1. Important information and who we are
Reprieve U.S. is a 501(c)(3) charitable organization with the EIN 72-1514282. To contact us, please email [email protected] or mail P.O. Box 792325, New Orleans, LA.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where identifying information has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact data includes billing address, delivery address, email address and telephone numbers and any exchanges such as emails, telephone conversations or other electronic communications with our employees and other staff members.
- Financial data includes bank account and payment card details, as well as information required to comply with our anti-money laundering obligations.
- Transaction data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile data includes donations made by you, your interests, information about your professional role and background, preferences, feedback, survey responses and messages of support to our beneficiaries.
- Usage data includes information about how you use our website, products and services.
- Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- CCTV footage recorded if you visit our premises.
- Recruitment data provided to us in your CV and covering letter, as well as the information you have provided on your application form, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, criminal conviction data, , and any information provided to us during an interview.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data could be derived from your personal data but it is not considered personal data in law as this data will not directly or indirectly reveal your identity.
We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview. We will also use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. 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 either with your explicit consent or only to the extent permitted by applicable law.
If you fail to provide certain information when requested during our recruitment process, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for a role and you fail to provide us with relevant details, we will not be able to take your application further.
3. How is your data collected?
We use different methods to collect data from and about you, including through:
Direct interactions. When you correspond with us by post, phone, email or otherwise.
Third parties. We will receive personal data about you from various third parties:
- 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 sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our organisation and comply with our legal and regulatory obligations.
- For recruitment purposes, from your referees, recruitment agencies, background check providers, credit references agencies and the Disclosure and Barring Service.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- where we need to comply with a legal obligation; or
- where we have your consent to do so.
We may use your information for the following purposes:
- 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;
- for recruitment purposes to assess your skills, qualifications, and suitability for a role, carry out background and reference checks (where applicable), communicate with you about the recruitment process and keep records related to our hiring processes;
- 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;
- if you have given your consent, to allow selected third parties to contact you about their services or issues which may be of interest to you; and
- to analyse and better understand the composition and interests of our supporter base.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
6. Disclosures of your personal data
We may share your personal data with the parties set out below:
- other members of the Reprieve group;
- your colleagues within the organisation that you represent;
- 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;
- 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;
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International transfers
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to your data by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission, which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request from us by contacting us.
10. Your legal rights
You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Request consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).