Who We Are
Friends International (FI) are a Christian charity that supports international students in the UK. We do this through encouraging and equipping UK churches to serve, minister and engage with international students and to share with them the Christian faith. For further details please see https://friendsinternational.uk/about
For Our Websites Terms and Conditions please see: https://friendsinternational.uk/websites-terms
For Our App Terms and Conditions please see; https://friendsinternational.uk/app-terms
In this Policy, the following terms shall have the following meanings:
- “FI”, “Us” “We” and “Our”
- “Local Centre”
- means a geographical place where there is an FI Local Ministry. This usually consists of a Branch or Development Group Committee that works with FI employee(s) and local churches to provide our core Ministry services to International Students; and
- “Support Centre”
- means our central administration function based at our registered office.
- “you / your”
- means any living individual including incorporated businesses who use any of Our services accessed via Our Websites or App; and
- means Our main website https://friendsinternational.uk and any subsidiary FI Websites that are linked into the main website. These would include regional Websites and specialist areas such as TEN, True, and Philip Project. These subsidiary sites are listed at the end of this policy; and
- means the FI Mobile Application; and
- “personal data”
- means any information that relates to an identifiable person who can be directly or indirectly identified from that information. In this case, it relates to personal data you give to Us via our Support Centre, our local Centres, Our Websites or App.
2 Your Rights
2.1.1 The right to be informed about Our collection and use of your personal data;
2.1.2 The right of access to the personal data which We hold about you;
2.1.3 The right to request that We correct any personal data if it is found to be inaccurate, incomplete, or out of date;
2.1.4 The right to request your personal data is erased where it is no longer necessary for Us to retain such data;
2.1.5 The right to change or withdraw your consent at any time;
2.1.6 The right to request that We provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability);
2.1.7 The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
2.1.8 The right to object to Us using your personal data for particular purposes;
2.1.9 Rights with respect to automated decision making and profiling; and
2.1.10 The right to lodge a complaint with the Information Commissioners Office. (See Section 15 below for details).
If you have any queries or you wish to complain about how We use your personal data, please contact us in the first instance using the details in Section 14 below.
4 What Personal Data Do We collect?
We collect the personal data defined by this policy when you access Our Websites or App, or when you communicate with Our Support Centre or Local Centres. This includes when you donate money, order materials, request information, sign up for an event, provide comments, volunteer or apply for a job with Us, use social media or otherwise provide Us with your personal data, including by post or telephone.
4.1 FI Website Account
4.2 What information do We collect when you use Our Websites with or without an account?
4.2.2 If you decide to leave a comment on Our Websites including via Our App blogging feature, We may collect your name and e-mail address and any comments you submit to the blog.
In the following circumstances, We will collect additional Personal Data within Our Websites:
4.3.1 When you open an account, We will collect your name and email address registration date, and last visit date;
4.3.2 If you order books or materials from the Book Shop We will collect your name, address, phone number and email;
4.3.3 If you donate money We will collect your name, address, phone number and email and your Bank or payment details. We do not store credit or debit card details;
4.3.4 If you apply to join one of Our Summer Teams We will collect your name, gender, nationality and email;
4.3.5 If you request Our ‘Meet you at Heathrow’ service, We will collect your name, gender, nationality, email, arrival date and flight number;
4.3.6 If you apply to join Our Reach Team or True Leadership Team We will collect your name, gender, nationality, occupation or university where you are studying, email, address, and telephone;
4.3.7 If you sign up to the TEN Website We will collect your name and email;
4.3.8 If you sign up to the TEN Website and choose the ‘share your stories with Us service We will collect your name and email address, and the story you submit to Us;
4.3.9 If you apply to join Our Hospitality Scheme in your location, We will collect your name, gender, nationality, occupation or university where you are studying, email address, address, and telephone number and any specific dietary requirements you have and if you are comfortable around pets. We also optionally collect details of any hobbies or interests, and names of friends that you would like to be grouped with together with other sensitive personal data which is appropriate to provide you with a safe and enjoyable experience;
4.3.10 Where you apply to be a volunteer or an employee We will collect the personal data you provide to Us as part of the recruitment process. This may include sensitive personal data on your health, disability, or religious beliefs. We will also collect personal data from your referees which may include sensitive personal data; and
4.3.11 Where you apply to travel with Us on conferences or similar We will collect personal data such as name, address, phone number, and email. We will also collect sensitive personal data, such as dietary, mobility requirements or health information.
4.4 Personal Data collected by downloading or using our App
Our Friends International App is used by International Students to generate community between students and Friends International staff, helping Us to support students better, and make their experience in the UK more positive. The App contains the following functions: Profile creator; Event finder; Host finder; Notification system; Staff finder; LifeUK pages; A blog feed from Our Websites; and a ‘Survival Skills’ survey.
4.4.2 Host Finder. If you apply to join Our Hospitality Scheme in your location; We will additionally collect any specific dietary requirements you have and if you are comfortable around pets. We also optionally collect details of any hobbies or interests, and names of friends that you would like to be grouped with;
4.4.3 Blogging Feed. If you decide to leave a comment on Our Websites Using the App blogging service; We’ll additionally collect any comments you enter into the blog; and
4.4.4 Survival Skills Survey. We will collect the answers you enter into the survey. Your answers will not be used to identify you personally but will be anonymously aggregated to produce statistics to enable Us to understand the views of the users of the App. This will help Us learn how We can improve Our services to users.
4.5 Personal Data Collected in our Local Centres
In each FI Local Centre We may locally collect and store your personal data as part of Our relationship building ministry. This is used to provide International students with information on events as well as maintain contact with them. This is covered by Friends International’s Legitimate Interest in seeking to achieve Our core local ministry. Such data could include sensitive personal data which is only held where there is sufficient direct contact by Us as a Christian Charity to make such processing appropriate, and where there is no disclosure to any 3rd party without your explicit consent.
4.6 Personal Data Collected in our Support Centre
Where you contact Our Support Centre by post, telephone or email and request to use one of Our services We will collect the personal data you have chosen to give Us. this includes when you donate money, order materials, request information, sign up for an event, provide comments, volunteer or apply for a job with Us, or otherwise provide Us with your personal data.
4.7 Personal Data Collected From Third parties
In addition, We collect personal data from third parties including but not limited to; Event organisers like Eventbrite; Email programs such as Mailchimp; Fundraising sites like JustGiving and Stewardship; Financial sites such as PayPal, Worldpay; and social media sites such as Facebook, WhatsApp, Twitter and WeChat. This is where you have independently consented to use these third-party suppliers to enable you access Our services in some way. You should check their privacy policies to ensure you understand and are happy about how they will process your personal data in these circumstances. We will take all reasonable steps to ensure that your personal data collected via third parties will be handled safely, securely and in accordance with your rights, Our obligations, and the obligations of the third parties. Links to the Privacy Policies of some of the most common third parties used are provided at the end of this document for your convenience.
5 How Do We Use Your Personal Data?
5.1 Our Obligations
FI complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data for longer than is necessary; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
5.2 What is the legal basis for processing your Personal Data?
Our processing of your personal data will always have a legal basis, either because you have explicitly consented to Our use of your personal data, or because it is necessary to supply you with the services you have requested or is necessary for Us to perform a contract with you, or because it is in our legitimate interests. Specifically:
5.2.2 All personal data which is stored and processed centrally by Our Support Centre requires consent to process so that We can keep you informed about Friends International news, events, and activities including fundraising activities and appeals;
5.2.3 Personal data is also collected and processed in the normal course of the recruitment and employment of staff in accordance with normal employment contractual relationships;
5.2.4 Personal data relating to both financial supporters and employees is also processed where necessary to meet Our legal obligations relating to employment, social security, social protection law, Financial regulation, fraud and other crime;
5.2.5 All personal data collected directly from Supporters, Volunteers and International Students in their local centre may be stored and used as part of Our relationship building ministry. This is used to organise and equip Our volunteers as well as provide International students with information on events and maintain contact with them. This is legally processed under the basis of Friends International’s Legitimate Interests in seeking to achieve Our core local ministry. Such data could include sensitive personal data which is only held where there is sufficient direct contact by Us as faith-based Christian Charity to make such processing appropriate, and where there is no disclosure to any 3rd party without your explicit consent; and
5.2.6 Our Employees will also locally collect and store the personal data of their own personal supporters to provide them with news, prayer and fundraising updates and requests. This is legally processed under the basis of Friends International’s Legitimate Interests in seeking to develop and sustain the support base necessary to facilitate each Employees’ personal Ministry.
We use your personal data in a way appropriate to the services you have used, the way you have chosen to access them, the personal data you have disclosed as you have done so, and upon the legal bases set out in this Policy.
Our data processing activities enable Us to:
5.3.2 Process your gifts and gift aid applications;
5.3.3 Manage Our employees and volunteers;
5.3.4 Maintain Our own accounts and records;
5.3.5 Ask you for financial and non-financial support, such as volunteering or prayer;
5.3.6 Enable Us to provide the website and App services you have requested to use;
5.3.7 Administer your website account and App account (if applicable) and any activities you undertake whilst accessing the website and /or App as a logged in user;
5.3.8 Provide information or materials you have requested;
5.3.9 Contact you occasionally to conduct research about your opinions of current services or of potential new services that may be offered;
5.3.10 Better understand your views and so improve how We deliver Our services;
5.3.11 Administer the recruitment process if you apply to be a volunteer or employee;
5.3.12 Use third parties to provide services such as references and criminal referencing in connection with your application (DBS checks);
5.3.13 Provide appropriate support in the event of assistance being requested including in an emergency;
5.3.14 Answer any questions you may have or feedback you may give about any of Our services;
5.3.15 Deliver the volunteering, conference or holiday opportunity you have applied for, including the disclosure of sensitive data, such as medical or dietary information, to Our partner(s) where necessary to deliver a safe and pleasant event for all involved; and
5.3.16 Where We have a legal right or duty to use or disclose your information (including for financial processing and accounting, crime and fraud prevention).
6 How We Protect Your Personal Data
Data security is important to us and We take all reasonable steps to ensure that your data is collected, stored and processed securely, whether in electronic or hard copy formats and is protected from unauthorised access, use or disclosure. We ensure that access to personal data is restricted only to those personnel whose job roles require such access and that suitable training is provided for these personnel.
7 Where do We Store Your Personal Data?
We store your Data in the UK and European Economic Area (EEA). However, in rare circumstances some of your personal data may be stored outside the EEA and you are deemed to be accepting and agreeing to this by using our Websites and App. If we do store your personal data outside the EEA we will take all reasonable steps to ensure your personal data is treated as securely and safely as it would be if that data was within the UK or EEA under GDPR.
8 Do We Share Your Personal Data?
We use third parties to process personal data on Our behalf. For example, a mailing house for dispatching Our magazines or PayPal to receive payments for materials, a CRM (Customer Relationship Management) software supplier and an IT services supplier. When We do use third parties we will take all reasonable steps to ensure your personal data is handled in accordance with your rights, Our obligations, and the obligations of the third party in law. In this case We remain responsible for the storing and processing of your personal data in accordance with the GDPR regulations. We do not store your credit or debit card details.
We may in certain circumstances such as legal requirements, a government authority or an order of the Court, be legally required to share data held by us which may include your personal data including sensitive personal data.
9 How Long Do We Keep Your Personal Data?
We will keep your personal data only for as long as we consider it necessary to carry out each activity. Our local Ministries will only continue to store personal data relating to International Students where there is a reasonable possibility of an ongoing relationship. Similarly, our local employees will only continue to store personal data relating to their personal supporters where there is a clear expectation from the supporter that they wish to maintain that personal contact in connection to their Friends International Ministry. We also take account of legal obligations and accounting and tax considerations as well as considering what would be reasonable for the activity concerned. We retain personal data about gifts and gift aid declarations for up to 7 years after the tax year to which they relate.
10 How Can You Control Your Personal Data?
11 Further processing
12 FI Subsidiary Websites
13 External Links
Where links on our Websites or App take you to external websites owned by third-parties outside of our control, we accept no responsibility for the content or any damage or loss caused by websites that are not owned or operated by us. Even though we have made every effort to ensure these links are authentic you follow them at your own risk. In addition, the presence of a link does not imply we agree with the content or endorse the provider.
13.2 Third Party Websites
We may have links via our Websites or App to various third-party external websites including social media sharing buttons. You use these at your own discretion and accept that doing so may publish content to your social media profile feed or page. We recommend you check the Privacy Policies of these sites before providing them with your personal data. You can find further information about terms and privacy statements of some of these sites below.
14 Contact Details
You can contact the ICO on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.
This document was last updated on September 11th, 2018. V1.5