Your privacy is important to the Coalition for Global Prosperity (CGP). This privacy notice provides information about the different types of personal information that we collect and the ways in which we use it. If you have any questions please contact us using the contact details included at clause 13.
1. Who We Are
The Coalition for Global Prosperity (CGP) is a UK registered company (registered under number 10894509) at registered address The Rain Gods, 76 Vincent Square, London, SW1P 2PD, UK. To fulfil our mission, we collect data on and bring together political, military, business and faith leaders who believe that an effective development budget, alongside an active diplomatic and defence strategy, keeps Britain at the forefront of saving lives, alleviating poverty and bringing freedom, security and prosperity to those who need it most.
Where applicable, CGP complies with EU data protection law when collecting, using, storing and otherwise processing your personal data (as defined in the EU Data Protection Regulation ((EU) 2016/679) (“GDPR”)). Below is overview of how CGP complies with EU data protection law.
2. When do we collect personal information about you?
We may hold personal information relating to you from a number of sources and will collect personal information about you:
a. When you give it to us directly
For example, personal information that you submit by contacting us or any personal information that you share with us when you communicate with us in person, by email, phone or post.
b. When we obtain it indirectly
Your personal information may be shared with us by third parties. To the extent that we have not done so already, we will notify you when we receive personal information about you from them, and tell you how and why we intend to use that personal information.
c. When it is publicly available
Your personal information may be available to us from external publicly available sources. This may include information available on Companies House, Charity Commission and other charity registers, the UK Parliament website, reputable media articles, publications and company websites and professional networking sites such as LinkedIn. Depending on your privacy settings for social media services, we may access information from those accounts or services, including from Facebook, Instagram, Twitter and YouTube.
d. When you visit our website
3.What personal information do we use?
We may collect, store and otherwise process personal information depending on how you interact with us including but not limited to:
Your name and contact details, including email address, postal address, telephone number and social media identity;
Information about your role in your organisation and your professional qualifications;
Your communication preferences;
Any other personal information which you choose to share with us.
Special categories of data
Data protection law recognises certain categories of personal information as sensitive and therefore requiring more protection. These categories of data include information about your race or ethnic origins, political opinions, religious beliefs and health data.
In certain situations, CGP may collect and/or use special categories of data. We will only process these special categories of data if there is a valid reason for doing so and where the law allows us to do so. Please see section 5 below for the bases we rely on.
4. Reason for Processing
By sharing your personal data with us, we count you as a “member” and may send you emails to provide you with information about our activities and updates about our work, services, activities or publication. The reason we process your personal data, keeping it safe on our systems and servers, contacting you with opportunities to take action, is to fulfil our mission to increase understanding of the impact British-funded development makes in creating a safer, healthier and more prosperous world for everyone. We will never sell or profit from your personal data and you can unsubscribe at any time.
5. Lawful processing
We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:
1. Legitimate interests
Where applicable law allows us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights.
We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks e.g. when we receive external emails we will scan such emails for any threats. We will also rely on the legitimate interest ground to communicate with you in most instances.
Where we ask for your consent for our use of your personal information for a specific purpose. You always have the right to withdraw your consent.
3. Legal obligation
Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject.
4. Contractual relationship
Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract). For instance, if you are one of our suppliers under contract.
When we collect and use special categories of data, we also rely on the following bases:
Personal information that has been manifestly made public by the individual e.g. for instance, where a politician has a clear public affiliation with a political party.
Processing in the course of our legitimate activities with appropriate safeguards on condition that the processing relates to persons who have regular contact with us in connection with our purposes and their special category data is not disclosed outside the CPG without their consent.
Where we have obtained your explicit consent to the use of your special category data. You always have the right to withdraw your consent.
If we consider you may be interested to hear about our work, we may analyse your personal information to create a record of your interests and preferences, to allow us to ensure that communications (e.g. by post, telephone, email, text or social media) and invitations to our events are appropriate and relevant. For instance, we look at MPs voting records and at the activities of international aid campaigners to see if those individuals would be interested to learn about our activities. We may also identify particular politicians in the UK Parliament or business leaders who have shown an interest in aid work in a specific country or countries in order to contact such individuals with information about our work.
If you would prefer us not to use your personal information for research please let us know by using the contact details included at clause 13.
7. Do we share your personal information?
Except where set out in this privacy notice, CGP will never sell, rent or lease your personal information to others. We do not share your personal information with third parties for marketing purposes.
We may disclose your personal information to selected third party processors (such as agents or sub-contractors) for the purposes outlined at clause 4. For instance, we use cloud providers to store personal information on our behalf. The third party in question will be required to use any personal information they receive in accordance with our instructions. For instance we may use a third party like Eventbrite (www.eventbrite.co.uk) as our processor to handle the ticketing at an event that we organise.
We reserve the right to disclose your personal information to third parties:
in the event that we buy or sell any business or assets, in which case we will disclose your personal information to the prospective buyer or seller or such business or assets;
if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
with our professional advisors e.g. lawyers, where necessary to protect our interests;
for auditing purposes e.g. finance audits where we employ chartered accountants;
if we are under any legal or regulatory obligation to do so; and
in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise or defend our legal rights.
8. International Data Transfers
As we sometimes use third parties to process personal information, it is possible that personal information we collect from you will be transferred to and stored in a location outside the UK or the European Economic Area (EEA).
Please note that certain countries outside of the UK or EEA have a lower standard of protection for personal information, including lower security protections. Where your personal information is transferred, stored, and/or otherwise processed outside the UK or EEA in a country which does not offer an equivalent standard of protection to the UK or EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards designed to protect your personal information. For instance we use cloud providers to store personal information who have servers in the US and are signed up to the Privacy Shield. If you have any questions about the transfer of your personal information, please contact us using the details at clause 13.
9. How long do we keep your personal information?
Unless still required in connection with the purpose for which it was collected and/or processed, we will generally remove your personal information from our records six years after the date that it was collected. However, before this date: (i) if your personal information is no longer required in connection with such purpose(s); (ii) we are no longer lawfully entitled to process it; or (iii) you validly exercise the rights of erasure under clause 10, we will remove it from our records.
10. Your rights and preferences
CGP may contact you by post and by telephone, email, text, social media or other electronic means depending on what the law allows and on your communication preferences.
Where we rely on your consent to use your personal information, you have the right to withdraw your consent.
When we use your personal information you have the right to:
Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we are able to confirm your identity, we will provide you with this personal information.
Request that we erase the personal information we hold about you, as far as we are legally required to do so.
Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
Object to the processing of your personal information where we: (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for statistical purposes.
Ask for the provision of your personal information in a machine-readable format (the data portability right) to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are party; and in either instance, we are processing it using automated means.
Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
If you decide you do not want to receive any further emails from CGP, please tell us and we will remove you from our mailing list. At any point you can request to unsubscribe from CGP’s mailing by contacting us using the details listed at clause 13.
Please note that where you ask us to delete your personal information we will maintain a skeleton record comprising your name and contact details to ensure that we do not inadvertently contact you in the future.
Please note that you also have the right to lodge a complaint with the Information Commissioner’s Office at www.ico.org.uk/concerns.
11. Other websites
CGP is not responsible for the privacy practices or the content of linked web sites. Please review the privacy notices of such websites.
12. Updating this privacy notice
CGP may update this privacy notice by posting a new version on this website. If we update this privacy notice in a way that significantly changes how we use your personal information, we will bring these changes to your attention. Otherwise, we recommend that you periodically review this privacy notice to be aware of any other revisions.
13. How to contact us
If you have any questions about how we use your personal information and how we comply with our responsibilities, please contact us as follows:
Email: firstname.lastname@example.org with “Privacy Concern” in the subject line of the email.
Telephone: 00 44 (0)203 917 1680
Post: Privacy Concern, The Coalition For Global Prosperity, The Rain Gods, 76 Vincent Square, London, SW1P 2PD.
Dated: [January 2019]