Privacy Notice

1. Who are we?
2. What information is covered by this Privacy Notice?
3. What information do we collect about you?
4. How do we use your personal information?
5. Do we use your personal information for direct marketing?
6. Do we share your personal information with third parties?
7. Do we transfer personal information outside the EEA?
8. What are your rights (EEA residents only)?
9. How do we protect your personal information?
10. How long do we keep your personal information?
11. How do we deal with children’s privacy?
12. How can you contact us?
13. Which version of this Privacy Notice applies?

Protect (Whistleblowing Advice) Limited (“Protect“, “we” or “us“) is committed to protecting your privacy and ensuring the highest level of security for your personal information.

This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.

We take the sensitivity of our advice work and the confidentiality of Advice Line callers incredibly seriously and all calls to our Advice Line are protected by legal privilege.

We will never share any confidential information you give us for the purposes of providing you with advice with anyone else without your explicit consent.

Please read the following carefully to understand our views and practices regarding your personal information.

1. Who are we?

For the purposes of applicable data protection laws, the data controller is Protect (Whistleblowing Advice) Limited, a company limited by guarantee with its registered office at Green House, 244-254 Cambridge Heath Road, London E2 9DA.

2. What information is covered by this Privacy Notice?

In this Privacy Notice, “personal information” or “personal data” means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly.

3. What information do we collect about you?

We collect the following personal information about you:

1. Information we collect about you through our Advice Line and legal advice services:

 

We collect the following information from you when you provide it to us through the Advice Line, contact forms or other communication channels (e.g., email):

• Contact information including your name, email address and telephone number (mobile or home);
• Information relating to your employment (such as your position, name of your employer, the length of time you have been employed, tasks, etc.);
• Other information relating to your request for advice, which you provide to us in connection with your request for advice (this might include details of specific incidents or events);
• Unique case reference number which we generate to keep a record of your request for advice;
• Special categories of personal data, to the extent that you provide this to us in connection with your request for advice, including data relating to: trade union membership, health, race, ethnic origin, sexual orientation, political views and religious views; and
• any other types of personal data collected

As a general rule, users of our Advice Line service should not provide us with personal information relating to third party individuals (e.g., colleagues or managers).

1. Information we collect about you through Business Support and Whistleblowing Benchmark:

• We collect the following information from you when you provide it to us through the Benchmark platform, online contact forms or other communication channels (e.g., telephone, email etc.):
  • your name, job, title, email address, phone number, location (country) and your desired products;
  • other personal information related to your request for products/services, which you provide to us when engaging with our sales team either online, by phone, by mail or in person, including billing information, telephone numbers (including mobile numbers) and e-mail address; and
  • your communication and marketing preferences.

Where we receive information from Business Support and Benchmark clients about employees, customers or other individuals, the relevant client is responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.

1. Information we collect about you from our website:

We collect the following information from you:

• where you have made a donation to us, information relating to your donation, including your name, email address, donation amount and payment card details; and
• information relating to your online browsing activities on our website, including pages visited and other metrics (see our Cookies Notice below).

4. How do we use your personal information?

1. Information we collect about you through our Advice Line and legal advice services:

We process the following information:	For the following purpose(s):	Based on the following justification(s):
Contact information: Name, address, e-mail and telephone number (mobile or home)	Managing our relationship with you, including: (a) Responding to your request for advice (b) Keeping you informed about your request for advice (c) Notifying you about changes to our terms or to this Privacy Notice (d) Verifying your identity	Our legitimate interests in responding to requests for advice as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large or compliance with legal obligations to which we are subject
Name, address, e-mail and telephone number (mobile or home) Information relating to your employment (such as your position, name of your employer, the length of time you have been employed, tasks, etc.) Other information relating to your request for advice, which you provide to us in connection with your request for advice (this might include details of specific incidents or events)	Processing your request for advice and providing advice in response to your request	Our legitimate interests in responding to requests for advice as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large or compliance with legal obligations to which we are subject
Name, address, e-mail and telephone number (mobile or home) Information relating to your employment (such as your position, name of your employer, the length of time you have been employed, tasks, etc.) Other information relating to your request for advice, which you provide to us in connection with your request for advice (this might include details of specific incidents or events)	Anonymising information relating to your request so that it can be used for the purposes of whistleblowing research and campaigning.	Our legitimate   interests in conducting research and policy campaigns as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large. We will anonymise your information before using it for these purposes.
Special categories of personal data to the extent that you provide this to us in connection with your request for advice, including data relating to: trade union membership, health, race, ethnic origin, sexual orientation, political views and religious views	Processing your request for advice and providing advice in response to your request	Processing is carried out by us in the course of our legitimate activities with appropriate safeguards, or your explicit consent where required by law
Name, address, e-mail and telephone number (mobile or home) Information that you provide about our services for feedback purposes	Reviewing feedback that you provide to us in relation to our Advice Line and legal advice services	Our legitimate interests in improving our Advice Line and legal advice services as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large
Name, address, e-mail and telephone number (mobile or home) Information relating to your employment (such as your position, name of your employer, the length of time you have been employed, tasks, etc.) Other information relating to your request for advice, which you provide to us in connection with your request for advice (this might include details of specific incidents or events)	Responding to requests from law enforcement and complying with our legal obligations	It is necessary for us to process your personal data in this manner in order for us to comply with legal obligations to which we are subject

 

1. Information we collect about you through Business Support and Whistleblowing Benchmark:

 

We process the following information:	For the following purpose(s):	Based on the following justification(s):
Name, job, title, email address, phone number, location (country) and your desired products Other personal information related to your request for products/services, which you provide to us when engaging with our sales team either online, by phone, by mail or in person, including billing information, telephone numbers (including mobile numbers) and e-mail address Your communication and marketing preferences	Managing our relationship with your organisation, including: (a) Responding to your requests for demos or queries regarding our products and services (b) Keeping you informed about products and services that you have purchased. (c)  Notifying you about changes to our terms or to this Privacy Notice (d) Sending you service-related messages, for example regarding the administration of your account (e) Responding to customer service enquiries (f) Verifying your identity	Contractual necessity,  our legitimate interests in responding to requests for advice as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large or compliance with legal obligations to which we are subject
Name, job, title, email address, phone number, location (country) and your desired products Other personal information related to your request for products/services, which you provide to us when engaging with our sales team either online, by phone, by mail or in person, including billing information, telephone numbers (including mobile numbers) and e-mail address	Fulfilling your orders for products and services	Contractual necessity, our legitimate interests in responding to requests for advice as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large
Client contact information, such as name, address, e-mail and telephone number	Crime and fraud prevention and detection and related purposes	Our legitimate interest in protecting our organisation against crime and fraud
Name, address, e-mail and telephone number (mobile or home) Information that you provide about our services for feedback purposes	Reviewing feedback that you provide to us in relation to our business services	Our legitimate interests in improving our business services  which are provided as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large
Client contact information, such as name, address, e-mail and telephone number	For marketing purposes, to keep your organisation updated on our products and services and to send you our newsletter	Our legitimate interest (to develop our products and services and grow our charity as part of our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large), or your consent where this is required by law

 

1. Information we collect about you from our website:

We process the following information:	For the following purpose(s):	Based on the following justification(s):
IP address Browser type and version Device identifier, location and time zone setting Browser plug-in types and versions, operating system and platform, page response times, and download errors Websites you visit before and after our website and products you viewed or searched for Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page	Collecting and analysing  information on your recent visits to our website and how you move around different sections of our website. We do this to understand how people use our website so that we can make it more intuitive. and improve your experience. We may need to process your personal information in order to keep our website safe and secure and protect against illegal or fraudulent activity such as cyber attacks.	Our legitimate interests to monitor how our website is used to detect and prevent fraud, other crimes, and the misuse of our website or your consent where required by law
Name, email address and payment details	To process your donation payment	Our legitimate interest in processing your donations so that we can use your donation to pursue our charitable goal of supporting whistleblowing cases through to effective resolution, which is in the interests of society at large
IP address Browser type and version Device identifier, location and time zone setting Browser plug-in types and versions, operating system and platform, page response times, and download errors Websites you visit before and after our website and products you viewed or searched for Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page	To deliver relevant website content, to market our services to you and measure or understand the effectiveness of the marketing materials we serve to you.	Our legitimate interests (to understand how customers use our products and services, to develop and improve them, to grow our business and to inform our marketing strategy), or your consent where required by law.

5. Do we use your personal information for direct marketing?

Advice Line and general website: We do not use your personal information for direct marketing purposes.

Business Support and Benchmark only: We may send you carefully selected information about our products and services. You have the right to opt out of receiving direct marketing at any time.

6. Do we share your personal information with third parties?

Your personal information are intended for Protect but may be shared with third parties in the following circumstances:

• Our service providers: We use third party service providers to assist us with the provision of Protect’s services and products to you. Specifically, we may share personal information with:
  • IT service providers we engage to help us provide our products and services and to operate our website, including providers of payment processing services, web-hosting services, online survey services, marketing services and IT support/maintenance services;
  • Third-party companies that we use to audit or improve the delivery and performance of content on our website (for example, through Google Analytics); and

 

• Our pro bono network of law firms that assist us in delivering advice to individuals using our advice line service.

In the course of providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with personal information which is necessary for them to perform their services.

• Third parties permitted by law: In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities).

We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.

• Third parties connected with business transfers: We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.

7. Do we transfer personal information outside the EEA?

We do not transfer your personal information outside of the EEA.

8. What are your rights (EEA residents only)?

You have the following rights:

• Access. You have the right to request a copy of the personal information we are processing about you.
• Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
• Deletion. You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
• Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
• Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
• Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes where you wish to opt out from marketing messages.

Where we process your personal data for research or statistical purposes, we may rely on certain exemptions to the rights above where permitted under applicable data protection laws. You can find out more about these exemptions using the following link: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/exemptions/.

 

You can make a request to exercise any of these rights in relation to your personal information by sending the request by email to dpo@protect-advice.org.uk. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

Telephone:  +44 0303 123 1113

Email:         casework@ico.org.uk

Website:     www.ico.org.uk

Web-form:  www.ico.org.uk/concerns/

Address:     Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF

If you are based in, or the issue you would like to complain about took place, elsewhere in the European Economic Area (EEA), a list of local data protection authorities in the other EEA countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

9. How do we protect your personal information?

We have implemented technical and organisational security measures to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this Privacy Notice, encryption, as well as other administrative, technical and physical safeguards.

While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

10. How long do we keep your personal information?

We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use personal information, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

11. How do we deal with children’s privacy?

We will never knowingly collect personal information from individuals under the age of thirteen (13) years without first obtaining verifiable parental consent. If you are under the age of 13, you should not provide information to us. If we become aware that a person under 13 has provided personal information to us without verifiable parental consent, we will remove such personal information from our files.

12. How can you contact us?

If there are any questions or concerns regarding this Privacy Notice, please contact us as follows:

• by email: dpo@protect-advice.org.uk

 

 

[In addition, we have appointed a data protection officer (DPO) who is responsible for overseeing our privacy practices and can be contacted at: dpo@protect-advice.org.uk

 

13. Which version of this Privacy Notice applies?

We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will notify you of these changes via email (if you have provided your email address to us) and post an alert on the home page of our website.

 

LAST UPDATED

 

July 2020