data providers or publicly available sources for anti-money-laundering, background checking or similar purposes, and to protect our organisation and comply with our legal and regulatory obligations.
We may collect information from third party data providers or publicly available sources for fundraising purposes.
The uses that we make of your information
We may use your information for the following purposes:
to progress our casework, where you have given it to us for that purpose.
to operate, manage, develop and promote our organisation, including managing and administering donations and other support actions;
to operate, administer and improve our website and premises and other aspects of the way in which we conduct our operations;
to protect our organisation from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;
to comply with our legal and regulatory obligations and bring and defend legal claims;
if you have given your consent, to provide you (by electronic means only) with information about our news, activities, appeals, campaigns and fundraising;
to analyse and better understand the composition and interests of our supporter base.
We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary management purposes (for example, where necessary when a staff member is out of the office or has left GLAN).
We will only process your personal information as necessary so that we can pursue the purposes described above, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information. We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise you should assume that we need the information for our organisation or compliance purposes (as described above). If you are uncertain as to GLAN's need for information that we request from you, please contact the GLAN representative asking for the information, or Contact us (see below), with your query.
If we are using your sensitive personal data (including personal data relating to your racial or ethnic origin, political, religious and philosophical beliefs, trade union membership, sexual orientation or health, we will only do so with your explicit consent or, if otherwise, only to the extent permitted by applicable law.
Disclosure and international transfer of your information
We may disclose personal information about you, where reasonably necessary for the various purposes set out above:
to trusted partners on a specific, case-by-case basis, and only where necessary in the pursuit of our legitimate interests. For example, this may be where we work with another organisation or lawyer on particular casework, and where it would be impracticable to seek your consent for this. If these partners are not domiciled within the EU, we will ensure strict independent conditions of confidentiality.
to your colleagues within the organisation that you represent;
to service providers who host our website or other information technology systems or otherwise hold or process your information on our behalf, under strict conditions of confidentiality and security; We operate security protocols to varying degrees of stringency, depending on the sensitivity of client information. If you have security concerns, contact us to discuss this.
to a person who takes over our organisation and assets, or relevant parts of them; or
in exceptional circumstances:
to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
where we are required by law to disclose.
These disclosures may involve transferring your personal information overseas. In those cases, where we transfer personal data to our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your personal information is protected, on terms approved for this purpose by the European Commission. Please Contact us (see below) if you would like to know whether any such agreements are in place or, if so, to see a copy.
Retention and deletion of your information
We will delete the information that we hold about you when we no longer need it. The retention periods are as follows:
Mailing list: Ongoing, until you unsubscribe.
Unsuccessful job/voluntary position applications: 6 months after data received.
Volunteers: two years after voluntary position finishes.
Register of experts: if we have not engaged you within two years of taking your information, we will contact you periodically to seek your consent for continuing to hold your data.
Casework: If your data is being used for the purposes of casework (for example, if we have collected information about your experiences or if you are a witness), your data will be held for the duration of the case and for a further six years after the conclusion of any legal proceedings, unless there is a public interest in retaining that data beyond six years. The retention will be kept under review. You have a right to ask us whether or not your data is held and to request its deletion.
If for any purpose, including assisting you in bringing a legal action, we require from you any personal data, we will, prior to obtaining that data from you, send you a letter or email setting out the basis on which we will hold that data
You have a right of access to the personal information that we hold about you, and to some related information, under data protection law. You can also require any inaccurate personal information to be corrected or deleted. You may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances.
If you wish to exercise any of these rights, please Contact us as set out below. You can also lodge a complaint about our processing of your personal information with the Information Commissioners Office.
We welcome questions, comments and requests regarding this privacy statement and our processing of personal information. Please send them to email@example.com.
Changes to this policy
Any changes we make to this privacy statement in the future will be posted to our website www.glanlaw.org and also available if you contact us. Please check back frequently to see any changes.