Compassion in World Farming Privacy and Security Policy (last reviewed 10 June 2024)

1. Introduction

At Compassion in World Farming International (Compassion) we are committed to protecting the privacy of your personal data. Any personal data that you share with us will be kept safe and secure. We want to be clear about how and when we collect data from you and how and why we use it. This Privacy Policy explains in detail the types of data we may collect about you and how we will use and store your personal data.

We would suggest that you read this Privacy Policy carefully to ensure that you are well informed about and understand our practices. We may from time to time update this notice, so please do take the time to check it regularly. If we are in regular contact with you, and there are significant updates, we will inform you.

2. Who is Compassion in World Farming International?

Compassion in World Farming International is a registered charity in England and Wales (registered charity number 1095050) and a company limited by guarantee in England and Wales (registered company number 4590804).

Compassion in World Farming is based at: River Court, Mill Lane, Godalming GU7 1EZ, UK.

Compassion in World Farming has also founded separate charitable entities in a number of other countries to enable us to more effectively drive our programme of work. All of these are founded, controlled and managed by and under the umbrella of Compassion in World Farming International.

The lead Data Protection Authority for Compassion in World Farming is the Information Commissioner’s Office, Wycliffe House, Walter Lane, Wilmslow, Cheshire SK9 5AF, UK.

3. What Personal Data Do We Collect?

The type of personal information that we could collect about you includes:

• Name & Title
• Gender
• Date of birth
• Postal address
• Phone number
• Email address
• Social Media profiles
• IP Address
• Financial details relevant to donations
• Status as a UK taxpayer (we use this for Gift Aid administration only)
• How you heard about us
• Details about the campaigns that you choose to support
• Details of your donations or other ways you support us e.g. volunteering, leaving a gift in your Will
• Photographs or digital images (e.g. in photos taken at Compassion events)
• How we communicate with you and any preferences you may have
• Details of any contact that we may have with you
• Relationships with other people on our database e.g. members of the same household

4. Cookies

Cookies are small text files on your computer, smart phone, tablet or other device. They are made by your web-browser when you visit a website. Every time you go back to that website, your browser will send the cookie file back to the website’s server. Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience.

Cookies help Compassion identify which bits of our website people are using, and help us to improve the user experience. Information supplied in cookies also allows us to measure the effectiveness of online marketing campaigns for Compassion so that we can become more efficient.

A cookie, by itself, can’t be used to identify you; we cannot and do not link it with personal information we hold about you (e.g. your name, address, email address). For more information about how our website uses cookies click here.

5. How and Why Do We Use Your Personal Data?

We use your data for the following purposes:

• To respond to any correspondence you enter into with us.
• To manage and process your donations and/or any other way you support us, to keep a record of our relationship.
• To keep you updated on the work that we are doing and tell you how your donations are being used.
• To ensure we act on any requests you make about how we do/don’t contact you.
• For campaigning and fundraising purposes (see Section 8 for more details).
• Where you sign a petition or otherwise take action, your details maybe sent on to the campaign target, or an email be sent on your behalf, as indicated when you take action.
• To help us analyse and understand our audience. We use Google Analytics and Google Signals to collect information about your online behaviour which allows us to make improvements to our campaigning and fundraising and our service to supporters and other stakeholders. You can control what Google records and which ads it shows you by visiting https://myadcenter.google.com.
• If you opt in, third parties, including Meta, may use cookies, web beacons, and other storage technologies to collect or receive information from this website and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting. Some mechanisms for exercising such choice can be found at https://www.aboutads.info/choices and https://www.youronlinechoices.eu/ or by searching online.
• For research and analysis, to help us to grow the movement against factory farming by finding new audiences and like-minded persons who have similar interests and characteristics. Where research requires your direct involvement, participation will always be optional.
• To allow us to verify your identity if we are required to do so, to be able to comply with laws and regulations, to protect our organisation and your personal data from fraudulent activities.
• For legacy administration purposes (where you are involved, for example as an Executor, in the administration of an Estate that includes a bequest to Compassion). For more information click here.
• We use publicly available information, and on occasion third party services (for example, research and screening providers), to help us identify individuals who may be capable of supporting Compassion at a higher level financially. Once identified, we may collect additional, publicly available, information to supplement a profile that will help us contact relevant people in the most appropriate way.
  
  The additional, publicly available, information we may review includes, but is not limited to, internet searches, charitable giving history, news sites, social networks such as LinkedIn, public registers such as Companies House and information pertaining to shareholdings, remuneration, directorships and professional networks. The legal basis that we use when processing information in this way is legitimate interest.
• To comply with our legal obligations and to share data with law enforcement agencies if required to do so.

6. What are the Legal Bases that We Use to Process Your Personal Data?

Consent: We use consent to send you details on fundraising and campaigning by email and text. As is your right, you can withdraw your consent at any time. All our fundraising and campaigning emails include an unsubscribe link.

Where you sign a petition or otherwise take action, we also use consent to send your details on to the campaign target, or to send an email on your behalf, as indicated when you take action.

Performance of a Contract: We would need to process your information if you enter into a contract with us – for example, to provide your goods or services when you purchase Christmas cards or raffle tickets.

Legal Obligation: We need to retain and use certain records to uphold the law, for tax purposes such as Gift Aid administration, to satisfy legal, regulatory and compliance obligations.

Legitimate Interest: We may collect and use data where this is reasonably necessary for our legitimate interests. Such processing will be fair, balanced and will not unduly impact on your rights as an individual. For example, there may be times when it is not practical or appropriate to ask for your consent and where we are confident this will not impact on your rights.

Our legitimate interests include campaigning and fundraising to support our charitable objectives. These objectives are to end factory farming and to pioneer abundant sustainable food that is free from animal cruelty. In support of these legitimate interests we may collect or process personal data in the following ways:

• For administration and governance activities related to Compassion and its entities;
• To record and respond to any correspondence you enter into with us;
• To send you campaigning and fundraising materials by post (you can opt-out of these communications at any time);
• To contact, by email or phone, some very specific audiences relevant to our work (e.g. employees/representatives of food companies, Trusts & Foundations);
• To record and act on your campaigning and fundraising communication preferences;
• To administer donations and other ways you support us, and update you on how your donations are used;
• To thank you for your donations;
• For research and analysis to help us understand our audience, improve our campaigning, fundraising and service to supporters, and grow the movement against factory farming;
• In certain circumstances, to undertake research on individuals before we proactively contact them;
• To administer Estates and gifts in Wills where Compassion is an Executor or beneficiary;
• To better our efforts against fraud.

7. When and How Do We Collect Your Data?

We collect your data when you contact us directly, or interact with us via a third party, to:

• Make an enquiry to us
• Sign up to receive emails
• Take part in a campaign
• Make a donation
• Make a purchase from us (e.g. raffle tickets or Christmas cards)
• Enquire about or advise us of a gift left in your Will
• Engage with us on social media
• Volunteer for us by fundraising or campaigning
• Attend an event
• Connect with us online

In certain circumstances, we will conduct our own research and gather information that is available within the public domain. There is a certain amount of publicly available information from sources such as social media, published articles and news channels. We would use this information to improve our communications and fundraising approaches.

When you are engaging with Compassion through a third party, please also check their Privacy Policy.

8. Marketing (Campaigning and Fundraising)

As a charity we communicate with individuals to encourage participation in our campaigns and to raise money to fund our work. We send campaigning and fundraising communications in a variety of ways:

BY EMAIL, SMS & PHONE: We will only communicate for campaigning and fundraising purposes via these channels if you have given us your consent for us to do so. As is your right you can withdraw your consent for any method of communication at any time. All our campaigning and fundraising emails include an unsubscribe link, and you can also contact us via the details in section 14.

BY POST: We send campaigning and fundraising information in the post on the basis of our legitimate interests. You will not receive mail from us if you have specifically requested not to. If you would prefer NOT to receive communications from us in the post, you can let us know via the form included with any of our letters, or by contacting us directly (see section 14). Please note your preferences may not be updated immediately, but we will aim to process your request within 28 days.

BY SOCIAL MEDIAL ADVERTSING: If you are a social media user, we may use tools provided by the leading social media platforms, such as Meta, to reach individuals likely to engage with and respond to our campaigns. If you have participated in our campaigns and haven’t opted out, we may contact you via social media advertising. We may also use your profile anonymously, and in conjunction with many other profiles, to identify audiences that are also likely to engage with our campaigns and thereby help us achieve our charitable mission and objectives.

In order to improve the performance of our campaigns, we use conversion tracking to measure the outcome and improve the return on investment of Meta Ads, for example, by reporting on the actions that audiences take after viewing those ads. We add a tracking pixel or cookie to our website and then track these conversions back to ads we are running on Meta. No personal information is contained in or collected as a result of using pixels. To opt out of remarketing pixels and technologies, visit Meta’s ad preferences page.

9. How Long Do we Keep Your Data?

Your data is retained for as long as is necessary for the purpose that it was collected for. We are obliged to keep certain data to fulfil certain legal obligations and matters of record keeping e.g. financial records which we are required to keep for 6 years. Any data that is retained is minimised to ensure that we are keeping only that which is required. We will securely delete all data when it is no longer required.

10. Sharing Your Data

We will not sell or swap your personal data; and it is Compassion’s policy never to pass on your personal details to other organisations for their use, except when we have your express permission to do so or when the law requires it.

At Compassion we work with contracted suppliers and where applicable we will share your information. Your data will only be used under our explicit instructions and only for the purposes we specify, to carry out necessary operations for us, such as sending letters or processing financial transactions. All of our suppliers are trusted and have signed agreements with us, each of them agreeing to respect the security of your personal data. We review the policies and procedures of all third party suppliers to ensure we are satisfied with the level of their compliance with data protection laws, and that their systems are secure. In the event that we stop using a supplier, any of your data that they hold will be securely deleted.

There may be a need to disclose your personal data upon request to regulatory and government bodies as well as law enforcement agencies.

11. Children & Vulnerable Individuals

Protecting children

Compassion in World Farming is committed to protecting the privacy of children. Although we are not responsible for determining the age of website visitors, our websites are primarily designed and intended for use by people ages 16 and over. If you are younger than this you should review the terms of this Privacy Policy with your parent or guardian to make sure that you both understand them. No information should be submitted to our website, or communication entered into with Compassion, by children without parental consent. All applicable laws are followed with respect to data collection from children.

NB – Parents and Guardians should be aware that, owing to the nature of our work, images (e.g. the carefully considered use of photographs of dead, dying or otherwise suffering animals) on Compassion in World Farming websites or used in our communications may be considered unsuitable for children.

Protecting supporters in vulnerable circumstances

We’re committed to offering the very best standards of supporter care and protecting our supporters’ privacy, dignity and wellbeing. If we believe that a supporter may be in vulnerable circumstances that could affect their capacity to make a decision about supporting us financially, or in other ways, we will do all we can to protect that supporter. See our policy for assisting supporters in vulnerable circumstances.

12. Your Rights

We want to ensure that your rights are upheld when we use and store the information you give to us.

Accessing the information that we hold on you – Subject Access Request

You can request a copy of the information that we have on you. This will be free of charge in most cases. Please let us have details of the personal data you want to see and proof of your identity. You can send an email to access@ciwf.org or write to us at The Data Manager, Supporter Engagement Team, Compassion in World Farming, River Court, Mill Lane, Godalming, GU7 1EZ, UK

Correcting the information that we hold on you

If your personal information is out of date or is incorrect, we will correct it for you on request.

Erasing your personal data from our records

Simply let us know and we will delete your details from our database. This will mean that all records of you will be erased. Please note, for legal reasons we may be required to keep certain information e.g. in the case of financial details, where we are duty bound to keep these on file for 6 years.

Opting-out of all marketing (campaigning and fundraising) communications

We will stop all campaigning and fundraising communications, or communications via a specific channel, on request. If you have given us consent you can withdraw your consent at any time. We aim to update your record within 28 days.

Restricting the processing that we do

If you do not wish your information to be used for the purposes of screening or profiling, let us know. We aim to update your record within 28 days.

Using your information elsewhere

On request, we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format.

If you feel that your data is not being managed in an appropriate manner, you can raise a concern with the Information Commissioner’s Office. You can also find general information from the ICO here: https://ico.org.uk/for-the-public

13. How We Keep Your Data Safe?

As an organisation we are committed to keeping your data safe. Your personal data is stored on a secure network and we regularly monitor our systems for vulnerabilities. Access to your data is closely monitored; it is only accessible by staff, volunteers and contractors who are bound by appropriate policies and procedures to protect your information.

We will review the policies and procedures of any third parties that we deal with, and ensure they are compliant with data protection laws.

14. Your Data Manager Contact at Compassion in World Farming

If you wish to contact Compassion in World Farming in respect of our Privacy Policy or data management, e.g. gaining access to your data, or having a correction made, please contact our Data Manager by the following means:

By Email:

• To unsubscribe from receiving our emails, please click on the ‘unsubscribe’ link at the bottom of any email we send to you, or contact supporters@ciwf.org
• To request access to the personal data we hold about you: access@ciwf.org.uk
• For all other enquiries: supporters@ciwf.org

By Post: The Data Manager, Supporter Engagement Team, Compassion in World Farming, River Court, Mill Lane, Godalming, GU7 1EZ, UK

By Phone: +44 (0)1483 521 953

If you are requesting access to the personal data we hold about you, please provide details of the personal data you want to see and proof of your identity.

If you wish to contact the regulator (Information Commissioner’s Office) you can do so at: https://ico.org.uk/concerns

15. Transferring Your Data

Compassion in World Farming International operates a network across Europe and has an office in the USA. All of our data is stored with the EU and Canada. By submitting your data to Compassion you are agreeing to this transfer, storing and processing. There are some instances where your data may be shared across our network; however data from the EU would not be processed within the USA. If you are interacting with Compassion USA, your data will be transferred, processed and stored within our secure servers in the EU and Canada.