Last updated: 18/11/2024
Introduction
Cruelty Free International and Cruelty Free International Trust are committed to protecting your privacy and we want everyone who supports us to feel confident about how we protect and use any personal information you provide to us, or that we collect from you.
This privacy policy explains how we process personal information at Cruelty Free International, including details about the circumstances in which we process personal information jointly with our sister organisation, Cruelty Free International Trust (“CFI Trust”).
Cruelty Free International is a “controller” of personal information. This means that we are responsible for, and control the processing of, any personal information that you either provide to us, or that we collect from you. When we process personal information with CFI Trust jointly, Cruelty Free International and CFI Trust are “joint controllers”, which means that both organisations are jointly responsible for this personal information. This Policy explains the various scenarios in which CFI Trust and Cruelty Free International are joint controllers, how we process your personal information in these circumstances, and how you can exercise your rights against one or both of Cruelty Free International or CFI Trust.
Cruelty Free International is a company limited by guarantee registered in England and Wales with registration number 04115167 and registered office address 16a Crane Grove, London, N7 8NN.
CFI Trust is a charity registered in England and Wales with charity number 1081183 and registered address at 16a Crane Grove, London, N7 8NN.
Please note that Cruelty Free International and CFI Trust are separate entities that operate in different ways. For more information about this, see here. However, we do work closely together, which means that, in some cases, we are joint controllers of the personal information that we collect and use.
Unless stated otherwise, when we use the terms ‘we’, ‘us’, or ‘our’ in this Policy, we are referring to Cruelty Free International and CFI Trust. If there are parts of the Policy that only apply to Cruelty Free International (for example because they relate to Cruelty Free International’s use of personal data as a controller on its own, without any involvement of CFI Trust) we have made this clear below.
Cruelty Free International and CFI Trust each complies with its own data protection policies including (without limitation) Cruelty Free International’s Data Privacy Policy and Data Retention Policy (and Schedule).
We make every effort to ensure that your personal information is processed in a fair, open and transparent manner, in line with the UK General Data Protection Regulation, the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR) and other applicable data protection laws.
Please read this policy carefully, along with any other documents referred to in this policy, to understand how we collect, use and store your personal data.
What is the purpose of this document?
This Policy sets out why we collect personal information about individuals and how we use it. It also explains the legal basis for this and the rights you have regarding the way your personal information is used.
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely
- How we collect information about you
We collect personal information about you in the following ways:
When you interact with us directly: This could include when you enquire about our activities, register for an event with us, make a donation, sign a petition, apply for a job or volunteering opportunity or otherwise provide us with your personal information. This also includes when you phone us, visit our website, or get in touch through the post, or in person.
When you interact with us via third parties: This could be if you provide a donation to us via a third party platform such as JustGiving, when you sign one of our petitions that are hosted on third party sites (including, for example, change.org), or from one of the other third party providers that we work with when you provide your consent for your personal information to be shared with us.
When you have provided permission for a company or other organisation to share your data with third parties, including charities. This could be when you buy a product or a service, register for an online competition or register on a website to complete a survey.
When you visit the Cruelty Free International or CFI Trust websites: We gather general information which might include which pages are visited most often and which services, events or information are of most interest to you. We may also track which pages you visit when you click on links in emails from Cruelty Free International. We also use cookies to help our site run effectively. Please look at the ‘Cookies’ section below on what this means for you.
We use this information to personalise the way the Cruelty Free International website is displayed when you visit and to make improvements to ensure we provide you with the best service and experience possible. Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our website.
When your information is available publicly. So that we can tailor the way we communicate with you about our work and make our communications more relevant to you, we might gather publicly available information about you. This could include your interests, postcode-based demographics, and past campaigning or donation activities. Through understanding more about you we can be more cost-effective in our marketing, campaigning and fundraising communications to you, and better inform you about our work. For more information about this, please see Section 4 below.
We may gather this information from online articles and newspapers, social media platforms and/or third-party sites that host our petitions (such as Change.org). This information is only accessible based on the permission you give through these services and platforms. If you are unsure about what these permissions are, or would like to change them, check the privacy notices on their websites.
We might also gather publicly available information about individuals who may be interested in supporting or giving major gifts to charities or organisations like us in the future. However, we will never keep potential donors’ publicly available information without their consent, which will be sought at the earliest practical opportunity.
In some cases, we also use publicly available sources to ensure that the information we hold about you is up to date and accurate. For example, we may use the Royal Mail National Change of Address database to ensure that the addresses we have on record are correct.
- Information we collect and why we use it
Personal Information means any information that relates to an individual. It does not include information where the identity of the individual has been fully and effectively removed (anonymous data). The information we collect might include personal details such as your:
- First and Last Name
- Date of birth
- Gender
- Email address
- Postal address
- Telephone number
- Employment history and qualifications (if you apply for a job or volunteering opportunity)
- Credit/debit card details (if you are making a purchase or donation) as well as bank details (where you set up a direct debit with us)
- UK tax payer (to confirm Gift Aid if opted in)
as well as additional information you provide in any correspondence between us.
N.B.
Credit and debit card payment information
If you use your credit or debit card to make a donation or fundraise for us, we will ensure that this is done securely and in accordance with the Payment Card Industry Data Security Standard (PCI DSS). To find out more about PCI DSS standards, visit their website at www.pcisecuritystandards.org Following the completion of your transaction, card details and validation codes are securely destroyed once the payment or donation has been processed.
Your communications with our teams (including by telephone or email) may also be monitored and/or recorded for training, quality control and compliance purposes.
Special category data as defined under Article 9 UK GDPR
Special Category Data as defined under Article 9 of GDPR is subject to extra protection under data protection law, and covers the following data types:
- racial or ethnic origin
- political opinions
- religious or philosophical beliefs
- trade union membership
- physical or mental health conditions
- genetic data
- biometric data
- sexual life and sexual orientation
Criminal convictions data is also subject to extra protection, and covers details of:
- the commission or alleged commission of any offence; or
- any proceedings for any offence committed or alleged to have been committed, the disposal of such proceedings or the sentence of any court in such proceedings
Special category data and criminal convictions data are sometimes referred to collectively as ‘Sensitive Personal Information’.
We do not anticipate that we will collect Sensitive Personal Information about you unless you apply for a role with us, in which case we may need to do so. For further details, please see our separate Applicant Privacy Notice.
- How we use your personal information
We may use your personal information to:
- Give important information and support you’ve asked for, whether this be over the phone, via text message, social media or through an email or post.
- Provide or administer activities relating to all our services: updating you with important administrative messages, to help us identify you when you contact us, and help us to properly maintain our records.
- Enhance the service that our staff provide, to improve our information and communications, or to personalise the website to better suit your needs.
- Provide you with information about our plans. This may be letting you know about new services that we hope will be useful and interesting to you, and may include fundraising updates; of course, we will only do this either with your consent, where we need to fulfil a contract or service with you, or where we believe you will expect to be updated and contacted by us.
- Analyse the personal information we collect about you so that we can better understand our supporters, their preferences and needs and important trends. This may mean looking at all the interactions you have with us so we can aim to offer you the right information or offers at the right time; including financial interactions so we can ensure we ask you for an appropriate level of support. It may also mean collecting information about you from publicly available sources or through third-party subscription services or service providers; information may include details about the area where you live, or people like you, so we can better inform how we talk to you about our work. We believe this enables us to offer you more appropriate offers and communications, you can of course opt out of this activity at any time by enforcing your right to object to profiling based activities by contacting us.
- Analyse information about our supporters at a broader level (i.e. in an anonymised or aggregate form) to understand their lifestyles and demographics, so that we can better understand how our work is impacting different groups of people.
- Keep a record of your relationship with us.
- To process your donations and/or other payments, to claim gift aid on your donations and verify any financial transactions.
- For monitoring, evaluation and audit of service provision.
- To invite you to participate in surveys or research.
- Ensure that our records are accurate and up to date.
We may need to disclose your information if required to do so by law (for example, to comply with applicable laws, regulations and codes of practice or in response to a valid request from a competent authority); or, in order to enforce our conditions of sale and other agreements; To do some of this, we may share your information with our trusted partners and suppliers, but is always carried out under our instruction, and is never for their marketing approaches. We ensure that they store the data securely and delete it when it is no longer needed.
Cruelty Free International Purposes
There are some purposes for which only Cruelty Free International (and not CFI Trust) will process your personal information. For example, Cruelty Free International may process your personal information for the purposes above and:
- As part of our media activity and campaigning.
- As part of our advocacy and lobbying activity.
- To promote cruelty free products, including sending you emails about those products if you have expressed an interest in them.
- To administer our Leaping Bunny programme, or other programmes or projects that we may run to further our aims or values.
CFI Trust Purposes
Similarly, there are some purposes for which only CFI Trust (and not Cruelty Free International) will process your personal information. For example, CFI Trust may process your personal information as part of educational services and services that we provide to under 18-year-olds. NB If you use these services, we will refer you to another, under-18s Privacy Notice, that will explain how we use personal information more clearly.
- Supporter research and analysis
We may use profiling and/or data segmentation techniques to create a profile of your interests, preferences and/or ability to donate to us. Our work is only made possible thanks to the generosity of our supporters, so we want to ensure that our fundraising efforts are as effective as possible. By developing a better understanding of our supporters through researching, including using publicly available sources, we are able to tailor and target our communications and fundraising messages to those most likely to be interested in them. This enables us to make appropriate requests to those who are more likely to be willing and able to donate more than they already do, or leave a gift in their will, and allows us to be more efficient and cost-effective with our resources and in the way that we raise funds. It also helps to ensure communications are relevant and timely, and reduces the risk of someone receiving information that they might find irrelevant, intrusive, or even distressing, so that we can provide an improved experience for our supporters.
We use information that is already in the public domain (information that has been published in print or online) to identify high net worth individuals who may be interested in supporting our work with a major gift. This might also include estimating the gift capacity of those individuals, based on their visible assets, history of charitable giving and how connected they are to Cruelty Free International.
By way of example, we may use publicly available sources of information such as Companies House, the electoral register, the phone book, the Charity Commission’s Register of Charities, Who’s Who, LinkedIn and other social media sites, real estate websites, company annual reports, and articles in newspapers and magazines.
We also carry out research to identify existing supporters who may be able to donate more than they currently do (and in particular to provide us with large donations). This is based both on publicly available information, and information our supporters have given us directly (e.g. where a person lives, who they bank with, what their occupation is and their age). We may from time to time engage a specialist third party prospect research company to screen our database against their demographic database for this purpose.
We’re committed to putting you in control of your data and you have the right to opt out from our profiling activity at any time by contacting us at supportercare@crueltyfreeinternational.org.
We are legally required to carry out checks on individuals who give us large donations, to comply with our duties in respect of anti-money laundering legislation and the prevention of fraud.
- Legal basis for your information
In order to collect and use personal information, we must have a reason under the law. This is sometimes known as a ‘legal basis’.
We rely on the following legal bases to collect and use personal information:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests). Examples of where we have legitimate interest includes, contacting you about our work via post, identifying individuals who may be interested in making donations to us, using your personal information for data analytics, conducting research to better understand our supporter base, improving our services and communications or for our legal purposes, such as dealing with complaints and claims. We will make it easy for you to opt-out of postal communications and fundraising activities at any time if you wish.
Where Cruelty Free International processes personal information for its own purposes (and not jointly with CFI Trust), it relies on the lawful basis that this is in its legitimate interests – by way of example, Cruelty Free International has a legitimate interest in furthering its aims and values, including by advocating for certain causes (in media and otherwise) and promoting cruelty free goods.
- Where it is necessary to fulfil a contract with you.
- Where it is necessary to comply with a legal obligation on us (for example, reporting to HM Revenue and Customs or Companies House.
In some cases, we may ask for your consent to collect and use your personal information. In particular, we may obtain your consent in order to send you email marketing, newsletters, or other communications that we think might be of interest to you (see further details below). Where consent is the appropriate legal basis for using your personal information, we will use this only once we have your consent for the specific service or request, we are fulfilling for you.
In cases where we may need to transfer and process your personal information outside the UK, we will comply fully with our legal obligations as a controller of personal information and take all steps necessary to ensure that your personal information is treated securely and in accordance with legislation.
- Marketing
We’d like to keep you in the loop regarding our progress as organisations. So, to update you on what we’re doing and ask whether you’d be able to support us, where we are able to, we’d like to keep in touch with you (by post, phone, email, text and other electronic means) about our progress and how you can continue to help us in this important mission.
We will only contact you about Cruelty Free International’s or CFI Trust’s work and how you can support us by email or text message if you have opted-in to receive communications from Cruelty Free International or CFI Trust via these channels.
However, if you have provided us with your postal address or phone number we may send you information about Cruelty Free International’s (and CFI Trust’s) work and how you can support us by mail or phone unless you have specifically told us that you would prefer not to hear from us in this way.
You can update your preferences with us by contacting us or by clicking the unsubscribe button at the bottom of relevant communications.
Data collected by us (such as the fact that you visited a Cruelty Free International or CFI Trust page) may also be shared with social media providers (e.g. Meta or Google) via our use of Meta Pixels and similar tools. Meta and/or Google (as appropriate) uses this information to display our ads on your social media page(s) and to create ‘lookalike’ audiences. For more information about Meta Pixels and how you can opt in or out, please see our Cookie Policy.
We work only with social media platforms that provide a facility for secure and encrypted upload of data and immediately delete any records that do not match their own user base.
When we engage with Meta to identify you on their platform and provide you with our adverts, we are joint controllers of your personal information with Meta. Our agreement with Meta sets out our responsibilities to you – for example, we are responsible for informing you about this activity. Cruelty Free International and/or CFI Trust and Meta are all responsible for keeping your information secure. You can exercise your privacy rights with any of us individually.
- Who sees your personal information?
The personal information we collect about you will be used by our staff (and volunteers) at Cruelty Free International and/or CFI Trust so that they can support you, and we may share your personal information between us where appropriate and useful to provide that support. We may also share your personal information:
- with selected organisations that work with us or on our behalf to deliver our services;
- with our partner organisations in some cases, including with Cruelty Free Europe;
- with our fulfilment partners who help to create and send information to you to reduce our costs, or with our partners who help us to process donations and claim Gift Aid.
- with legal and regulatory authorities if required to do so by law, including pursuant to a subpoena, court order, or other legal process, or as otherwise required or requested by law, regulation, or government authority programs, or to protect our rights or the rights or safety of third parties;
- as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
- with our professional advisors, lawyers, accountants and auditors;
- with your consent or as otherwise disclosed at the time of data collection or sharing.
We never sell or share your information so that they can contact you for any marketing activities. Nor do we sell any information about your web browsing activity.
We may transfer your personal information out of the UK in some circumstances, for example if we are using a service provider in another jurisdiction (for example, a service provider that we use, e.g. to manage our email lists and consent records, may have servers in another jurisdiction, such as the US). When we transfer personal information out of the UK, we take steps to ensure that your personal information is protected in accordance with appropriate safeguards, especially where the recipient country is not considered to be adequate by the UK Secretary of State. In particular, we rely on appropriate safeguards under data protection legislation, such as the UK International Data Transfer Agreement to protect your personal information.
Where we share your personal information with our trusted partners and suppliers, we require in contracts with those service providers that the processing of your personal information is always carried out under our instruction and is never for their marketing approaches. We ensure that they store the information securely and delete it when it is no longer needed.
We may also use information to produce anonymous reports to our funders and stakeholders. As noted above, anonymised data is not personal information because no individuals can be identified from it.
- Keeping your information safe
We will take all reasonable care to safeguard your information, through security policies and secure business processes and we take the security of your personal information very seriously.
We've implemented appropriate physical, technical and organisational measures to protect the personal information we have under our control, both on and off-line, from improper access, use, alteration, destruction and loss.
And, we only keep it as long as is reasonable and necessary, which may be to fulfil statutory obligations.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information only to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. Details of these measures may be obtained on request.
Details relating to any transactions entered into through the Cruelty Free International website will be encrypted in transit to ensure their safety. Encryption is the process through which sensitive information is scrambled before it is transmitted so that it remains private even if it is intercepted. However, unless your internet browser supports you will not be able to take advantage of this level of security.
Offline, your personal information is kept in our databases and offices, or, where relevant, by our partner companies.
Any debit or credit card details which we receive on our website are passed securely to our payment processing partner, according to the Payment Card Industry Security Standards.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
While we seek to use appropriate organisational, technical and administrative measures to protect personal information within our organisation, unfortunately no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to exercise your data protection rights” section below.
- Third party links
The Cruelty Free International website may contain links to third-party websites. These websites should have their own privacy policies and as such we do not accept any responsibility or liability for their policies.
Please be aware that advertisers or Web sites that have links on our site may collect personal information about you. This Privacy Policy does not cover the information practices of those websites or advertisers.
- How long we hold your information
We will endeavour not to keep your personal information for longer than necessary and to keep your information accurate and up to date for the period that we retain it.
The criteria we use to determine the retention period of personal information are: (i) the respective statutory retention period; (ii) our contractual and/or business relationships with you; (iii) (potential) disputes; and (iv) any guidelines issued by relevant regulators. After expiration of that period, the relevant information is routinely deleted, as long as it is no longer necessary for the fulfillment of a contract, the initiation of a contract or to protect or defend our position or that of a third party. If you have any questions about our retention periods, please contact us using the details in the “How to exercise your data protection rights” section below.
- Your rights
Please be reassured that respect lies at the heart of everything our committed staff and volunteers do. However, you have a variety of rights in respect to the personal information that we hold about you which are set out below. If you wish to exercise any of these rights or make a complaint, please get in touch with us directly.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no lawful reason to continue to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). –
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- Object to automated decision making. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law.
- You have the right to withdraw consent to marketing at any time by contacting us using the details set out in Section 12 of this policy.
Please note that some of these rights only apply in certain circumstances and we may not be able to fulfil every request. We may also ask you to verify your identity so that we can evidence it is in fact you making the request.
- How to exercise your data protection rights
If you wish to exercise any of your data protection rights, whether in respect of your interaction with Cruelty Free International or CFI Trust, or if you would like to find out more about our privacy and data retention practices, please contact us by:
Writing: Cruelty Free International, 16a Crane Grove, London, N7 8NN
Email: supportercare@crueltyfreeinternational.org (for requests relating to the handling of personal data by Cruelty Free International) or supportercare@crueltyfreeinternationaltrust.org (for requests relating to the handling of personal data by CFI Trust).
Tel: 0207 700 4888
- Responsibility for data protection compliance at Cruelty Free International
The Deputy Chief Executive at Cruelty Free International is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Deputy Chief Executive using the details set out above.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. You can do that here https://ico.org.uk/
- How we use cookies on our website
A cookie is a small file placed on your computer's hard drive. Cookies can be used to provide core functionality for a website (e.g. login details and passwords), for website traffic reporting or for marketing purposes. Some cookies are essential and enable core functionality such as page navigation and access to secure areas. While others help us to improve your experience by providing insights into how the site is being used.
A cookie in no way gives us access to your computer or any information about you, other than the data you have chosen to share with us.
We sometimes use traffic log cookies to identify which pages are being used on our website. This helps us analyse data about web page traffic and improve our website in order to tailor it to user needs. We only use this information for statistical analysis purposes.
Disabling cookies on your browser
If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.
If you wish to restrict or block web browser cookies which are set on your device, then you can do this through your browser settings; the Help function within your browser should tell you how.
Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.
For more information about how we use cookies, please visit our Cookie Policy.
What is the purpose of this document?
Cruelty Free International is a "controller". This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy policy because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal information will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation ((EU) 2016/679) (UK GDPR).
Data protection principles
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
The kind of information we store about you
When you apply to work with us, we will collect, store, and use the following categories of personal information about you in connection with your application:
- The information you have provided to us in your curriculum vitae and covering letter.
- The information you have provided on our application form, including name, title, address, telephone number, personal email address, date of birth, employment history, qualifications.
- Any information you provide to us during an interview.
We may also collect, store and use the following types of more sensitive personal information (also known as special category data):
- Information about your health, including any medical condition, disability status, health and sickness records.
How is your personal information collected?
We collect personal information about candidates from the following sources:
- You, the candidate.
- Any recruitment agency, from which we collect the following categories of data.
- Your named referees, from whom we collect the following categories of data.
How we will use information about you
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our hiring processes.
- Comply with legal or regulatory requirements.
Having received your CV and covering letter OR your application form, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then take up references before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
How we use particularly sensitive personal information
Some personal information is subject to greater protection under data protection law because it is particularly sensitive. This is known as ‘special category data’ or ‘sensitive personal information’ includes (among other things) data relating to health, religion, race, ethnicity, philosophical beliefs, sex life sexual orientation.
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
- We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Information about criminal convictions
We may collect criminal convictions data to the extent necessary as part of our recruitment process, and in accordance with our obligations under employment law and/or as necessary for safeguarding purposes.
Legal Basis
In order to collect and use personal information, we must have a reason under the law. This is sometimes known as a ‘legal basis’.
We rely on the following legal bases:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests). For example we have a legitimate interest to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that role
- Where necessary to decide to enter into a contract with you
- Where it is necessary to comply with a legal obligation on us (for example, reporting to HM Revenue and Customs or Companies House.
In the context of sensitive personal information we rely on the condition that this is necessary for us to comply with our obligations under employment law, for equal opportunities monitoring and/or for safeguarding purposes.
Automated decision-making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Data sharing
We may share your personal information:
- with selected organisations that work with us or on our behalf to deliver our services;
- with our partner organisations in some cases, including with Cruelty Free Europe and Cruelty Free International Trust;
- with legal and regulatory authorities if required to do so by law, including pursuant to a subpoena, court order, or other legal process, or as otherwise required or requested by law, regulation, or government authority programs, or to protect our rights or the rights or safety of third parties;
- as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
- with our professional advisors, lawyers, accountants and auditors;
- with your consent or as otherwise disclosed at the time of data collection or sharing.
Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained on request.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
While we seek to use appropriate organisational, technical and administrative measures to protect personal information within our organisation, unfortunately no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “How to exercise your data protection rigths” section below.
Data retention
How long will you use my information for?
We will retain your personal information for a period of six months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact the Deputy Chief Executive:
In writing at: Cruelty Free International, 16a Crane Grove, London, N7 8NN
By email at: supportercare@crueltyfreeinternational.org (for requests relating to the handling of personal data by Cruelty Free International) or supportercare@crueltyfreeinternationaltrust.org (for requests relating to the handling of personal data by CFI Trust).
By phone at: 0207 700 4888
Responsibility for data protection compliance
The Deputy Chief Executive is responsible for overseeing compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the Deputy Chief Executive. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.