What this privacy notice covers
At Amnesty International Ireland, we believe that you have a right to privacy and we take defending that right very seriously.
We have made improvements to our privacy notice so that it is clear and easy for you to exercise the rights you are granted under data protection legislation, and for you to choose how you want to hear from us.
The purpose of this notice is to give you a clear explanation about how Amnesty International Ireland – and any third parties we work with – collect and use the personal information you provide to us.
We take care to ensure that we use your information in accordance with all applicable laws concerning the protection of personal information. This privacy notice explains:
- Who we are
- What information Amnesty International Ireland may collect about you
- Our legal basis for using your information
- How we will use your information
- How we will contact you
- Why we undertake profiling and research
- Who we may share your information with
- How we ensure your information is accurate
- How we keep your information safe
- Other ways we look after your personal information
- How you can manage your contact preferences
- Your rights regarding the information you provide to us
- How we update this privacy notice
- How you can contact us
If you have any questions regarding this privacy notice, please contact us at email@example.com or write to Data Protection Officer, Amnesty International, 48 Fleet St., Dublin 2.
Who we are
Amnesty International is a global movement of over seven million people who stand up for humanity and human rights. Amnesty International Ireland is part of the worldwide Amnesty movement and is used as a collective name for:
Amnesty International Irish Section CLG
Amnesty International (Ireland) Foundation
Within the context of this privacy notice, ‘we’, ‘our’ or “Amnesty International Ireland” is a collective name for the Limited Company and the Foundation. Both of these organisations are data controllers of your information under data protection legislation and this privacy notice applies to the Limited Company and the Trust.
We are dedicated to responsibly oversee the use of data and personal information across all parts of Amnesty International Ireland and are responsible for responding to enquiries you may have about your data protection rights.
What information we may collect about you
We collect information about the members and supporters in our movement who campaign and fundraise with us. The information we gather may include:
Name, mailing address, email address, telephone number, date of birth, age, and gender where appropriate (e.g. when registering to run a marathon on our behalf).
We keep a record of what you’ve told us about how you like to be contacted (e.g. emails only) and what you’d like to receive (e.g. petitions about the death penalty).
Sometimes we collect information about your interests, such as your involvement in Team Amnesty sporting events, so we can contact you about information that is relevant to you.
We may also collect and record any other relevant information you share with us about yourself, such as affiliations with community groups or your employer.
We may collect your bank account details when setting up a regular direct debit, a credit card or debit card number when processing payments by card, and details about your taxpayer status when claiming tax.
Record of your support
We collect and process information about your interactions with us, including:
- Details about our contact with you through email, text message, post, on the phone or in person
- Details about donations you make to us
- Details about events that you register for, or attend
Any other support you provide to us.
This is personal information that is more sensitive. This includes details about a person’s race and ethnicity, sexual orientation, gender preferences or preferred pronouns, religious beliefs, trade union memberships, political opinions, and information about their health.
Sensitive information may be collected from you if you choose to provide it to us, such as when you volunteer with us, sign up to our networks, or attend our events. For example, if you tell us about your accessibility needs or dietary requirements, you are disclosing sensitive information.
Generally, we do not collect or keep a record of sensitive information. If we do need to gather this information (for example, to enable you to participate in an athletic event on our behalf) we only do so with your explicit consent. We have measures in place to protect your sensitive information and its confidentiality.
As a global movement of people, Amnesty International Ireland embraces the fact that our supporters are of all ages. We are committed to safeguarding the welfare of all children and young people involved in our work.
If you are under 13, we will always ask for consent from a parent or guardian to collect information about you and to continue to contact you. We may also collect the name and contact details of your parent or guardian, where appropriate.
With very few exceptions, all Amnesty International Ireland events and petitions have clear rules on whether or not children and young people can take part. Where we do collect personal information from children and young people, we ensure that our privacy notices are ‘child friendly’ and written in clear and plain language.
Our legal basis for using your information
To comply with Irish data protection rules, Amnesty International Ireland must have a legal justification for collecting and using your personal information.
The legal basis that we rely on will depend upon the circumstances in which we collect and use your personal information. In almost all cases, our processing of your personal information will fall into one of the following categories:
- Where you have provided your consent to allow us to use your data in a certain way. For example:
- Niamh joins an Amnesty Student group and her first action is to add her name to our latest petition online.
- Niamh also ticks the box to be updated by email about our other campaigns, fundraising activity and events.
- We invite her to an event by email
- Where the processing of your personal information is necessary to carry out the performance of a contract with you. For example:
- Sinead purchases clothing on our online shop
- To complete the purchase, Sinead provides us with her address and credit card information
- We use Sinead’s information and address to arrange delivery to her home
- Where the processing of your personal information is necessary for us to comply with alegal obligation. For example:
- Amnesty International Ireland holds an Annual General Meeting (AGM) with our members
- Before the meeting, we must notify our members about the AGM and any proposed resolutions
- This ensures we comply with our legal obligations.
- Where it is in our legitimate intereststo contact you in order to raise funds and achieve our human rights objectives. In doing this, we have determined that such processing is not likely to be too intrusive, or excessively infringe on your rights and freedoms. For example:
- Patrick gives €13 a month to Amnesty International Ireland and has done so for ten years and opted in to hear about our campaigns and other ways he could support us
- He gets regular updates about our work as well as our annual magazine
- From time to time we also send Patrick fundraising appeals in the post about pressing human rights issues.
- In some circumstances, we may use a combination of consent and legitimate interests to process your personal information. For example, if you sign up to our Pocket Protest SMS network, we rely on your consent to send you petitions by text message, and we rely on our legitimate interests to call you about getting more involved in our work:
- Sorcha reads about Amnesty International Ireland’s Pocket Protest on our website and signs up with permission to contact
- She responds to our campaign petitions by text
- Several months later we may call Sorcha to see if she would like to become a member with a regular donation.
These legitimate interests may include:
- Operational work:including achieving our objectives to protect and promote human rights, conducting statutory and financial reporting, and ensuring regulatory compliance.
- Administration and management:including administration relating to volunteers and staff to comply with legal requirements, the provision of information and services, research, and the management of events.
- Campaigning, fundraising and marketing: including sending direct marketing by post (and in some cases by telephone for existing supporters and Pocket Protest network members), thank you letters, analysis and segmentation to improve the efficiency of our communication and manage your communication preferences. To find out more about how we process your information, or if you would like to change how we contact you, please let us know though the contact choices below.
How we use your information
In our Donor Charter we have committed to making it convenient for you to tell us how you want to hear from us. We carefully manage the communications we send you to ensure we are contacting you in the most appropriate way. If you ask us to stop contacting you, we will, unless we are legally obliged to communicate with you.
We may use the personal information we collect from you to:
- Provide you with information about us and the work that we do, including our human rights campaigns as well as products and services that you’ve asked for online or from our shop.
- Administering and managing your donation, including data processing relating to Tax claims, legacies, events and raffles.
- Manage your direct marketing and communication preferences.
- Ask for your financial support, such as making a donation to our latest appeal.
- Encourage you to take action as part of our latest campaign.
- Comply with our legal and regulatory obligations.
- Analyse the performance of our campaign actions and fundraising appeals.
- Keep a history of your support, including donations you have given (unless you have opted for these to be anonymous) and actions you have taken.
- Target online advertising effectively, reaching people who share similar interests and characteristics to our supporters.
- Create a record of your interests, preferences and level of potential engagement or donation.
- Organise and administer attendance at our events, such as Electric Picnic or our Annual Conference.
How we will contact you
The below explains how we will contact you about human rights issues, including direct marketing relating to our campaigns, fundraising appeals and events.
We have processes in place to review how we communicate with you, especially in situations where you have not engaged with us for a while, or where the circumstances of how you interact with us change. Where you tell us that you no longer want our updates, we will act on this as soon as we can.
We will only contact you by email if you have given us your consent along with your email address. An exception to this is where you have recently made a purchase from the Amnesty shop, as we can use the ‘soft opt-in’ grounds to contact you about similar products and services, unless you say no to emails from us.
Email is low-cost and fast to send and respond to, and time is often not on our side when we are fighting to protect the life or freedom of an individual. You can opt out at any time by clicking on the ‘unsubscribe’ link at the bottom of our emails.
We will only contact you by text if you have given us your consent along with your mobile phone number. Text messages are a fast and low-cost way to ask you to support a petition, stand up for an individual whose rights are being abused and occasionally, to raise funds. You can opt out at any time by following the unsubscribe instructions in our text messages.
From 25th May 2018, if you are new to Amnesty International Ireland, we will only contact you by telephone if you have given us your consent along with your phone number. Exceptions to this are:
- where you have signed up to our Pocket Protest SMS network, or taken a text-based action, as we will use your mobile phone number to call you about the impact of your activism, and to ask you to make a donation to support our human rights work.
- where you sign up to fundraise for us (for example, by participating in an event or organising your own), as we will call you about ways you can achieve your fundraising target and how we can support you.
If you have already provided us with your phone number, we may call you occasionally, and will be checking that you consent to future phone contact during the call. Being able to call our supporters is important to our ability to raise funds quickly, and most of our calling is carried out by Amnesty International I staff who share your passion for protecting our human rights. You can opt-out of phone calls at any time by contacting us.
If you have provided us with your postal address, we may send you post unless you have told us that you would prefer not to receive such information. You can opt-out of receiving post from us at any time by contacting us.
Where needed, we may also contact you for administrative purposes using the contact details that you have given us – for example, in relation to Tax Aid claims or to post you a product which you have bought from us.
Profiling and research
We regularly use profiling techniques to target our resources and fundraising activity more effectively, so that we can make appropriate requests to those who have the means and the desire to give more. We do this in the following ways:
In order to protect the reputation of Amnesty International Ireland, our fundraising policy and procedures (as well as certain legal and regulatory obligations), may require us to use your personal information to carry out due diligence on your donation. We may need to use publicly available information to conduct ethical screenings on potential donors of a significant gift, to ensure our reputation is protected. This might include researching the sources of the donor’s money, previous business practices and reputation.
If you choose not to have your personal information analysed for due diligence purposes, we may not be able to accept your donation.
Using publicly available information
When communicating with individuals who have given, or might consider giving, a substantial donation to Amnesty International Ireland, we may seek to find out more about that individual, their interests and their motivations for giving, and may invite them to become more involved in supporting our human rights work.
We may do this by collating biographical, financial, corporate and philanthropic information from a wide variety of sources, including information that is held on our supporter database and information that is publicly available. This publicly available information could be obtained by searching for current directorships or relevant newspaper or media coverage about an individual.
An example of how this might work in practice is illustrated below.
- Niall is the CEO of a start-up company and Amnesty International Ireland €10,000
- After due diligence screening we accept the donation and send him a thank you email
- We ask him if he would like to meet us in person to talk about our work in more detail and Niall says yes.
- We research Niall online to see what his interests may be and what previous charitable giving he may have made.
If you would prefer for us not to use your information in this way, please contact us.
Targeted supporter communications
We want to ensure our updates are as interesting and engaging as they can be to our supporters, so we tailor our communications based on what we know about our supporters’ interests and experiences. This also helps us with using our resources as efficiently as we can.
We do this by using profiling and analysis techniques to target our marketing communications. This involves analysing responses to our previous campaigns and fundraising appeals, to look for patterns amongst our current supporters which we can then use to tailor who we send communications to in the future. This is so we can send relevant campaigns and fundraising appeals to supporters who would be the most interested in them.
Who might we share your information with?
Amnesty International Ireland respects your right to privacy and your ability to choose how you hear from us. We do not sell or share your details reciprocally to anyone. We do not make cold telephone calls to members of the public and we do not purchase information in order to do so.
We will, except as indicated below, only share your details with third parties if you ask us to – for example, when you sign our petitions, or where we believe we are under a legal or regulatory duty to do so – for example, in a situation where we need to safeguard a vulnerable person.
We use external service providers to help us send you communications and provide you with our services. These providers may include payment providers, fundraising agencies, fulfilment houses, mailing houses, mobile marketing providers and software platform providers. Where needed, we would give relevant persons within these service providers access to your personal information, but only after we have conducted the necessary checks.
Everything an external service provider does is strictly governed by a contract. In addition, before we share any information with those service providers, we put in place a signed Data Processing Agreement which confirms that the personal information we provide will only be used for the purposes we specify and will be processed in line with data protection legislation. As part of this agreement, the provider needs to comply with strict security measures, including having a secure method for disposing of personal information when it is no longer needed and having a secure process for transferring personal information – for instance, by using encryption.
Some service providers may occasionally be based outside of the European Economic Area (EEA). We ensure any data transfers outside of the EEA are compliant with relevant data protection legislation and that the processing of your personal information is protected by appropriate security measures. For example, if we worked with organisations who process data in the US, we will verify that their data processing standards meet the EU-US Privacy Shield framework. This framework sets out clear safeguards and transparency responsibilities for US-based organisations processing the data of EU citizens.
We participate in Facebook’s Custom Audience and Lookalike Audience programs, which enable us to display our content to our existing or potential supporters on Facebook. We provide personal information such as your email address or phone number to Facebook which securely encrypts it. That personal information is then deleted by Facebook if it does not match with a Facebook account or once they confirm you have an account.
For more information, please see https://www.facebook.com/business/help/744354708981227
If you do not want your information to be used in this way, please contact us.
Ensuring your information is accurate
We only hold your personal information on our systems for as long as is necessary for the purposes outlined above. We remove personal data from our systems once it is no longer required, in line with our guidelines on how long important information must remain accessible for future use or reference, as well as when and how the data can be destroyed when it is no longer needed.
The length of time each category of data will be retained will vary depending on how long we need to process it for, the reason it was collected, and in line with any statutory requirements. After this point the data will either be deleted, or we may retain a secure anonymised record for research and analytical purposes.
In certain situations, for example where a supporter has told us they are going to remember Amnesty International Ireland with a gift in their will, we will retain their details so that we can effectively administer the gift and communicate appropriately with their next of kin or executor.
Keeping your personal information safe
Amnesty International Ireland has robust measures in place to ensure our physical and technical systems are secure. We take appropriate precautions to protect all personal information we keep on our database, including using encryption and monitoring access to our secure networks and systems.
We also take care to ensure we have secure systems for processing your payment information, such as your credit card or debit card details. Our current payment service providers use a range of methods to protect your personal information including secure payment gateways.
Despite our best efforts to protect your personal information electronically, the security of information sent over the internet cannot be guaranteed and may be illegally intercepted or changed after it has been sent. Amnesty International Ireland cannot accept liability for this if this happens.
Other ways we look after your personal information
We report on data protection through regular briefings, meetings and other appropriate channels where required.
Amnesty International Ireland also has a dedicated Data Protection Officer, who oversees our compliance with data protection rules and is our main point of contact for data protection enquiries.
Our Data Protection Officer is responsible for:
- Educating the organisation on the importance of being compliant
- Providing guidance and advice to the organisation and our staff and volunteers as required.
- Providing advice on the design and implementation of any process that involves the processing of personal data.
Data protection training
We provide data protection guidance and training for our staff in our office so they are aware of their data protection responsibilities. Training is provided when staff and volunteers first join us, and at regular intervals after this as refresher training. Our data protection training covers Irish data protection law, the risks associated with using personal information and how to handle personal information responsibly in compliance with the law.
Managing your contact preferences
You can change your contact preferences at any time. This includes telling us that you don’t want us to contact you for marketing purposes.
You can do this quickly and easily by:
- Clicking the ‘unsubscribe’ link at the footer of our emails to indicate that you do not wish to receive our fundraising or campaigning updates.
- Asking us to stop sending you marketing texts by sending us an “opt-out” text message – following the instructions we provide you in the text messages you receive from us.
- Contact us.
If you change your preferences and ask to stop receiving our updates, we will ensure your contact information is disposed of in a secure manner.
Your data protection rights
You are in control of how we use your data and you have the right to ask us to stop processing your personal information. You also have the right to request a copy of the information we hold about you.
You are also granted a number of additional rights under data protection legislation, which are outlined below:
- Where we are processing data based on your consent, you have the right to withdraw consent at any time.
- You have the right to change your personal informationif it is incomplete or inaccurate.
- You have the right to request the deletion or removalof your personal information in certain circumstances, including where it is no longer necessary for us to hold it for the purposes for which we are processing it.
- You have the right torestrict our processing of your data if there is disagreement about its accuracy or legitimate usage.
- You have the right to move, copy or transferyour personal information easily and safely from one IT environment to another, in some circumstances.
- You have the right to object to processingbased on legitimate interests (as described above) including profiling activity, and “direct marketing”.
Please note that these rights are not exercisable in all circumstances. For example, personal data might not have to be erased if it is needed in the interests of public health, or to support legal claims, compliance and scientific or historical research.
For more information about these rights, please contact the Data Protection Commissioner’s Office.
Subject Access Requests
If you would like more detail or a copy of the personal information that Amnesty International Ireland keeps on file about you, please us at firstname.lastname@example.org or contact the office at 01 8638300.
Anyone can make a request for a copy of the information that Amnesty International Ireland keeps on file about them free of charge. We will only charge a reasonable administrative fee for this if the request itself is excessive or repetitive.
Making a complaint
Listening and responding to feedback from our supporters and members is very important to us.
You can make a complaint or raise a concern about how we process your personal information by contacting our Data Protection Officer.
We will acknowledge a complaint about any aspect of our data protection policy within 5 working days and aim to resolve complaints within 10 working days of receiving it. If you are dissatisfied with our response, please contact us using the details below.
Amnesty International Ireland
Sean MacBride House
Data Protection Officer
48 Fleet Street
Tel: (01) 863 8300 (Monday to Friday – 9am to 6pm)
Fax: (01) 671 9338
If you are not happy with how we have handled your complaint, you can contact the Data Protection Commissioner’s Office (which is responsible for upholding information rights in the Ireland.) Alternatively, you may choose to contact this body directly, regardless of whether you have raised the complaint with us first.
Changes to this privacy notice
This privacy notice may change from time to time. For example, we may update this notice to reflect any relevant changes to legislation and regulation, and any changes to Amnesty International Ireland policy.
Please visit this website section periodically to keep up-to-date with the changes in our notice.
Please contact our Fundraising Team if you would like to:
- change your personal information
- change how we communicate with you
- request more detail about the personal information we hold about you and how we use it
Amnesty International Ireland
Sean MacBride House
48 Fleet Street
Tel: (01) 863 8300 (Monday to Friday – 9am to 6pm)
Fax: (01) 671 9338