Our Privacy Policy

ActionAid: Who We Are and What We Do
ActionAid is an international charity that works with women and girls living in poverty. Our dedicated local staff are helping end violence against women and girls and changing lives, for good. We won’t stop until women and girls are out of danger, out of poverty and on track to create the future they want.
We are a charitable company limited by guarantee, registered in the Netherlands as Vereniging ActionAid International RSIN number: 813342211, registration number: 27264198.

Information on this policy
Your personal information (such as your name and contact details, known as ‘personal data’) is protected by specific legislation:
• General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)
• Privacy and Electronic Communications (EC Directive) 2003

The laws in this area continue to develop quickly. We take our responsibilities around data very seriously, and it’s important to us that you understand how and why we ask for and work with your details. Your privacy is important to us and we have policies to ensure that we collect only the data that we need to carry out our business, and that we don’t keep it any longer than we need to.
At ActionAid, everything we do is geared towards ensuring the rights and improving the lives of women and girls. We seek to develop a greater understanding of our supporters through their personal data in order to help us give them the best possible experience, fundraise more efficiently and help us change lives for good.
This policy explains how we collect, manage, use and protect your personal data, including how we work with third parties.
We never sell or swap your details with any other organisation for their marketing purposes.
If you would like more information on anything in this policy, please do get in touch with our Team.
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

Our Data Protection Officer is Marcelo Montenegro. He/She can also be contacted using the email address marcelo.montenegro@actionaid.org

Understanding Your Rights
It is important that you understand your legal rights around your personal data and how we may use it. If you would like to discuss or exercise any of these rights, please do get in touch with our Team:
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

Right to be informed This Privacy Policy ensures that you are informed about how we will process your personal data. You might also see messages on some of our forms (or otherwise when we collect personal data from you) that explain why we ask for specific pieces of information from you.

Right of access You have the right to access a copy of your personal data and receive certain information about what the data is and how and why we are processing it. Please note that we will require you to prove your identity before we disclose any information.

Right to rectification If you feel that any of the information that we hold about you is incorrect, do let us know so that we can look into it.

Right to object You have the right to object to the processing that we have outlined in this policy.

Right to erasure / to be forgotten You have the right to request that we delete your information and can discuss this with us at any time.

You should know that there are some circumstances where we may need to keep your details, for example, if it is necessary to comply with a legal obligation on us. If this situation occurs, then we will explain and discuss these circumstances with you.

Right to restrict processing You can request that we restrict processing of your data, as an alternative to deleting it – this means that we will keep the data but stop processing for most purposes. You may want to exercise this right if you feel that the data is inaccurate, that our processing of it is unlawful, whilst we progress a request from you to object to processing, or if we have no further need of the data, but you require us to keep it in relation to the establishment, exercise or defence of a legal claim.

Rights related to automated decision making You have rights to avoid being subject to decisions based solely on automated processing (including profiling) which has a significant effect on you. At ActionAid we do not carry out any such processing.

Right to data portability You have the right to request a copy of certain personal data to have it transferred to another organisation in certain circumstances.

You should know that there are some circumstances where these rights may not apply, but where this is the case we will always explain this to you. Please do contact us if you have any questions or concerns on how we collect and use your personal data, or on your rights, as we are always happy to speak to you.

Why we collect and use personal data
We collect personal data to help us to process your requests, keep in touch with you and to help us to interact with you in the most effective way.

Examples of why we process your personal data include:
• To keep you updated on our work and the impact of your support;
• To make sure you know about events that you can participate in as a campaign supporter;
• To invite you to participate in campaigns;
• To send you fundraising appeals;
• To support you as a volunteer;
• To provide services, products or information you have requested;
• To check with you on how you want us to contact you, and record these preferences;
• To keep notes of conversations that you have with our team, as a reference if you want to revisit the conversation later;
• To notify you of changes to our policies when these affect you;
• To ensure that content from our site is presented in the most effective way for you and your computer;
• If we need to do so to comply with a law, process or regulatory requirement.

The information that we collect:
The personal data that we collect about you will be based on how you interact with us, but we collect the following information from many of our supporters:
• Your name;
• Your email addresses;
• Your gender
• How you would like to hear from us, and when you told us this;
• Your date of birth;
• Your location
• Events that you have taken part in or enquired about.
You can find out more on other information that we may collect and hold below.

Sensitive Data
Some personal data is legally considered to be sensitive, and so is subject to additional safeguards – in data protection law this is known as ”special category” data. Data on the following matters is classed in this way:
• Race;
• Ethnic origin;
• Political opinions;
• Religion or philosophical beliefs;
• Trade union membership;
• Genetics;
• Biometrics (where this is used for identification purposes)
• Health;
• An individual’s sex life; or
• Sexual orientation

Similar protections apply to personal data relating to criminal convictions and offences.

We will only collect or use this type of data if there is a specific reason for doing so. We will always explain this reason to you when we ask for the data and will usually ask for your explicit consent to use it. For example, if you register to run a marathon on our behalf, we will ask to collect and store information on your health for your own protection and to make sure that we can provide you with appropriate facilities and support. We wouldn’t ask for consent if it is information that you have clearly made public, for example, the political views of a political figure or candidate, or your religion if you are working with us because you represent a faith group such as your church.

Age is not legally considered as a special category of data, but we will always treat it sensitively.

You might also want to look at how we collect information about you, which includes occasions where we may work with third parties. You can find this below.

How and When we collect information about you
There are a number of ways that we collect information; most often this will be directly from you, for example, if you register in our website, or directly with one of our ActionAid officers. Whenever we ask for information from you we will explain why we are asking for it (including by reference to this policy), and you will always be given a choice about how we communicate with you.
We do not buy lists of data to use for mass marketing purposes but in some very specific circumstances we will gather data from publicly available sources and may use a third party company to help us do so. You can find more information on this research and details of these sources in our Information on Profiling section.
Sometimes you will also provide data to third parties who then pass it to us with your permission. For example, you can sign in to our website using your Facebook, Google or Twitter account.
You can find out more about this in our section on how we work with third parties.

Anonymous information: Cookies
Like most websites, the ActionAid site uses Cookies; small data files that are downloaded when you use a website, to make the site easier to use. The information that is gathered is totally anonymous to us, but it helps us to see how people use our site, so that we can provide a better user experience.
You can find out all about Cookies in our specific Cookies Policy.

Our legal basis for processing your information
We will always make sure that we consider why we are processing your personal data and identify our legal basis for doing so. Often this will be because you have given us your consent. We may also process your data where we are furthering our legitimate aims and have assessed that the processing is not likely to be too intrusive, or to unduly infringe on your rights and freedoms. In legal terms, this is called the “legitimate interests” basis.
In some cases, we have a legal or statutory duty to process information, and we will always comply with any legal requirement.
We may also process your personal data where it is necessary to carry out the terms of a contract which we have with you (or when we are in the process of forming that contract with you).

Marketing Communications
We will make it easy for you to tell us if you would like to receive “marketing” communications (including fundraising and campaigning communications) from us and hear more about our work. In every communication, we will always make it clear how you can tell us if you choose not to receive further marketing communications, either at all, on certain topics or by certain methods.
If you tell us that you do not want to receive marketing communications, we will remove you from our list and will then not send you any further marketing materials.

Processing your data on the basis of your consent:
There are a number of circumstances where we only process your data on the basis of your consent. Examples of this are:
• To send you marketing by email.
• To send you direct messages through social media.

When you give your consent for us to contact you, we do not treat this as valid indefinitely. However, we understand that our supporters want to continue to hear from us whilst they have an active relationship with us, and for a period afterwards.
• An example of what we mean by an active relationship is when you take a campaigns action for us, such as signing a petition

We will consider your consent to be valid whilst you take these actions, and then for 24 months afterwards, to enable us to keep you up to date with our work and to offer you other ways you might choose to support us. At the end of this time period then we will get in touch with you to re-confirm that you are happy to continue to hear from us.

You can withdraw your consent at any time. If you wish to do so, or have any questions on this, please do just get in touch with our Supporter Contact Team at any time and they’ll be happy to help:
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

The Legitimate Interests basis
We have a duty to the women and girls who we stand with: to promote ourselves and our work; to responsibly raise as much money as possible to further our charitable aims; to update our supporters and the general public on our progress; and to operate in an effective way. We always pursue these interests in a respectful manner, with our supporters at the heart of what we do.

We might further our legitimate interests in the following ways:

• To communicate with you about marketing and fundraising materials or products:
o To send you mail relating to activity that we think you may be interested in (unless you have told us you do not want this). We will always consider how much mail you receive from us, and what the topic is, to ensure that it is appropriate.
o To use social media so that you see ActionAid adverts on your newsfeed. You can find more information on this in our Working with Third Parties section.
• To ensure that we understand our supporters and so can contact them in a way that is relevant for them, and to make sure that we are using our marketing budgets effectively:
o To segment and analyse our data that we hold so that we can understand who our supporters are and contact them about specific activity. For example, to identify which supporters have previously participated in a campaigining activity, such as signing a petition.
• To manage our everyday business needs;
o To work with third party suppliers, where we can make use of their expertise in a specialist field, or where they can provide services at a more cost-effective rate than we could manage internally. You can find more information on this in our Working with third parties section.
o To update our database records to keep them accurate, for example, to amend an address where we receive returned mail.

You have the right to object to us processing your data on the grounds of our legitimate interests.
If you would like us to stop using your data on this basis, please do get in touch with our Supporter Contact Team. You will also see a ‘please do not contact me by post’ box on our communications where we are using the legitimate interest basis, and you can also tick this to ask us to stop sending these.

Administrative Messages
There are some administrative messages that we legally must share with you, which are not affected by how you have told us you would like us to contact you for marketing purposes.

How we work with third parties in processing personal data
At ActionAid, we sometimes work with third parties. It’s important that you understand the circumstances where this might happen, and who we work with.
We never sell or swap your details with any other organisation for their marketing purposes.
These are some examples of how we work with third parties:
• Where we work with other ActionAid offices, subsidiaries, and affiliates
• Where a company sends us data because you have given permission for them to share it, for example, where you sign in to the website using your social media account.
• Where we might use your email address to communicate with you on social media. This won’t be through direct, personal messages, but updates about our work and stories that we think you might be interested in, which might appear in the form of content on your newsfeed.
• Where we legally have to share information.
You can find specific examples of how we work with third parties, as well as details of specific companies who send us data below.

Third Parties who send us data
Some third-party organisations collect data on our behalf, and share it with us, in accordance with their policies and procedures for data protection compliance. Whenever you give your data to any organisation, you should always make yourself aware of their Data Protection and Privacy Policies.
Here are some examples of organisations we currently receive this information from:
Social media platforms: Facebook; Twitter; Google;

Social Media
Using social media is a great way for us to update you on our work, and let you know the difference your support is making. When we use your data in this way we upload a file to Facebook which is ‘locally hashed’; a highly secure encryption method. This file is used to find our supporters on Facebook and Instagram by matching email or phone number data to Facebook and Instagram accounts.

In addition to this, we may use your data to create ‘lookalike’ audiences on Facebook and Instagram. This means that Facebook and Instagram will match interests, behaviour and demographics to create a new audience which closely matches our existing supporters. Using this method is the most efficient way for us to reach more people who are likely to take an interest in our work, meaning we use our funds most effectively.

If you don’t want us to use your data in this way, please get in touch with our Supporter Contact team and we will make sure your details are not included.
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

Where we have a legal requirement
We will always share data where we have a legal requirement to do so.

How long we keep your data for
We want to make sure that we have up to date records for as long as you are actively supporting ActionAid, so for as long as you take actions on our behalf or to engage with us, such as participate in our campaigns. Once you are no longer an active supporter, we will keep your data for a set period of time, which we calculate depending on the information that you originally provided, and why you gave it to us. At the end of this time period, we will remove any personal details from our records of you, to ensure that any information is entirely anonymous.
You can find more detailed information on how long we keep your data for, and other timescales that might apply below.

If you have taken campaigning actions for us, we will keep your data for 5 years. We always report back to supporters who take part in campaigning activities, to update them on the success of that campaign. Some of our campaigns can take up to 5 years to be completed.

What happens at the end of this time period?
At the end of this time period, we will remove your personal details from our records, to ensure that they are entirely anonymous. We keep records on how our supporters have interacted with us, but not of who those supporters are. For example, we want to be able to see how many supporters told us that they took a campaign action or requested information from us. This helps us to understand how to use our resources in the future.

Your right to be forgotten
You have a right to be forgotten, which means that you can ask us to delete your personal details before the end of the time limits we’ve listed in the table above. You should know that there are some circumstances where we may need to keep your details, for example, in order to comply with a legal obligation. If this situation occurs then we will explain and discuss these circumstances with you.
If you would like to discuss or exercise this right, please do get in touch with our Supporter Contact Team.
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

How we keep your information secure
ActionAid takes the care of your data very seriously and we use a combination of organisational and technological security measures to protect your personal information to the highest possible standards. This includes the use of secure servers, firewalls, virus & malware protection, secure socket layer (SSL) encryption and secure file transfer protocol for our work with third parties.
Access to all ActionAid data is protected by complex passwords, including letters, numbers and characters: in some cases more than one method of authentication is used. We make sure that only staff who need to access your personal data can do so. Any member of our staff who has access to your personal data is given training to make sure that they understand the importance of keeping your information safe and secure at all times.
Whilst we take all of the measures that we’ve outlined above, unfortunately, the transmission of information using the internet is not completely secure. Although we will do our best to protect your personal data sent to us this way, we cannot guarantee the security of data transmitted to our site.
In the extremely unlikely event that we experience a data breach, our Data Protection Officer would immediately work with our Information Security Officer and the Information Commissioner’s Office if necessary.

Where we keep your information and when it might be transferred outside of Europe
ActionAid is aware that countries outside of the European Economic Area have differing standards of data privacy.
Some countries (but not every country in which we work) have been determined by the European Commission to have “adequate” standards of data protection compliance. Organisations we work with who process data in the USA have verified that their data processing standards meet the standards in the EU-US Privacy Shield, which sets out clear safeguards and transparency responsibilities for US-based organisations processing data from EU citizens, or that they otherwise have proper safeguards in place.

How to control the marketing that we send you
We want to make sure that we keep in touch with you when, and how you want. Every marketing communication that we send will outline how you can update us on your preferences, and all of our emails have an Unsubscribe link.

You are also always welcome to get in touch with our Supporter Contact Team in any of the following ways:
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

We will ensure that our records are updated as soon as possible once we receive your instructions. For our postal communications, it can take up to 28 days for any change to take full effect because of the production times for our campaigns, but in most cases we would expect the change to be effective much more quickly. If you do receive any mail within this 28-day window, you can simply recycle it.

Information on profiling
We undertake a number of different activities that can be known as “profiling”. We use these to help us to understand how best to manage our resources, so that we can understand your interests or your capacity to give, and give you a truly tailored experience.
The most common form of profiling that we undertake is to segment and analyse our supporter data. In practice this means sorting our data to build reports to understand the characteristics of our supporters, and how they choose to interact with us. We also use segmentation to identify particular audiences for some of our communications: for example, to send information on specific campaigning actions to supporters who are located in certain countries or regions. One part of segmentation is propensity modelling, where we look at different aspects of the data that we hold to determine how likely a supporter is to respond to communications that we send. Based on what you’ve done before, we will tailor any ask we make to you.
We also use profiling to help us to understand wealthy or influential individuals who are happy to support ActionAid to a greater extent than is possible for most people. We will research their philanthropic interests so that we can reach out to them and invite them into a dialogue about the ways in which they might help.
You can find more about this type of profiling below.
If you do not wish us to use your details in this way, please contact our Supporter Contact Team.
Email: contact@womenslabour.org
Telephone: +27 11 731 4500
Post: Postnet Suite 248, Private Bag X31, Saxonwold 2132, Johannesburg, South Africa

Changes to this Policy
From time to time, we may make changes to this Policy and you will always be able to see here when it was last updated. If we make significant changes, such as in how or why we process your personal data, we will also publicise these changes on our website or may contact you directly with more information.
Please do revisit this policy each time you consider giving your personal data to ActionAid.

The last significant updates to this policy were in April 2019.