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Media Defence Privacy Policy

 

How we respect privacy when we deal with personal information we collect

This Privacy Policy applies to information Media Legal Defence Initiative, trading as Media Defence, collects about individuals who interact with our organisation. It explains what personal information we collect and how we use it.

For the purposes of the UK GDPR / Data Protection Act 1998, Media Defence is registered as a data controller with the Information Commissioner in the United Kingdom.

If you have any comments, questions or requests about this notice or regarding the processing of your personal data, feel free to contact us at info@mediadefence.org.

Consent to use of your data

By proceeding to use our website, you consent that Media Defence may process the personal data (including sensitive personal data) that we collect from you in accordance with this Privacy Policy. In particular, we will use information that we hold about you for the purposes and in the manner outlined below.

Personal data that we process

The type and amount of information we collect depends on how you use the website and how you interact with our organisation.

The type and amount of information we collect depends on how you use the website and how you interact with our organisation.

We collect three types of information:

  1. Anonymous data that is automatically collected from all visitors to our website.
  2. Personal data that visitors voluntarily submit so that we can provide you with a service.
  3. Financial data that visitors voluntarily submit to receive a grant or make a donation.

 

  1. Anonymous Data

You can access all pages on the website without telling us who you are and without revealing any personal information. We collect some information when you visit our website, but this does not allow us to identify you personally.

See section on cookies and website tracking in this document for more information.

  1. Personal Data (including sensitive personal data)

We may collect information directly from you which personally identifies you (name, address, email etc) when you participate in the following activities:

  • making a donation to support Media Defence;
  • contacting us to seek information or advice;
  • applying for and receiving a grant;
  • applying to participate in training or other event or activity; or
  • subscribing to an email list to receive more information about our work and how you can get involved or donate.

Criminal offence data

Personal data relating to criminal convictions and offences, or related security measures will be collected from you if you apply for a grant or for technical legal support in your case, and if the criminal offence data is relevant to your application. For example, if you are applying for financial and/or legal support to defend or appeal a criminal or civil case against you, we will ask for information about that case. We will not collect data relating to other criminal convictions and offences that are not relevant to the case for which you are applying to us for support. You may decline to provide this information; however, this may make it impossible for us to continue to deliver legal or financial support to you.

Special category data

We may collect special category data (for example information about your race, ethnic origin, politics, religion, trade union membership, health, sex life, sexual orientation), where it is relevant to the legal case for which you have applied to us for support. We will only request this data if it is relevant to the legal case we are supporting you in, for example, if a component of your case is related to discrimination based on one or more of the special categories listed above, we will ask you for information about it. You may decline to provide this information; however, this may make it impossible for us to continue to deliver legal or financial support to you.

  1. Financial Data

We collect your financial data for the purpose of fulfilling our contractual duties to you or to others – i.e. when we need this data to process a grant to you or a donation from you.

When you make a one-off online donation to Media Defence, your payment details are processed by the secure payment gateway, Virgin Money Giving. When you make a payment, Virgin Money Giving asks for your name, address, phone, email address, and credit/debit card information. This information is used to process your payment and to verify credit/debit card data. Your credit/debit card details will only be retained by Virgin Money Giving. In the case of a suspected fraudulent transaction, card details may be disclosed to Media Defence for the sole purpose of performing further checks. More information about how Virgin Money Giving will use your data is here: https://uk.virginmoneygiving.com/giving/terms/privacy-policy.jsp.

When Media Defence pays a grant to you, we will ask you for financial information as may be necessary for the purposes of processing the grant. This information will be shared with Media Defence’s banks and financial service providers (for international payments) so that they can carry out the transfer. These institutions may use information about you for the purpose of processing the payment, and for preventing, detecting and prosecuting financial crime and the funding of terrorism. More information about the banks and financial service providers we use, and how they will use your data is available here: https://www.triodos.co.uk/en/about-triodos/important-information/privacy-statement/

https://www.barclays.co.uk/content/dam/documents/personal/important-information/Barclays-Data-Privacy-Notice-Personal.pdf

Where we have no contractual basis for retaining financial data (i.e. when transactions have been processed) we retain only that financial data which is required to satisfy our obligations to maintain accurate financial and tax records.

The following table explains the types of data we collect and the legal basis, under current data protection legislation, on which this data is processed. The information you provide will not be sold or rented nor will it be shared with third parties unless we have your permission or are required to disclose the information by law.

PurposeData (key elements)Basis
Enquiring about our organisation and its workName, email, messageLegitimate interests – it is necessary for us to read and store your message so that we can respond in the way that you would expect.
Subscribing to email updates about our workName, emailConsent – you have given your active consent. You can withdraw consent at any time and there will always be an unsubscribe option in the communications we send to you.
Making a donation

(Donations made through our website are processed through a third party: Virgin Money Giving. Their privacy policy is available here.

Name, email, address, payment information

 

Legitimate interests – this information is necessary for us to fulfil your intention of donating money and your expectation of receiving a confirmation message.

Legal obligation – where we are required by law to process your information, e.g. to verify your identity.

Website functionalityWebsite activity collected through cookies. The information we collect includes the browsers visitors’ use, what time they visit and which pages are most viewed.

We do not link any of this anonymous data with any personal data that you may provide to us.

Legitimate interests – it is necessary for us to store a small amount of information, usually through cookies, to deliver functionality that you would expect and to enable us to evaluate the site and work to improve it.

 

Applying for a grant from us

(Grant applications are processed through a third party: Odoo. Their privacy policy is available here.

Your case details and history (name, address, criminal offence data)

Financial information (bank details, name, address and telephone number)

 

 

Legitimate interests – this information is necessary for us to provide legal and financial support to you. With your agreement we may also share your legal/case information with external lawyers who act in your case.

Contract – if we are providing legal and/or financial support to you, we will sign a contract with you detailing the support we will give. To process your grant application and to prepare the contract if your application is successful, we will require information from you related to your case. If we are making a payment to you, we will have signed a contract with you setting out the conditions of the grant, the amount to be paid and to whom and requesting your financial information to arrange payment.

Legal obligation – Payment processing and fraud: Where submitted, your bank details may be disclosed to banks or relevant financial institutions to arrange payments. In the case of a suspected fraudulent transaction, your details may be further disclosed for the sole purpose of performing further checks.

Applying to participate in training or other event or activity

 

Your personal and professional details and history (this may include your name, address, email, telephone number, nationality, education /employment history)

If your application is successful, we will also request copies of identification and travel documents and next of kin contact details in order for us to facilitate your travel (this may include a copy of your passport, visa, medical insurance certificate).

Legitimate interests – This information is necessary for us to process your application and if you are successful, to facilitate your travel and/or participation in the training or event. Where arranging international travel and/or residential accommodation, we may also share your details with third parties, for example with a travel agent, airline or hotel.
Providing feedback on services you have received or activities you have participated in (monitoring and evaluation data)Your feedback on the services you received from us or activities you participated in.Legitimate interests – It is necessary for us to collect feedback from our beneficiaries and service users to enable us to evaluate our activities and work to improve them.

Feedback collected from you on services you have received or activities you have participated in (monitoring and evaluation data) is processed anonymously unless consent is given for non – anonymised processing.

Express consent – When collecting non-anonymised data, for example to feature your case in a public report, we will seek you express consent.

 

How we use your data

We will only use your data in connection with the purposes for which it is submitted, or as otherwise explained on our website or as necessary for us to comply with our legal obligations, as set out in the table above and as set out in any separate contractual document with you.

For example, we may use your personal information to:

  • Reply to enquiries you send to us;
  • Provide financial and technical legal support to you if you have applied to us for a grant;
  • Process your application and/or facilitate your participation in a training or other event or activity organised by Media Defence, including collecting feedback from you after the event;
  • Handle donations that you initiate; or
  • Where you have specifically agreed to this, send you marketing communications by email relating to our work which we think may be of interest to you.

For what purposes will your data be processed?

  • If you are accessing our financial and technical grant making service, your data will be used only for this purpose;
  • If you are making a donation or an enquiry, we will contact you about this specific action and about your future support for Media Defence;
  • If you are applying to participate in training or other event or activity, your data will be used only for this purpose; and
  • If you have participated in a training or event, or received support from us, we will request feedback on your experience to help us learn from and improve the services that we offer.

When we share your data

We will only pass your data to third parties in the following circumstances:

  • Where you have provided your explicit consent for us to pass data to a named third party;
  • To other organisations who provide a service to us or you (e.g. legal firms or individual lawyers working on your case, banks, payment processing companies, travel agents);
  • To our donors as part of our reporting requirements, unless otherwise agreed or we have been informed that doing so would undermine a case or the safety of any individuals involved.
  • Where we are using a third party purely for the purposes of processing data on our behalf and that third party has appropriate safeguards in place that fulfil our legal obligations in relation to the use of third-party data processors; or
  • Where we are required to do so by law.

How we store your data

Your personal data will be kept by Media Defence in a secure environment. We take appropriate precautions to protect all personal information we store, including using encryption and monitoring access to our secure networks and systems.

Despite our best efforts to protect your personal information electronically, the security of information sent over the internet cannot be guaranteed and may be illegally intercepted or changed after it has been sent. Media Defence cannot accept liability for this if this happens.

How long we keep your data

We take the principles of data minimisation and removal seriously. We only ever ask for the minimum amount of data for the associated purpose and we will only retain your personal information for as long as is necessary for the purposes outlined above.

The length of time each category of data will be retained will vary depending on the purpose for which it was obtained and its nature, and in line with any statutory requirements. After this point the data will either be deleted, or we may retain a secure anonymised record for research and analytical purposes.

We remove personal data from our systems once it is no longer required, in line with our guidelines on how long important information must remain accessible for future use or reference, as well as when and how the data can be destroyed when it is no longer needed.

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Where data is collected on the basis of consent, we will seek renewal of consent at least every three years.

Rights you have over your data

You have a range of rights over your data, which include the following:

  • Where data processing is based on consent, you may revoke this consent at any time and we will make it as easy as possible for you to do this (for example by putting ‘unsubscribe’ links at the bottom of all our marketing emails);
  • You have the right to ask for rectification and/or deletion of your information;
  • You have the right to access your information; and
  • You have the right to lodge a complaint with the Information Commissioner if you feel your rights have been infringed.

More information about your legal rights ca be found on the Information Commissioner’s website here: https://ico.org.uk.

If you would like to access the rights listed above, or any other legal rights you have over your data under current legislation, please get in touch with us.

Please note that relying on some of these rights, such as the right to deleting your data, will make it impossible for us to continue to deliver some services to you. However, where possible we will always try to allow the maximum access to your rights while continuing to deliver as many services to you as possible.

Cookies & usage tracking

A cookie is a small file of letters and numbers that is downloaded on to your computer when you visit a website. Cookies are used by many websites and can do a number of things, e.g. remembering your preferences and counting the number of people looking at a website.

We use cookies to collect anonymous information about how people use our website. We use Google Analytics for this purpose. Google Analytics generates statistical and other information about website usage by means of cookies, which are stored on users’ computers. The information collected by Google Analytics about usage of our website is not personally identifiable. The data is collected anonymously, stored by Google and used by us to create reports about website usage. Google’s privacy policy is available at http://www.google.com/privacypolicy.html.

Note about Internet service providers

Media Defence reminds visitors that most Internet service providers maintain records of all URLs visited by their customers. Visitors should contact their Internet Service Provider for more information.

Modifications

We may modify this Privacy Policy from time to time and will publish the most current version on our website. Please visit this website section periodically to keep up to date with the changes in our notice. If a modification meaningfully reduces your rights, we’ll notify people whose personal data we hold and is affected.

May 2021