GDPR/Privacy Policy

Policy Table of Contents

1.0 Introduction and purpose of this Policy
2.0 Who we are

2.1 Third-party links
3.0 The data we collect about you
3.1 Other data we collect
3.2 Accuracy of data
4.0 How is your personal data collected?

4.1 Direct interactions
4.2 Enquiry Forms
4.3 Automated technologies or interactions
4.4 Third parties or publicly available sources

5.0 How we use your personal data

5.1 Purposes for which we will use your personal data

6.0 Opting out

6.1 Change of purpose

7.0 Disclosures of your personal data
8.0 Data security
9.0 Data retention
10.0 Handling “Cookies” “do not track” requests and similar technologies

10.2 Do not track

11.0 Changes to this Policy
12.0 Your legal rights
13.0 Glossary

1.0 Introduction and purpose of this Policy

Welcome to JesusWalker International GDPR/Privacy (this “Policy”). This policy applies to the websites operated by JesusWalker International (hereafter Websites), regardless of where you visit it from, including but not exclusively jesuswalker.org plus the collection and processing of data through direct mail, telephone and social media channels. It informs you about your privacy rights and how the law protects you.

JesusWalker International is committed to protecting and respecting your privacy. This policy describes how we collect and process your personal data and with whom we may share it. We outline the choices you have regarding our use of your personal data and the steps we take to protect the security of your personal data and how to contact us.

We encourage you to read the whole of this Privacy Policy carefully. It should be considered together with any other privacy or fair processing notices we may provide on specific occasions when collecting or processing personal data about you. The intention is that you are fully aware of how and why we are using your data.

In this Policy, JesusWalker International is referred to as “we”, “us” or “our”.

2.0 Who we are

JesusWalker International is responsible as data controller under applicable legislation. We adhere to the principles of the Regulation (EU) 2016/679 General Data Protection Regulation (GDPR). We endeavour to ensure that the personal information we collect, and use will always be held, used, transferred and otherwise processed in accordance with current legal obligations.

We have appointed a data protection officer, responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights (set out in Section 13)

please contact the data protection officer using the details set out below:

• Full name of legal entity: JesusWalker International

• Responsibility for data privacy: Data Protection Officer

• Postal address: JesusWalker International, 2 Ilam Court, Ashbourne, Derbyshire, DE6 1SL

• Email: dataprotection@jesuswalker.org

2.1 Third-party links

This privacy policy only applies to Website and social media locations directly controlled by us. Our Websites and social media locations may include links to third-party websites, plug-ins and applications. We do not control these third-party websites. By clicking on those links or enabling those connections, you explicitly acknowledge that we are in no way responsible or liable for any of those third-party websites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.

3.0 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 the identity has been removed (anonymous data). We may collect, use, store and transfer different classes of personal data grouped together follows:

Individual: first name, last name.

Contact: postal address, email address and telephone numbers.

Technical includes internet protocol (IP) address, browser type and version and the domain name of the internet service provider, 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 the Website.

Profile: includes your interests, gender, preferences and feedback.

Usage includes information about how you use the Website.

Marketing and Communications includes your preferences in receiving marketing from us and your communication preferences.

Financial: Information on donations received when processing through the gift aid scheme.

3.1 Other data we collect

On each visit to our sites, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this data using cookies, server logs and other similar technologies. Please see our Section 11.0 for further details. We also collect, use and share non-personal Aggregated Data for example statistical or demographic data. This Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We sometimes use this non-personal information to improve the design and content of the websites and to enable us to personalise your experience.

We may aggregate your usage to calculate the percentage of users accessing a specific Website feature. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this policy.

3.2 Accuracy of data

Please keep us informed if your personal data changes during your relationship with us. While we endeavour to ensure that the information we hold about you is accurate and kept up to date, we assume that in the absence of contrary evidence, the information you provide us with is accurate. Should you inform us of inaccuracies in the information which we hold in relation to you or,

if we discover that such information is inaccurate, it shall be promptly rectified by us. We do not intentionally retain any information about you which is out of date or which is no longer required.

Where we need to collect personal data by law, or in order to do something that you have asked us to do (such as send you our newsletter, or respond to an enquiry you have made) and you fail to provide that data when requested, we may not be able to do as you have asked (for example, to send you our newsletter on request).

4.0 How is your personal data collected?

4.1 Direct interactions

You may give us your Individual, Contact Profile, Marketing and Communications, and by completing forms in paper or electronic form via the Infinity platform (Organisational Management System) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

subscribe to our publications or social media locations

request promotional ministry content to be sent to you

Community survey

give us some feedback

4.2 Enquiry Forms

If you submit an enquiry through the website, your details will be added to our Organisational Management System ‘Infinity’. If you tick the ‘sign me up to the newsletter’ box on the enquiry form, then you will be added to our newsletter list. You may also receive other communications as a result including new ministry notices, event notifications, or further information on our organisational ministries. You can cancel this subscription at any point and have your data deleted from our records by emailing hello@jesuswalker.org.

4.3 Automated technologies or interactions

As you interact with the Website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For more information about how we use cookies through the Website, please see Section 11.0.

4.4 Third parties or publicly available sources.

We may receive personal data about you from various third parties and public source including technical data from the following parties:

analytics providers such as Google based outside the EU

communication providers such as WhatsApp

advertising networks – none currently used

search information providers – none currently used

5.0 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 when:

We need to contact you in support of any ministry activity you are involved in, or supporting any activity with administrative or legal checks required by law.

It is necessary for our legitimate interests (or those of a third party) and your interests and

fundamental rights do not override those interests.

We need to comply with a legal or regulatory obligation.

Section 13 outlines the lawful basis that we will rely on to process your personal data. Generally, we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to direct communications at any time by contacting us.

5.1 Purposes for which we will use your personal data

The table below, describes the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Legitimate interests are identified where appropriate. We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. If you require details about the specific legal ground, we are relying on to process your personal data, please contact us.

Purpose/activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you including: (a) Notifying you about changes to this Policy. (b) Communicating with you. (c) Responding to you when you contact us. (d) Requesting completion of a review or a survey by you.	(a) Individual. (b) Contact. (c) Profile. (d) Marketing and Communications.	(a) Necessary to comply with a legal obligation. (b) Necessary for our legitimate interests (to keep our records updated and to study how visitors utilise the ministry activities we provide.
To administer and protect the organisation and ministry Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Individual. (b) Contact. (c) Technical.	(a) Necessary for our legitimate interests (for running our the organisation: Provision of administration and IT services, network security, fraud prevention. In the context of a charity reorganisation or restructuring exercise. Necessary to comply with a legal obligation.
To deliver relevant Website content and promotions to you and measure or understand the effectiveness of the promotions we serve to you.	(a) Individual. (b) Contact. (c) Profile. (d) Usage. (e) Marketing and Communications. (f) Technical.	Necessary for our legitimate interests: To study how our visitors/members interact and use the organisational ministry activities. To develop our ministry activities. To inform our online community strategy to grow the organisational use.
To suggest or recommend organisational ministry activities that may be of interest to you.	(a) Individual. (b) Contact. (c) Technical. (d) Usage. (e) Profile.	(Necessary for our legitimate interests (to develop our organisational ministry activities and awareness).
To enable you to partake in a competition or complete a survey.	To enable you to partake in a competition or complete a survey.	(a) Individual. (b) Contact. (c) Profile.
To process donations through the gifted scheme operated by HMRC.	(a) Individual. (b) Contact. (c) Financial.	(a) Financially supporting the organisational ministry activities and awareness.
To communicate weekly/monthly/quarterly events and information that is personal to the members solely within the group of Soul Friends.	(a) Individual. (b) Contact. (c) Profile.	(a) Engagement with organisational ministry activities. (b) Supporting individual members or groups for the purposes of pastoral care.

6.0 Opting out

You may opt-out of receiving marketing email messages at any time, free of charge, by following the opt-out links on any marketing communication sent to you or contact us: hello@jesuswalker.org.

6.2 Change of purpose

We only use your personal data for the purposes which we collected it, unless we reasonably consider that we need to use it for another reason and that compatible with the original purpose. If you wish to get an explanation regarding compatibility of the new purpose, please contact 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.

7.0 Disclosures of your personal data

We may disclose your personal information to companies and individuals who perform technical functions and services on our behalf. Such functions may include hosting the Sites, analysing data and providing other support services. All such parties are required to keep your personal data secure and only handle your data in accordance with appropriate data protection and security regulations including none disclosure agreements. We also request that data is only processed with due diligence and in accordance with our explicit written instructions and in line with GDPR and other relevant legislation.

In most circumstances we will not disclose personal data without consent. However, when we receive a complaint or communication from, for example, the Information Commissioner’s Office or another regulator or relevant body (such as the Police), we may need to share personal information.

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.

8.0 Data security

To the best of our ability, 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. We limit access to your personal data to those staff members, authorised organisational member volunteers, trustees, and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Procedures are in place to deal with any suspected personal data breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.

All data stored is subject to the legislation and directives of the governing state, we actively ensure all data held is stored in the United Kingdom and/or European Union.

9.0 Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes of its collection and in order to provide you with ministry activities and to conduct our legitimate organisational ministry activities or where otherwise required by law. including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider:

The nature, amount, and sensitivity of the personal data
Any potential risks 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
Applicable legal requirements

The longest we will normally hold personal data is 7 years after the last recorded contact, however the retention period will depend on relevant laws, ongoing queries or any other legal claim or dispute. Should you wish us to delete the personal data that we have on file for you, you can request deletion by emailing dataprotection@jesuswalker.org from the email address we have on file for you. That email must include a phone number so that we can verify your identity before deleting your records. Such requests normally result in deletion of your contact record in the Organisational Management System ‘Infinity’, and removal of any email subscriptions you hold with us.

11.0 Handling “Cookies” “do not track” requests and similar technologies

11.1 Cookies

We use “cookies” and other types of tracking software to personalise your visit to our Sites and gaining a better understanding of your particular interests and enhance your experience by customising our pages for you. Our Sites require the use of cookies in order to work at their best. If you do not wish these cookies to be used, then please note that you may not experience our Sites working to their best effect.

A cookie is a message given to a web browser by a web server and which is then stored by the browser in a text file. Each time the browser requests a page from the server this message is sent back which enables the user’s computer to be identified.

We may use the information provided by cookies to analyse trends, administer the Sites, or for research and marketing purposes to help us better serve you. No information which personally identifies you will be collected through the cookies. You can set your browser and our website in ‘Privacy Settings’ to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

11.1 Do not track

With respect to our websites and applications, we are not committed to respond to “do not track” signals in browsers We process your personal data through our websites and applications in accordance with this Privacy Policy, irrespective of your tracking settings.

12.0 Changes to this Policy

Our goal is to keep this privacy policy up to date. JesusWalker International encourages you to periodically review this policy to be kept informed about how we are protecting your information. We reserve the right, at our sole discretion, to modify, add or remove sections of this policy at any time to reflect organisational and visitor feedback. JesusWalker International encourages you to periodically review this Policy to be informed of how we are protecting your information.

Changes to this policy will be notified on jesuswalker.org. When we post changes, we will update the “last updated” date in the cover of the policy. We encourage you to regularly check this Privacy Policy for changes. Your continued use of the Sites, following the posting of changes to this privacy policy, will show you accept these changes. JesusWalker International welcomes your comments regarding this Privacy Policy. please email dataptotection@jesuswalker.org.

13.0 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (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 to continue 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 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 of 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 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.
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 ministry activities 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. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may however charge a reasonable fee if your request is apparently unfounded, repetitive or excessive.

What we may need from you

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 try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month, for example if there is a delay in confirming your identity, or if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14.0 Glossary

Lawful Basis

Legitimate Interest means the interest of our organisation in conducting and managing our activities to enable us to support you and the community to fulfil our charity objectives. 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). For further information please contact us. Complying 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.

Third Parties

Service providers acting as processors based within the United Kingdom who provide [IT and system administration services].
Professional advisers acting as processors including lawyers, bankers, auditors and insurers based within the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

GDPR/Privacy Policy

Governance matters.