The Philanthropy Company Ltd
This privacy notice was last updated on October 2019.
The Philanthropy Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
- Who we are
The Philanthropy Company is a fundraising consultancy which provides advice and support services to non-profit organisations. We also provide philanthropy advice to donors. The Philanthropy Company is the controller and responsible for your personal data (collectively referred to as the Philanthropy Company, “we”, “us” or “our” in this privacy notice).
Our full details are:
The Philanthropy Company Ltd registered in England No. 04207583 at 264 Banbury Road, Oxford, OX2 7DY. Operational and postal address at 12 Melcombe Place, London, NW1 6JJ.
We do not have a data protection officer (DPO), but if you have any questions about this privacy notice, including any requests to exercise your legal rights, please do contact us using the details set out immediately below.
Natalie Coles, Business Manager
Tel: 020 3367 2091
You have the right to 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- The type of data we collect/process and why
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The majority of our work is fundraising advice and consultancy. In order to run our business, we collect and process information from our clients including personal information about the people who work for our clients and our clients’ donors and supporters.
If you contact us about our consultancy services or if you are connected to one of the organisations (as a donor/supporter/volunteer) with whom we work; if you apply for a job with us or enquire about being an Associate with us we may collect, use and store different kinds of personal data about you as follows:
Identity Data: includes first name, last name, title, the organisation you work for and your job title.
Contact Data: includes work address, job title, home address, work or personal email address and telephone number(s).
Marketing and Communications Data: includes your preferences in receiving information from us about our services.
We do not collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- How we collect personal data
We will only use personal data when the law allows us to. We use different methods to collect data from and about you including through:
Direct interactions: You may give us your identity and contact information when you correspond with us by post, phone, or email to enquire about our services. We keep this information on our database in order to record interactions we have had with potential clients whether or not they go on to contract our services. It is important for us to keep basic contact information about organisations who are interested in our services in case they contact us again in future.
Confidential notes from meetings or telephone conversations our clients often ask us to undertake feasibility studies which involves meeting with or speaking to their trustees, donors or other external supporters. If you fall into this category, our clients may pass your contact details to us (with your permission) so we can correspond directly. We take confidential notes at these meetings which are fed back to our clients anonymously. We may keep these notes and the identity of the person interviewed on our system beyond the duration of the contract in case we work with the client again in the future.
- How we use 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.
For marketing purposes
We will ask you to consent to be sent marketing if:
- you make an enquiry about The Philanthropy Company and our services
- you make an enquiry to us about philanthropy in general
- You enter into a business relationship with us
- you have told a third party that you would like them to pass us your contact details so that we can send you updates.
You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not via post), or you may ask us not to send you any marketing communications at all. We do not store information about people who look at our website.
We will ask you to indicate your marketing preferences when we first communicate or have contact with you.
Personal data that you provide to us is also used to:
- Manage and administer our business; this includes communicating with clients about the nature of the contract and sending occasional emails after the contracts have finished such as event invitations or emails about the company’s services.
- For potential clients making a request to use our services we use the contact details provided to send information relating to our products and services.
- In respect of individuals we interview on behalf of our clients e.g. Trustees or Major Donors, we ask for permission to record their feedback and to share the information with our clients (in an anonymised way).
- We use data shared by the client to allow us to conduct research, benchmarking and analysis as part of an agreed contract which enables us to provide fundraising advice to our clients.
- We hold and use data from the public domain (prospect research) to help us understand individuals that might potentially support our clients. We approach prospect research carefully and ethically and have strict guidelines in place and consider this to be in our legitimate interest.
Often our clients ask us to provide analysis or research services to help them identify the people, companies, trusts and foundations, or other funders who might have the interest and capacity to provide major support (whether financial donations, through their networks and influence, or as ‘in-kind’ support, such as a donation of goods or services) towards their cause. This type of support is critical for the sustainability and success of our clients, and by helping them to target their resources more effectively, we encourage greater efficiency and better returns in fundraising. We perform this function on the basis of legitimate interest, as without providing our research and analysis services our role in supporting charities to raise the funding they need to run their programmes would be significantly reduced. All individuals concerned will be either existing donors or part of the existing networks of a client or will be publicly known major donors, or closely linked to a funding body.
We do NOT provide personal contact information to the client such as home address, telephone number or email address.
Our research services include the following:
- Providing a list of potential funders for a client.
- Reviewing the client’s existing donor database to determine if there are people who might have the capacity to give more.
- Analysing the success of different aspects of their fundraising (for example their major donor programme) and providing guidance on future work.
- Conducting ‘due diligence’ on potential major donors.
- Interviewing existing donors or other stakeholders to determine who they might be willing to introduce the client to, leading to a new prospective donor.
- Creating research briefings on individuals, trusts or companies in advance of meetings or approaches to ensure that fundraisers are sufficiently informed to make their ‘ask’.
- Providing a list of prospects to our clients prioritised according to their connection to the cause, the level of their past giving to our client and to others, and other biographical information which could be used to indicate their connections or giving capacity, mentioned below.
- This includes wealth estimates, where publicly available and only for those considered ‘top funders’, please see below for a definition of ‘top funder’.
- Proposing a potential ‘ask’ amount to our clients, past on that individual, trust or corporate’s past giving and other biographical information, mentioned below.
In this role we sometimes perform the role of the Data Controller (when we create a list of prospective funders from scratch), and we sometimes perform the role of Data Processor (when a client securely provides data from their own records or database, which we use):
- In cases where we are the Data Controller, we have a Data and Research Policy which our clients will sign to assure us that they understand the importance of keeping the information we create for them securely and treating it compliantly, and we encourage our clients to approach any individuals listed as soon as practicable, so that they are made aware of who is holding their data, on what basis, and for what purpose.
- In cases where we are the Data Processor, we ensure that clients give us only the information that their supporters expect them to for the purpose of prospect research and analysis, which will vary depending on their particular privacy policies. We also ask that they list us as a third party in their policy. We process this data compliantly and in strict accordance with our agreement with them.
Whether we are the Data Controller or the Data Processor, we securely hold the information on our Google Drive and Donor Perfect. We delete or anonymise all personal data after 12 months of the contract end date with the client, with the exception of any work completed on global ‘top funders’ (such as the Gates Foundation). We retain this information, removing any confidential details pertaining to a particular client, when it concerns a top philanthropist (most frequently in the UK but also other parts of the world) or a key trustee, board member or executive of a major trust, foundation or company. This relates to a very small proportion of the general population (for example those who are on the Sunday Times Rich List or the board of a FTSE 250 company).
These individuals tend to be prolific and well-known individuals who we believe would expect us to know about them and their giving history. We review this information annually to ensure that it remains up to date and we delete individual records when it appears that they are no longer interested in giving to charity or if they leave their role at a trust or a company.
We welcome contact from any individual who might be included in the above should they wish to see or edit the information we hold on them or to opt out entirely.
We only use publicly available sources, or information provided by our clients themselves, when providing our research services. All our research is reported objectively and includes only information that is relevant and necessary for fundraising. We never include anything in any of our research which we would not be happy for the individual to read. This may include obtaining information such as name, age, job title, previous charitable giving, interests and associations from the following sources:
- Media reports available on the internet e.g. Wikipedia, and the Sunday Times Rich List.
- Philanthropy directories e.g. Trustfunding, Foundation Center Directory Online).
- Registers of information e.g. Companies House (including company annual accounts), Who’s Who, Charity Commission (UK, Scotland, Ireland), Guidestar.
- Information on people which is given freely by themselves on the internet such as company websites, LinkedIn, Twitter.
- Charity websites, and other public reports (such as Association of Charitable Foundations Giving Trends report) used to ascertain philanthropic and charitable interests of organisational donors and individual philanthropists who may have an interest in supporting the work of our client(s).
- business ownership and interests.
This information is only shared with our clients.
- Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the address above.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If this requires your consent, you are not required to give your consent just because we ask for it. If you do give your consent, you can change your mind and withdraw it at a later date by contacting us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Who we might share personal data with
We may have to share your personal data with the parties set out below:
External Third Parties
- Service providers based in the UK who provide IT and system administration services, website maintenance services, server and hosting services.
- Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors/accountants and insurers based in the UK who provide banking, legal, insurance and accounting services].
- HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
- International Transfers
Our database is hosted by a company based in the US who have partnered with Amazon Web Services (AWS), a fully accredited and SSAE16, SOC, PCI-DSS level 1, and ISO-9001/27001 certified hosting facility. https://www.donorperfect.com/pdf/Amazonws-DP-2016.pdf
Their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented:
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. For further details, see European Commission: EU-US Privacy Shield (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en).
- Data Security
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
All staff and associates receive data protection training which is regularly reviewed and we have a breach policy in place.
- How long do we keep personal information?
We will only retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. It is in our legitimate business interests to retain contact information for our clients and information about the work we carried out for them in case we work with those clients in future.
Likewise, if you applied for a job at the Philanthropy Company (and were unsuccessful) or enquired about becoming an Associate with us, we will keep your details on file for 12 months. If you do not carry out any work with us during that period we will automatically delete your information from our files. We carry out annual audits of our data to ensure we are not continuing to hold any unnecessary information. A request can be made at any time to remove personal details from our database by contacting our office (contact details above).
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 requirements.
- Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are as follows:
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 your personal data:
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 which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data:
You can 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 which override your rights and freedoms.
Request restriction of processing your personal data:
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data:
If requested, 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.
Right to withdraw consent:
You can withdraw 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.
If you wish to exercise any of the rights set out above, please contact us at the address above.
Exercising your rights
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
Where relevant we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We will respond to all legitimate requests within one month, with ‘day one’ being the date of receipt. For complex cases, this may take up to two months. If this is the case we will notify you as soon as possible.