This privacy notice describes how and why Global Witness uses your personal information, how we protect your privacy and your rights regarding this information. It applies to the personal data we process as part of our work to support those disproportionately affected by climate change, including the data we process on our website www.globalwitness.org (“the Site)”.
The Site and services are operated by Global Witness (a private limited company by guarantee), registered office at Global Witness, 2nd Floor, 55 Ludgate Hill, London EC4M 7JW (“we”, “us” and “our”). Global Witness is the ‘Data Controller’ for the purposes of data protection laws - the General Data Protection Regulation and other applicable data protection rules (including the Data Protection Act 2018, UK GDPR, marketing and cookies laws, together with associated guidance) (the "Data Protection Laws").
We are committed to protecting your privacy online whilst providing a personalised and valuable experience. Collecting personal information is important so that we can meet the expectations and needs of our supporters and partners. It is also a legal requirement for some of the things Global Witness does such as processing donations. We take care to ensure that we use your personal information in accordance with Data Protection Laws.
1. Legal Basis
Under the Data Protection Laws, we are required to explain:
- what personal information we collect; and
- how and why we use your personal information.
We are also required to have a legal basis on which to process your personal information. This is summarised below.
The legal basis relied upon by Global Witness to process your personal information depends upon the circumstances in which we collect and use this information.
In most cases our processing of your personal information will fall into one of the following categories:
- Contractual necessity: where the processing of your personal information is necessary to carry out the performance of a contract with you.
- Legal obligation: where the processing of your personal information is necessary for us to comply with a legal obligation such as auditing of donations.
- Legitimate interests: when relying on this legal basis we will process your personal information in a way that fits with Global Witness’s legitimate interests and yet does not override your interests or fundamental rights and freedoms relating to your personal information.
- Consent: where you have explicitly agreed that your personal information may be used for a particular purpose or purposes such as email updates about GW’s work.
2. The information we collect about you and how we use it
We collect your contact details including name, residential address, postcode, email address and telephone numbers.
For financial transactions and donations, we collect credit card information, bank account details, gift aid status for the purposes of that transaction.
We also collect information about your use of our Site, and your campaigning interests.
We use the information you provide to:
- email you with information, where you have provided us with your email address and consent
- enable us to provide you with the services, event invitations, newsletters and information about us and our fundraising campaigns offered through the Site and which you request
- audit the downloading of data from the Site
- improve the layout and/or content of the pages of the Site and customise them for users
- identify visitors to the Site
- carry out research on our users' demographics
- provide you with the opportunity to express their preferences about communications they receive
- keep a record of any donations you have made to us, events you have attended, emails we have sent you and any forms you have filled out on our site. We may also keep a record of your interests, so that we contact you with information about the most relevant campaigns.
Profiling and analysis
- We may also analyse your personal information to target our campaigning and fundraising communications. This may include looking at responses to previous projects, campaigns and fundraising appeals and/or researching publicly available information so that we can tailor communications appropriately and reach the right audience.
- We sometimes use publicly available sources of personal information, such as Companies House, Charity Commission, Who’s Who, electoral roll, newspaper articles, biographies. This allows us to get a better understanding of our supporters and to identify potential donors.
- We also use commercially available information such as postcode data to analyse geographic and demographic trends.
- We may use personal data together with publicly available information to carry out due diligence checks related to a particular donation, or someone’s potential as a donor. We do this to ensure that we comply with ethical, legal and regulatory standards.
- If you volunteer for us or apply for a job with us, we use information necessary for us to process your application and assess your suitability (such as employment status, previous experience, unspent criminal convictions).
We will retain the information above for as long as is necessary for the purpose it was collected.
Applications to vacancies
We use information necessary for us to process your application and assess your suitability (such as employment status, previous experience, unspent criminal convictions). Global Witness collects a range of information about you in relation to recruitment. This includes:
- your name, address and contact details, including email address and telephone number
- details of your qualifications, skills, experience and employment history
- information about your current level of remuneration, including benefit entitlements
- whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process
- information about your entitlement to work in our office locations
- equality and diversity personal data.
Your information may be shared internally for the purposes of the recruitment process.
Equality and diversity personal data is used for independent monitoring purposes only.
We will inform you prior to seeking your personal data from third parties, such as references supplied by former employers.
If your application for employment is unsuccessful, the organisation will hold your data on file for 6 (six) months after the end of the relevant recruitment process, in case of any queries about the recruitment process.
3. Marketing and promotional materials
We may use your personal information to provide you with marketing and promotional materials, such as newsletters, fundraising and campaign materials. We do so to carry out the objectives of Global Witness and will never sell and/or share your personal information with third parties for marketing purposes.
You may opt-out of receiving marketing and promotional materials from us at any time by emailing us at [email protected] or using the 'unsubscribe' link in the marketing or promotional email.
You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the Site whilst it is in transit over the internet and any such submission is at your own risk.
5. Sharing your personal information
We will only disclose your personal information to:
- Companies within our group.
- Our professional advisors (including without limitation tax, legal or other corporate advisors who provide professional services to us).
- Other third party suppliers, business partners and sub-contractors for business administration, support, processing, services, or IT purposes.
- Analytics or search engines, that enable us to optimise and improve your website experience.
- Third parties that you approve (including without limitation, social media sites and third party payment providers).
- Our regulators, law enforcement or fraud prevention agencies, as well as our legal advisers, courts, the police and any other authorised bodies, for the purposes of investigating any actual or suspected criminal activity or other regulatory or legal matters.
- HMRC, IRS or other tax bodies or agencies to comply with our legal and regulatory obligations.
We will disclose your personal information to third parties:
- In the event we are the subject of any insolvency situation (e.g. the administration or liquidation).
- If we, or a substantial portion of our assets, are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
- In order to enforce or apply our terms and conditions.
- To protect our rights, property, or safety, or that of our staff, our customers, or others. This includes exchanging information with other companies and organisations (including without limitation HMRC, the local police or other local law enforcement agencies) for the purposes of staff and customer safety, crime prevention, fraud protection and credit risk reduction.
6. Donations processing
7. International transfers of your personal information
We may transfer your personal information to GW staff or offices based in countries other than the country in which it was originally collected (for example, outside the UK/EEA) in order to provide you with our services. These countries may not have the same data protection laws as the country in which you initially provided the information and may not provide the same level of protection.
If we transfer personal information to countries outside of the UK/EEA, we would rely on UK and/or European Commission rules to ensure the data protection is adequate. Alternatively, we would rely on appropriate safeguards such as by agreeing standard contractual clauses adopted by the European Commission.
8. Your rights
You have the right:
To be informed: A right to be informed about the personal information we hold about you.
Of access: A right to access the personal information we hold about you.
To rectification: A right to require us to rectify any inaccurate personal information we hold about you.
To erasure: A right to ask us to delete the personal information we hold about you. This right will only apply where (for example):
- we no longer need to use the personal information to achieve the purpose we collected it for;
- where you withdraw your consent if we are using your personal information based on your consent;
- or where you object to the way we process your information (in line with Right 6 below).
To restrict processing: In certain circumstances, a right to restrict our processing of the personal information we hold about you. This right will only apply where (for example):
- you dispute the accuracy of the personal information held by us;
- where you would have the right to ask us to delete the personal information but would prefer that our processing is restricted instead;
- or where we no longer need to use the personal information to achieve the purpose we collected it for, but you need the personal information for the purposes of establishing, exercising or defending legal claims.
To data portability: In certain circumstances, a right to receive the personal information you have given us, in a structured, commonly used and machine readable format. You also have the right to require us to transfer this personal information to another organisation, at your request.
To object: A right to object to our processing of the personal information we hold about you where our legal basis is for the purpose of our legitimate interests, unless we are able to demonstrate, on balance, legitimate grounds for continuing to process the personal information which override your rights or which are for the establishment, exercise or defence of legal claims.
In relation to automated decision making and profiling: A right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you.
To withdraw: A right to withdraw your consent, where we are relying on it to use your personal information (for example, to provide you with brochures and newsletters).
9. Child safety
Protecting the safety of children when they use the internet is very important to us. We recommend that children receive permission from their parent or guardian before gaining access to the Site or sending personal information to us or anyone else online.
10. Exemptions for journalism, academic research, art, literature
Personal data collected for certain purposes are exempt from most of the provisions of the Data Protection Act 2018. Global Witness is most likely to rely on the exemption when it is processing personal information for its journalistic investigations that are in the public interest. The ICO has recently updated its guidance to journalists.
11. External links
The Site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
12. Cookies and similar technologies
We occasionally participate in Facebook’s Custom Audience and Lookalike Audience programs, which enable us to display our content to our existing or potential supporters on Facebook. This enables us to use our promotional budgets much more efficiently. We provide personal information such as your email address to Facebook who securely encrypt it. That personal information is then deleted by Facebook if it does not match with a Facebook account or once they confirm you have an account.
For more information, please see:
- https://www.facebook.com/business/help/744354708981227 and
If you do not wish your information to be used in this way please contact us at [email protected].
We welcome your views about our Site and this policy. If you would like to contact us with any queries or comments, request further information or exercise any of your available rights set out above, please email us at: [email protected] or write to us at: Global Witness, 2nd Floor, 55 Ludgate Hill, London EC4M 7JW.
We encourage you to contact us first if you have any queries, comments or concerns about the way we handle your personal information. However, if you are not satisfied with our handling of any request by you in relation to your rights or concerns, you also have the right to make a complaint to our supervisory authority, which is the UK's Information Commissioner's Office. Their address is: First Contact Team, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
We will update this notice from time to time by changing it on the Site.
This policy was last reviewed and updated: 1 February 2024