Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) if you are based in the EU.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our: TransitionZero is a registered charity numbered 1194424 and a company limited by guarantee in England numbered 12914740. Our registered office is at 28 St. John's Square, London, England, EC1M 4DN, and our main trading address is 1 Fetter Lane, London, EC4A 1BR.
Personal data: Any information relating to an identified or identifiable individual.
Special category personal data: Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data (when processed to uniquely identify an individual). Data concerning health, sex life or sexual orientation.
Data subject: The individual who the personal data relates to.
Personal data we collect about you
We may collect and use the following personal data about you:
your name and contact information, including email address and telephone number and employer details
information to check and verify your identity,
location data, if you choose to give this to us
your professional interests
your professional online presence, eg LinkedIn profile
information from accounts you link to us, eg Facebook
information about how you use our website, IT, communication and other systems
your responses to surveys, e.g. your expected use of data downloads
We collect and use this personal data to help us to deliver our charitable aims.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information from a third party, e.g.:
your employer
from cookies on our website—for more information on our use of cookies, please see the Cookies Settings button on our website.
via our IT systems, eg:
from door entry systems and reception logs;
through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
where you have given consent;
to comply with our legal and regulatory obligations;
for the performance of a contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party.
A legitimate interest is when we have an operational or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why:
| Statistical analysis to help us manage our charity, e.g. in relation to our the management of our finances, stakeholder base, charitable projects and research or other efficiency measures | Our reasons |
|---|---|
| Delivering our charitable aims, including receiving grant funding or delivering grant obligations | For our legitimate interests or those of a third party, i.e. to carry out the aims of our charity |
| Conducting checks to identify our donors and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our charity, eg under health and safety law or rules issued by our professional regulator | To comply with our legal and regulatory obligations |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring our organisations’ policies are adhered to, eg policies covering security and internet use | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures |
| Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can best achieve our charitable aims |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our charity, e.g. in relation to our the management of our finances, stakeholder base, charitable projects and research or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can best achieve our charitable aims |
| Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us To comply with our legal and regulatory obligations |
| Updating and enhancing stakeholder records | For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our stakeholders and parties who have expressed an interest in our charitable aims. |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver our charitable aims |
| Telling you about the work we do, projects we are involved in and reports we have published | For our legitimate interests or those of a third party, i.e. to promote our charity and the work we do |
| External audits and quality checks, eg the audit of our accounts | For our legitimate interests or a those of a third party, ie to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
we have your explicit consent;
the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
the processing is necessary to establish, exercise or defend legal claims.
Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our work and research.
We have a legitimate interest in using your personal data to tell you about our work and projects. This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
contacting us at info@transitionzero.org;
using the ‘unsubscribe’ link in emails; or
updating your marketing preferences on our Newsletter via Mailchimp.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
our grant funders
our Board of Trustees
other third parties we use to help us run our charity, eg marketing agencies or website hosts;
third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
our bank;
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
share personal data with external auditors, e.g. accreditation and the audit of our accounts;
disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations;
share some personal data with other parties, such as the potential transfer of some or all of our activities during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
Where your personal data is held
Personal data may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK/EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK and EEA’.
How long your personal data will be kept
We will keep your personal data for as long as is necessary:
to carry out the aims of any grant funding we have received or given;
to defend any legal claims;
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.
When it is no longer necessary to keep your personal data, we will delete or anonymise it.
Transferring your personal data out of the UK and EEA
To carry out our charitable aims, it is sometimes necessary for us to share your personal data outside the UK/EEA, eg:
with our Grant funders or other charities with whom we deliver projects located outside the UK/EEA;
with our workers based outside of the UK/EEA
with your and our service providers located outside the UK/EEA;
if you are based outside the UK/EEA;
where there is a European and/or international dimension to the research or projects we are undertaking.
Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK/EEA where:
the UK government or, where the EU GDPR applies, the European Commission has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
a specific exception applies under data protection law
These are explained below.
Adequacy decision
We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include:
all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’);
Gibraltar; and
Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.
The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.
Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place or relying on an exception, as explained below.
Transfers with appropriate safeguards
Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects.
The safeguards will usually include using legally-approved standard data protection contract clauses.
The standard data protection contract clauses are published by the EU at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
Transfers under an exception
In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, eg:
you have explicitly consented to the proposed transfer after having been informed of the possible risks; or
the transfer is necessary to establish, exercise or defend legal claims
We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.
Further information
If you would like further information about data transferred outside the UK/EEA, please contact us (see ‘How to contact us’ below).
Your rights
You have the following rights, which you can exercise free of charge:
| Your rights | Description |
|---|---|
| Access | The right to be provided with a copy of your personal data |
| Rectification | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of processing | The right to require us to delete your personal data—in certain situations |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object | The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests. |
| Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
email, call or write to us—see below: ‘How to contact us’; and
provide enough information to identify yourself (eg your full name, address and email) and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine operational need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published in October 2021.
We may change this privacy notice from time to time—when we do we will update it on our website.
How to contact us
Individuals in the UK
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
TransitionZero
Office 2.05
22 Tudor Street
London
EC4Y 0AY
info@transitionzero.org