Welcome to the Engaging Networks privacy notice

Contents

This version was last updated on 22 March 2022. This policy can also be downloaded in PDF format here.

Introduction

As individuals, we want to know that personal information about ourselves is handled properly and we and others have specific rights in this regard. In the course of its activities Engaging Networks will collect, store and process personal data, and it recognises that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

Status of the policy

This policy sets out Engaging Networks’ rules on data protection, data subject rights and the data protection principles. These principles specify the legal conditions that must be satisfied in relation to the obtaining, handling, processing, transportation and storage of personal data. This privacy notice aims to give you information on how Engaging Networks collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to receive information from the Company, receive a demonstration of or subscribe to the services (subject to the terms of the Company’s Data Privacy Addendum executed upon subscription). This notice and all of our services are not intended for children and we do not knowingly collect data relating to children.  Anyone who considers that this policy has not been followed in respect of personal data about themselves or others should raise the matter with the Data Protection Officer in the first instance ([email protected]). Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Who we are

We are Engaging Networks, a registered company England and Wales.  We provide a platform for not-for-profits. While we do not need to process certain data (e.g. Special Category data), our clients may do. We cannot advise or comment on the privacy policies or practices of organisations who use our platform, but we encourage responsible and compliant behaviours. Our office addresses/contact details are:
UK: Third Floor, 10-12 Emerald Street London WC1N 3QA United Kingdom Phone: +44 (0)20 7253 0753 Email: [email protected] US: One Thomas Circle, Suite 700 Washington DC 20005 United States Phone: (+1) 202 525-4910 Email: [email protected]
For queries regarding personal data, our Data Protection Officer can be contacted at [email protected]. All users of Engaging Networks’ UK services and website have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) and to seek compensation through the Courts. You may contact our European Representative as Required under Article 27 GDPR as follows: Email: [email protected] Postal Address: Engaging Networks Nominated Representative, c/o Castlebridge Nominated Representative Services, Unit 7, 12 Mountjoy Square, Dublin 7, Ireland

2. Glossary of data protection terms

Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems. Data subjects for the purpose of this policy include all living individuals about whom Engaging Networks holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information. Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in possession of Engaging Networks).  Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).  It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way. Personal details such as someone’s contact details or salary fall within the scope of The General Data Protection Regulation 2016/679 Sensitive personal data includes information about a person’s political opinions, racial or ethnic origin, religious or similar beliefs, trade union membership, sexual orientation, genetic, biometric and health data. Sensitive personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned. Data controllers are the people or organisations who determine the purposes for which, and the manner in which, any personal data is processed.  They have a responsibility to establish practices and policies in line with GDPR. Engaging Networks is the data controller of all personal data belong to employees and clients of our company.  Our clients are data controllers for all of their supporters’ personal data. Only they determine the purposes and means of the processing of personal data that we carry out. Data users include employees whose work involves using personal data.  Data users have a duty to protect the information they handle by following Engaging Networks’ data protection and security policies at all times. Data processors include any person who processes personal data on behalf of a data controller. Engaging Networks is a processor of the personal data entrusted to us by our clients, who are the Data Controllers of their supporters’ personal data. Processing is any activity that involves use of the data.  It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, storing, retrieving, using, disclosing, erasing or destroying it.  Processing also includes transferring personal data to third parties.  We may not transfer/share personal data under the control of our clients without the client’s explicit permission. Third parties are:

3. The data we collect about you and how it is collected

Engaging Networks is the Data Controller for all personal data provided by employees, our customers (clients) own personal data and the personal data of potential customers. We are the Data Processor for all personal data that is provided to us by our clients (in particular their supporter records). The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in The General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018, and other regulations. 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). We may, depending on the processing, collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Web Beacons

We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, which includes Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). We do not retain any financial data (including bank account and payment card details).

Third Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data needed to provide you with our services

Where we need to collect personal data under the terms of a contract we have with our clients and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How is personal data collected?

We use different methods to collect data from and about you including through: (a)  analytics providers such as Google based outside the EEA or UK; (b)  advertising networks such as Google Adwords, Facebook Lookalike Audiences or similar services based inside or outside the EEA UK; and (c)  search information providers [such as Google, Bing or similar based inside or outside the EEA or UK).

5. 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:

Lawful Bases

Below are the lawful bases we rely on to process personal data: Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Purposes for which we use personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose/Activity Type of data Lawful basis for processing
Registering new customers (a) Identity(b) Contact Performance of a contract
Processing and delivering orders including:(a) Managing payments, fees and charges(b) Collecting money owed to us (a) Identity(b) Contact(c) Transaction Performance of a contract
Advocacy Databases (a) Identity(b) Contact Performance of a contract (access to publicly available contact details of political representatives in the UK and Northern Ireland, Canada, Australia, the United States, Germany and the European Parliament)
Relationship management including:(a) Notifying you about changes to our terms or policies(b) Asking for reviews or issuing user surveys (a) Identity(b) Contact(c) Marketing and Communications (a) Performance of a contract(b) Necessary to comply with a legal obligation
To enable you to complete a survey or provide feedback about the service or participate in special promotions (a) Identity(b) Contact(c) Usage(d) Marketing and Communications (a) Consent(b) Performance of a contract with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity(b) Contact(c) Technical  (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity(b) Contact(c) Profile(d) Usage(e) Marketing and Communications(f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical(b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity(b) Contact(c) Technical(d) Usage Consent. Our legitimate Interests

Cookies

When you use our website, if you provide consent, we will store cookies on your computer in order to facilitate and customise your use of our site if your settings allow us to. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Read our Cookie Policy and manage your cookie preferences here

Promotional offers from us

You will receive marketing communications from us if you have requested information from us or subscribed to services from us and, in each case, you have not opted out of receiving that marketing.  We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. We may use email addresses and first name / last name details to create ‘custom audiences’ and identify ‘lookalike’ audiences on social media channels to provide information, services, or products that we feel may be of use or interest to those audiences. This involves uploading these supporter details to third-party social media organisations, including Facebook, from which they identify ‘lookalike’ cohorts. This upload is governed by terms and conditions restricting the processing and use of the data and you can manage your Facebook ad settings on https://www.facebook.com/help/568137493302217. To stop receiving marketing messages, you can click on the unsubscribe link on any email sent from us to you or by contacting us at any time at [email protected]. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose  

We will only use your personal data for the purposes for which we collected it.  If we need to use your data for any other purpose, we will contact you directly.

6. Disclosures/sharing of personal data

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. We share personal data within the Engaging Networks Group. This will involve transferring your data outside the EEA and UK. Whenever we transfer personal data out of the United Kingdom or the EEA, we ensure a similar degree of protection is afforded to the data by using service providers and signing specific contracts that satisfy European Commission or Information Commissioner’s Office (ICO) standards, giving personal data the same protection that it has in Europe or the United Kingdom.

7. Retention Policy

The following table identifies the terms referred to in this policy:
Client Organisation that has contracted Engaging Networks to provide software platform & publicly available advocacy databases for the purposes of fundraising, data management, advocacy, bulk email and event management.
Supporter Persons actively engaged with the client organisation e.g. sending emails to MPs in support of the client cause
Donor Persons who donate money towards supporting the work of the client
Contractors People or entities who work for Engaging Networks on a fixed contract
Employees Full time employees of Engaging Networks
Partners Organisations who work in partnership with Engaging Networks to provide a service to clients
We use the following technologies and processes:

1. Salesforce

2. Google Workspace

3. Egnyte

4. Zoom

5. Software hosting

6. Engaging Networks Platform

7. Conference Networking

8. Thinkific

9. ZoomInfo

10. Mixmax

8. Data protection principles

Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be: Engaging Networks is responsible for our clients’, their supporters’ and our employee’s personal data and must be able to demonstrate compliance with all of the above principles through our policies, actions and documentation.

Fair, Transparent and lawful processing

GDPR is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case Engaging Networks), the purpose for which the data is to be processed by Engaging Networks, and the identities of anyone to whom the data may be disclosed or transferred. For personal data to be processed lawfully by Engaging Networks, at least one of the following conditions must be met:
  1. That the data subject has explicitly consented to the processing
  2. that the processing forms part of a contract or steps taken at the request of the data subject to enter a contract
  3. that the processing is necessary for the legitimate interests of the data controller or by a third party
  4. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  5. processing is necessary for compliance with a legal obligation to which the controller is subject
  6. processing is necessary in order to protect the vital interests of the data subject or of another natural person
When sensitive personal data is being processed, additional conditions must be met to ensure highly levels of protection and security. In most cases the data subject’s explicit consent to the processing of such data will be required.

Purpose limitation

Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by GDPR. This means that personal data must not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed and explicit consent given before any processing occurs.

Data minimisation

Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject or as instructed by our clients. Any data which is not necessary for that purpose should not be collected in the first place.

Accurate data

Personal data must be accurate and kept up to date. Information which is incorrect or misleading is not accurate and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed.

Storage limitation

Personal data should not be kept longer than is necessary for the purpose. This means that data is destroyed or erased from Engaging Networks systems when it is no longer required.

9. Data Subjects’ Rights

Data must be processed in line with data subjects’ rights. Data subjects have a right to:

10. Data security

Engaging Networks must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. Data subjects may apply to the courts for compensation if they have suffered damage from such a loss. GDPR requires Engaging Networks to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if we have full agreement from the controller and the third-party agrees to comply with those procedures and policies and or if they put in place adequate measures themselves. Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows: In the event of an incident affecting the security of personal data as Processor, it is Engaging Networks’ responsibility to notify our clients (Controllers) as soon as the issue is detected.

Other Policies

Event Refund Policy

Engaging Networks hosts company information events, either in person or online. Individuals registering and paying to attend these events are entitled to a 50% refund of the event ticket price if they cancel at least 10 working days prior to the date of the event. No other refunds are offered.

Academy User Policy

Engaging Networks provides training to clients and agencies through our online training platform (The Academy). Our academy user policy is detailed here.