Open Britain / Democracy Unleashed
Last Updated: June 2020
Open Britain Limited (“Open Britain”, “we” and “our”) is a company limited by guarantee registered in England and Wales (company no. 09641190). Our registered office is at Orion House, 14 Barn Hill, Stamford, England, PE9 2AE.
We collect personal data from and about individuals (“you”) when running campaigns about the future of democracy and political engagement in the UK. When processing your personal data, Open Britain is the data controller. Our ICO registration number is ZA141509.
When we collect your personal data during a campaign, we refer to ourselves by the campaign name. We are now campaigning using the name ‘Democracy Unleashed’ but we may have collected your personal data using former campaign names, which include the ‘People’s Vote Campaign’ and ‘Britain Stronger in Europe’.
About Open Britain & Democracy Unleashed
Our purpose and overall mission is to campaign to revitalise democracy in the United Kingdom and beyond.
Our supporters help us to achieve this in a variety of ways, primarily by:
- Fundraising and donating money in order to support our programme of work
- Campaigning for change, through signing petitions, writing letters, and taking part in other campaigning actions
- Volunteering at events and in our offices
- Participating in our digital activities
We take active steps to make sure that our supporters are aware of the ways in which they can help us achieve our overall purpose.
Personal Data We Collect
If you are a supporter or donor, we typically collect the following types of personal data: your name, email address, social media details, postal address, telephone or mobile number, bank account details to allow our payment processers to process donations, details about donations you make and any other personal data you share in correspondence with us.
If you contact us, we will collect the personal data you share with us. If you work for a supplier, we may collect your name and business contact information from you or a colleague for the purposes of maintaining our relationship with the supplier.
Website Cookies, Analytics & Third-Party Sites
When you visit our website, we may also log information about your visit including your IP address and some basic details about the device you use, to help us understand how our website is used and to improve site performance. These logs do not include any directly identifiable information about you.
How We Collect Your Personal Data
We collect your personal data from you directly when you sign up on our website to receive more information, answer one of our online surveys, sign one of our online petitions or sign up to show your support for one of our campaigns on our website or through our social media channels. We also collect your personal data if you make a donation to us, contact us or work for one of our suppliers.
Open Britain may also collect your personal data indirectly, such as when you sign a campaign or petition sheet at a community meeting or a street stall or an online petition run by an independent organisation with shared objectives and campaign purposes similar to ours. These independent third parties will only pass your data to Open Britain / Democracy Unleashed where you have given them your consent to do so.
We do not typically collect personal data indirectly for the Democracy Unleashed campaign, but we did work together with other organisations during the People’s Vote and Stronger In campaigns, and may have collected your personal data from their grass roots campaign activities as described above.
Use of Your Personal Data & Lawful Bases
Open Britain / Democracy Unleashed will only process your personal data for specific purposes where we have a lawful basis for doing so, such as (i) where the processing is in our own legitimate interest and our interest is not overridden by your interests or fundamental rights and freedoms; (ii) we are required to process your personal data for compliance with a legal obligation to which we are subject; (iii) the processing is necessary to perform a contract between us and you; and/or (iv) you have consented to our use of your personal data.
The purposes for which we process your personal data are as follows:
We rely on our own legitimate business interests to process your personal data for the following reasons:
- To keep a record of donations made and actions taken by our supporters and our communications with them
- To support volunteers at their events
- To record campaigning actions by supporters
- For service administration, such as administering any donations you have made, to confirm receipt of donations (unless you have asked us not to do that), and to say thank you and provide details of how your donations might be used
- In relation to correspondence you have entered into with us whether by letter, email, text, social media, message board or any other means, and to contact you about any content you provide
- For internal record keeping, in order to keep a record of your relationship with us
- To use IP addresses to identify the location of users, to block disruptive use and to establish the number of visits from different countries
- For market research
- To analyse and improve the activities and content offered by the Open Britain website to provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes
- For the dissemination of relevant information to journalists
Compliance with a legal obligation
We may need to comply with legal requests where disclosure is required or permitted by law. For example, to government bodies for tax purposes or law enforcement agencies for the prevention and detection of crime, subject to such bodies providing us with a relevant request in writing.
For the purposes of a contract with you
We may process your personal data where it is necessary for the performance of a contract with you, such as for the completion of transactions you have entered into with Open Britain or the activity or online content you have signed up for.
If we need to collect personal data under the terms of a contract we have with you, 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. 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.
With your consent
We will only process your personal data for the following reasons with your consent:
- To send you marketing information about all of our campaigns, projects, fundraising activities and appeals
- To share campaign content with you on social media sites, such as Facebook
- To invite you to participate in surveys or research about Open Britain, Democracy Unleashed or our work and campaigns
- We will only collect special categories of personal data from you with your explicit consent for the purposes provided in the supplemental privacy notice we provide you with at that time
You may withdraw your consent at any time by emailing [email protected] or contacting us using the details provided below.
Open Britain / Democracy Unleashed will only contact you for marketing purposes, for example to keep you up to date about all of our campaigns and our work, or to let you know of ways in which you can support that work, where we have your consent or we are otherwise allowed to do so.
You can tell us to stop sending or sharing marketing content to or with you at any time by emailing [email protected] or contacting us using the details provided below. You can also unsubscribe from our marketing emails using the opt-out link provided in every email or opt-out of social media marketing using the tools available on the social media site.
Please note, that opting out of Open Britain / Democracy Unleashed marketing will not guarantee that you never see Open Britain content on social media, since the social media site may select you based on other criteria and without your data having been provided by Open Britain.
Sharing Your Personal Data
Open Britain / Democracy Unleashed will not sell your personal data or share it with any third party to use for any purpose that is inconsistent with the purposes for which it was collected.
If you sign one of our petitions, we may share your details in the petition with government bodies or third parties for the purpose of showing the level of support for the campaign. We will only do this if we have clearly informed you that the petition will be presented to a third party before you sign it.
We may share your email address and phone number with the social media sites we use, such as Facebook, in order to show you Democracy Unleashed and other Open Britain campaign content when you use these services. We only do this if you have consented to marketing. The social media sites will also use your personal data to identify and show our content to other people who we believe may be interested in it, based on their profile of you. You can withdraw your consent to marketing at any time, by contacting us at [email protected].
Open Britain may share your personal data with service providers who help us to deliver our projects, fundraising activities and appeals. These "data processors" will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing data protection clauses that protect your personal data. We do not allow these organisations to use your data for their own purposes or disclose it to other third parties without our consent and we will take all reasonable care to ensure that they keep your data secure.
Our processors may operate in countries outside the UK and EEA. Where this applies, we only share your personal data with them where the country is recognised by the European Commission as providing adequate data protection standards or we have implemented appropriate safeguards to ensure the protection of your personal data, such as standard data protection clauses adopted by the European Commission.
Our primary data processor is Nationbuilder who are based in the US. Nationbuilder participates in the EU-US Privacy Shield Framework whose participants are recognised by the European Commission as providing adequate data protection standards.
How Long We Keep Your Data
We will hold your personal data on our systems for as long as is necessary for the purposes described above, and in accordance with applicable laws.
Where you contribute material to us, e.g. user generated content or in response to a particular campaign, we will only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted unless otherwise stated at the point of generation.
Keeping Your Data Secure
We ensure that there are appropriate technical and organisational controls in place to protect your personal data. Where possible, our online forms use industry standard encryption and our network is protected and routinely monitored.
We undertake regular reviews of who has access to the information we hold to ensure that your personal data is only accessible by appropriately trained staff, volunteers and contractors.
We use third party data processors to process personal data on our behalf. We do comprehensive checks on these companies before we work with them, and put a contract in place that sets out our expectations and requirements, especially regarding how they manage the personal data they collect on our behalf, or have access to. We have a robust partner monitoring framework to ensure these contractual obligations are met.
Where Open Britain relies on your consent to process your personal data, you can withdraw this consent at any time. If you wish to withdraw your consent, please contact us at [email protected] or using the details below.
You are entitled, in accordance with applicable law to object to, or request restriction of processing of your personal data, and to request access to or rectification of your personal data. In some circumstances you can compel us to erase your personal data and request a machine-readable copy of your personal data to transfer to another service provider.
You can exercise your rights by contacting us using the details below. You can also lodge a complaint with the Information Commissioner’s Office. They can be contacted using the information provided at: https://ico.org.uk/concerns/.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights listed above). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
The accuracy of your information is really important to us. We want to ensure that we are able to communicate with you in ways that you are happy with, and to provide you with information that is of interest. If you are aware of changes or inaccuracies in your personal data, you should inform us of such changes so that the personal data may be updated and corrected.
If you wish to change how we communicate with you, make a complaint or update the information we hold, then please email us at [email protected] or write to us at the following address:
14 Barn Hill