At Rainbow Migration, we take protecting your data seriously and are committed to being transparent about how we collect, use and store your data.
Who we are
We are Rainbow Migration, a registered charity in England and Wales (charity number 1158228). We are registered with the Office of the Immigration Services Commissioner (OISC) as immigration advisers (registration number N201700019). We are also registered with the Information Commissioner’s Office (ICO) as data controllers. Our registration number is Z9665753.
For the purposes of this policy, references to ‘we’ and ‘us’ mean Rainbow Migration.
What information we collect
We collect personal and statistical information from you when you take part in particular activities, request information from us and look at our websites or social media profiles.
The information we collect includes (but is not limited to):
- Email address
- Phone number
- Credit card information when making a donation
- Bank account details when setting up a direct debit
- Contact consents i.e. whether you’ve said you’d like to hear from us by email
- Taxpayer status for collecting Gift Aid
- Age, nationality, immigration status, gender identity, sexual orientation (where necessary for us providing support to you)
The information we collect depends on how you are engaging with us. For example, if you are making a donation and want to include Gift Aid, we need to collect your title and full postal address in order to provide that information to HMRC to process your Gift Aid. If you are seeking support from one of our services, we may need to collect your age, nationality, immigration status, gender identity, sexual orientation and other personal information in order to help us work on your case.
In general, we collect information from you when you:
- access our services via telephone, email, our online contact form or face-to-face events
- make a donation to us, either by post, bank transfer, online (either directly or by using a third party donation platform such as CAF or Virgin Money Giving), over the phone or via SMS. We also collect information about you when you make a donation to us through setting up a standing order or Direct Debit, or donating via payroll giving (Give As You Earn).
- sign up to support our work by fundraising for us by taking part in challenge events or other means, including via third party sites such as Virgin Money Giving, where you give your consent for your information to be shared with us
- agree to or enquire about leaving a gift in your Will
- become a Rainbow Migration Member or Friend
- sign a petition or take part in a similar campaign action to support us
- sign up to receive our emails
- apply for a staff or volunteer opportunity with us
- register to attend an event, training course or workshop with us
- engage with us in a professional or commercial or other work capacity
- interact with us for any other reason
We also hold information about your engagement with us including the ways you have supported us in the past, for example, through donating, taking campaign actions or utilising our services.
Although in most case the personal data that we collect about you will have come from you, there are a small number of situations in which we are given personal data by someone else (referred to as a third party). This may for example be because:
- we are asked for our specialist advice or support on your behalf by someone who is already helping or advising you
- someone we are supporting or advising tells us about you because you are relevant to their case, for example if you are a witness or adviser to them
Data about you from a third party will only be collected and used to the extent that is necessary for the provision of our services (generally legitimate interest based processing).
We collect statistical data about how you’ve engaged with us via our website, social media channels and email. This data is anonymised and accessed through Google Analytics and AdWords, Mailchimp, Facebook Insights, Twitter Analytics and YouTube Studio Analytics. We cannot identify you through this data.
We sometimes ask people to complete surveys find out more about their opinions on the work we’re doing or issues related to our work. This includes feedback about services and training that we have provided.
Why we collect this information
We collect personal data to allow us to process:
- donations (including processing Gift Aid, where people have elected to contribute Gift Aid)
- campaign actions that involve communicating with Government and other relevant policy positions
- information about fundraising events people are running or taking part in for us
- information about people who have signed up for training, workshop or other events with us
- job and volunteer applications
- requests for our services
- information about our service users to get a better understanding of their experiences. This involves compiling statistics, undertaking research and communicating our work publicly using anonymous information from service users. We will never share anything that identifies any individual person without their permission.
We collect personal data so that we can contact:
- people who have opted-in to hear from us by email, post, phone or SMS (consent based contact)
- people who we are working with in our services (legitimate interest based contact)
- people who have applied for job or volunteer positions with us (consent and legitimate interest based contact)
- people who have told us they are fundraising for us, for example by running a marathon or holding a bake sale (consent and legitimate interest or contract based contact)
Sensitive personal data
Under data protection law, certain categories of personal information are recognised as sensitive, including information regarding sexual orientation and health (known in law as special category personal data’) or relating to criminal convictions. We collect this data for a number of reasons including:
- where it is necessary to the provision of a service or enables us to support you with specific needs. This might relate to support or legal advice we are providing to you in relation to your asylum case or in helping you to access relevant services.
- where it is necessary so that adjustments can be made to accommodate your needs if you are volunteering or working for us.
- where it is strictly necessary about someone whilst they are working for us.
- where supporters have shared such information with us over the phone or in writing. In such cases, we may use this information to tailor our communications to individuals in line with the consent provided for how we should communicate with them.
We will generally only collect and process this sensitive data with your knowledge and either express consent, or in order to give you legal advice about your case or where we are legally obliged to.
Sensitive personal data is held securely in our databases and only accessed by relevant staff and volunteers as necessary to their role and the exercise of their duties.
We collect statistical information about how our website, social media and email updates are being used. This information helps us improve the services and information we offer you, by providing us with insights into what content, activities and communications styles are most popular or relevant to our supporters.
We use Google Analytics and AdWords, Mailchimp, Facebook Insights, Twitter Analytics and YouTube Studio Analytics to collect this information, which is anonymised. We cannot identify you from this information.
Survey and feedback data
We collect this data to understand and improve the services we provide and for use in evaluation of different areas of work as well as the design and planning for future work.
How we use information we collect from you
The main ways in which we use the information you provide to us is to complete an action or deliver a product or service to you that you have reasonably requested. This may include but is not limited to processing a donation (including claiming Gift Aid, where you have asked that we do this), delivering training, running our memberships programmes and providing client services.
We may also use the information you have provided to get in touch with you about our work, unless you have specifically told us not to. Please note that we will not send you emails or text messages about our work unless you have specifically asked us to.
How we will not use the information we collect from you
We will never sell your data, and we will never share it with other organisations for the purposes of their own marketing. We are not involved in any data swapping schemes.
We may need to share some personal information or data with third parties including:
- Other legal and support service providers if you ask us to refer you to them for additional help;
- IT service providers who process our computer data for us (for example cloud storage) – these processors keep all data securely and cannot access it for their own use;
- Our regulators when we are required to by their official processes;
- Government and other official bodies where the law requires it (for example HM Revenue and Customs for Gift Aid donations);
- When strictly required to safeguard someone.
We do not share personal information with UK Visas and Immigration or UK Border Force except with your express consent.
If your personal information is transferred outside the UK for processing or storage purposes we will ensure that safeguards are in place to protect it to at least the standard applied within the UK.
Any other websites which may be linked to by our website, such as donation or social media platforms, are subject to their own policy, which may differ from ours and which we are not responsible for.
How long we keep your personal information
We keep personal data for as short a time as possible. This will often be determined by our legal obligations. Key time limits are:
- Service users who have received support services or legal advice – 6 years from the conclusion of the service. People who are signposted to other services because we do not offer the service or information they need will have their data kept for 18 months.
- Staff and volunteers – 6 years post employment
- Members – 6 years post membership lapsing
- Fundraising – donation information for 7 years and contacts may be kept indefinitely
- Applicants for voluntary or employed posts – 12 months after successful conclusion of the recruitment or 12 months after receipt if they were unsolicited
How we protect your personal information
Our data management takes all appropriate measures to keep your data safe both physically and electronically and (where relevant) to keep your data accurate and up to date.
On our website, all of our donations are managed through third party platforms called Virgin Money Giving and CAF. We do not keep the card payment details of any donations made via these platforms, SMS or via other third party platforms such as Facebook Donate, Amazon Smile or Give As You Live.
Our website uses an encryption protocol that protects data while it is travelling from one server to another, and is regularly updated with the latest security upgrades.
Please note that while we have taken every appropriate measure to secure your data, transmission of information over the Internet is never one hundred per cent secure so while we take all reasonable precautions, we can’t guarantee the security of any information you submit to us via our website.
Any personal information is kept on secure cloud storage and backups provided by reputable companies and protected by data protection compliant contracts. Access is restricted to staff and where strictly appropriate, to specified volunteers and only where necessary.
Data is held within the UK or where necessary, due to reputable third party IT suppliers, within the EU/EEA or in other countries such as the USA and protected by GDPR approved contract terms.
Personal data is destroyed or deleted securely when it is no longer necessary for us to keep it.
We use Civic UK Cookie Control on our website to help you better understand and manage your cookie preferences and settings. Read more about how this works. You can change your cookie settings for our website at any time by going to the Civic Cookie Control icon in the bottom left corner of every page.
The law gives you certain rights in terms of accessing the information we hold about you, correcting that information if necessary, and asking us to stop using or delete it should you like it to be erased. The extent of these rights depends on type of information and the lawful basis that we have for having it. For example, we cannot erase data where we have a legal obligation to keep it.
In addition to this, you have the right to update marketing and fundraising communication preferences. You can do this by opting in or out. To opt out, you can click on the link at the bottom of any marketing email or write to the Data Protection Officer using the contact details below.
To exercise any of your rights, please get in touch. You can contact us in the following ways.
FAO Data Protection Officer
7 – 14 Great Dover Street,
London, SE1 4YR
By email: email@example.com
By phone: 020 7922 7812
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us in the following ways:
7 – 14 Great Dover Street,
London, SE1 4YR
By email: firstname.lastname@example.org
You can also complain to the ICO if you are unhappy with how we have used your data:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
Updates to this policy